My LVLFi Lifestyle Privacy Policy

Effective Date: August 1, 2018

OVERVIEW

This Privacy Policy describes the privacy practices for the LVLFi Hub Application(the “App”). You will learn about the information we collect, how we use it, who we share it with, the controls we give you over your information, and the measures we take to keep it safe.
Please review this Privacy Policy carefully. When you submit information to or through the App, you consent to the collection and processing of your information as described in this Privacy Policy. If you have not done so already, please also review the App’s Terms and Conditions and the App’s End User License Agreement. This Privacy Policy is incorporated into and made a part of the App’s Terms and Conditions.
If you do not agree with any part of this Privacy Policy, the App’s Terms and Conditions, or the App’s End User License Agreement, then please do not download or use the App.
If you have other products or services within the LVLFi Ltd application products (“LVLFi”), you are subject to the terms and conditions, privacy notices, and other policies for those products and services. Additional detail about LVLFi’s other privacy policies and notices is available at www.LVLFi.com/privacy-policies

INFORMATION WE COLLECT

When you use our App, we collect the following types of information.

INFORMATION YOU PROVIDE US

  • ACCOUNT INFORMATION
Some information is required to create an account on our App, such as your name, email address, password, age group, country of residence, gender, and your mobile telephone number. You may also choose to provide other types of information, such as a profile photo, community username, food log, and messages on discussion boards or to your friends on the App.
  • ADDITIONAL INFORMATION, INCLUDING SOCIAL MEDIA AND EXERCISE/ACTIVITY INFORMATION
To help improve your experience or enable certain features of the App, you may choose to provide us with additional information. For example:
If you contact us or participate in a survey, quiz, poll, contest, promotion, or other similar activity we collect the information you submit such as your name, contact information, response, and message.
If you choose to connect your account on our App to your account on another service, we may receive information from the other service. For example, if you connect to social media sites through our App such as Facebook, Twitter, and LinkedIn, we may receive information like your name, profile picture, age range, language, email address, posts, pictures, information about your contacts, and other personal information you have separately provided to the social media sites. Your social media site may allow you to control what information you choose to share with the App. In addition, you can stop sharing with us the information from social media sites by removing our access to those sites.
You may also choose to grant us access to your exercise or activity data from another service or device. For example, you may choose to connect your wearable fitness device to the App, which will allow us to receive information from that fitness device. You can stop sharing with us the information from the services and devices by removing our access to those services or disconnecting the device.
You may choose to manually enter certain exercise or activity data. For example, you may choose to enter that you lifted weights for 45 minutes, or that you burned 200 calories playing basketball.

INFORMATION WE RECEIVE FROM YOUR USE OF OUR APP

  • INFORMATION FROM CONNECTED DEVICES
If you have connected a device (e.g., wearable fitness device, scale) to the App, we will receive the information collected by that device that you have chosen to share with us. For example, your device may collect data like the number of steps you take, your distance traveled, calories burned, weight, heart rate, sleep stages, active minutes, and location. The data we receive varies depending on which device you use and what you choose to share with us through the App. When your device syncs with our App, data recorded on your device is transferred from your device to our App.
  • LOCATION INFORMATION
The App includes features that use precise location data, including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs. We collect this type of data if you grant us access to your location. You can always remove our access using your mobile device settings. We may also derive your approximate location from your IP address. If you choose to permit the App to access location information from your device, this information allows us to know your precise location and calculate motion (e.g., how fast you are driving) and time (e.g., when you are at a specific location).
  • HOW YOU INTERACT WITH THE APP
When you access or use our App, we receive certain data that shows how you are interacting within the App. This includes information about when you view or search content in the App, create or log into your account, pair your device to your account, or open or interact with an application such as a social media account via the App on your device. We also collect your step data. This information is used for a variety of reasons, as explained further in the How We Use Information section. For example, if your interactions within the App indicate that you have won a prize, we will contact you with how what prize you have won and how to claim that prize. Additional detail about how your information is shared is available in the How Information Is Shared And Disclosed section.
  • USAGE INFORMATION
We also collect data about the devices and computers you use to access the App, including IP addresses, browser type, language, operating system, mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on the permissions you have granted us), and cookie information.

