Privacy Policy

Troglo LTD (LVNDR) Privacy Policy

When you use our services, you’re trusting us with your personal data. We understand that this is a big responsibility and we work hard to protect your personal data and put you in control. This Privacy Policy is meant to help you understand what personal data we collect or generate when you use our website and mobile application. It also explains why we collect your personal data, how you can update, manage, export and delete your personal data, what choices you have relating to your personal data and how you can contact us.  

We encourage you to read this Privacy Policy as well as our Terms and Conditions (referred to as our “Terms”).

Who we are

We are Troglo Ltd (LVNDR), a company registered in England under company number 11324206 (herein referred to as “LVNDR”, “we”, “us” or “our”). You will find our registered office at Flat 3, 61 Borough Road, Southwark, London, England SE1 1DZ. 

Information about your personal data

This Privacy Policy relates to data about you and your interaction with our services. “Personal Data” is data that can be used to identify you, directly or indirectly, alone or together with other information. This includes things such as your name, phone number, location, and data obtained through our website at https:// lvndr.com, and the Troglo mobile application (the “App”). Troglo (LVNDR) collects, uses, discloses and processes Personal Data as outlined in this Privacy Policy, including to operate and improve the services and our business; for advertising and marketing; and to provide you with innovative sexual wellbeing services, as further described in this Privacy Policy. 

What personal data do we collect?

We ask you for certain personal data to provide you with the services you request. For example, when you contact our consumer services, request to receive communications, create an account, or use our website or App.

This personal data includes your:

• Contact details, including name, email.
• Login and account information, including screen name, password and unique user ID;
• Personal details including your gender identity, genitals you sport, your sexual orientation, your age, past vaccinations, and your use of pre-exposure drugs and anti-contraception;
• Medical information such as your past vaccinations, your use of pre-exposure drugs and anti-contraception, and your HIV and STI status;
• Sexual activity data, including the processing of the date and type of sexual activity, how you met your activity partner, where it happened and whether you enjoyed yourself and felt safe. We also process the way you address your partner, their gender and the safety precautions you used in your activity.
• Personal preferences including your marketing and cookie preferences.

We collect additional personal data from you to enable particular features within our website and App.  For example, we may request access to your phone’s location data.  In addition, certain personal data is automatically collected from your device or web browser. More information about these practices is included in the “Cookies and Log Files” section of this privacy policy below. This data includes:

• Device battery information; and
• Cookies, IP addresses, referrer headers, data identifying your web browser and version, and web beacons and tags.

Cookies and Log Files

We collect and process information about the apps, browsers, and device you use to access our website and App. This includes your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. We also collect information about the interaction of your apps, browsers, and devices with our services, including IP address, crash reports, system activity, and the date, time, and referrer URL of your request.

“Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web  site. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your Device until you delete them) to provide you with a more personal and interactive experience on our website and App, and to improve our marketing efforts, including through the use of targeted advertising. Persistent cookies we place may be removed by following instructions provided by your browser. If you choose to disable cookies, some areas or features of the Troglo (LVNDR) Services may not work properly. Troglo (LVNDR) has an interest in the collection of such information for fraud monitoring and analytics purposes.

How do we collect your personal data?

Most of the personal data we collect is provided to us directly by you. We use this data to provide you with our services as per our Terms and for our own legitimate business reasons.

Aside from data we collect directly from you, we collect your personal data in a number of ways, including:

• When you provide us feedback or contact us for support;
• When you register for an account or interact with our services;
• When you input sexual wellbeing and activity data within our App or use our services that collect or infer such data from mobile device sensors;
• When you communicate with us or sign up for promotional materials;
• When you participate in special activities, offers, or programs;
• When you engage with our online partners, communities or advertising;
• When you access third party products and services;
• When you connect with us through social media;
• When we collect data from third parties or publicly available sources;
  
• When we comply with legal requirements, law enforcement and for public safety purposes; and
• When you participate in a survey.

How do we use your personal data?

We use your personal data in the following ways:

• To identify you: To identify you as a user of our services.
  
• To  provide  the  features  of  the  website,  App  and  services  you request:  When you use our website and App, we will use your personal data to provide the requested product or service.  For example, if you participate in an event or promotion, we will use the contact information you  give us to communicate with you. If you use our App to track your sexual activity, we will collect this personal data and store it so that you can review it in the App.
• To communicate  information  about  our  services,  website  and  App and for other promotional purposes: If required, we will ask for your consent to send you marketing communications and news concerning Troglo (LVNDR)’s products, services, events and other promotions. You can opt-out at any time after you have given your consent. If you are an existing  subscriber  or  member  of  LVNDR  (for  example, you  have  created an  account  on  the  App),  we  may  use  the  contact  details  you  provided  to send you marketing communications about similar Troglo (LVNDR) products or services where permitted by applicable law. We may use your personal  data that you provide to us to personalize communications on products and services that may be interesting to you. Marketing and advertising material provided by Troglo (LVNDR) may appear within our App, on our website, on Apps owned by third parties, or on websites controlled by third parties. The marketing and advertising may relate to Troglo (LVNDR)’s products or services, or any affiliated third party.
• To  operate,  improve  and  maintain  our  business,  products  and services;  we use the personal data you provide to us to operate our business. For example, we may use personal data about how you use our services  to  enhance your user experience and to help us diagnose technical and service problems and administer our website and App.
• To  protect  our  rights  or  safety; we may also use your personal data about how you use our website and App to prevent or detect fraud, abuse, illegal use, violations of our Terms, and to comply with court orders, governmental requests or applicable law.
• Employment; if you apply for employment with Troglo (LVNDR) or currently work for Troglo (LVNDR), to manage your employment application, assess your qualifications, and manage your employment with us (applies solely to the LVNDR website).
  

