PRIVACY POLICY
Last updated January 01,
2020
Thank you for choosing to be part of our community
at Lamah Technologies LLC (“Company”,
“we”, “us”, or “our”). We are committed to
protecting your personal information and your right to privacy. If you have any questions or
concerns about this privacy notice, or our
practices with regards to your personal information, please contact us
at [email protected].
When you visit our website http://www.makani.ly (the
"Website"), use
our mobile application, as the case may be (the "App") and
more
generally, use any of our services (the "Services", which include
the Website and App), we appreciate
that you are trusting us with your personal information. We take your privacy very seriously. In
this privacy notice, we seek to explain to you in the clearest way possible what information we
collect, how we use it and what rights
you have in relation to it. We hope you take some time to read through it carefully, as it is
important. If there are any terms in this privacy notice that you do not agree with, please
discontinue use of our Services immediately.
This
privacy notice applies to all information collected through our Services (which, as described
above, includes our Website and App),
as well as any related services, sales,
marketing or events.
Please read this privacy
notice carefully
as it will help you understand what we do with the
information that we collect.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. DO WE USE GOOGLE MAPS?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you
disclose to us
In Short: We collect
information that you provide to us.
We
collect personal information that you voluntarily provide to us when you register on
the Services, express an interest in obtaining information about us or our products
and Services, when
you participate in activities on the Services or otherwise when you contact
us.
The personal information that we collect depends on the context of your interactions
with us and the Services,
the choices you make and the products and features you use. The personal information we collect
may include the following:
Personal Information Provided by You. We
collect names; phone
numbers; mailing addresses; passwords; contact or authentication
data; usernames; and other similar information.
All personal information that
you provide to us must be true,
complete and accurate, and you must notify us of any changes to such personal
information.
Information automatically collected
In
Short: Some information — such as your Internet Protocol
(IP) address and/or browser and device characteristics — is collected automatically
when you visit our Services.
We
automatically collect certain information when you visit, use or navigate the Services.
This information does not reveal your specific identity (like your name or contact information)
but may include
device and usage information, such as your IP address, browser and device characteristics,
operating system, language preferences, referring URLs, device name, country, location,
information about who and
when you use our Services and other technical information. This information is
primarily needed to maintain the security and operation of our Services, and for our
internal analytics and reporting
purposes.
Like many businesses, we also collect information through cookies and similar
technologies.
The information we collect includes:
Log and Usage
Data. Log
and usage data is service-related, diagnostic usage and performance information our servers
automatically collect when
you access or use our Services and which we record in
log files.
Depending
on how you interact with us, this log data may include your IP address, device information,
browser type and settings and information
about your activity in
the Services (such as the date/time
stamps associated with your usage, pages and files viewed, searches and
other actions you
take such as which features you use), device event information (such as system activity, error
reports (sometimes
called
'crash dumps') and hardware settings).
Device Data. We collect
device data such as information about your computer, phone, tablet or other device you use to
access the Services.
Depending on the device used, this device data may include information such as your IP address
(or proxy server), device application identification numbers, location, browser type, hardware
model Internet
service provider and/or mobile carrier, operating system
configuration information.
Location Data. We collect information
data such as information about your device's location,
which can be either precise or imprecise. How much
information we collect depends on the
type of settings of the device you use to access the Services. For example, we may use GPS
and other technologies
to collect geolocation data that tells us your current location (based on your IP address). You
can opt out of allowing us to
collect this information either by refusing access to the
information or
by disabling your Locations settings on your device. Note however, if you choose to opt out, you
may not be able to use certain aspects of the Services.
Information collected
through our App
In Short:
We collect information regarding
your geo-location, mobile device, push notifications, when you use
our App.
If
you use our App, we also collect the following information:
Geo-Location
Information. We may request access or permission to and track location-based
information from your mobile device,
either continuously or while you are using our App, to provide certain location-based services.
If you wish to change our access or permissions, you may do so in your device's
settings.
Mobile Device Access. We
may request access or permission to certain features from your mobile device, including your
mobile device's view wi-fi connections, precise location (gps and
network-based), approximate
location (network-based), receive data from internet, run at startup, full
network access, prevent device from sleeping, and other features. If you wish to
change our access
or permissions, you may do so in your device's settings.