INFORMATION COLLECTED BY USE OF COOKIES AND SPOTLIGHT TAGS

We allow third-party companies, including Google Analytics and others, to use cookies and spotlight tags to collect certain information when you visit the App website at www.LVLFi.com (“Usage Information”). Usage Information helps us measure the performance of our online advertising campaigns, analyze visitor activity on our websites, and for other business purpose. Usage Information may include browser type, device type, operating system, application version, the page served, the time, the preceding page views, and your use of features on the website.
  • ABOUT COOKIES AND HOW WE USE COOKIES
Cookies are used to store information on your computer and are a way to have your web browser “remember” specific bits of information about your previous visits to our site. They allow you to access secured information, conduct secured transactions, and take advantage of promotional opportunities. They are designed to help you have a better user experience within our website, and we use the information to improve our site content and site functionality.
Different websites store the information in cookies differently. Cookies allow us to identify your device, which in combination with other information we are collecting, may allow us to identify you personally. Any such information is stored in our protected systems and not in the cookie or on the Internet.
Cookies save you time as they help us to remember who you are and they help us to be more efficient. We can learn about what content is important to you and what is not. We can revise or remove web pages that are not of interest and focus our energies on content you want.
  • TYPE OF COOKIES WE USE
There are different types of cookies. We use what are referred to as session cookies. These are temporary and expire when you leave our website or are inactive for a specified length of time. Session cookies allow the website to recognize you as you navigate between pages during a single browser session and allow you to use the website most efficiently.
  • ABOUT SPOTLIGHT TAGS
Spotlight tags analyze behavior of users who have previously clicked or viewed one of our online advertisements. Spotlight tags only collect anonymous, non-personally identifiable information, and at no time do spotlight tags record user name, password, email, IP home addresses, etc. Spotlight activities are reported only if they are created by a user who meets the following three criteria:
  1. Clicks one of our ads and is redirected to our website, or views one of our ads and accesses our website later;
  • Performs an activity on a page containing a spotlight tag; and
  • Performs this activity within 30 days of clicking and/or viewing one of our ads.
How you can control what data is collected through cookies
The information we collect may depend on your browser settings. Most web browsers automatically accept cookies, but you can usually alter the setting of your browser to prevent that; however, doing so may limit your access to certain sections of our website, including account information found behind the log in.
If you do not wish to receive cookies, please refer to the help section of your Internet browser (Chrome, Safari, Firefox, Internet Explorer, etc.) to learn how to either block all cookies or receive a warning before a cookie is stored on your computer. In addition to altering the cookie settings on your browser, you can also install the Google Analytics Opt-out Add-on, which prevents Google Analytics from collecting information about your website visits.
– Internet applications
During some visits to our website we may collect session information, including page response times, download errors, what time you visited our website, how long you were on our website, if you’ve been to the website before, what web pages you visited, page interaction such as scrolling, clicks, and mouse overs, what type of browser you used to access our website and methods to browse away from the page. This information helps us identify ways to modify and improve our websites. Examples of information we collect and analyze include the Internet protocol (IP) address or other unique identifier for the device you use to access the Internet, login email address, computer and connection information such as browser type, version, and time zone setting, browser plug-in types and versions and operating systems.
LVLFi considers the information collected through our Website Digital Technologies valuable. At this time, LVLFi does not respond to do-not-track signals or similar technologies sent by a browser setting. However, visitors will continue to have the ability to control cookie settings for LVLFi’s websites. The information we receive from your web browser and device may or may not be personally identifiable.

