Privacy Policy

We are L33 Solutions Limited, a company incorporated in England and Wales. Our company number is 10875610 and our registered office is at 1 Victoria Court, Bank Square, Morley, Leeds, West Yorkshire, England, LS27 9SE (“L33 Solutions”). L33 Solutions are committed to ensuring that User privacy is protected. L33 Solutions will continue to comply with the provisions of the General Data Protection Regulation ((EU 2016/679) (“GDPR”) unless and until the GDPR is no longer directly applicable in the UK, together with any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, including the Data Protection Act 2018 (“DPA”) and any successor legislation to the GDPR and the DPA (together “Data Protection Legislation”). L33 Solutions are the data controller of data User pass to L33 Solutions pursuant to this policy.

This privacy policy together with L33 Solutions’ cookie policy sets out how L33 Solutions collect personal data from User in the use of the App and/or Services and how the personal information User provides will be processed by L33 Solutions. By using the App and/or Services User is accepting and consenting to the practices described in this privacy policy. If User does not consent, User should not submit any personal data to L33 Solutions.

1.1 What information L33 Solutions hold and how L33 Solutions will use it:

1.1.1 Information User gives to L33 Solutions: User may give L33 Solutions information about User by using the App and/or Services. The information User gives L33 Solutions may include User name, email address/location and phone number. L33 Solutions will retain this information while corresponding with User and then for a further period of two years;

1.1.2 Information L33 Solutions collect about User: L33 Solutions may collect the following information from User when User visits L33 Solutions App and uses the Services:

1.1.2.1 technical information, including the Internet protocol (IP) address used to connect User’s mobile device, mobile application or computer to the Internet, User’s login information, browser type and version, time zone setting, browser plug in types and versions, operating system and platform; and

1.1.2.2 information about User’s visit, including the full Uniform Resource Locators (URL), clickstream to, through and from the App (including date and time), products and pages User has viewed or searched for, page response times, App errors, length of visits to certain pages in the App, App interaction information, methods used to browse away from the page and any phone number used.

1.1.3 Information L33 Solutions receive from other sources: This includes information L33 Solutions receive about User when User use other apps operated by us or other services we provide. This information may include your name, email address, postal address and phone number.

1.2 The App uses cookies to distinguish User from other users of the App. For detailed information on the cookies L33 Solutions use and the purposes for which L33 Solutions use them, User should review L33 Solution’s Cookie Policy at https://fitain.app/en/cookie-policy/.

1.3 Provided that L33 Solutions has obtained User’s consent to the extent L33 Solutions are required to under the Data Protection Legislation, L33 Solutions may use the information that L33 Solution’s receive and/or collect about User to:

1.3.1 fulfil L33 Solutions’ obligations under any contract L33 Solutions have entered into with User and to provide User with information, products and services User has requested;

1.3.2 send User newsletters and marketing information if User has consented to L33 Solutions doing so or if there are other grounds in Data Protection Legislation which mean L33 Solutions are entitled to send marketing communications to User;

1.3.3 notify User of products and services L33 Solutions offer that are similar to those who User has purchased or enquired about;

1.3.4 notify User of other products and services L33 Solutions feel may interest User, or permit third parties to do so if User has consented L33 Solutions doing so;

1.3.5 notify User of changes to L33 Solutions services and products; and

1.3.6 monitor App and/or Services usage and provide statistics to third parties for the purposes of improving and developing the App and the Services L33 Solutions provide via the App.

1.4 L33 Solutions collect and process the majority of User’s personal information on the grounds of legitimate interests, which include some or all of the following:

1.4.1 where the processing enables L33 Solutions to enhance, modify, personalise or otherwise improve the App and/or Services, and communications for the benefit of L33 Solution’s customers;

1.4.2 to identify and prevent fraud;

1.4.3 to enhance the security of L33 Solution’s network and information systems;

1.4.4 to better understand how people interact with the App and/or Services;

1.4.5 to administer the App and/or Services and carry out data analysis, troubleshooting and testing;

and

1.4.6 to determine the effectiveness of promotional campaigns and advertising.

