Last updated: September 13, 2018

Privacy Policy

Laetly, Inc. (“we”, "our" or “us”) is concerned about your privacy, and we want to familiarize you with how we collect, use and disclose your information. This Privacy Policy describes our practices in connection with information which we collect through the Laetly website, our social media pages, other electronic communications, as well as HTML-formatted email messages that we send to you or receive from you (collectively, the “Platform"). Please note that this Privacy Policy applies only to our online information-gathering and dissemination practices in connection with the Platform and does not apply to any of our practices conducted offline. If you have any questions or comments about the Privacy Policy or our privacy practices, please contact us at info@laetly.com.

Terms not defined in this Privacy Policy are defined in our Terms of Use, available at: www.laetly.com/terms.

1. Acceptance of terms. By using the Platform, you agree with all terms of this Privacy Policy. Please do notuse the Platform if you disagree with any part of this Privacy Policy.

2. "Personal Information". We automatically track certain basic information about our users and their in-Platform actions. We use this information to do internal research on our members' usage patterns, interests, preferences and general behavior, to better understand and serve you and our community. When you sign up for a Platform user account (“User Account”), we collect information about you and your use of the Platform, which may include the following (and which may change from time to time):

  • your email address;

  • your first and last name;

  • your telephone numbers;

  • gender;

  • additional information shared by you;

  • a password selected by you;

  • credit/debit card information;

Your credit/debit card information will be transferred to a third party that handles payments for us. To keep your credit/debit card information safe and secure, we do not store full credit/debit card information on our servers.

3. "Other Information". We may also collect information such as:

  • your location;

  • message(s) you send to us;

  • information we receive from other sources, such as public databases, joint marketing partners, social media platforms, from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties.

4. Third Party Partners. We currently contract with e-commerce and other online partners to help manage and optimize our business and communications. We use the services of Platform "analytics partners" to help us measure the effectiveness of our advertising, and how visitors use the Platform. We may receive additional information about you, such as demographic data, payment information, or fraud detection information, from third-party partners and combine it with other information that we have about you.

5. Use of Personal Information. We use the information we collect about you:

  • To respond to your inquiries and fulfill your requests;

  • To keep a record of your contact information and correspondence, and use it to respond to you, if you contact us through the Platform;

  • To send administrative information, for example, information regarding the Platform and changes to our terms, conditions, and policies;

  • To allow you to send Platform-related content to a friend through the Platform. By using this functionality, you are telling us that you are entitled to use and provide us with your friend's name and email address;

  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving or modifying our Platform, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities;

  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce the Platform's Terms of Use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain;

  • To create a better, more personalized experience for you based on your individual usage habits, improve our marketing and promotional efforts, analyze Platform usage, and customize our Platform's content and layout in order to better meet your needs;

  • To use for promotional, sales or any use that we consider appropriate, your correspondence with us, or photographs submitted for publication in the Platform;

  • To send you text messages and push notifications;

  • Facilitate transactions and payments.

6. Disclosure of Personal Information. We may disclose information we collect about you:

  • To our affiliates and partners for purposes described in this Privacy Policy, consistent with our goal of providing the highest level of service;
  • To our third-party service providers that provide services such as Platform hosting, Platform-related consulting and monitoring, data analysis, information technology and related infrastructure, customer service, email delivery, auditing and other similar services;
  • To identify you to anyone to whom you send messages through the Platform;
  • Posted by you on the Platform or provided by you through registration process. Please note that any information you post or disclose through the Platform will become public information, and may be available to us, to users of the Platform and to the general public. We urge you to be very careful when deciding to disclose your Personal Information and Other Information, or any other information, on the Platform;

  • To a third party (whether affiliated or unaffiliated with us) in the event of any reorganization, merger, sale, joint venture, assignment, conveyance, transfer or other disposition of all or any portion of our business, assets or interests (including in connection with any bankruptcy or similar proceedings);

  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce Platform’s Terms of Use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) respond to claims that any posting or other content of our Site violates the rights of third parties, including without limitation providing information necessary to satisfy the notice and counter-notice procedures pursuant to the Digital Millennium Copyright Act. You authorize us to disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability. Without your affirmative consent, we do not sell, rent or otherwise share your personally-identifiable information with other third parties, unless otherwise required as described above;

• To a third party to facilitate transaction and payment.