HOW WE USE INFORMATION

  • We may use the information we collect for any of the following purposes:
  1. If your interactions within the App (e.g., clicking on educational or informative content) indicate you might be interested in, or have a need for, a certain financial product or service, this information may be provided to a LVLFi advisor to facilitate future conversations.
  • To develop, provide, improve and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;
  1. For example, we use the information to provide you with the services you request; understand how you and other users interact with the services; track exercise, activity, and other trends; provide customer support; troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and services.
  2. We may also use your information to help you find and connect with other users and to allow other users to find and connect with you on the App. For example, your account contact information allows other users to add you as a friend. When another user has your email or mobile phone number in their contact list or in their friend network on a connected service, we show that user that you are a user of the App.
  3. When you allow us to collect precise location information, we use that information to provide and improve features of the App such as showing you certain insights about your day-to-day activities.
  • For customer service, security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the App;
  1. We use the information we collect to promote the safety and security of the App, our users, and other parties. For example, we may use the information to authenticate users, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.
  • To communicate with users either via email, telephone, text (SMS) messages, mail, or as otherwise authorized by you;
  1. We use your information to send you Service notifications and inform you of new features or products we think you would be interested in. You can control marketing communications and most Service notifications by using your notification preferences in account settings or via the ‘Unsubscribe’ link in an email. We also use your information to respond to you when you contact us.
  • To better understand how users access and use the App, for the purposes of trying to improve the App and to respond to user preferences, including language and location customization, personalized help and instructions, or other responses to users’ usage of the App;
  1. We use the information we collect to personalize the App, make inferences, and show you more relevant content. Here are some examples:
  2. Information like your height, weight, gender, and age group allows us to personalize your daily exercise and activity statistics like the number of calories you burned and the distance you travelled.
  3. Based on your sleep data, we may make inferences about your sleeping patterns and provide you with customized insights to help you improve your sleep.
  4. We may personalize exercise and activity goals for you based on the goals you previously set and your historical exercise or activity data.
  • to help us develop new products and services and improve our existing products and services;
  • to provide users with educational or informative content that may be relevant to you;
  • to provide users with advertising and direct marketing that is more relevant to you;
  • to take the information we collect from your use of the App and combine it with information we receive from other sources, such as your interactions with LVLFi.com, your interactions with an advisor, or information you provided as part of other products and services you have with us;
  • to enforce our Terms and Conditions of the App or other applicable policies; and
  • to assess the effectiveness of and improve advertising and other marketing and promotional activities.
Please note that information collected through the App may be used in an aggregated or individualized manner.

HOW INFORMATION IS SHARED AND DISCLOSED

We do not share your personal information except in the circumstances described below.

WHEN YOU AGREE OR DIRECT US TO SHARE

You may direct us to disclose your information to others, such as when you use our community features like the forums and other social tools. For certain information, we provide you with privacy preferences in account settings and other tools to control how your information may be accessed by other users on the App. Just remember that if you choose to participate in a challenge, information like your profile photo, points earned, total steps in the challenge, personal statistics, and achievements, is not governed by your privacy preferences and will be visible to all other challenge participants.
You may also authorize us to share your information with others, for example, with a third-party application when you give it access to your account. Remember that their use of your information will be governed by their privacy policies and terms. You can revoke your consent to share with third-party applications or employee wellness programs using your account settings.

FOR PROCESSING WITHIN LVLFI

We may share information we collect about you with other member companies within LVLFi for a variety of purposes. For example, we share information to assist us in providing service and account maintenance of the App and other products and services you may have with LVLFi, to help us design and improve products, to offer products and services that may be of interest to you, and to provide educational or informative content that may be relevant to you.

FOR PROCESSING EXTERNALLY BY OUR THIRD-PARTY SERVICE PROVIDERS

We may share information we collect from you with external third-party service providers, and other partners who process information for us, based on our instructions, and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures. These partners provide us with a variety of services, including customer support, information technology, data analysis, research, and surveys.
For example, we may share your information with third-parties, such as reinsurers who provide us with data analysis and research, and with third-party developers who assist us in operating and improving the App.