Mobile Device
Data. We automatically collect device information (such as your mobile device ID,
model and manufacturer),
operating system, version
information and system configuration information, device and
application identification numbers, browser type and version, hardware model Internet service
provider and/or mobile
carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may
also collect
information about the phone network associated with your mobile device, your
mobile device's
operating system or platform, the type of mobile device you use, your mobile device's unique
device ID and information about the features of our App you accessed.
Push
Notifications. We
may request to send you push notifications regarding your account or certain features of the
App. If you wish to opt-out from receiving these types of communications, you may turn them off
in your device's
settings.
The information is primarily needed to maintain the security and operation of
our App, for troubleshooting and for our internal analytics
and reporting
purposes.
2. HOW DO WE USE YOUR INFORMATION?
In
Short: We process your information for purposes based on
legitimate business interests, the fulfillment of our contract with you, compliance
with our legal obligations, and/or your consent.
We
use personal information collected via our Services for a variety of business purposes
described below. We process your personal information for these purposes in reliance on our
legitimate business
interests, in order to enter into or perform a contract with you, with your consent, and/or for
compliance with our legal obligations. We indicate the specific processing grounds we rely on
next to each
purpose listed below.
We use the information we collect or receive:
To
facilitate account creation and logon process. If you choose to link your
account with us to a
third-party account (such as your Google or Facebook account), we use the information you
allowed us to collect from those third parties to facilitate account creation and logon process
for the performance
of the contract.
To post testimonials. We post testimonials on
our Services that may contain personal information. Prior to posting a testimonial, we
will
obtain your
consent to use your name and the consent of the testimonial. If you wish to update, or delete
your testimonial, please contact us at [email protected] and be sure to include your
name, testimonial
location, and contact information.
Request feedback. We may use
your information to request feedback and to contact you about your use of
our Services.
To enable user-to-user communications. We
may use your information in order to enable user-to-user communications with each user's
consent.
To manage user accounts. We may use your information for the
purposes of managing
our account and keeping it in working order.
To send administrative information
to you. We may use your personal information to send you product, service and
new feature information
and/or information about changes to our terms, conditions, and policies.
To
protect our Services. We may use your information as part of our efforts to
keep our Services safe
and secure (for example, for fraud
monitoring and prevention).
To
enforce our terms, conditions and policies for business purposes, to comply with legal
and regulatory requirements or in connection with our contract.
To respond to legal requests and prevent harm. If we receive a subpoena or
other legal request, we may need to inspect the data we hold to determine how to
respond.
Fulfill and manage your orders. We
may use your information to fulfill and manage your orders, payments, returns, and exchanges
made
through the Services.
Administer prize draws and
competitions. We
may use your information to administer prize draws and competitions when you elect to
participate in our competitions.
To deliver and facilitate delivery of services
to the user. We
may use your information to provide you with the requested service.
To respond
to user inquiries/offer support to users. We may use your information to
respond to your inquiries
and solve any potential issues you might have with the use of our Services.
To
send you marketing and promotional communications. We and/or our third-party
marketing partners
may use the personal information you send to us for our marketing purposes, if this is in
accordance with your marketing preferences. For example, when expressing an interest in
obtaining information about
us or our Services, subscribing to marketing or otherwise contacting us, we will collect
personal information from you. You can opt-out of our marketing emails at any time (see the "WHAT ARE
YOUR PRIVACY RIGHTS"
below).
Deliver targeted advertising to you. We may use your
information to develop and display personalized content and advertising (and work with third
parties who do so)
tailored to your interests and/or location and to measure its
effectiveness.
3. WILL YOUR INFORMATION BE SHARED WITH
ANYONE?
In Short: We only share
information with your consent, to comply with laws, to provide you with services, to
protect your rights, or to fulfill
business obligations.
We
may process or share your data that we hold based on the following legal basis:
Consent: We may process your data if you have given us specific consent to
use your personal
information in a specific purpose.
Legitimate Interests: We may
process your data when it is reasonably necessary to achieve our legitimate business
interests.
Performance of a Contract: Where
we have entered into a contract with you, we may process your personal information to fulfill
the terms of
our contract.
Legal Obligations: We may disclose
your information
where we are legally required to do so in order to comply with applicable law, governmental
requests, a judicial proceeding, court order, or legal process, such as in response to a court
order or a subpoena
(including in response to public
authorities to meet national security or law enforcement
requirements).