7. Collection of Personal Information and Other Information. We and our third-party service providers may collect information about you in a variety of ways, including:

  • Through your browser or device: certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type, screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Platform you are using. We use this information to ensure that the Platform functions properly;

  • Through mobile sensor data: we collect from Drivers’ devices data (such as speed, direction, height, and acceleration) to improve location accuracy and analyze usage patterns;

Using cookies: cookies are pieces of information stored directly on the device that you are using. We may use cookies in connection with the Platform. You can prevent your web browser from accepting new cookies or disabling cookies altogether. The “Help” feature on most browsers contains those settings. However, because cookies allow you to take advantage of some of Laetly’s essential features, we recommend that you leave them turned on. For instance, if you block or otherwise reject our cookies, you may not be able to add items to your shopping cart, proceed to checkout, or use any Laetly services that require you to sign in;
  • Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Platform to, among other things, track the actions of users of the Platform (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Platform and response rates;

  • IP Address: your "IP Address" is a number that is automatically assigned to the device that you are using by your Internet Service Provider ("ISP"). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Platform, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites and applications. We use IP Address for purposes such as calculating usage levels of the Platform, helping diagnose server problems, and administering the Platform;

  • From you: information, such as your location, as well as other information, such as your preferred means of communication, is collected when you voluntarily provide this information. Unless combined with Personal Information, this information does not personally identify you or any other user of the Platform;

  • By aggregating information: aggregated Personal Information does not personally identify you or any other user of the Platform;

8. Use and Disclosure of Other Information. Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it as described in this Privacy Policy, as well as for all the purposes for which we use and disclose Personal Information. In some instances, we may combine Personal Information and Other Information (such as combining your name with your geographical location). If we combine any Personal Information and Other Information, the combined information will be treated by us as Personal Information as long as it is combined.

9. Payment information. All payments are facilitated through a third-party payment processor. Your information is subject to third party payment processing’s terms of use and privacy policy. Please see third party payment processing’s policies for how your data may be used or stored.

10. Third-party services. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site, application or service to which the Platform may link. The inclusion of a link on the Platform does not imply endorsement of the linked site, application or service by us or by our affiliates. Please note that we are not responsible for the collection, usage and disclosure policies and practices (including data security practices) of other organizations, companies or affiliates, such as any application, social media platform, or wireless service provider, including any personal information you disclose to others through or in connection with the Platform.

11. Security. We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with this Privacy Policy.

We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input. We reveal only the last four digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer.

12. Your choice regarding our use of your Personal Information for marketing purposes. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out from receiving these marketing-related emails by contacting us by email at info@laetly.com.We will try to comply with your request(s) as soon as reasonably possible. Please note that if you do opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

13. How you can change or suppress your Personal Information. You may request to correct, update, suppress, or otherwise modify, any of your Personal Information that you have previously provided to us through the Platform, or object to the use or processing of such Personal Information by us. In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to us suppressed from our database or otherwise let us know what limitations you want to place upon your Personal Information which you have provided to us. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably possible. Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed.

14. Retention period. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. We will retain in our files information you may have requested us to remove if, in our discretion, retention of the information is necessary to resolve disputes, troubleshoot problems or to enforce the Terms of Use. Furthermore, your information is never completely removed from our databases due to technical and legal constraints (for example, we will not remove your information from our back up storage).

15. Use of electronic communication by minors. The Platform is not directed to individuals under the age of eighteen (18), and we request that these individuals not provide Personal Information through the Platform. We restrict Platform to persons age 18 years or older. Laetly does not sell products for purchase by children. We sell children's products for purchase by adults. If you are under 18, you may use Laetly only with the permission and oversight of a parent or guardian. We do not knowingly collect personal information from children under the age of 13 without the consent of the child's parent or guardian.

