Privacy Policy

Introduction

LemonEdge Technology LTD. (“LemonEdge”, “we”, “our” and/or “us”) values the privacy of our website visitors, service users, individual customers and customer personnel (“Users” and/or “you”). If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), “personal data” means any information relating to an identified or identifiable individual.

This Privacy Policy (the “Privacy Policy”) explains how we collect, use and disclose personal data from our Users. The Privacy Policy applies where we are acting as a data controller with respect to the personal data of our Users; in other words, where we determine the purposes and means of the processing of our Users’ personal data.

Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the collection, sharing and publication of your personal data.

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The personal data that we collect

In this Section we have set out the general categories of personal data that we

process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number. The source of the contact data is you. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.

We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.

We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website ("transaction data").The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.

We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.

Purposes of processing and legal bases

In this Section , we have set out the purposes for which we may process personal data and the legal bases of the processing.

Operations ‍

We may process your personal data for the purposes of operating our website, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business. Or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract

Publications

We may process account data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is consent.

Relationships and communications

‍ We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.

Direct marketing

We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes..

Research and analysis

We may process usage data and/or transaction data for the

purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

Record keeping

We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

Security

We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

Insurance and risk management

We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

Legal claims

We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

Legal compliance and vital interests

We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

Providing your personal data to others

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

Your personal data held in our website database, those agreed through contractual agreements will be stored on the servers of our hosting services providers.

We may disclose your personal data to subcontractors insofar as reasonably necessary for the delivery of agreed contract, by consent.

Financial transactions relating to our services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

In addition to the specific disclosures of personal data set out in this Section , we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your

personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We may disclose and transfer your personal information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets.

International transfers of your personal data

In this Section , we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area.

The hosting facilities for our website are situated in the US and UK. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of Standard Contractual Clauses adopted or approved by the competent data protection authorities, or another mechanism that is considered appropriate in accordance with applicable data protection laws. You can contact us for more information about our international transfers, and to obtain a copy of the transfer mechanisms we use.

Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate (“Third-Party Services”).  We are not responsible for the privacy practices of these Third-Party Services.  Please be aware that this Privacy Policy does not apply to your activities on these Third-Party Services or any information you disclose to these Third-Party Services.  We encourage you to read the privacy policies of these Third-Party Services.

Security

We make reasonable efforts to protect your personal information by using physical and electronic safeguards designed to improve the security of the personal information we maintain.  However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your personal information.

Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 16 years of age, and no parts of our services are directed to children.  If you learn that a child has provided us with personal data in violation of this Privacy Policy, please alert us using the contact details below.

Retaining and deleting personal data

This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data as follows:

1. contact data will be retained for a     minimum period of 2 months following the date of the most recent contact     between you and us, and for a maximum period of 2 years following that     date;
2. account data will be retained for a minimum period of 2 years following the date of closure of the relevant account, and for a maximum period of 5 years following that date;
3. transaction data will be retained for a minimum period of 2 years following the date of the transaction, and for a maximum period of 5 years following that date;
4. communication data will be retained for a minimum period of 2 years following the date of the communication in question, and for a maximum period of 5 years following that date;
5. usage data will be retained for 1 year following the date of collection;

Notwithstanding the other provisions of this Section , we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Your rights

You can unsubscribe from our promotional emails via the link provided in the emails.  It may take up to ten business days for us to process your request.  Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

If you are located in the EEA or the UK, you have the additional rights described below:

1. the right to access - you can ask for copies of your personal data;
2. the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
3. the right to erasure - you can ask us to erase your personal data;
4. the right to restrict processing - you can ask us to restrict the processing of your personal data;
5. the right to object to processing - you can object to the processing of your personal data;
6. the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
7. the right to complain to a supervisory authority - you can complain about our processing of your personal data to a data protection authority, which in the UK is the Information Commissioner’s Office, in Guernsey is the Office of the Data Protection Authority, and in Jersey is the Office of the Information Commissioner; and
8. the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy.  Before fulfilling your request, we may ask you to provide reasonable information to verify your identity.  Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain personal information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then

sent back to the server each time the browser requests a page from the server.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

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