Privacy Policy
Last Updated: January 20, 2023
This Privacy Policy (the “Policy”) describes what personal information Litify, LLC and its subsidiaries and affiliates (“Litify,” “we,” “our,” or “us”) may collect about you, how we may use it, with whom we may share it, and what choices you may have regarding our use of your personal information. This Policy applies to personal information we collect about you in connection with our website located at https://www.litify.com/ and any other websites and platforms we own and operate that link to this Policy (collectively, the “Site”), and our related services, events, social media pages, and email and other electronic communications (collectively, and together with the Site, the “Services”). Please note, our privacy practices are subject to the applicable laws of the places in which we operate. You will see additional region-specific terms that only apply to users located in those geographic regions, or as required by applicable laws. This Policy does not apply to personal information that we may store or maintain on behalf of the users of our Services, where applicable.
We may update this Policy from time to time so please review this Policy regularly. Such changes will be effective upon posting the revised Policy on the Site. You will be able to tell when this Policy was last updated by the Last Updated date included at the bottom of this Policy. In some cases, we may notify you about an update by sending you an email, posting a notice about the update on the Sites and Services, or other means as may be required by applicable law. Continuing to use the Site or communicating electronically with us thereafter constitutes your acknowledgement of such changes to this Policy.
Personal Information We Collect
Personal Information You Provide to Us. Personal information you provide to us through the Services or otherwise may include the following categories. We may also collect other personal information that is not specifically listed here, which we will use as described in this Policy or as otherwise disclosed at the time of collection.
- Contact information, such as first and last name, email address, phone number, mailing address, and social media handle.
- Professional information, such as company name, job title, company location, email, and phone, and other details we may collect about your business or profession.
- Account information, such as your account name or username, log-in details, information that you store in your account, and other details about your use of the Services.
- Transaction history, such as records of products and services you have purchased from us.
- Payment information, such as payment amounts and payment methods used to complete transactions, and other relevant information about the financial institutions you use to conduct business. All payment processing services connected with your use of theServices are provided to you by third-party payment processors. Litify does not access or keep information related to credit cards, banking information, or other sensitive financial information.
- Marketing information, such as any preferences you set in your account and any marketing or communications preferences.
- Survey responses, such as the information you provide in response to our surveys, questionnaires, or contests.
- Customer service recordings, such as chat communications recorded for training and quality assurance purposes.
- Communications, such as the information associated with your requests or inquiries, including for support, assistance, or order information, and any feedback you provide when you communicate with us.
Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g.,information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us.
Personal Information Automatically Collected. Litify, our service providers, and our advertising partners may automatically log information about you, your computer, or mobile device, and your activity over time on our Services and other sites and online services. Personal information that may automatically be collected includes:
- Online activity information, such as the website you visited before browsing to the Services, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
- Device information, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state, or geographic area.
Like many online services, we use cookies and similar technologies to facilitate some of the automatic data collection described above, such as:
- Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising. For more information, please visit our Cookie Policy.
- Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
- Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
- Session replay technologies, which are third-party software used to record a video replay of users’ interactions with the Website. The video replay may include users’ clicks, mouse movements, scrolls, mobile app touches, typing, and other activity taken during the session. We use these replays for research and development purposes, such as to help us troubleshoot problems with theWebsite, understand how users interact with and use the Website, and identify areas for improvement.
Personal Information Collected Offline. We collect personal information offline, such as when you attend one of our conferences or other events.
Personal Information Obtained from Third Parties. We may receive personal information from third parties, such as our service providers, advertising partners, data analytics partners, operating systems and platforms, social media platforms, event sponsors, publicly available sources, or data providers. We may merge or combine such personal information with the personal information we collect from you directly or automatically.
Personal Information Obtained through Referrals. Users of the Services may have the opportunity to refer colleagues or other contacts to us and share their contact information. Please do not provide us with someone’s contact information unless you have their permission to do so.
