Privacy Policy
Lighter Life LTD has established this Privacy Policy to articulate the methods by which we gather, employ, reveal, and manage personal data as part of our business operations. This document outlines our procedures related to the data obtained by Lighter Life LTD, referred to as "we", "us", and "our", through our websites and mobile applications where this Privacy Policy is visible.
The scope of this Privacy Policy extends to our websites, mobile applications, and any other digital services where it is displayed, including the information we collect via our social media channels and features (referred to individually as a "Service" and collectively as the "Services"). This policy not only details how we handle personal information but also clarifies the options and rights individuals have regarding their personal data.
Occasionally, we may present you with additional privacy disclosures at the point of data collection. Such "in-time" notices will dictate the processing of the information provided at that particular moment.
1. INFORMATION WE COLLECT
Information about you can be gathered through various methods, including your interaction with our Services, your communications with us via phone, email, or social media, and your participation in our events or promotions.
The data we collect—either directly from you or through automatic means—might be recognized as personal information or personal data in certain regions, including under the European General Data Protection Regulation (GDPR). The term 'personal information' in this Privacy Policy refers to both personal information and personal data as they are defined by the laws applicable in the concerned jurisdiction.
We collect different categories of personal information depending on the Service used:
A. Internet or other electronic network activity. Examples include information about your engagement with websites, applications, or advertisements. Further details are provided in the section below on information collected automatically.
B. Commercial information. Examples include records of products or services you’ve purchased, acquired, considered, or your purchasing or consumption patterns.
C. Deductions made from other personal information. Examples include a created profile that indicates your preferences, attributes, and behaviors.
It should be noted that for certain Services, you might input or grant access to specific physical or health-related information. This data will be stored on your device and used only as outlined in the "Information collected from you" section below.
2. SOURCES OF INFORMATION AND PURPOSES OF USE
We receive information from you both directly and through your engagement with our Services. Furthermore, we acquire data about you, including personal details, from our business partners and third-party vendors.
Opting not to share your personal information with us is within your rights, but this choice may impede our ability to deliver our Services to you or affect the quality of service you receive from us.
Information collected from you
We may gather various types of information from you, including:
l Feedback: Occasionally, we may seek your feedback through surveys for suggestions or improvements. By providing feedback, you acknowledge that it becomes the property of Lighter Life LTD, which we may use at our discretion.
l Name: Your name helps us to personalize your experience with our Services.
l Telephone number: Your phone number may be necessary for us to provide technical aspects of our Services.
l Email address: We use your email to communicate with you about our products and Services, respond to your inquiries, and send you account updates.
l Username and/or PIN: Used to secure your access to our website or app.
l Other User Information: You may provide other personal details, like photos or health information, to enhance your use of our Services, which will be stored on your device and not shared with us unless specified.
l Payment Information: If you purchase from us, we or an authorized third party will process your payment information.
l Photograph: Any photos you provide to our Services.
Automated Information Collection:
l We collect data automatically via cookies and similar technologies (see our Cookies Policy for details). This can include pixel tags and HTML5 used to track interaction and enhance our Services.
l This tracking may be conducted by us or third-party providers, detailed in Section 3 of this Privacy Policy.
l Automated Information may include details like IP address, device type, country code, and access times, which help us improve our Services, ensure security, and provide a personalized experience.
Information from Integrated Services:
l We may also obtain information, including personal information, from integrated services such as social media platforms.
l If you use your social media account to access our Services, you may be sharing certain information with us, and we encourage you to review the privacy policies of these providers.
l Lastly, we use a third-party provider, OpenAI, LLC, for AI-generated content. For their privacy practices, refer to Section 4.
In all instances, we collect and use information in line with this Privacy Policy.
3. HOW WE MAY USE YOUR PERSONAL INFORMATION
The collected information serves multiple functions, including but not restricted to:
l Performing Our Services:
Account maintenance, customer service, website and app operation, order processing, user verification, and payment processing.
l Internal Research:
Analyzing our Services' performance, improving them, and guiding the development of new features and products.
l Personalization:
Tailoring user experiences by remembering your details to simplify future interactions with our Services.
l Auditing Consumer Interactions:
Tracking website and app usage, and evaluating the efficacy of our marketing efforts.
l Security:
Ensuring a secure user experience and protecting our digital platforms from cyber threats and misuse.
l Debugging/Repair:
Identifying and fixing issues that impair the functionality of our Services.
l Marketing:
Gaining insights into customer preferences to enhance the marketing of our Services.
l Quality and Safety:
Enhancing service quality, maintaining safety, and addressing quality and safety issues.
l Legal Compliance:
Adhering to legal, regulatory, and policy requirements.
l Other Purposes:
As specified when collecting your personal information.