Vital Interests: We may disclose your information
where we believe
it is necessary to investigate, prevent, or take action regarding potential violations of our
policies, suspected fraud, situations involving potential threats to the safety of any person
and illegal activities,
or as evidence in litigation in which we are involved.
More specifically, we may need to
process your data or share your personal information in the following situations:
Business Transfers. We
may share or transfer your information in connection with, or during negotiations of, any
merger, sale of company assets, financing, or acquisition of all or a portion of our business to
another company.
Vendors, Consultants and Other Third-Party
Service
Providers. We may share your data with
third-party vendors, service providers, contractors or agents who
perform services for us or on our behalf and require access to such information to do that work.
Examples include: payment processing, data analysis, email delivery, hosting services, customer
service and
marketing efforts. We may allow selected third parties to use tracking technology on
the Services, which will enable them to collect data on our behalf about how you interact
with our Services over
time. This information may be used to, among other things, analyze and track data, determine the
popularity of certain content, pages or features, and better understand online activity. Unless
described
in this notice, we do not share, sell, rent or trade any of your information with third parties
for their promotional purposes.
Third-Party Advertisers. We may
use third-party
advertising companies to serve ads when you visit or use the Services. These companies may
use information about your visits to our Website(s) and other websites that are contained in web
cookies and
other tracking technologies in order to provide advertisements about goods and services of
interest to you.
Affiliates. We may share your information with
our affiliates, in
which case we will require those affiliates to honor this privacy notice. Affiliates include our
parent company and any subsidiaries, joint venture partners or other companies that we control
or that are
under common
control with us.
4. WHO WILL YOUR INFORMATION BE SHARED
WITH?
In Short: We only share
information with the following third parties.
We
only share and disclose your information with the following third parties. We have categorized
each party so that you may easily understand the purpose of our data collection and processing
practices. If
we have processed your data based on your consent and you wish to revoke your consent, please
contact us using the contact details provided in the section below titled "HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?".
Advertising, Direct Marketing, and Lead
Generation
Google
AdSense, Facebook Audience
Network and Amazon
Mobile Ads
Cloud Computing
Services
Amazon Web
Services (AWS)
Communicate and Chat
with Users
Facebook Customer
Chat
Data Backup and
Security
Amazon Glacier
Functionality and Infrastructure
Optimization
Firebase Legacy
Retargeting Platforms
Google Analytics
Remarketing, Google Ads Remarketing , Facebook Custom
Audience and Facebook
Remarketing
User Account Registration
and Authentication
Lamah
Authentication System
User
Commenting and Forums
Facebook Comments
Website
Hosting
WordPress.com
5. DO WE USE COOKIES AND OTHER
TRACKING TECHNOLOGIES?
In Short: We
may use cookies and other tracking technologies to collect and store your
information.
We
may use cookies and similar tracking technologies (like web beacons and pixels) to access or
store information.
Specific information about how we use such technologies and how you can
refuse certain
cookies is set out in our Cookie Notice.
6. DO WE USE GOOGLE
MAPS?
In Short: Yes, we use Google
Maps for the purpose of providing
better service.
This Website or App uses
Google Maps APIs which is subject to Google's Terms of Service. You may find the Google Maps
APIs Terms of Service here. To find
out more about
Google’s Privacy Policy, please refer to this link. We obtain and store on your device
('cache') your location. You may revoke your consent anytime
by contacting us at the contact details provided at the end of this
document.
7. HOW LONG DO WE KEEP YOUR
INFORMATION?
In Short: We keep your
information for as long as necessary to fulfill the purposes outlined in this privacy
notice unless otherwise required by law.
We
will only keep your personal information for as long as it is necessary for the purposes set out
in this privacy notice, unless a longer retention period is required or permitted by law (such
as tax, accounting
or other legal requirements). No purpose in this notice will require
us keeping your personal
information for longer than the period of time in which users have an account with
us.
When we
have no ongoing legitimate business need to process your personal information, we will either
delete or anonymize such information, or, if this is not possible (for example, because your
personal information
has been stored in backup archives), then we will securely store your personal information and
isolate it from any further processing until deletion is possible.
8.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In
Short: We aim to protect your personal information through
a system of organizational and technical security measures.