How do we share your personal data?

We may disclose your personal data for the purposes as described in the prior section of this privacy policy, and in the following situations:

• Third Party  Tracking  Companies: We share your hashed Device  ID, profile  information,  and  demographic  information  with  analytics  partners. These  third  parties  may  also  collect  information  directly  from  you  as described  in  this  Privacy  Policy.  The  privacy  policy  of  these  third  party companies applies to their collection, use and disclosure of your information.  For  example,  one  of  our  partners  is  Google  Analytics  which collects information and report website trends without identifying individual visitors.
• Third Party Advertising Companies:  We share your hashed Device ID, your  device's  advertising  identifier,  a  portion  of  your  profile  information, and some of your demographic information with our advertising partners. These  third  parties  may  also  collect  information  directly  from  you  as described  in  this  Privacy  Policy  through  technology  such  as  cookies.  The privacy  policy  of  these  third  party  companies  applies  to  their  collection, use and disclosure of your information.
• Third Party Service Providers:  We share your Personal Data with third party service providers to: provide you with the Troglo (LVNDR) services; conduct  quality  assurance  testing;  provide  technical  support;  and/or  to provide  other  services  to  Troglo  (LVNDR).  Except  as  otherwise  stated  in this  Privacy  Policy,  these  third  party  service  providers  are  required  by contract not to use your Personal Data other than to provide the services requested  by  Troglo  (LVNDR).  We  do  not,  however,  provide  HIV  status data to our third party service providers, other than companies that host data on our behalf (e.g., Google Firebrand).
  
• Partner Promotion: We offer contests, sweepstakes, or other promotions with third party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner the information that you  provide  will  be  shared  with  us  and  with  them.  Their  use  of  your information is not governed by this privacy policy.
• Affiliates and Acquisitions:  We may share your Personal Data with our parent  company,  any  subsidiaries,  joint  ventures,  or  other  companies under common control. If another company acquires our company, business,  or  our  assets,  that  company  will  possess  the  Personal  Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
  
• Other Disclosures With   Your   Consent:    We may explicitly ask if you would   like us to share your information with other third parties who are not described elsewhere in this policy. For example, we may ask you if you would like to back- up your account, or the information stored within your local  device,  to  a  third  party  back-up  service  such  as  Apple  or  Google Firestore. We may also ask you if you would like us to notify your partners for you.
  
• Legal compliance: Troglo (LVNDR) may disclose Personal Data in response   to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws; to establish or exercise our  rights  to  defend  against  legal  claims;  if  we  believe  it  is  necessary  to investigate,  prevent,  or  take  action  regarding  illegal  activities,  suspected fraud,  safety  of  person  or  property,  violation  of  our  policies,  or  as otherwise required by law.
  

Legal basis for processing your personal data

For the purposes of applicable data protection laws, Troglo (LVNDR) is the controller of the personal data you provide to us (“Data Controller”). As a Data Controller, we process the personal data in accordance with this privacy policy.

We collect and process your personal data for a variety of purposes outlined in this privacy policy. In certain cases, separate consent is not required, including:

1. The performance of a contract. To perform our contractual obligations to you,  including  account  registration,  and  contacting  you  in  relation  to  our services.
2. To meet legal obligations. To comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation.
3. For legitimate interests. To operate our business and provide the services to  you,  except  where  your  rights  and  freedoms  override  our  legitimate interest.  For  example,  we  may  process  on  the  basis  of  legitimate  interest when  communicating  with  you  regarding  our  services,  including  to  provide you with important updates regarding changes to our Terms, or in order to respond to your requests. We may also rely on legitimate interest in order to improve  and  develop  our  services  and  your  experience,  or  to  send  you  a survey request.

Consent

In some cases, we will ask for your consent to process your personal data. You may indicate your consent in a number of ways, including, as permitted by law, ticking  a  box  (or  equivalent  action)  to  indicate  your  consent  when  (i)  providing us with your personal data through our services or a form (including enrolling in promotions); or (ii) registering or creating an account with us.

We may request your consent to contact you by telephone or email or SMS/text message about other offers, products or services we think may be of interest to you.

We may also request your consent when processing sensitive personal data, such as medical information, health data, or sexual activity data. Our App may require this data to provide the services to you. If you choose not to provide sensitive personal data, certain features of the App may be unavailable or not function properly.