1.5 If L33 Solutions require User personal data for fulfilment of a contract with User (for example to provide goods and services User has requested) L33 Solutions may be unable to fulfil the contract without User personal data.

1.6 If L33 Solutions are unable to rely on legitimate interests or any other ground set out in the Data Protection Legislation to process User personal data, L33 Solutions will obtain consent from User to the processing.

1.7 If L33 Solutions obtain consent from User to do so, L33 Solutions may provide User personal data details to third parties so that they can contact User directly in respect of services and/or products in which User may be interested.

1.8 User has the right to withdraw their consent to the processing of User personal data at any time. If User would like to withdraw User consent, or prefer not to receive any of the above mentioned information (or if User only want to receive certain information) from L33 Solutions User should let L33 Solutions know by contacting L33 Solutions at [email protected]. User should bear in mind that if User objects this may affect L33 Solutions’ ability to carry out the tasks above for User benefit. Withdrawal of User consent won’t affect any processing L33 Solutions has carried out in respect of User personal data prior to User withdrawing consent.

1.9 If User wants to have information removed from L33 Solutions database or if User does not want L33 Solutions to contact User for marketing purposes, please let L33 Solutions know by clicking the “unsubscribe” option in any email L33 Solutions send to User and providing the details requested or by contacting L33 Solutions at [email protected] and L33 Solutions will take steps to ensure that this information is deleted as soon as reasonably practicable.

1.10 L33 Solutions will not share, sell or distribute any of the information User provides to L33 Solutions (other than as set out in this policy) without User’s prior consent, unless required to do so by law.

1.11 Where L33 Solutions have given User (or where User has chosen) a password which enables User to access certain parts of the App and/or Services, User is responsible for keeping this password confidential. L33 Solutions asks User not to share a password with anyone.

1.12 Protecting User security and privacy is important to L33 Solutions and L33 Solutions make every effort to secure User information and maintain User confidentiality in accordance with the terms of the Data Protection Legislation. The App is protected by various levels of security technology, which are designed to protect User information from any unauthorised or unlawful access, processing, accidental loss, destruction and damage.

1.13 L33 Solutions will protect your personal data but the transmission of information via the App and/or Services is not completely secure. Any such transmission is therefore at User’s own risk.

1.14 L33 Solutions may share User information with selected third parties including:

1.14.1 business partners, suppliers and sub-contractors for the performance of any contract L33 Solutions enter into with them or User;

1.14.2 third parties who may wish to contact User in respect of services and/or products they offer or sell which may be of interest to User, provided L33 Solutions receive User consent to such disclosure; and/or

1.14.3 advertisers and advertising networks that require the data to select and serve relevant adverts to User and analytics and search engine providers that assist L33 Solutions in the improvement and optimisation of the App and/or Services.

1.15 Please note that L33 Solutions may need to disclose User personal data where L33 Solutions:

1.15.1 sell any or all of L33 Solutions business or assets or L33 Solutions buy another business or assets in which case L33 Solutions may disclose User personal data to the prospective buyer or seller;

1.15.2 are under a legal duty to comply with any legal obligation or in order to enforce or apply L33 Solutions terms and conditions; or

1.15.3 need to disclose it to protect User rights, property or safety of L33 Solutions customers or others, including the exchange of information with other companies and/or governmental bodies for the purposes of fraud prevention and credit risk reduction.

1.16 The data that L33 Solutions collect from User 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 L33 Solutions or for one of L33 Solutions suppliers. Such staff may be engaged in, among other things, the fulfilment of User’s order, the processing of Users payment details and the provision of support services. By submitting User personal data, User agrees to this transfer, storing or processing. L33 Solutions will take all steps reasonably necessary to ensure that User personal data is treated securely and in accordance with this privacy policy. The destination to which User personal data will be transferred will either offer adequate protection of User personal data, as determined by the European Commission, or L33 Solutions will make sure there are appropriate safeguards in place.

