LIVINGTONE OVERSEAS INC understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone and will only collect and use personal data in ways that are described in this Policy, and in a way that is consistent with our obligations and your rights under the law.
We (“LIVINGTONE OVERSEAS INC”, “we”, “our” and “us”) are: LIVINGTONE OVERSEAS INC, Tortola Pier Park, Building 1, Second Floor, Wickhams Cay I, Road Town, Tortola, British Virgin Islands
1. Definitions and Interpretation In this Policy the following terms shall have the following meanings: “Cookie” “Cookie Law” means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part below; and means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
3. What is Personal Data? Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. Anonymous information, which we are not in a position to relate to you, does not qualify as personal data.
6. ! IP address; ! Name (including family name); ! Login; ! Web browser type and version; ! E-mail; ! Phone number; ! Operating system; and A list of URLs starting with a referring site, your activity on our Site, and the site you exit to. How Do We Use Your Personal Data? Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for one of the following purposes: ! Providing and managing your access to our Site; ! Personalising and tailoring your experience on our Site; ! Supplying our products and services to you. ! Personalising and tailoring our products and services for you. ! Supplying you with information by email and/or post that you have opted-in to With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or post with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. 7. How Long Will We Keep Your Personal Data? We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the as long as the company has a legitimate or lawful basis for keeping such records. 8. How and Where Do We Store or Transfer Your Personal Data? We may store some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in Cyprus and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within Cyprus and under the GDPR as follows. We store your data with external third parties, as detailed below in Part 9 that are based outside of the EEA. The following safeguards are applied: We use specific contracts with external third parties that are concluded in accordance with regulations adopted by the European Commission for the transfer of personal data to third countries. Contracts like this ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission site (https://ec.europa.eu/info/law/law-topic/data-protection_en). Please contact us using the details below in Part 14 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country. 9. Do We Share Your Personal Data? We will not share any of your personal data with any third parties for any purposes, except the cases directly indicated in this Policy. We may sometimes contract with third parties for data processing purposes. If any of your personal data is transferred to a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
12. How Can You Access Your Personal Data? In addition to your opt-out right, you may exercise the following rights at any time: - You may ask us to provide you with copies of the personal information that we hold about you, or with information about the processing of such information. - You may ask us to update and correct any out-of-date or incorrect personal information that we hold about you. If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email shown in Part 14. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress. If you wish to exercise any of these rights, then please, contact us as described in part 14.
16. Children We recognize that we have a special obligation to protect personal information obtained from children. We will not knowingly collect personal information from any child, or process such information, without parental consent. For the purpose of this Policy, a child means any individual who is under the age of 18 (or the minimum legal age to consent to the collection and processing of personal information where this is different under applicable law). 17. Security LIVINGTONE OVERSEAS INC has implemented all reasonable technical, administrative and physical security measures to protect the security of your personal information. All received information that the client provides is stored on secure servers and only authorized staff have access to this information. We take reasonable precautions to prevent the loss, misuse or alteration of your personal information. Our employees, contractors and agents may be given access to your personal information which we collect, but their use shall be limited to the performance of their duties in relation to facilitating your use of the Services. Our employees, contractors and agents who have access to your personal information are required to keep that information confidential and are not permitted to use it for any purposes other than those listed above or to deal with requests which you submit to us. 18. Enquiries If you have any enquiries about this Policy, or any questions about the use of your personal information, please e-mail our privacy team at: email@example.com.