Privacy Policy

Effective date:
February 15, 2021

This Privacy Policy explains in detail how we collect, use and disclose your personal data. Please read this document carefully before submitting any personal data to us. 

1. GENERAL INFORMATION

1.1 About the Privacy Policy. This Lifetimely Privacy Policy (the “Privacy Policy”) governs the processing of personal data collected from natural persons (“you” and “your”) through the customer analytics software-as-a-service available at https://lifetimely.io, the related domain names, software and services (collectively, “LIFETIMELY”). The Privacy Policy does not cover any third-party websites, applications, software, products or services that integrate with LIFETIMELY or are linked to from LIFETIMELY. 

1.2 Owner of LIFETIMELY. LIFETIMELY is owned and operated by Lifetimely Oy having a registered office at Lauttasaarentie 27 A3, 00200 Helsinki, Finland, and the company registration number 3107222-6 (“we”, “us”, or “our”). 

1.3 Our role as a data controller and data processor. We act in the capacity of a data controller and a data processor with regard to the personal data processed through LIFETIMELY in terms of the applicable data protection laws, including the EU General Data Protection Regulation (GDPR). Our role depends on the specific situation in which personal data is handled by us, as explained in detail below:

  • Data controller. We are responsible for the collection and use of your personal data through LIFETIMELY and we make decisions about the types of personal data that should be collected from you and purposes for which such personal data should be used. Therefore, we act as a data controller with regard to the personal data collected directly through LIFETIMELY (e.g., when you send us an inquiry or conclude a service contract). We comply with data controller’s obligations set forth in the applicable laws.
  • Data processor. We act in the capacity of a data processor in situations when you submit files or generate data through LIFETIMELY for processing (“Your Data”) and Your Data contains your or other individuals’ personal data. We do not own, control, or make decisions about Your Data. We process Your Data only in accordance with the instructions issued by a respective data controller. To ensure that Your Data is processed in accordance with the strictest data protection standards, we have drafted and offer for conclusion a data processing agreement that is available for consultation at www.lifetimely.io/policies/data-processing-agreement (the “DPA”). The DPA is incorporated by reference into out Terms and Conditions, therefore, you conclude it automatically upon your acceptance of the Terms and Conditions

1.4 Your consent. Before you submit any personal data through LIFETIMELY, you are encouraged to read this Privacy Policy that is always available on LIFETIMELY to understand on what legal bases (other than your consent) we rely when handling your personal data. In some cases, if required by the applicable law, we may seek to obtain your informed consent for the processing of your personal data. For example, you consent may be necessary if: (i) we intend to collect other types of personal data that are not mentioned in this Privacy Policy; (ii) we would like to use your personal data for other purposes that are not specified in this Privacy Policy; or (iii) we would like to transfer your personal data to third parties that are not listed in this Privacy Policy. 

1.5 Minors. LIFETIMELY is not intended for use by children (i.e., persons who are minors in their country of residence). Therefore, we do not knowingly collect minors’ personal data. If you, as a parent or a legal guardian of a child, become aware that the child has submitted his/her personal data to us, please contact us immediately. We will delete your child’s personal data from our systems without undue delay.

1.6 Term and termination. This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.

1.7 Amendments. The Privacy Policy may be changed from time to time to address the changes in laws, regulations, and industry standards. We encourage you to review our Privacy Policy to stay informed. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent.


2. WHAT PERSONAL DATA DO WE COLLECT AND FOR WHAT PURPOSES DO WE USE IT? 

2.1 We respect data minimisation principles. Thus, we collect only a minimal amount of personal data through LIFETIMELY that is necessary to ensure the proper provision of LIFETIMELY as described below. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. We do not use your personal data for any purposes that are different from the purposes for which it was provided. When processing personal data, we make sure that we do so by relying one of the available legal bases. You can find more information about the legal bases below.

  • Registration of User Account. When you register your user account, we collect your email address, name, company name, website URL, and your role in the company. We use the said information to register and maintain your user account, enable your access to LIFETIMELY, provide you with the requested services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ‘pursuing our legitimate business interests’ (i.e., operate, analyse, grow, and administer LIFETIMELY). 
  • Inquiries. When you contact us by email, we collect your name, email address, and any information that you decide to include in your message. When you contact us by using the “Contact” functionality, we collect your name, email address, company name, and any information that you decide to include in your message. We use such data to respond to your inquiries. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to grow and promote our business) and ‘your consent’ (for optional personal data).
  • Payments. When you make a payment, you will be asked to provide your payment details like your name, credit card number, expiration date, security code, and billing address. Please note that we do not process payments - it is done by our third-party payment processors Shopify and Stripe. Your payment data is used to process your payments and maintain our business records. The legal bases on which we rely are ‘performing a contract’ and ‘pursuing our legitimate business interests’ (i.e., administer our business).
  • IP address. When you use LIFETIMELY, we or our third-party analytics service providers (as explained in section 3 below) collect your IP address. We use your IP address to analyse the technical aspects of your use of LIFETIMELY, prevent fraud and abuse of LIFETIMELY, ensure the security of LIFETIMELY, and tailor LIFETIMELY for your location. The legal basis on which we rely when processing your IP address is ‘pursuing our legitimate business interests’ (i.e., to analyse and protect LIFETIMELY).
  • Cookies. When you browse LIFETIMELY, we collect your cookie-related data. For more information about the purposes for which we use cookies, please refer to our Cookie Policy. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to analyse and promote our business) and ‘your consent’ (for non-essential cookies).

