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PRIVACY POLICY :.

Last updated: 13 May 2020 :.


Thank you for visiting https://level99.co (the “Website”) which is operated by Level99 Limited, (“L99”, “we”, “us” or “our”). For the purposes of EU data protection laws, L99 is the Data Controller (i.e. the company who is responsible for, and controls the processing of, your personal data). :.


This Privacy Policy applies to information we collect and use about visitors to our Website. Please read this Privacy Policy carefully in order to understand our views and practices regarding your personal data and how we will treat it. :.


If you have questions or concerns regarding this Privacy Policy, you may contact us by emailing at: legal@level99.co. :.


1.    COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA :.


1.1    We collect personal data about you when you voluntarily submit information directly to us when you access and use the Website. This can include information you provide to us when you e-mail us using the links on the Website, fill in a form, correspond with us via the Website, phone, email or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, respond to surveys or use some other feature of the Website as available from time to time. You are responsible for any third party personal data shared through this Website and confirm that you have such third party’s consent to provide such personal data to L99. :.


1.2    If you do not provide such information, you may be unable to enjoy certain services or the intended benefits of relevant services provided by us. :.


1.3    The table at Annex 1 sets out the categories of personal data we collect about you, how we use such information and how it is disclosed. The table also lists the legal basis which we rely on to process the personal data. :.


1.4    We also automatically collect personal data about you indirectly, including about how you access and use the Website and information about the device you use to access the Website. :.


1.5    The table at Annex 2 sets out the categories of personal data we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal data. :.


1.6    We may link or combine the personal data we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us. :.


1.7    We may anonymise and aggregate any of the personal data we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Website and developing new products and features. We may also share such anonymised information with others. :.


2.    DISCLOSURES OF YOUR PERSONAL DATA :.


2.1.    We may have to share your personal data with the following parties for the purposes set out as follows, as further detailed in Annex 1 and Annex 2: :.


2.1.1.    Website providers and advisors. Personal data may be disclosed to third party vendors and other service providers that perform services for us, on our behalf. :.


2.1.2.    Purchasers and third parties in connection with a business transaction. Personal data may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business. :.


2.1.3    Law enforcement, regulators and other parties for legal reasons. Personal data may be disclosed to third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to protect the security or integrity of the service; and/or (c) exercise or protect the rights, property, or personal safety of users of the Website or others. :.


3.    RETENTION PERIODS :.


3.1.    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for (as set out in paragraph 1 above, and in Annex 1 and Annex 2 below), including for the purpose of satisfying any legal, accounting, or reporting requirements. :.


3.2.    To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means, and the applicable legal requirements. :.


3.3.    In some circumstances, you can ask us to delete your data: see paragraph 5.1.4 below for further information. :.


3.4.    In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. :.


4.    STORING AND TRANSFERRING YOUR PERSONAL DATA :.


4.1.    Security. We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, change or damage. All personal data we collect will be stored on secure servers. :.


4.2.    International Transfers of your Personal Data. Your personal data may be transferred to, and processed and stored in, countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are located in the European Economic Area ("EEA"), your personal data may be processed outside of the EEA (an "International Transfer"). Any International Transfers of your personal data are made either: (a) to a country or territory ensuring an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data as determined by the European Commission; (b) to a third party that is a member of a compliance scheme recognised as offering adequate protection for the rights and freedoms of data subjects as determined by the European Commission, such as the EU-U.S. Privacy Shield; or (c) pursuant to appropriate safeguards, such as the Standard Contractual Clauses (processors) approved by European Commission Decision C(2010)593 or any subsequent version thereof released by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Policy. :.


5.    YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA :.


5.1.    In the circumstances and under the conditions, and subject to the exceptions, set out in applicable law you may have the following rights in respect of your personal data that we hold:


5.1.1.    Right of access. You have the right to obtain: 


5.1.1.1.    confirmation of whether, and where, we are processing your personal data; 


5.1.1.2.    information about the categories of personal data that we are processing, the purposes for which we process your personal data, and information as to how we determine applicable retention periods; 


5.1.1.3.    information about the categories of recipients with whom we may share your personal data; and 


5.1.1.4.    a copy of the personal data we hold about you. 


5.1.2.    Right of portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another data controller. 


5.1.3.    Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal data that we hold about you without undue delay. 


5.1.4.    Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay, if the continued processing of that personal data is not justified.


5.1.5.    Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.


5.1.6.    Right of objection. You have a right to object to processing of your personal data, based on legitimate interests and direct marketing. 


5.2.    If you wish to exercise one of these rights and are entitled under applicable law to do so, please contact us using the contact details at the end of this Privacy Policy. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. :.


