Privacy Policy

Last Updated: 3rd May 2018

 

This Privacy Policy (the “Policy”) explains how personal information is collected, used and disclosed by Life Impact Ltd and its subsidiaries (collectively, “Life Impact Ltd,” “we,” “our” or “us”). This Policy applies to visitors and users (individually, “you) of Life Impact Ltd's websites, applications and other online services (each, a “Site” and, collectively, our “Sites”), although not all services described here are available in all jurisdictions.

By visiting or using our Sites, to the extent permitted by the applicable law, you are consenting to us gathering and processing information about you in accordance with this Policy, although consent may not be required for all of the elements described in this Policy. For particular types of information or processing, we may provide you with choices or request your further consent related to what information we collect and how we may process it.

Third parties such as social networks that you use in connection with our Sites may also collect, use and share information about you. This Policy does not cover such third parties or their services and we do not take any responsibility for how such third parties may use any information they collect. For information about third party privacy practices, please consult with them directly.

 

BRIEF OVERVIEW

1. Information We Collect

We may collect your information in connection with your registration, use, purchase or inquiries on or about our Sites that link to this Policy. See below...

2. How We Use Your Information

We may use your information to provide services, respond to and fulfill your requests, operate and market our Sites, comply with applicable law, and as otherwise permitted by applicable law. See below...

3. Sharing Your Information

Information you submit when you visit our Sites will be used by the us only as necessary for our legitimate business interests. Personally identifiable information is never sold or leased to any third parties. See below...

4. Security of Your Information

We maintain commercially reasonable technical, administrative and physical security measures designed to protect your information. See below...

5. Cookies and Other Tracking Technologies

We may use cookies and similar technologies to help provide our Sites, offer you a more personalised user experience and market products and services to you. See below...

6. Your Choices

You can opt out of receiving marketing communications from us, change your communication preferences, amend your payment information details for purchases made and/or opt-out of any of your pre-agreed sharing of your information with third parties. See below...

7. Access and Correction of Your Information

We provide you the opportunity to access, correct and update your information. See below...

8. International Transfers

We may transfer your information outside of your home country. To protect your information, any such international transfers will be made in accordance with applicable law. See below...

9. Links to Other Websites

Our Sites may contain links to other websites or services that are not owned or controlled by Life Impact Ltd, including links to websites of our advertisers, sponsors and partners. See below...

10. Changes to This Policy

You will be notified about any material changes to this Policy via a posting on our Sites, and as otherwise required by applicable law. See below...

11. Contact Us

If you have questions about this Policy, please contact us. See below...

12. Residents of the United Kingdom and the European Union

Residents of the United Kingdom and the European Union may have additional rights. See below...

 

1. INFORMATION WE COLLECT

Personal Information. By visiting or using our Sites, we may collect the following categories of personal information (“personal information”) you provide to us: name; email address; postal address; phone number (including your mobile phone number); billing information; survey responses; demographics; primary home and/or work geographical location; marketing responses; photos of you (such as if you add a photo of yourself to your profile); account settings; passwords; names and email addresses of any people you invite to purchase any of out digital and non-digital services through our Affiliate scheme; and other information you may provide about yourself or others to our Sites or to which you provide us with access via third-party platforms.

We do not proactively collect personal information considered as sensitive personal information such as health-related information. However, for certain services on our Sites, credit or debit card account information may be required.

In addition, we may receive certain categories of personal information listed above and some device information listed below (such as your name, email, browsing history on our sites and other details) from sources other than you, such as from third-party websites, applications and services (each, a “third-party platform”). If you are an existing Life Impact Ltd customer, we will combine this information with information we collect on our Sites and use it for the purposes described below.

Personal information, device information and location information are collectively referred to as “your information.” Our Sites are for persons 16 or older. As such, Life Impact Ltd does not knowingly collect personal information from children under the age of 16.  If you learn that your child has provided us with their information without your consent and he or she is under the age of 16, please let us know at [email protected] or write to us, as detailed in Section 9 below, so we may remove it from our systems.  