1.17 There are a number of rights available to User under Data Protection Legislation:

Access to your information

1.17.1 User can ask L33 Solutions to confirm that L33 Solutions process User personal data and provide access to and copies of the information L33 Solutions hold about User. L33 Solutions will process User request to access User information and provide this information to User free of charge unless User’s request is manifestly unfounded or excessive or repetitive, in which case L33 Solutions are entitled to charge a reasonable fee. L33 Solutions may also charge if User requests more than one copy of the same information. L33 Solutions will provide the information User requests as soon as possible and in any event within one month of receiving User request, unless there are extenuating circumstances. If L33 Solutions need more information to comply with the User request, L33 Solutions will let User know.

Rectification of your data

1.17.2 L33 Solutions will comply with User request within one month of receiving it, unless L33 Solutions don’t feel it is appropriate for L33 Solutions to do so in which case L33 Solutions will let User know why. L33 Solutions will also let User know if L33 Solutions need more time to comply with the User request.

Right to be forgotten

1.17.3 In some circumstances, User has the right to ask L33 Solutions to delete personal data L33 Solutions hold about User. This right is available to User:

1.17.3.1 where L33 Solutions no longer need User personal data for the purpose for which L33 Solutions collected it;

1.17.3.2 where L33 Solutions have collected User personal data on the grounds of consent and User withdraws that consent;

1.17.3.3 where User objects to the processing and L33 Solutions don’t have any overriding legitimate interests to continuing processing the data;

1.17.3.4 where L33 Solutions have unlawfully processed User’s personal data (i.e L33 Solutions have failed to comply with GDPR);

1.17.3.5 where the personal data has to be deleted to comply with a legal obligation; and

1.17.3.6 where the personal data L33 Solutions’ process relates to the offer of online services to a child.

There are certain scenarios in which L33 Solutions are entitled to refuse to comply with a request. If any of these apply, we will let User know.

Right to restrict/object to processing

1.17.4 In some circumstances User is entitled to ask L33 Solutions to suppress processing of User personal data. This means that L33 Solutions will stop actively processing User personal data but L33 Solutions don’t have to delete it. This right is available to User:

1.17.4.1 if User believes the personal data User holds is not accurate – L33 Solutions will cease processing it until L33 Solutions can verify its accuracy;

1.17.4.2 if User has objected to L33 Solutions processing the data (see below)- L33 Solutions will cease processing it until L33 Solutions have determined whether L33 Solutions’ legitimate interests override User objections;

1.17.4.3 if the processing is unlawful; or

1.17.4.4 if L33 Solutions no longer need the data but User would like us to keep it because User needs to establish, exercise or defend a legal claim.

1.17.5 User is entitled to object to L33 Solutions processing User personal data:

1.17.5.1 if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;

1.17.5.2 for direct marketing purposes (including profiling); and/or

1.17.5.3 for the purposes of scientific or historical research and statistics.

1.17.6 In order to object, User must have grounds for doing so based on User’s particular situation. L33 Solutions will stop processing User data unless L33 Solutions can demonstrate that there are compelling legitimate grounds which override User interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.

Data Portability

1.17.7 User has the right to ask L33 Solutions to provide User personal data in a structured commonly used and machine-readable format so that User is able to transmit the personal data to another data controller. The right only applies:

1.17.7.1 to personal data User provides to L33 Solutions;

1.17.7.2 where processing is based on User consent or for performance of a contract (i.e the right does not apply if L33 Solutions process User personal data on the grounds of legitimate interests) and;

1.17.7.3 where L33 Solutions carry out the processing by automated means.

1.17.8 L33 Solutions will respond to User’s request as soon as possible and in any event within one month from the date L33 Solutions receive it. If L33 Solutions need more time, L33 Solutions will let User know.

1.18 If User has any complaints about L33 Solutions use of User personal data, User should contact L33 Solutions. User is also entitled to report any concerns which User may have to a supervisory authority in User’s jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office. User can call the ICO on 0303 123 1113 or get in touch via other means as set out on the ICO website at https://ico.org.uk/concerns/.

1.19 If User has any queries or comments on L33 Solutions privacy policy or would like to exercise any of the rights available to User, please contact L33 Solutions at [email protected]. L33 Solutions always welcome User’s views about our App and our privacy policy.