5.3.    You also have the right to lodge a complaint with The Information Commissioner’s Office: 

Website: https://ico.org.uk
Helpline: 0303 123 1113

6.    COOKIES AND SIMILAR TECHNOLOGIES :.


6.1.    This Website uses cookies. To learn more and for a detailed cookie notice, please consult the Cookie Policy. :.


7.    LINKS TO THIRD PARTY SITES :.


    The Website may, from time to time, contain links to and from third party services. If you follow a link to any of these services, please note that these services have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those services. :.


8.     CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”) :.


8.1     This paragraph provides additional details relating to the California Consumer Privacy Act. :.
8.2     Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal data we collect (including how we use and disclose this information), to delete their personal data, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights. :.
8.3     California consumers may make a request pursuant to their rights under the CCPA by contacting us at legal@l99.co. We will verify your request using the information associated with you, including email address. Government identification may be required. Consumers can also designate an authorised agent to exercise these rights on their behalf. :.


9.     CHANGES TO THIS POLICY :.


    We evaluate our privacy policies and procedures to implement improvements and refinements from time to time. Accordingly, we may update this Privacy Policy from time to time, and so you should review this page periodically. If we make material changes to this Privacy Policy, we will update the "last updated" data at the start of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.  :.


10.    NOTICE TO YOU :.


    If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Website. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy. :.


11.    CONTACTING US :.


    If you have any questions about this Privacy Policy, please feel free to contact us legal@level99.co. Alternatively, you may write to us at:


Level99 Limited
White Collar Factory
1 Old Street Yard
London
EC1Y 8AF
United Kingdom

FAO: Legal

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ANNEX 1 - PERSONAL DATA WE MAY COLLECT WHEN YOU USE THE WEBSITE :.

Category of personal data :. How we use it :. Legal basis for the processing :.
Contact information and basic personal details such as your first name, last name, telephone number and email address. :. We may use this information to communicate with you and to deal with enquiries and complaints made by or about you relating to the Website. :. The processing is necessary for: 
 
  • the performance of a contract and to take steps prior to entering into a contract; and 
  • our legitimate interests, namely administering the Website, for marketing purposes and communicating with users. :.
Contact information and basic personal details such as your first name, last name, telephone number and email address. :. We use this information to operate, maintain and provide to you the features of the Website. :. The processing is necessary for: 
 
  • the performance of a contract and to take steps prior to entering into a contract; and 
  • our legitimate interests, namely administering the Website, for marketing purposes and communicating with users. :.

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ANNEX 2 – PERSONAL DATA COLLECTED AUTOMATICALLY :.

Category of personal data :. How we use it :. Legal basis for the processing. :.
Information about how you access and use the Website including, for example, how frequently you access the Website, the time you access the Website and how long you use the Website for, whether you access the Website from multiple devices, the website from which you came and the website to which you go when you leave the Website, and other actions you take on the Website. :. We use this information to present the Website to you. :. The processing is necessary for our legitimate interests, namely to tailor the Website to the user and improve the Website generally. :.
Information about how you access and use the Website including, for example, how frequently you access the Website, the time you access the Website and how long you use the Website for, whether you access the Website from multiple devices, the website from which you came and the website to which you go when you leave the Website, and other actions you take on the Website. :. We use this information to administer the Website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to help us develop new products and services. :. The processing is necessary for our legitimate interests, namely communicating with users and responding to queries, complaints, and concerns, and for developing and improving the Website. :.
Information about how you access and use the Website including, for example, how frequently you access the Website, the time you access the Website and how long you use the Website for, whether you access the Website from multiple devices, the website from which you came and the website to which you go when you leave the Website, and other actions you take on the Website. :. We use this information to detect and prevent fraud. :. The processing is necessary for our legitimate interests, namely the detection and prevention of fraud. :.
Information about your device including information about your computer, tablet, smartphone or other electronic device you use to connect to the Website. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Website through the device, your Internet service provider or mobile network and your IP address. :. We use this information to present the Website to you. :. The processing is necessary for our legitimate interests, namely to tailor the Website to the user and improve the Website generally. :.
Information about your device including information about your computer, tablet, smartphone or other electronic device you use to connect to the Website. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Website through the device, your Internet service provider or mobile network and your IP address. :. We use this information to administer the Website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to help us develop new products and services. :. The processing is necessary for our legitimate interests, namely communicating with users and responding to queries, complaints, and concerns, and for developing and improving the Website. :.
Information about your device including information about your computer, tablet, smartphone or other electronic device you use to connect to the Website. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Website through the device, your Internet service provider or mobile network and your IP address. :. We use this information to detect and prevent fraud. :. The processing is necessary for our legitimate interests, namely the detection and prevention of fraud. :.

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