Device Information. When you visit our Sites or open communications (such as emails), some information is automatically collected from devices (e.g. mobile, computer, laptop and tablet) used to visit or use our Sites including, but not limited to, your operating system, access times, browser information (e.g. type, language and history), settings and other data about your device that we use to provide the services or as otherwise described in this Policy (“Device Information”). We also collect information about your usage and activity on our Sites using certain technologies, such as cookies and other technologies. Cookies are pieces of information that a website transfers to an individual’s computer hard drive for record keeping purposes.

Location Information. If you use our Sites, we may receive your generic location (such as your city or neighborhood). We may use and store this information to provide and improve features of our Sites, for example, to tailor our Sites on a needs-based manner to better facilitate your requests and to provide you more relevant content. Please see the Your Choices section, below, for more information about how to adjust your preferences, including those related to location information.

 

2. HOW WE USE YOUR INFORMATION

We may use your information for the following purposes (“Purposes”), to provide you with the services, products and functionality offered on our Sites and fulfill your requests and to communicate with you about your account or use of our Sites, services, products and/or functionality; respond to, or follow up on, your comments and questions, and otherwise provide customer service; communicate with you about special offers and other marketing communications; operate and improve our Sites, products, services, and functionality; authenticate your credit or debit card account information, if applicable; tailor your experience on our Sites, including search results and displaying relevant advertising; provide information, services and products to our customers; link or combine with other information we get from third parties to help understand your needs and provide you with better service; perform statistical analysis; protect, investigate, and deter against fraudulent, unauthorized or illegal activity; comply with our policies, procedures and legal obligations; and as otherwise consented to by you and as required or permitted by the applicable law.

If you do not provide us with certain of your information, we may not be able to fulfill the requested purpose of collection, such as to respond to your queries or provide our Sites to you.

Combined Information. We may combine your personal information with device information and location information (with your consent, where required) to serve you specifically, such as to deliver a product to you according to your preferences or restrictions, or for advertising or advertising targeting purposes. When we combine personal information, device information and location information in this way, we treat it as, and apply all of the safeguards in this Policy applicable to, your information.

Electronic Communications. Consistent with the above Purposes, we may communicate with you via electronic messages, including email, text message or mobile push notification to, for example: send you information relating to our products and services, including purchase receipts, technical notices, updates, security alerts and support and administrative messages; and/or, subject to the Your Choices section, below, and/or the applicable law, communicate with you about contests, offers, promotions, rewards, upcoming events and other news about products and services offered by Life Impact Ltd, our subsidiaries, our affiliates and other business partners. With your consent, where required, we may contact you at the mobile phone number that you provide to us by way of direct dial calls and text messages in connection with the above Purposes.

Our Role as Data Controller and Data Processor. We generally act as the data controller of your information; however, under certain Life Impact Ltd programs, our Affiliates may sometimes engage you to communicate certain offers. Although we provide the tools to help the Affiliates market our products and services as well and as legally as possible we are not responsible for their use of your information which they will have acquired from you independently of us and our Sites. 

Aggregated Information. We may aggregate personal information collected from you and other users as well as device information and location information (with your consent, where required) to produce general statistics that cannot be linked to you or any other specific user and with which we attempt to provide you with a better experience, to improve our services and to analyze and understand how our Sites and products and services are used.

Retention. We will retain your information for the period necessary to fulfill the Purposes outlined in this Policy and as otherwise needed to comply with the applicable law and internal company policies.

 

3. SHARING YOUR INFORMATION

When you initially provide your credit or debit card account information through our Sites in order to purchase our products and services we provide your credit or debit card account information to our third-party payment service providers. As explained in the Life Impact Ltd Terms of Use, these third parties may store your credit or debit card account information so you can use our payment services through our Sites in the future to the extent permitted by the appropriate law.

For information about the security of your credit or debit card account information, see the Security of Your Information section, below.

Our Sites may allow you to connect and share your actions, comments, content and information publicly or with friends. Our Sites may also allow you to connect with us on, share on and use third-party platforms, including those on which Life Impact Ltd has a presence. Please be mindful of your personal privacy needs and the privacy needs of others as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. Life Impact Ltd also does not control the privacy practices of third party platforms. Please contact those sites and services directly to learn about their privacy practices.