16. Cross-border transfer. The Platform is controlled and operated by us from the United States, and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Platform you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

17. GDPR disclaimer. The Platform is not intended to be used by individuals residing in the European Union, is not advertised or directed towards individuals residing in the European Union, and is not hosted on websites, platforms, or is using technology or similar that is located or operated inside the European Union. The provisions contained in this Privacy Policy may or may not be compliant with European Union law, including its General Data Protection Regulation ("GDPR"), or affiliated or similar laws. However, we make good faith efforts to comply with GDPR, and to that end we provide the following "GDPR Statement":

If our Privacy Policy is subject to GDPR, then the following applies:

(a) At Laetly, we recognize the sensitive nature of the personal data we collect and the importance of protecting it. The GDPR requires us to obtain consent from European Union ("EU") residents before using their data in any way. It also entitles them to access their data and ask for it to be removed and forgotten from any databases on request.

(b) Below is a list of privileges and how you can exercise these privileges and rights included with GDPR.

(c) You have a right to consent to how Laetly uses your data. Below is a list of the data points we collect and how they are used. We never abuse your information. Along with consenting, you also have the right to withdraw your consent.

(d) We collect data, including:

  • First Name – used as a contact point reference

  • Last Name – used as a contact point reference

  • Email Address – used as a contact point

  • Phone Number – used as a contact point

  • Interest – used to track the brand(s) you’re interested in

  • Source – used to track how you found Laetly

  • Other Text Field Box – collects any information you wish to provide us

(e) Your data is used for marketing emails and marketing promotions such as newsletters, informational updates about Laetly, and invitations to special events, webinars, and conferences.

(f) Your data is stored for an indefinite matter of time if you don’t notify Laetly via the below methods to remove it. In the case that Laetly tries to contact you and your email address and/ or phone number are no longer viable, your information will be declared inactive and Laetly will not continue to attempt contact. If your contact information is updated with viable information, our records will be declared active as long as you haven’t exercised your right to revoke consent or be forgotten.

(g) Under GDPR you have the right to ask for all the data collected on you. Your data is stored in a secure database. It will take up to 72 hours to retrieve and send you collected data. The data will be provided in the form on a spreadsheet and sent via personal email.

(h) Your right to be forgotten refers to your right to have your information wiped from our database. If you wish for your information to be removed please email us at info@laetly.com and we’ll confirm your information is removed via personal email within 72 hours.

(i) If you wish to submit a formal complaint against how your data is being used, collected, or stored by Laetly, contact us at info@laetly.com.

(j) If you’ve consented to receive messages from us and need to revoke that consent, please contact us at info@laetly.com and we’ll update our records and ensure your data is not stored. We’ll confirm your withdrawal via personal email within 72 hours.

18. Sensitive information. Please do not send us, and do not disclose, any sensitive Personal Information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Platform or otherwise to us.

19. Updates to this privacy policy. We may change this Privacy Policy. Please take a look at the "Last Updated" legend at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy in the Platform. Your use of the Platform after those changes means that you accept the revised Privacy Policy.

20. Dispute Resolution. Any dispute, claim or controversy arising out of or relating to this Privacy Policy or previous Privacy Policy statements shall be resolved through negotiation, mediation and arbitration as provided under our Terms of Use.

21. Entire agreement. This Privacy Policy hereby incorporates by reference any additional terms that we post in the Platform (including, without limitation, our Terms of Use) and, except as otherwise expressly stated herein, this Privacy Policy is the entire agreement between you and us relating to the subject matter herein and supersedes any and all prior or contemporaneous written or oral agreements or understandings between you and us relating to such subject matter.

22. Contacting us. If you have any questions about this Privacy Policy, please contact us by email at info@laetly.com.

23. ADA Compliance, Disabilities, Accessibility. Laetly attempts to make its information accessible to all individuals. If you use special adaptive equipment and encounter problems when using our Platform, please report them using the following contact information: info@laetly.com. We will let you know if the information is available in an alternate format. We strive to meet World Wide Web Consortium (W3C) Recommendations and other web industry standards, specifically conforming to HTML 5, CSS Level 3, WAI-ARIA, and the U.S. Access Board's Section 508 guidelines.

Laetly is committed to making its Platform available to as many people as possible, and makes every effort to ensure its communications are accessible to those with special needs, including those with visual, hearing, cognitive and motor impairments.

If you come across a page you find difficult to use, please contact us at info@laetly.com. All materials © 2018 Laetly Inc., unless otherwise noted. All rights reserved.