To fulfill these purposes, we may combine information received at various times and through various methods, including both personal information and Automated Information, complementing it with data from other sources. We may anonymize or aggregate data so that it no longer identifies an individual, allowing us to use it for business analysis and planning without limitations.
4. HOW WE MAY SHARE INFORMATION ABOUT YOU WITH OTHERS
l We may disclose your information as outlined in this Privacy Policy or according to a specific privacy notice provided at the time of collection.
l Third-Party Service Providers
l For various business purposes, we may share your information with these third-party service categories:
l - Customer Communications and Insights Platforms: To facilitate communication and manage your account, as well as for internal analytics, we might share your phone number, email, app usage, and interactions with our third-party customer communications platform provider.
l - Internal Business Insights Platforms: Our third-party internal business analytics platform assists us in understanding app usage and interactions, as well as in deriving insights for product and feature enhancement. For services like monitoring app use and customer behavior, we may provide these providers with user identifiers, IDFA, device ID, IP address, and app usage data.
l - Customer Support: Your emails to our support, as detailed in the "How to Contact Us" section, may be processed through a third-party customer support platform, which has access to your personal information and email content. This service helps us in handling your account inquiries and in gathering user feedback about our product's quality or safety.
l - Measurement and Attribution: These providers offer tools for tracking and attributing new subscription sign-ups and for understanding app usage. We utilize unique user identifiers from these third-party providers to assess our ad effectiveness and to learn about our apps' usage, aiming to enhance their quality and safety.
l - Other Technology Providers: This includes cloud storage and web hosting providers, to whom we may provide Automated Information and/or aggregate or non-personal data for purposes like monitoring network traffic and guarding against malicious activities.
l - Payment Processors: For payments made outside Apple or Google stores, we process transactions through third-party providers like Braintree (https://www.braintreepayments.com/). We share necessary information, like your email address, with our payment processor to facilitate receipt delivery and address payment issues.
l Marketing Providers: We, or third-party service providers assisting us in marketing, may use the information we collect to advertise and offer our other products to you. We might share specific data with Facebook for creating Custom or Lookalike Audiences. You can find out more about Facebook Lookalike Audiences at https://www.facebook.com/business/help/164749007013531 and about managing off-Facebook activities at https://www.facebook.com/off-facebook-activity. We recommend reviewing Facebook's Privacy Policy at https://www.facebook.com/privacy/policy/. Furthermore, if we acquire your information through activities like contests, sweepstakes, events, or promotions co-hosted with third parties, your participation authorizes us to share your information with these co-sponsors. We may also share your information with third-party administrators of these promotions, as well as provide aggregated data to third parties to better understand our user demographics for more effective marketing of our products.
l AI-generated Content Provider:
l OpenAI, L.L.C., U.S.A.
l For details about OpenAI's privacy practices, visit https://openai.com/privacy/.
l To understand the license terms related to User Content, please go to https://openai.com/terms/.
Corporate Transactions
In the event of a corporate event like a merger, acquisition, reorganization, bankruptcy, liquidation, asset sale, or business wind-down ("Corporate Transaction"), we may share your information. Subject to legal constraints, we have the right to transfer the information we hold in case of any Corporate Transaction, including the sale or transfer of part or all of our business or assets. If such a transfer occurs, we aim, when possible, to instruct the recipient to handle the information according to this Privacy Policy. Following such a transaction, you may reach out to the new entity for queries about how your personal information is processed.
Legal, Regulatory, Compliance, and Similar Reasons
Moreover, we might disclose and/or share your information to adhere to legal or regulatory obligations, including court orders, subpoenas, or warrants, to meet industry standards, legal processes, and our company policies, and to safeguard against, identify, and address fraud, illegal activities (like responding to hacking or misuse of our websites and applications), adverse event reporting, and claims and other liabilities.
We also reserve the right to disclose your information when we believe it's necessary to limit liability, protect our or others' rights and properties, or to investigate and counteract claims against us.
Additionally, we may gather, use, and disclose your personal data as legally required or allowed, or as you direct, in line with this Privacy Policy.
5. Do Not Track Disclosures
Some internet browsers may send "do-not-track" (DNT) signals to the websites they interact with. There's ambiguity regarding users' intentions in sending these signals and their awareness of them, due to differences in how browsers implement and activate this feature. Currently, there's no consensus in the industry on how websites should act upon receiving such signals. Consequently, our websites do not currently recognize or act on DNT settings in your web browser. We plan to review our approach to these signals once a definitive standard is established and adopted.
Be aware that certain external entities like advertising networks, web analytics firms, and social media and networking platforms gather information about your online activities across various websites over time. These parties may not alter their tracking methods based on the DNT settings in your web browser, and we do not require them to respect these settings. You can find information on how to opt-out of data usage by these third parties in the section titled "Information collected by automated means" above.