We do not share your information with third parties other than as described above and as follows:

  • We may share information with third partiesfor their own marketing purposes which are subject to the separate privacy policies of such third parties. We will do this on the basis of your consent, where required by law, and if not required by law on the basis of our legitimate interests in sharing data with our partners so that we can help you see offers and services which are most relevant to you. To learn more about your choices related to how we share your information with third parties, please see the Your Choices section, below.
  • We may share information with third-party vendors, consultants, and other service providers who perform functions on our behalf (e.g. hosting or operating our Sites, data collection, reporting, ad response measurement, site analytics, data analysis, delivering marketing messages and advertisements, processing credit card payments and providing fraud detection services). We do not authorize these third parties to use your information for purposes other than for which it has been provided, and do not authorize these third parties to disclose that information to unauthorized parties. We require these third parties to maintain appropriate security to protect your information from unauthorized access or processing.
  • We may disclose your information to regulatory authorities, courts, government agencies and other third parties where we believe that doing so would be in accordance with or permitted or required by any applicable law, regulation or legal process, to defend the interests, rights and/or property of Life Impact Ltd or others, or to respond to emergencies.
  • We may disclose or transfer your information to a third party if we sell, transfer, divest or disclose all or a portion of our business or assets to another company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding.
  • We may share aggregate statistical data for the improvement of services offered by our Sites. We may also share aggregated or de-identified information with third parties in our discretion.
  • We may otherwise share your information as directed by you or subject to your consent.

 

4. SECURITY OF YOUR INFORMATION

Life Impact Ltd takes commercially reasonable technical, administrative and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration and destruction.

When your credit or debit card account information is being transmitted to our Sites or through our Sites, it will be protected by cryptographic protocols. To be clear, Life Impact Ltd does not itself store your credit or debit card account information, and we do not have direct control over or responsibility for your credit or debit card account information. We use third party payment processors that are the controllers of your credit card information. Our contracts with third parties that receive your credit or debit card account information require them to keep it secure and confidential. 

Nonetheless, we cannot guarantee that transmissions of your credit or debit card account information or your other information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by Life Impact Ltd or our third party service providers. Except to the extent that liability cannot be excluded or limited due to the applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third party access or other causes beyond our control.

You play an important role in keeping your information secure. You should not share your user name, password or other security information for your Life Impact Ltd account with anyone. If we receive instructions using your user name and password, we will consider that you have authorized the instructions. If you have reason to believe that your interaction with us is no longer secure (e.g. if you feel that the security of any account you might have with us has been compromised), please contact us immediately as detailed in the Contact Us section, below.

Also, when using bulletin boards and chat and comment areas on our Sites, you are solely responsible for the content of messages you post. Users should be aware that when they voluntarily disclose personal information (e.g. user name, e-mail address, phone number, address and such like) on the bulletin boards or in the chat and comment areas, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features.

 

5. COOKIES AND OTHER TRACKING TECHNOLOGIES

We collect information about your usage and activity on our Sites using certain technologies, such as cookies and other technologies. Third parties may also view, edit or set their own cookies and use other technologies. The use of these technologies by such third parties is subject to their own privacy policies and is not covered by this Policy, except as required by law.

Cookies make using our Sites easier by, among other things, saving your passwords and preferences for you. These cookies are restricted for use only on our Sites, and do not transfer any personal information to any other party. Most browsers are initially set up to accept cookies. You can, however, reset your browser to refuse all cookies or indicate when a cookie is being sent. Please consult the technical information relevant to your browser for instructions. If you choose to disable your cookies setting or refuse to accept a cookie, some parts of our Sites may not function properly or may be considerably slower.