How We Use Personal Information
We may use the personal information that we collect for the purposes set forth below and as otherwise described in this Policy or at the time of collection:
To Provide the Services. We may use personal information to provide our Services and operate our business. For example, we use personal information to:
- provide information to you that you request from us relating to our products or services;
- establish, manage, monitor, and maintain your account;
- communicate with you, including providing notices of any changes to our Site, products, or services;
- verify your identity or determine your eligibility for offers and promotions;
- provide any surveys or other promotions you participate in;
- provide customer service and technical support, which may include responding to your requests, resolving issues, or troubleshooting problems;
- improve and customize the Services; and
- fulfill any other purpose for which you provide personal information.
Research and Development. We use personal information for research and development purposes, including to study and improve the Services and our business, understand and analyze the usage trends and preferences of our users, and develop new features, functionality, products, and services. Aspart of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.
Direct Marketing. We may send you Litify-related or other direct marketing communications as permitted by law, including materials, updates, information, special offers, and promotional material from us and our business partners. You may opt-out of our marketing communications as described in the “Your Choices” section below.
Interest-BasedAdvertising. We work with third-party advertising companies and social media companies to help us advertise our business and to display ads for our products and services. These companies may use cookies and similar technologies to collect information about you(including the online activity information and device information described above in the paragraph concerning personal information collected automatically) over time across our Services and other websites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. In addition, some of these companies may use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms. You can learn more about your choices for limiting interest-based advertising in the “Your Choices” section below.
To Comply with Laws and Regulations. We will use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For Compliance, Fraud Prevention, and Safety. We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a)maintain the safety, security, and integrity of the Services and our products and services, business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Services; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With Your Consent. We will disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.
How We Share Personal Information
In addition to the specific situations described in this Policy or at the point of collection, we may share personal information with the following entities or persons:
Affiliates and Related Companies. We may share your personal information with our affiliates, subsidiaries, and other related companies.
Service Providers. We may share your information with third-party service providers that perform services on our behalf, such as web-hosting companies, analytics providers, information technology providers, marketing companies, and other purposes.
Advertising Partners. We may share personal information with third parties who we partner with for advertising campaigns or that collect information about your activity on the Services for the purposes described in the “Interest-Based Advertising” section above.
Other Users of the Services. Partners and users of ourServices who participate in our community portal may be able to submit content to the Services (such as comments, questions, stories, reviews, surveys, blogs, photos, and videos), and we will identify you by displaying information such as your name, username, or a link to your user profile along with the content you submit. We do not control how other users or third parties use any personal information that you make available to other users.
Authorities and Others for Compliance, Fraud Prevention and Safety. We may disclose personal information for the compliance, fraud prevention, and safety purposes as described above, including in good faith belief that such action is necessary to comply with legal obligations. Under certain circumstances, this may include disclosures to law enforcement, government authorities, and other parties if required to do so bylaw or in response to valid requests by public authorities (e.g., a court or a government agency).
Professional Advisors. We may disclose your information to professional advisors for advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters where necessary in the course of the professional services that they render to us.
Business Transaction Participants. We may disclose personal information to potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a transaction in which we are acquired by or merged with another business, or we sell, liquidate, or transfer all or a portion of our assets (including in connection with a bankruptcy or similar proceedings).
Your Choices
You can make the following choices regarding your personal information:
Update Account Information. If your personal information in your account is incorrect, you may correct the personal information by sending a written request for correction to the address below. Your request must include (a) all of the incorrect personal information that you wish to change, (b) the corrected personal information, and (c) your signature authorizing such changes. We will then correct the personal information in our database and send a written confirmation to you.
Marketing Emails. You may choose to provide us with your email address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials to you. You can stop receiving promotional emails by submitting a request at the contact in the “Contacting Us” section below or following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you transactional communications, such as those about your account, to fulfill orders you have made, to ask you to rate services you have received, or other service-related communications.
Analytics. We may use third party analytics tools, such as Google Analytics, in order to better understand your use of our Services and how we can improve them. These tools collect information sent by your browser or mobile device, including the pages you visit and other usage information.For more information regarding how Google collects, uses, and shares your information please visit http://www.google.com/policies/privacy/partners/. To prevent data from being used by Google Analytics, you can download the opt-out browser add-on at: http://tools.google.com/dlpage/gaoptout?hl=en.
Cookies. Most browsers let you remove or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Services and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
Advertising Choices. You can limit the use of your personal information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative and the Digital Advertising Alliance. Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here.