6. Social Media and Other Communications
We are active on various social networking and blogging platforms including Facebook, Instagram, Google, LinkedIn, Twitter, Snap, TikTok, and Pinterest, and we may integrate third-party social networking functions into our Services. This integration allows users to interact and share content and information on these social media platforms. Additionally, we may use third-party platforms for publishing or managing our Services or parts of them. We either receive or may share information about you through these platforms and features, and this information is also governed by this Privacy Policy. Moreover, the third-party providers of the social media or blogging platforms we use have their privacy policies, detailing how they collect, use, and secure your information (for example, if you create an account directly with these platform providers). By engaging with social features, you consent to the privacy policies and terms of use of these third parties.
If you opt to interact with us or other users via social features on our websites, mobile applications, social media pages, or similar communication services, be aware that such interactions may be publicly accessible. For your safety, avoid sharing sensitive details like passwords, social security numbers, payment card information through these channels. While we reserve the right to monitor user interactions for security and training, we are not obliged to do so and may remove any content we find inappropriate at our discretion.
7. Information for Individuals in the European Economic Area (EEA)
Your Choices and Rights
If you reside in the EEA, you may have several rights concerning the use of your personal data:
- Access: You can request to access and obtain copies of your personal data.
- Correction: You have the right to correct or update any inaccurate or incomplete personal data.
- Objection and Restrictions: You can request us to stop or limit the use of your personal data in certain cases.
- Deletion: Under specific conditions, you can ask for your data to be erased or for restrictions on its use, in line with the "right to be forgotten."
- Portability: In some situations, you can ask for a transferable format of your personal data to move it to another service provider.
- Consent Management: If we process your data based on consent, you can withdraw this consent anytime without needing to justify your decision.
If you are in the EEA and wish to access, modify, or delete your personal data, you can contact us. However, if changes or deletions are made, or if you choose not to share certain data, we might not be able to provide our services fully. We may refuse requests for specific reasons, such as if they are illegal or infringe on others' rights. For example, some requests may not be feasible as they would prevent us from offering our service to you.
For your safety, we may ask for proof of identity before responding to the above requests.
Legal Basis for Processing Data
This section outlines the legal grounds we rely on to process personal data.
- We may process personal data based on legitimate interests like developing, administering, and improving our services, managing business operations, promoting research, supporting recruitment, or facilitating a Corporate Transaction.
- In some instances, we process personal data to fulfill contracts with business partners, including distributors of our products.
- We may need to process personal data to defend against fraud, illegal activities, and other liabilities, including enforcing our service terms.
- Processing certain data might be necessary for legal compliance or public interest, such as for reporting adverse events and product safety.
- We may process personal data as permitted by specific legal requirements.
If consent is required for processing your personal data, we will seek it at the time of collection.
International Data Transfers
We may transfer your personal data to other countries for processing as described in this Privacy Notice. For instance, data from outside the United States may be transferred to the U.S. The data protection laws in these countries may differ from those in the country where the data was initially collected. When transferring data internationally, we consider various legal requirements.
Specifically, we may transfer personal data from the EEA to:
- Countries recognized by the European Commission as having adequate data protection,
- Recipients adhering to standard contractual clauses, EU-US Privacy Shield, or Binding Corporate Rules,
- Based on the consent of the individual concerned, or
- As allowed by EEA legal requirements.
8. Information for Residents of California: Your California Privacy Rights
As a resident of California, the California Consumer Privacy Act ("CCPA") might grant you additional rights concerning your personal information beyond those detailed in this Privacy Policy. This section outlines your rights under the CCPA if you are a "Consumer" as defined by the law. It explains how to exercise these rights and refers to Sections 1 - 4 above for information on the data we collect, including its collection, use, and sharing processes.
Access to Information and Data Portability Rights
Under the CCPA, you can request, twice in a 12-month period, information about:
- The types of personal information we have gathered about you.
- The sources from which your personal information was collected.
- The purposes for collecting or selling your personal information.
- The categories of third parties with whom we have shared your personal information.
- The specific personal information we have collected about you.
- A list of personal information disclosed for business purposes in the past 12 months, or confirmation that no such disclosure occurred.
- A list of personal information sold in the past 12 months, or confirmation that no sale occurred. If sales occurred, we will detail:
- The types of your personal information sold.
- The categories of third parties to whom the information was sold.
You also have the right to a transportable copy of your personal information collected in the past 12 months.
Data Deletion Rights
Unless we have a reason to retain your data under CCPA, you can request the deletion of your personal information that we have directly collected and are maintaining. We are not obligated to delete information not collected directly from you.
Exercising Your Rights
To request access, portability, or deletion under CCPA, send a request to the Privacy / Legal Department at support@xemail.ai. Your request must:
- Provide enough details to verify your identity or that of your authorized representative.
- Clearly describe your request to enable us to understand, evaluate, and respond.