How We Protect Personal Data

Troglo (LVNDR) takes steps to help protect your personal data from unauthorized access, use, or disclosure, including a variety of technical and organizational security measures, including encryption and authentication tools. That said, no method of transmission over the Internet, or method of electronic storage, is fully secure, and Troglo (LVNDR) cannot guarantee the security of your personal data. In the event that we are required by law to inform you of any unauthorized access to your personal data, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

International transfers of your personal data

The personal data we collect (or process) in the context of our website and App will be stored by a third party service provider located in the EEA.

Some of the data recipients with whom Troglo (LVNDR) shares your personal data may be located in countries other than the country in which your personal data originally was collected, including the United States. The laws in those countries may not provide the same level of data protection compared to the country in which you initially provided your data. Nevertheless, when we transfer your personal data to recipients in other countries, we will protect that personal data as described in this privacy policy and in compliance with applicable law.

We take measures to comply with applicable legal requirements for the transfer of personal data to recipients in countries outside of the EEA that do not provide an adequate level of data protection. We use a variety of measures to ensure that your personal data transferred to these countries receives adequate protection in accordance with data protection rules; this includes signing the EU Standard Contractual Clauses, or verifying the recipient has adopted Binding Corporate Rules.

How we store your information

Typically we retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required for the operation of the Troglo (LVNDR) services or permitted by law. Typically, this means that we will keep your personal data for as long as you keep your Troglo (LVNDR) account In addition, we may keep your Personal Data and usage history (which includes a history o  profile text or photos that have been censored, banned) as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.

Where we no longer need to process your personal data for the purposes set out in this Privacy Policy, we will delete your personal data from our systems.

Where permissible, we will also delete your personal data upon your request. Information on how to make a deletion request can be found in the  “Contact Information” section on our website.

Your data protection rights

You have certain rights under data protection laws in relation to the personal data that we hold on you, including:

• Your  right  of  access:  You  have  the  right  to  ask  us  for  copies  of  your personal data. Requests for copies of your personal data will be dealt with within one month, unless your request is complicated or if you have made a large number of requests.  In these circumstances it may take us longer to deal with your request, in which case we will let you know if we need longer than one month to respond.
• Your right to rectification: You have the right to ask us to rectify information you  think  is  inaccurate.  You  also  have  the  right  to  ask  us  to  complete information you think is incomplete.
• Your  right  to  erasure:  You  have  the  right  to  ask  us  to  erase  your  personal information in certain circumstances, for example where there is no good reason  for  us  continuing  to  process  it;  you  have  successfully  exercised your  right  to  object  to  processing  (below);  or  where  we  may  have processed  your  data  unlawfully  or  where  we  are  required  to  erase  your personal data to comply with data protection laws.
• Your  right  to  restriction  of  processing:  You  have  the  right  to  ask  us  to restrict the processing of your personal data in certain circumstances.
• Your  right  to  object  to  processing:  You  have  the  right  to  object  to  the processing  of  your  personal  data  in  certain  circumstances.  This  applies where we are relying on a legitimate interest or those of a third party and you  feel  our  processing  on  this  ground  impacts  your  fundamental  rights; or  where  we  are  processing  your  personal  data  for  direct  marketing purposes. If you raise an objection we will stop processing your personal data unless very exceptional circumstances apply, in which case we will let you know why we’re continuing to process your personal data.
• Your right to data portability: You have the right to ask that we transfer the data you gave us to another organization, or to you, in certain circumstances.
• Right  to  withdraw  consent:  This  only  applies  where  we  are  relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

To exercise any of your rights, please contact us by emailing us at support@lvndr.com

How to complain

If you contact us with a privacy complaint it will be assessed with the aim of resolving the issue in a timely and effective manner.

You can also complain to the ICO if you are unhappy with how we have used your data:

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113

Applicability of this Policy

This Privacy Policy applies to all of the services offered by Troglo (LVNDR) and services offered on third-party sites.

This Privacy Policy doesn’t apply to:

• The information practices of other companies and organizations that advertise our services
• Services offered by other companies or individuals, including products or sites that may include Google services, be displayed to you in search results, or be linked from our services

Changes to this Policy:

We may change this Privacy Policy from time to time. If we decide to update our privacy policy, we will post the changes on our website and App. If we materially change the way in which we process your personal data, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to read our privacy policy and keep yourself informed of our practices.

We always indicate the date the last changes were published and we offer access to archived versions for your review.

Other Information

The following additional information relates to our privacy practices:

Permissible Age: The Troglo (LVNDR) services are intended for users 18 years of age and older only (twenty-one (21) years of age in places where eighteen (18) years is not the age of majority). We do not intentionally gather Personal Data about visitors who are under the age of majority. If you are aware that a child or minor has submitted Personal Data on the Troglo (LVNDR) services, please contact us using the information provided below so that we can take appropriate action.

Contact Information: Troglo (LVNDR) welcomes your comments or questions regarding this Privacy Policy. Please contact us at the following:

Name: LVNDR

Headquarters Address: 313 West barnes lane, KT3 6JE

Email:  support@lvndr.com