2.2 Sensitive data. We do not collect or have access to any special categories of personal data as defined by Art. 9 of the GDPR (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data is information that relates to your health, genetics, biometrics, religious and political beliefs, racial origins, membership of a professional or trade association, sex life, or sexual orientation. If Your Data contains the said sensitive data, we will process such data for the purpose of fulfilling our contractual obligations.

2.3 Processing of Your Data. When you upload or create Your Data on LIFETIMELY, we process Your Data as requested by you, including any personal data Your Data may contain. Your Data may contain the following information: your customers’ email addresses and countries, information about your customers’ orders and refunds, and analytics data related to your online store (e.g., as generated by Google Analytics). We process Your Data in order to (i) provide you with the requested services and (ii) perform our contractual obligations. The legal basis on which we rely is ‘performing a contract with you’.

2.4 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask to, we may not be able to perform the requested operation and you may not be able to use the full functionality of LIFETIMELY or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.

2.5 Sources of personal data. We obtain your personal data from the following categories of sources:

  • Directly from you. For example, if you submit certain personal data directly to us when registering your user account or contacting us;
  • Directly or indirectly through your activity on LIFETIMELY. When you use LIFETIMELY, we automatically collect technical information about your use of LIFETIMELY; and
  • From third parties. We may receive information about your from third parties to whom you have previously provided your personal data, if those third parties have a lawful basis for disclosing your personal data to us.


3. WHAT TECHNICAL (NON-PERSONAL) DATA DO WE COLLECT?

3.1 Log files and analytics data. In order to analyse your use of LIFETIMELY, we and our analytics service provider Google Analytics automatically collects certain technical non-personal data about your use of LIFETIMELY. Such data does not allow us us to identify you as an individual person in any manner. The non-personal data includes the following information: 

  • Your activity on LIFETIMELY (e.g., what functionalities you use, how much time you spend on LIFETIMELY, how long it takes for LIFETIMELY to load and process your requests, and what errors occur);
  • Your device type;
  • The operating system of your device;
  • Your browser type;
  • URL addresses that you visit; and
  • Your other online behaviour.

3.2 Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and any subsequent responses. Where reasonably possible, we remove all personal data that is not necessary for keeping such records. 

3.3 Purposes of technical (non-personal) data. We use your technical (non-personal) data for the following purposes:

  • To analyse what kind of users visit LIFETIMELY;
  • To examine the relevance, popularity, and engagement rate of LIFETIMELY; 
  • To investigate and help prevent bugs, security issues and abuse; 
  • To develop and provide additional features to LIFETIMELY; and
  • To personalise LIFETIMELY for your specific technical needs (e.g., to adjust the design and resolution for your device). 

3.4 Aggregated and de-identified data. If we combine your non-personal data with certain elements of your personal data and such a combination allows us to identify you as a natural person, we will handle such aggregated data as personal data. If your personal data is de-identified in a way that it can no longer be associated with a natural person, it will not be considered personal data and we may use it for any business purpose.


4. HOW DO WE COMMUNICATE WITH YOU?

4.1 Newsletters. If we have your email address, we may, from time to time, send you a newsletter informing you about the latest developments related to LIFETIMELY and our special offers. You will receive our newsletters in the following instances:

  • If we receive your express (“opt-in”) consent to receive marketing messages; or
  • If you voluntarily subscribe for our newsletter; or
  • If we decide to send you information closely related to services already used by you.

4.2 Opting-out. You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters, adjusting the settings of your user account, or by contacting us directly.

4.3 Tracking pixels. The newsletters sent by us may contain tracking pixels that allow us to conduct analysis of our marketing campaigns. Tracking pixels allow us to see whether you opened the newsletter and what links you have clicked on. We use such information to conduct analytics and pursue our legitimate business interests.

4.4 Service-related notices. If necessary, we will send you important informational messages, such as confirmation receipts, payment information, technical emails, and other administrative updates. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices. 


5. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

5.1 Retention of personal data. We store your personal data in our systems only for as long as such personal data is required for the purposes described in this Privacy Policy or until you request us to delete your personal data, whichever comes first. After your personal data is no longer necessary for its primary purposes and we do not have another legal basis for storing it, we securely delete your personal data from our systems.