FOR USE BY A LVLFI ADVISOR

We may share information we collect from you with a LVLFi advisor. This information is provided to an advisor to facilitate conversations you might have with an advisor and to help an advisor identify products or services that might be of interest to you.
For example, we may provide information to an advisor if:
  • your interactions within the App (e.g., clicking on educational or informative content) indicate you might be interested in, or have a need for, a certain financial product or service;
  • the information we receive from your social media sites (those sites that you have connected the App to) indicates that you have had a life event (e.g., a marriage, new job, or new child); or
  • the location data or other information we collect through the App indicates that you have had a life event (e.g., a marriage, new job, or new child) or have an interest in a specific product or service.
In addition, if you indicate in the App that you want to contact an advisor, that request will be provided to a LVLFi advisor. If you have a LVLFi advisor, the request will be sent to that individual. If you do not have a LVLFi advisor, you will be contacted by an advisor within the LVLFi advisor network.

FOR LEGAL REASONS OR TO PREVENT HARM

We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the App or the physical safety of any person.
If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and give affected users notice before transferring any personal information to a new entity.

HOW TO ACCESS OR DELETE YOUR PERSONAL INFORMATION

We provide you with account settings and tools to access and manage the personal information associated with your account. We store information associated with your account until your account is deleted. You can delete your account at any time by contacting Customer Support. Please note that it may take up to thirty (30) days to delete your account information, and we may preserve it for legal reasons or to prevent harm, including as described in the How Information Is Shared And Disclosed section.
You can also manage certain information about your LVLFi.com account by accessing “My Profile” at www.LVLFi.com.

OUR POLICIES FOR CHILDREN

The App is not directed toward or intended for use by children. Users under the age of 18, or the equivalent minimum age in the relevant jurisdiction, are not permitted to create accounts and use the App. Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at Play@LVLFi.com.

INFORMATION SECURITY

We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to maintain the security of your data. We have comprehensive security practices and procedures in place to protect data entrusted to us. Additional detail about how LVLFi protects your data is available online at https://www.LVLFi.com/privacy-policies under “Important Information”. No method of transmitting or storing data is completely secure, however. If you have a security-related concern, please contact our Privacy Officer at 8 Bryanston Square, London W1H 2DH, UK or Play@LVLFi.com.

EFFECTIVE DATE AND CHANGES TO THIS POLICY

The Effective Date of this Privacy Policy is set forth at the top of this page. Whenever possible, we will notify you before we make material changes to this policy and give you an opportunity to review the revised policy before deciding if you would like to continue to use the App. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so. Your continued use of the App after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions. Archived versions of this Privacy Policy are available online.

HOW TO CONTACT US

If you have questions about this policy, or about our use of your information, please contact us at Play@LVLFi.com or at:
Privacy Officer
8 Bryanston Square
London
W1H 2DH
UK

Important Information:

PROTECTING YOU AND YOUR INFORMATION

Your personal information is important to you. It’s important to us, too. That’s why we do so much to protect your information, while continually providing service you can count on. One of our highest priorities is maintaining the privacy and confidentiality of customer information.
While no one can guarantee absolute information security, we protect your information in many ways – from proactively preparing for disasters and business interruptions, to using safe and secure computing practices. We continuously review and make enhancements to how we safeguard and protect customer information.
We continuously review and make enhancements to how we safeguard and protect customer information.

Privacy and security are a priority

We take privacy and the confidentiality of our customers’ information very seriously at LVLFi. We are committed to maintaining your confidence in us. We apply industry best security practices and have
procedures in place to protect data entrusted to us. These procedures and related standards include limiting access to data and regularly testing and auditing our security practices and technologies. Employees and temporary workers are required to follow policies and procedures and understand the importance of maintaining the confidentiality of customer information. If they fail to do so, they are subject to disciplinary action. Personal information about employees or customers is only disclosed as required or permitted by law and in accordance with established company procedures.
We have a comprehensive information security program that includes administrative and technical safeguards for the protection of customer information.