Many of the opt-out preferences described in this section must be set on each device or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Information Security
We take reasonable measures to secure and protect the information we collect. Unfortunately the sending of information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of data that you choose to send us electronically, sending such information is entirely at your own risk.
Children’s Privacy
We do not knowingly solicit or collect personally identifiable information online from children under the age of 16.
Third Party Links
This Policy does not apply to third-party websites or social media features that may be accessed through links that we provide for your convenience and information. Accessing those links will cause you to leave our Site and may result in the collection of information about you by a third party. We do not control, endorse or make any representations about those third-party websites or their privacy practices, which may differ from ours. We encourage you to review the privacy policy of any site you interact with before allowing the collection and use of your information.
Notice to California Residents
This section applies only to California residents and supplements the information in our general Policy. It describes how we collect, use, sell, share, and retain personal information of California residents, and their rights with respect to their personal information. For purposes of this Notice to California Residents, “personal information” has the meaning given in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), but does not include information exempted from the scope of the CCPA. In some cases, we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section.
Personal Information Collected and the Purposes of Collection and Use. The list below summarizes the personal information we collect, or have collected in the 12 months preceding the last updated date of this Policy, by reference to the categories specified in the CCPA. Examples in the list refer to the types of personal information described in our general Policy under the section titled “Personal Information We Collect.”
- Identifiers, such as Contact Information, Professional Information, Account Information, Communications, and Referrals.
- Customer Records, such as Account Information, Payment Information, and Communications.
- Commercial Information, such as Transaction History and Marketing Information.
- Internet or Network Activity, such as Online Activity Information and Device Information.
- Geolocation Data, such as Device Information.
- Audio, Electronic, Visual, or Similar Information, such as Customer Service Recordings.
- Professional or Employment-Related Information, such as Professional Information and Survey Responses.
- Inferences, such as inferences drawn from the personal information identified above to create a profile reflecting your preferences, characteristics, behavior.
We may collect these categories of personal information directly from you and from your device, and from our service providers, advertising partners, and other third parties as further described in our general Policy under the section titled “Personal Information We Collect.”
The purposes for which we collect and use these categories of personal information are described in our general Policy under the section titled “How We Use Personal Information.”
To the extent that we may collect sensitive personal information (as defined under the CCPA), we only use or disclose it for purposes permitted under the CCPA (e.g., to perform the Services, detect security incidences and prevent fraud, and to verify and maintain the quality of the Services). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.
Personal Information Disclosed for Business Purposes, “Sold,” or “Shared.” In the 12 months preceding the last updated date of this Policy, we may have disclosed each category of personal information listed above to the persons and entities listed in the section titled “How We Share Personal Information” for the business purposes described in our general Policy.
In addition, we “sell” or “share” (and in the 12 months preceding the last updated date of this Policy have “sold” or “shared”) Internet or Network Activity to our Advertising Partners to help us market or advertise to you and to measure activity on the Services as further described under the section titled “How We Use Personal Information.” These disclosures are called “selling” or “sharing” under the CCPA because we are either disclosing your personal information in exchange for some sort of valuable consideration, or because such disclosure is for the purpose of cross-context behavioral advertising. You can find more detail about our practices in our general Policy, including in the section titled “How We Share Personal Information.”
We do not knowingly “sell” or “share” the personal information of California residents under 16 years of age.
Retention of Personal Information. We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your California Privacy Rights. As a California resident, in addition to the choices described in the general Policy, you have the rights listed below. Please note, these rights are not absolute, and, in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.
Right to Know. You can request the following information about how we have collected and used your personal information:
- The categories of personal information we collected;
- The categories of sources from which we collected that personal information;
- Our business or commercial purpose for collecting, selling, or sharing (as applicable) that personal information; and
- The categories of third parties to whom we disclose that personal information (as applicable).
Right to Access/Portability. You can request the specific pieces of personal information we collected about you.
Right to Correct. You can request that we correct inaccurate personal information that we maintain about you.
Right to Delete/Erase. You can request that we delete any of your personal information that we have collected from you.
Right to Opt-Out of “Sales”/“Sharing.” If we “sell” or “share” your personal information, you can request to opt-out.
Right to Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment.