5.2 Retention of technical (non-personal) data. We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. For example, we can store it for the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

5.3 Retention as required by law. In certain cases, we are required by law to store your personal data for certain period of time (e.g., for business records or accountancy purposes). Thus, we keep your personal data for the time period stipulated by the applicable law and securely delete it as soon as the required storage period expires.


6. HOW DO WE SHARE AND DISCLOSE YOUR DATA?

6.1 Disclosure to data processors. From time to time, your personal data is disclosed to our service providers with whom we cooperate (our data processors). For example, we share your personal and non-personal data with entities that provide certain technical support services to us, such as hosting and email distribution services. We do not sell your personal data to third parties. The disclosure is limited to the situations when your personal data is required for the following purposes:

  • Ensuring the proper operation of LIFETIMELY;
  • Ensuring the delivery of the services ordered by you;
  • Providing you with the requested information;
  • Pursuing our legitimate business interests;
  • Enforcing our rights, preventing fraud, and security purposes;
  • Carrying out our contractual obligations; or 
  • If you provide your prior consent to such a disclosure. 

6.2 List of our data processors. We use a limited number of data processors. We choose them only if they agree to ensure an adequate level of protection of your personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that have access to your personal data are: 

  • Our hosting and cloud storage service provider Hetzner located in Germany; 
  • Our payment service provider Stripe located in the United States;
  • Our software and payment service provider Shopify located in Canada;
  • Our email delivery service provider Sendgrid located in the United States;
  • Our marketing service provider Facebook located in the United States;
  • Our analytics service providers Google Analytics and Amplitude located in the United States; 
  • Our technical support service provider HelpScout located in the United States; and
  • Our independent contractors and consultants.

6.3 Disclosure of technical (non-personal) data. Your technical (non-personal) data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving LIFETIMELY, responding to lawful requests from public authorities or developing new products and services. 

6.4 Legal requests. If we are contacted by a public authority, we may need to disclose information about you to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

6.5 Successors. In case LIFETIMELY is sold partly or fully, we will provide your personal data to a purchaser or successor entity and request the successor to handle your personal data in line with this Privacy Policy. We will notify you of any changes of the data controller. 

6.6 Selling personal data. We do not directly sell your personal data to third parties. However, some of your personal data, including online identifiers (e.g., cookie-generated data and IP addresses) may be used for advertising, marketing, and monetisation purposes (e.g., programmatic advertising, retargeting, third-party marketing, profiling, or cross-device tracking). To make sure that you have full transparency and control over your personal data, we provide you with a possibility to manage your personal data used for such purposes as described in our Cookie Policy.

6.7 International transfers. Some of our data processors listed above are located outside the country in which you reside. For example, if you reside in the European Economic Area (EEA), we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for your personal data or we conclude a data processing agreement with the respective third party that ensures such protection. We will not transfer your personal data internationally if no appropriate level of protection can be granted.


7. HOW DO WE PROTECT YOUR PERSONAL DATA?

7.1 Our security measures. We implement organisational and technical information security measures to protect your personal data from loss, misuse, unauthorised access, and disclosure. The security measures taken by us include:

  • Access control;
  • Secured networks;
  • SSL protocol;
  • Encryption;
  • Strong passwords;
  • Strong authentication;
  • Anonymisation of personal data (when possible); and
  • Carefully selected data processors.

7.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data that was caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law. 


8. WHAT RIGHTS DO YOU HAVE WITH REGARD TO YOUR PERSONAL DATA?

8.1 The list of your rights. You have the right to control how your personal data is processed by us by exercising the rights listed below (unless, in very limited cases, the applicable law provides otherwise):

  • Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
  • Right to rectification: you can rectify inaccurate personal data that we hold about you;
  • Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
  • Right to restriction: you can ask us to restrict the processing of your personal data;
  • Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
  • Right to object: you can ask us to stop processing your personal data;
  • Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
  • Right to complaint: you can submit your complaint regarding our processing of your personal data.

8.2 How to exercise your rights? If you would like to exercise any of your rights, please contact us by email at hello@lifetimely.io or by post (you can find our postal address at the end of this Privacy Policy) and explain your request in detail. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information that allows us to identify you in our system. We will answer your request within a reasonable time frame but no later than 2 weeks.

8.3 Complaints. If you would like to launch a complaint about the way in which we process your personal data, we kindly ask you to contact us first and express your concerns. If we receive your complaint, we will investigate it and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

8.4 Non-discrimination. We do not discriminate you if you decide to exercise your rights. It means that we will not (i) deny any goods and services, (ii) charge you different prices, (iii) deny any discounts or benefits, (iv) impose penalties, or (v) provide you with a lower quality services.


9. CONTACT

If you have any questions about this Privacy Policy or our data protection practices, please contact us by:

Email: hello@lifetimely.io

Postal address: Lifetimely Oy, Lauttasaarentie 27 A3, 00200 Helsinki, Finland