Protected and prepared

Disasters and business interruptions can occur without warning. We are committed to protect and preserve
our business records and financial and informational assets through continuous business operations… Employees are trained to report data breaches immediately.

Protecting your data on-site

Our Physical Security Standards program helps all areas of our company reduce risk and work to ensure compliance with corporate standards. This program includes controls such as physical risk assessments, access control, and other policies and procedures.

Proactive protection via systems

Virus protection
Files coming into the company network are scanned for viruses
and other malicious software. We deploy anti- virus software in our
email management system, Web and application servers, as well as on all desktops. Employees are trained to recognize signs of potential computer infections in addition to recognizing phishing scams as preventive measures to decrease risk of an outbreak.

Proactive risk protection via processes

Risk management
We use multiple risk management processes and procedures.  We require all vendors to conform to standard security requirements.
Cybersecurity Protocols
We utilize a set of industry standards and best practices to align our risk management processes.
Encryption
We have encryption tools to enhance the integrity and confidentiality of confidential information. Documents and email that include sensitive information are encrypted prior to being sent over public networks. Company desktops are required to be encrypted.
Records retention and destruction
We retain business records for the period of time necessary to meet business requirements and legal obligations. We destroy business records in a manner designed to protect confidential information. All paper documents are shredded or otherwise rendered unreadable upon disposal.

People you can trust

One of our most important assets is our employees. And they take action to protect your information. All employees are required to complete privacy and security training. We also offer a wide variety of other training to all employees and temporary workers that help us achieve our goal of protecting your information.
LVLFi Ltd

Information Security

Protecting Your Information

LVLFi protects your information in many ways—from proactively preparing for disasters and business interruptions, to using secure computing practices. Doing so is one of our highest priorities to ensure your information’s confidentiality, integrity, and availability.
One of our highest priorities to ensure
your information’s confidentiality, integrity, and availability.

Our Program

LVLFi has a Information Security Program that safeguards information against unauthorized or accidental modification, disclosure, fraud, and destruction.
  • Collection of personal information is limited to business need and protected based on its sensitivity.
  • Employees are required to complete privacy and security training.
  • Work area assessments are completed to ensure protection of customer information and compliance with company policy.

Security Protocols

Customer access to web and mobile applications requires the use of unique usernames and strong passwords. LVLFi also uses adaptive authentication systems to evaluate a customer’s location at the time of authentication and historical patterns of login locations. Plus the following:
  • Login image and phrase.
  • Security questions and answers.

Incident Management

LVLFi  has processes to track, manage, and resolve all incidents.
All incidents are investigated. If a data security incident is discovered, an incident response plan is promptly initiated and thoroughly executed. We adhere to all applicable state and federal disclosure laws.

Antivirus Protection

All servers and workstations have antivirus software installed, and updates to definitions are applied frequently.
Information Technology managers review recurring reports to ensure compliance levels are met.

Encryption

Company desktops are required to be encrypted. Confidential data in transmission is encrypted.
Encrypted data is transmitted via secured connections, such as:
• HTTPS (HTTP over TLS).
• Secure File Transfer Protocol (SFTP) over the Internet • Pretty Good Privacy (PGP) encryption via SFTP.

Access

LVLFi  has a process to grant and revoke access to company resources (systems, data, mobile, etc.) that is supported by administrative controls.
Access is restricted to those with a business need. Employees may not access or disclose personally identifiable information for any purpose except as authorized for company-related business purposes.

Patch Management

Updates, patches, and fixes are quickly communicated to affected areas to address critical security issues (e.g., vulnerabilities).
Systems are consistently monitored to identify vulnerabilities and threats and updated when needed.

Third Party Service Providers

LVLFi has a Supplier Management Program which includes processes for vetting, selecting, and monitoring third party service providers.
Third party security profiles are completed when certain types of data are provided to and/or stored at a third party location. A separate risk assessment is completed if the third party is granted access to our networks, systems, or data.
LVLFi Ltd