 

6. YOUR CHOICES

Email. If you do not want to receive marketing and promotional emails from Life Impact Ltd you may click on the “Unsubscribe” link in the email to unsubscribe and opt-out of marketing email communications. If you have a Life Impact Ltd account, you may also opt-out of marketing emails in your account settings. Alternatively, to the extent that the applicable law requires your prior opt-in consent to receive marketing and promotional emails, you can choose not to opt-in. Please note that even if you opt-out of receiving marketing communications from one or all of our Sites, we may need to send you service-related communications, such as confirmations of any future purchases you have already made.

Mobile Push Notifications. You can use the settings on your mobile device to enable or turn off mobile push notifications from Life Impact Ltd.

Text Messages. If you no longer want to receive text messages from Life Impact Ltd, reply STOP (or as otherwise instructed) in the text message. If you have a Life Impact Ltd account, you may also adjust your account settings to opt-out of text messages. Alternatively, to the extent that the applicable law requires your prior opt-in consent to receive text messages, you can choose not to opt-in.

Cookie Choices. To exercise choices regarding cookies set through our website, as well as other types of online tracking and internet advertising. Cookies and similar tracking technologies, such as beacons, scripts and tags are small bits of code, usually stored on a user's computer hard drive or device, which enable a website to “personalize” itself for each user by remembering information about the user's visit to the website. We also use these technologies within emails or other communications we send to you. Where required by law, we will obtain your consent before we collect this information from your device or use these technologies.

Application location choices. As detailed in the Information We Collect section, above, we may collect information about your location if you enable location services through the settings in your mobile device, or, as required, with your consent. You can change the privacy settings of your device at any time to turn off the sharing of this location information with our Sites. If you choose to turn off location services, this could affect certain features or services of our Sites. If you have specific questions about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.

Sharing with Affiliates. You can opt-out of sharing your information with our Affiliates for their own marketing purposes or other uses with effect for the future by changing your Life Impact Ltd account preferences. You may also send such opt-out requests to us as detailed in the Contact Us section below.

In addition to the above methods of exercising choice, to the extent required by the applicable law or as otherwise noted in the Residents of the United Kingdom and the European Union section below, we may provide you with additional choices regarding the processing of your information, which you may exercise by contacting us as detailed in the Contact Us section below. We will try to comply with your request as soon as reasonably practicable as required by applicable law.  

 

7. ACCESS AND CORRECTION OF YOUR INFORMATION

If you have created an online account with us and would like to update the information you have provided to us, you can access your account to view and make changes or corrections to your information. You may also contact us as detailed in the Contact Us section, below.

 

8. INTERNATIONAL TRANSFERS

Information about you may be transferred to, or accessed by, entities located around the world as described in this Policy. Some of these entities may be located in countries that do not provide an equivalent level of protection as your home country. Where required, Life Impact Ltd has implemented appropriate cross-border transfer solutions to provide adequate protection for transfers of certain information. By using our Sites, and providing us information about you, you consent to the international transfer of information about you to the above parties.

 

9. LINKS TO OTHER WEBSITES

Our Sites may contain links to other websites or services that are not owned or controlled by Life Impact Ltd, including links to websites of our advertisers, sponsors and partners. This Policy only applies to information collected by our Sites. We have no control over these third party websites, and your use of third party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third party websites linked to our Sites. Your use of third parties’ websites linked to our Sites is at your own risk, so we encourage you to read the privacy policies of any linked third party websites when you leave one of our Sites.

 

10. CHANGES TO THIS POLICY

Except to the extent limited by the applicable law, we reserve the right to update this Policy to reflect changes to our information practices by prominently posting notice of the update on our Sites, and as required, obtaining your consent. Any updates will become effective immediately after posting the updates to this Policy and apply to all information collected about you, or where required, upon your consent. You agree that you will review this Policy periodically. If we make any changes to this Policy, we will change the “Last Updated” date above. You are free to decide whether or not to accept a modified version of this Policy, but accepting this Policy, as modified, is required for you to continue using our Sites. If you do not agree to the terms of this Policy or any modified version of this Policy, your sole recourse is to terminate your use of our Sites.

If we make any changes to this Policy that materially impacts previously collected information about you, we will obtain your prior express consent.