We may not be able to verify or fulfill requests for data not sufficiently associated with your personal information (e.g., data tied to a pseudonymous browser ID). We will explain any inability to fulfill a request in our response.
We strive to identify and respond to your CCPA rights requests without charging a fee, unless the request is excessive, repetitive, unfounded, or burdensome.
Opt-Out
There is not yet a consensus as to whether third party cookies and tracking devices associated with our websites and mobile apps may constitute a "sale" of your PI as defined by the CCPA. To make a request to opt-out of sale under CCPA, send mail to support@xemail.ai.
We won’t discriminate against you for exercising your CCPA rights. However, prices, rates, or service levels may vary if justified by the value of the data. Financial incentives for personal information collection, sale, and retention may be offered as permitted by CCPA, potentially resulting in different prices, rates, or quality levels. The specifics of any incentive will be detailed in the program terms, which are subject to change, so please review them regularly.
9. Online Privacy Choices and Rights
Access, Edit, and Delete Your Information
For residents of the European Economic Area, information on your rights to access, edit, and delete your data is in the "Information for Individuals in the European Economic Area" section of this Privacy Policy. California residents can find their rights in the "Information for Residents of California" section.
If you're outside the EEA or California, you may still have the right to request access to, correction of, or deletion of your personal information that you provided to Lighter Life LTD, depending on your location. We may ask for proof of identity and residency to process these requests. To make a request, contact us via the support email listed in the "How to Contact Us" section. Changes or deletions to your personal information, or your choice not to share certain information, may affect our ability to provide services to you. Once we verify account ownership, we will consider these requests based on our discretion and applicable laws.
Device Permissions
Mobile devices have permission systems for accessing specific types of data and notifications, like camera and microphone access, as well as push notifications. You can adjust your device settings to grant or deny permission for these data types or notifications, which may impact the functionality of some services.
Uninstall
To stop all data collection by the app, disable call forwarding, deactivate your account as instructed in the app's Settings, and uninstall the app using your device's standard process. Uninstalling the app will retain the unique identifier associated with your device. Reinstalling the app on the same device allows us to reconnect this identifier to your past transactions and activities.
Location Information
Some apps, if you opt-in, may collect precise real-time location data from your device. You can opt out of location data collection by managing location preferences in the app or on your device.
Marketing Opt-Outs
You have the option to opt out of Interest-based Advertising. Advertisers and Service Providers performing advertising services for us and others may be part of the Digital Advertising Alliance's ("DAA") Self-Regulatory Program for Online Behavioral Advertising. For opting out of Interest-based Advertising and Cross-device Data usage for ads, visit http://www.aboutads.info/choices/ and http://www.aboutads.info/appchoices. Some companies might also be Network Advertising Initiative ("NAI") members; learn more about NAI and your opt-out options at http://www.networkadvertising.org/choices/. Opting out means selected members should not deliver specific Interest-based Advertising to you, but it doesn't stop all targeted content or ads. Also, if your browsers reject cookies or you use different devices or browsers, or non-browser-based methods (like mobile apps), your opt-out may not be effective.
10. Data Retention
We generally retain your personal information for three years after you stop using our services or as long as needed to fulfill contractual or legal obligations. If you have ceased using our services and wish to inform us, please do so via the support email listed in the "How to Contact Us" section. We might keep non-personal information for various purposes like backups and analytics. We will store this data only if we believe there's a legitimate reason for it.
11. Protecting Personal Information
We employ measures to protect the integrity and security of the personal information we collect. However, we cannot guarantee complete security during its transmission or storage on our systems. Any information you send is at your own risk.
Be cautious when sending personal information via email, text, or web forms, as these transmissions may not be secure. If there's unauthorized access to your information during transmission, we are not liable for these breaches. You are responsible for the security of your account and password. Notify us promptly of any unauthorized use of your account.
If we suspect a security breach involving your personal information, we will try to notify you. This notification may be via email, through our website, or the app. You can request postal notifications or a printed copy of an electronic notice by contacting us through the provided email address.
12. Links to External Websites and Content
We may include links to third-party websites or content for your convenience. These external sites may have their privacy policies, which we do not control. We recommend reviewing their privacy practices before sharing your personal information.
13. Information About Children
We do not intentionally collect information from children under 16 years old (or older, as per applicable laws). If you are below this age limit, you should not download or use our services. If we learn of any personal information collected from a child under 16, we will delete it. You are responsible for any account activity by minors.
14. Privacy Policy Updates
We may update this Privacy Policy to reflect changes in our practices. We will revise the date at the top of the Privacy Policy when changes are made. Your continued use of the services after these changes indicates your acceptance. We may notify you of significant changes through additional means, like notifications on our website or app. Keep checking this policy regularly for updates.
15. Contacting Us
For questions or concerns about this Privacy Policy, our practices, or to request access to or correction of your information, you can reach us at the provided support email:support@xemail.ai.