How to Exercise Your Rights. You may exercise your California privacy rights described above using the following methods:
- Right to Know, Access/Portability, Correct, or Delete. Please submit these requests by completing the webform available here: “My Privacy Choices,” or by calling us toll-free at (888) 684-0196.
- Right to Opt-Out of “Sale”/“Sharing.” To opt-out your personal information from “selling” and “sharing” relating to the automatic collection of data on our Site by cookies and similar technologies, select the “Do Not Sell or Share My Personal Information” link at the bottom of the Site and update your preferences, or broadcast the Global Privacy Control (GPC) signal. Note that due to technological limitations, if you visit our Site from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to this screen to select your preferences and/or rebroadcast the GPC signal.
- In addition, if you direct us not to sell/share your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your right to know, access/portability, correct, and delete. This is a security measure to, for example, help ensure we do not disclose information to a person who is not entitled to receive it. The identity verification process may vary depending on how you submit your request.
Consistent with California law, you may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
We try to respond to all legitimate requests to know, access/portability, correct, and delete within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
Notice to Nevada Residents
Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information listed in the “Contacting Us” section of the general Policy.
Notice to European Residents
The information provided in this section applies only to individuals in the European Economic Area and the United Kingdom (collectively, “Europe”). Except as otherwise specified, references to “personal information” in this Policy are equivalent to “personal data” governed by European data protection legislation.
Controller. The controller of your personal information covered by this Policy for purposes of European data protection legislation is Litify, LLC. Our representatives are as follows:
EU: Osano International Compliance Services Limited
ATTN: SD63
3 Dublin Landings
North Wall Quay, Dublin 1, D01C4E0
UK: Osano UK Compliance LTD
ATTN: SD63
42-46 Fountain Street
Belfast, Antrim BT1 – 5EF
Legal Bases for Processing. The legal bases of our processing of your personal information as described in this Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us at privacy@litify.com.
- To Provide the Services: Processing is necessary to perform the contract governing our operation of the Services, or to take steps that you request prior to engaging our Services. Where we cannot process your personal information as required to operate the Services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interests as further described in this Policy.
- Research and Development: Processing is based on our legitimate interests in performing research and development as described in this Policy.
- Direct Marketing and Internet Advertising: Processing is based on your consent where that consent is required by applicable law. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consented or via the relevant Services. Where such consent is not required by applicable law, we process your personal information for this purpose based on our legitimate interests in promoting our business and providing you with tailored, relevant content.
- To Comply with Laws and Regulations: Processing is necessary to comply with our legal obligations.
- For Compliance, Fraud Prevention, and Safety: Processing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety, or property.
- With Your Consent: Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or via the relevant Services.
Use for New Purposes. We may use your personal information for reasons not described in this Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Retention. We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your Rights. European data protection laws may give you certain rights regarding your personal information.
- Access/Portability. You can request that we provide you with information about our processing of your personal information and give you access to your personal information, including a machine-readable copy to you or a third party of your choice.
- Correct. You can request that we update or correct inaccuracies in your personal information.
- Delete/Erase. You can request that we delete your personal information.
- Restrict. You can request that we restrict the processing of your personal information.
- Object. You can object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by completing our webform available here: “My Privacy Choices.” We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. In the European Economic Area, you can find your data protection regulator here. In the United Kingdom, you can find your data protection regulator here.
Cross-Border Data Transfer. If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us at privacy@litify.com for further information about any such transfers or the specific safeguards applied.
International Transfers
If you are using the Services from outside of the United States of America, please be aware that your information may be transferred to, stored or processed in the United States, where our servers are located and our central database is operated, and potentially other countries where we have service providers. The data protection and other laws in the locations where we handle your personal information might not be as comprehensive as those in your country. By using any portion of the Services, where applicable law permits, you understand and consent to such transfer and processing and the collection, use, and disclosure as described in this Policy.
Users located in Europe can view more information about cross-border transfers in the preceding section.
Contacting Us
Please do not hesitate to contact us regarding any matter relating to this Policy by completing the webform available here: “My Privacy Choices,” and describing your inquiry in the “Request Description” field. Alternatively, you may contact us by phone at (888) 684-0196 or writing to us at:
Litify
Attn: Legal
45 Main St., Suite 416
Brooklyn, NY 11201