 

11. CONTACT US

If you have any questions about this Policy or information we have collected about you, please contact us by email at [email protected] or by postal mail at:

Life Impact Ltd, Percy Laurie House, 217 Upper Richmond Road, London SW15 6SY. Great Britain.

Attention: Life Impact team

 

12. NOTICES TO RESIDENTS OF THE UNITED KINGDOM AND THE EUROPEAN UNION

Residents of the United Kingdom and the European Union. If you are a resident of the United Kingdom (“UK”) or the European Union (“EU”), you may have certain additional rights, as detailed below. For the purposes of this notice, “personal data” has the meaning ascribed in the EU General Data Protection Regulation.

Processing Bases and Consequences. To process your personal data, we rely on the following legal bases:

  • For the performance of a contract we have with you (such as if you use our products and services, we'll use your information to carry out our obligation to fulfill these products and services).
  • For compliance with a legal obligation to which we are subject (such as tax obligations and when we are obliged to comply with lawful requests from competent authorities such as law enforcement).
  • For the purposes of our legitimate interests (such as tailoring your experience on our Sites and for fraud detection), provided that such processing does not outweigh your rights and freedoms.

The processing may also be pursuant to other applicable legal bases for data processing, especially provisions set out by Member State law. To the extent that a legal ground described above would not apply to processing of your personal data by us, we will seek your consent for such specific purpose in accordance with the applicable law.

Your Rights. To the extent a specific element of our processing of your personal data relies upon your consent, you may withdraw such consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. Section 6 of the Privacy Policy describes the options we provide you to easily decline or withdraw your consent.

If you wish to object to the processing of your personal data on the basis of legitimate interest and no opt-out mechanism is available to you directly, please contact us.

If you do not provide us with certain key details of your personal data, we may not be able to fulfill the requested purpose of collection, such as to respond to your queries or provide our Sites to you. However, unless otherwise specified, not providing your personal data will not result in legal consequences for you.

Additional data privacy rights: Below please find information on additional rights you may have under the applicable law:

  • Access: You may request that we confirm whether or not we are processing your personal data. If we are, you may request a copy of your personal data, which we will provide free of charge, together with information about the processing, such as the purposes of the processing and the categories of personal data concerned. However, this is not an absolute right and the interests of other individuals may restrict your right of access. For further copies, we may charge a reasonable fee based on administrative costs. We may decline requests which are excessive, particularly if repetitive.
  • Rectification: You may edit some of your personal data in our Sites. You may also ask us to change, update or fix your personal data in certain cases, particularly if it’s inaccurate.
  • Erasure: You may request the erasure of your personal data.
  • Restrict Processing: You may ask us to restrict the processing of your personal data under certain circumstances, such as if your Personal Data is inaccurate or unlawfully held.
  • Data Portability: You may ask for a copy of the personal data you provided to us in a structured, commonly used and machine readable format and you may have the right to transmit this data to another entity.
  • Object: You may object to the processing of your personal data on grounds relating to your particular situation under certain circumstances, for example for direct marketing.If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us, unless there are overriding compelling legitimate grounds for the processing or as otherwise provided under the applicable law.

Please note that these rights may be limited under the applicable laws. To exercise your data subject rights under the EU’s General Data Protection Regulation, please submit your request to [email protected].  So that we can better process your request, please provide the email you use to log into whichever Life Impact Sites you use.

Please note that we may need to retain certain information for record keeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by the applicable law.

International Transfers. Personal data may be transferred to and processed by recipients that are located inside or outside the European Economic Area (“EEA”). For recipients located outside of the EEA, some are certified under the EU-U.S. Privacy Shield and others are located in countries with adequacy decisions and, in each case, the transfer is thereby recognised as providing an adequate level of data protection from a European data protection law perspective. Other recipients might be located in countries which do not provide an adequate level of protection from a European data protection law perspective and for which we will base the transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission or by a supervisory authority, approved codes of conduct together with binding and enforceable commitments of the recipient, or approved certification mechanisms together with binding and enforceable commitments of the recipient. You may request a copy of such appropriate safeguards by contacting us as set out in Section 6 of the Privacy Policy.

 

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