Any capitalized terms used throughout this Policy that are defined in our Terms, have the same meaning in this Policy.
This Policy relates to your use of our website, which can be accessed via the url www.alifeofriley.com (“Site”).
DATA CONTROLLER AND REPRESENTATIVE
This website is operated by The Progression Agency (“we”, “us” and “our”). We are your data controller. This means that we use, are responsible for and control the collecting and processing of, your personal data. You can find all our details under How to contact us.
As we are a company based outside the European Economic Area, we have nominated the following representative:
Life of Riley OÜ
Harja maakond, Tallinn, Lasnamäe-linnaosa, Sepapaja tn6, 15551
PERSONAL DATA WE PROCESS
Please note that you can always monitor and control the processing of your personal data by exercising Your rights.
It depends on the particular activities carried out by you through our Site which of the following personal data we collect and process from you. You can browse and use our Site without creating an account. Only if you sign up for an account and become a member, we collect your:
- e-mail address;
- account details: your username and password,
regardless of whether you create an account with us, we collect the following personal information:
- IP address;
- approximate location;
- any other personal data you provide us with voluntarily.
PURPOSES AND LAWFUL BASES FOR PROCESSING YOUR PERSONAL DATA
We use your personal data to create and manage your account with us, to forward notifications that a provider of an Event has messaged you via our internal messaging system and to notify you of any changes to our Site or to our services that may affect you. Your personal data are necessary to enable us to provide you with the functionalities we offer.
We may sometimes process personal data to comply with legal obligations imposed on us, for example in relation to the prevention of fraud and money laundering or in relation to tax regulations.
We may also use your personal data if it is in our legitimate interests to do so. Such interests include our ongoing effort to provide, improve and safeguard the different functionalities we offer. We use your IP address to determine your approximate location (country and city within that country). We do this in our legitimate interest to filter the Events relevant to you.
If none of the above lawful bases apply to the processing of your data, we rely on your consent to process such data. For example, if you enable your location on your device, this is considered to be your consent for us to process your location. If you do not want us to process your location, you can turn off this feature on your device. However, if you choose to turn off the location on your device you won’t be able to enjoy all of the functionalities of our App, because some of those will be based on your location. Besides personal data that we need to fulfill our obligations to you, you will also have the option to submit more information about yourself. This is done on a voluntary basis. By submitting such additional information, you express your consent to process such data.
In order to enable us to use your personal data for marketing purposes, such as sending you our newsletter by e-mail, we will ask for your express consent when you create an account. Whenever we rely on your consent to process your personal data, you can withdraw such consent at any time.
Our Site is not intended for children under the age of 18 or such higher legal age for majority applicable in your country of residence. We do not knowingly collect or distribute personal information from or about children under the age of 18 or such other applicable legal age for majority. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us so that we can remove such data immediately from our servers.
SHARING YOUR PERSONAL DATA
We would like to stress that we do not sell your personal information to any other party.
However, we do share your personal information with the following categories of third parties.
- Our providers of Events
If you have an account with us and you click on an Event, we will share your name
with the provider of that Event so that the provider knows who is interested in their
Event and to enable the provider to contact you via our Site. We do not provide them
with your e-mail address.
- Other circumstances in which we may share your personal data and with whom
We will also share your personal data in the following circumstances:
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our users will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any laws, legal obligations or investigations;
- to enforce or apply our Terms, policies or other agreements;
- to protect the rights, property, or safety of our company, its employees, our users or third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
In the event we receive a legal request to disclose your personal data, we may notify
you of such request before we do so, unless this is expressly prohibited by the
authority making the request or if notifying you would be detrimental to us, the party
requesting your personal information, or any other person affected, or to the
investigation itself. If we can’t notify you of such requests beforehand for the reasons
set out before, we will try to notify you afterwards.
We will not share your personal information with any other third party.
HOW AND FOR HOW LONG WE KEEP YOUR PERSONAL DATA
We put appropriate security measures in place to prevent personal data from being accidentally lost, or used or otherwise accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
All information you provide to us is stored on secure servers, based in the United Kingdom.
You are responsible for keeping your password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We only retain your personal data for as long as your account is active or for as long as we need it to fulfil the purposes for which we have initially collected it, unless otherwise required by law. We may retain certain information for longer to comply with applicable laws, to prevent fraud, or for obligations we have in relation to tax regulations.
TRANSFER OF PERSONAL INFORMATION OUTSIDE THE EEA
Our Site can be accessed by users located all over the world. If you are a user located in the European Economic Area (EEA): the personal data that we receive and collect from you may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
Such countries may not have the same data protection laws as the EU. In the event your personal information is transferred to such countries, we have ensured that appropriate safeguards are put in place to protect your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.
Under data protection laws, you have the following rights, which you can enjoy free of charge:
- Right of transparency and information about how we use your personal information.
- Right to ask us to confirm whether or not we hold any personal information from you and if we do, the right to ask us what information we have stored about you and for a copy of that information.
- Right to rectify any inaccurate personal data we hold about you or to complete any incomplete information.
- Right to have all personal data we keep from you erased in the following situations:
- the personal data are no longer necessary in relation to the purpose for which it was collected;
- you have withdrawn your consent to process your data and we do not have any other legal ground to keep processing your data;
- you object to the processing of your data while we do not have any overriding legitimate grounds to do so;
- your data have been unlawfully processed.
- Right of restriction of processing
You have the right to ask us to restrict the processing of your personal data if either
one of the following applies:
- if you contest the accuracy of the personal data, for a period so long that we can verify the accuracy of your personal data;
- if the processing is unlawful and you oppose the erasure of your data and ask for a restriction instead;
- we do no longer need your personal data for the purpose for which it was collected, but you require your data for the purpose of establishment, exercise or defence of legal claims;
- you have objected to the processing pending verification of the legitimate grounds to override such objection.
- Right to object to:
- processing of personal data concerning you based on legitimate interests or the performance of a task in the public interest. Such objection must be based on grounds relating to your particular situation. We are obliged to stop processing your data, unless either we can demonstrate that we have compelling legitimate grounds to override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims;
- direct marketing.
- Right to withdraw consent you have given us to process your personal data, where consent is being relied on as the lawful basis of such processing.
- Right to receive the personal data concerning you in a structured, commonly used, machine-readable format and, if technically possible, have this transferred to another service provider.
You can exercise your rights by checking certain boxes on the forms we use to collect your data, by adjusting your settings in your profile and by contacting us. We may request you for proof of identity and address when you exercise your rights.
CALIFORNIA RESIDENTS ONLY If you are a California resident, then, subject to certain limits under California law, you may ask us to provide you with (a) a list of certain categories of Personal Data we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year; and (b) the identity of those third parties. To make this request, California residents may contact us as specified in the How to contact us section below.
CHANGES TO THIS POLICY
MAKE A COMPLAINT
If you encounter any problems in relation to the use of your personal information, please contact us so we can try to resolve your issue or concern.
If you are a user based in an EU member state you also have the right to lodge a complaint with the supervisory authority in the EU member state where you work, normally live or where any alleged data infringement of data protection has occurred.
HOW TO CONTACT US
Questions, comments and requests regarding this Policy are welcomed and should be addressed to the data controller:
The Progression Agency
Knowledge Village Block 2B
Dubai, United Arab Emirates
© 2018 The Progression Agency
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