We
have implemented appropriate technical and organizational security measures designed to protect
the security of any personal information we process. However, despite our safeguards and efforts
to secure
your information, no electronic transmission over the Internet or information storage technology
can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other
unauthorized third parties will not be able to defeat our security, and improperly collect,
access, steal, or modify your information. Although we will do our best to protect your personal
information, transmission
of personal information to and from our Services is at your own risk. You should only
access
the Services within a secure environment.
9. DO WE
COLLECT INFORMATION FROM MINORS?
In
Short: We do not knowingly collect data from or market to
children
under 18 years of age.
We
do not knowingly solicit data from or market to children under 18 years of age. By using
the Services, you represent that you are at least 18 or that you are the parent or guardian
of such a minor and
consent to such minor dependent’s use of the Services. If we learn that personal
information from users less than 18 years of age has been collected, we will deactivate the
account and take reasonable
measures to promptly delete such data from our records. If you become aware of any data we may
have collected from children under age 18, please contact us
at [email protected].
10. WHAT ARE YOUR PRIVACY
RIGHTS?
In Short: You may review,
change, or terminate your account at any time.
If
you are resident in the European Economic Area and you believe we are unlawfully processing your
personal information, you also have the right to complain to your local data protection
supervisory authority.
You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If
you are resident in Switzerland, the contact details for the data protection authorities are
available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If
you have questions or comments about your privacy rights, you may email us
at [email protected].
Account Information
If you would at any
time like to review or change the
information in your account or terminate your account, you can:
■
Contact us using the contact information
provided.
Upon your request to
terminate your account, we will
deactivate or delete your account and information from our active databases. However, we may
retain some information in our files to prevent fraud, troubleshoot problems, assist with any
investigations,
enforce our Terms of Use and/or comply with applicable legal requirements.
Cookies and similar
technologies: Most Web browsers
are set to accept cookies by default. If you prefer, you can usually choose to set your browser
to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this
could affect
certain features or services of our Services. To opt-out of interest-based advertising by
advertisers on our Services visit http://www.aboutads.info/choices/.
Opting out of email
marketing: You
can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in
the emails that we send or by contacting us using the details provided below. You will then be
removed from
the marketing email list – however, we may still communicate with you, for example to send you
service-related emails that are necessary for the administration and use of your account, to
respond to service
requests, or for other non-marketing purposes. To otherwise opt-out, you may:
■ Contact us using the contact information
provided.
11.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most
web browsers and some mobile operating systems and mobile applications include a Do-Not-Track
(“DNT”) feature or setting you can activate to signal your privacy preference not to have data
about your online
browsing activities monitored and collected. At this stage, no uniform technology standard for
recognizing and implementing DNT signals has been finalized. As such, we do not currently
respond to DNT browser
signals or any other mechanism that automatically communicates your choice not to be tracked
online. If a standard for online tracking is adopted that we must follow in the future, we will
inform you about
that practice in a revised version of this privacy notice.
12. DO
CALIFORNIA RESIDENTS HAVE SPECIFIC
PRIVACY
RIGHTS?
In Short: Yes, if you are a
resident of California, you are granted specific rights regarding access to your
personal information.
California
Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are
California residents to request and obtain from us, once a year and free of charge, information
about categories
of personal information (if any) we disclosed to third parties for direct marketing purposes and
the names and addresses of all third parties with which we shared personal information in the
immediately
preceding calendar year. If you are a California resident and would like to make such a request,
please submit your request in writing to us using the contact information provided
below.
If you are
under 18 years of age, reside in California, and have a registered account with a Service,
you have the right to request removal of unwanted data that you publicly post on
the Services. To request
removal of such data, please contact us using the contact information provided below, and
include the email address associated with your account and a statement that you reside in
California. We will make
sure the data is not publicly displayed on the Services, but please be aware that the data
may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
13. DO WE MAKE UPDATES TO THIS
NOTICE?
In Short: Yes, we will
update this notice as necessary to stay compliant with relevant laws.
We
may update this privacy notice from time to time. The updated version will be indicated by
an updated “Revised” date and the updated version will be effective as soon as it is accessible.
If we make
material changes to this privacy notice, we may notify you either by prominently posting a
notice of such changes or by directly sending you a notification. We encourage you to review
this privacy notice frequently
to be informed of how we are protecting your information.
14. HOW CAN
YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about
this notice, you may contact
our Data Protection Officer (DPO), Lamah DPO, by email at [email protected], or by
post to:
Lamah Technologies LLC
Lamah DPO
1
J
Misrata, MIS F7P5G
Libya