- Limpa Tudo LLC, (the “Company”, “we”, “our”, or “us”) is committed to protecting your privacy. This Privacy Policy sets out how we collect, store, process, transfer, share, disclose and use data and personal information that identifies or is associated with you (“personal information”) and information regarding our use of cookies and similar technologies.
- We collect personal information about individuals that are our direct customers and, where our customer is a business or similar entity, we collect personal information about individuals that are our customer’s employees, agents and other representatives. These individuals about whom we collect personal information are referred to as “you” and “your” throughout this Privacy Policy.
- The Company provides information and links that allow customers to: browse, subscribe and access to sales copy pages, checkout pages, enrollment pages, advertisements, and other marketing messages (the “Services”) located at DanLok.com or any other websites operating by Dan Lok Education, Inc., its subsidiaries or affiliates (together known as our “Websites”).
- This Privacy Policy applies to our Websites and the Services. Before accessing our Websites or using the Services, please ensure that you have read and understood this Privacy Policy.
- By submitting your personal information to the Company, you consent to the collection, use, storage, processing and disclosure of your personal information in accordance with this Privacy Policy. If you do not consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy, please do not provide any personal information to the Company.
- This Privacy Policy does not cover third party websites, services, applications or payment gateways and payment transaction processes that may be accessed via our Websites, and we accept no responsibility or liability in respect of third-party websites. Please check the privacy policies published on any third-party websites which you may access through our Websites before submitting your personal information to them.
PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
- We collect personal information about you when you voluntarily submit information directly to us when you access our Websites or use the Services. This can include information you provide to us when you register for an account, fill in a form, correspond with us via our Websites, social media account, phone, email or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, respond to surveys or use some other feature of the Services as available, from time to time.
- In general, personal information may include, but is not limited to, your name, date of birth, financial information, home address, phone number, IP address, location data, weblogs, date, time, browser used, referring web addresses, other communication data, searches conducted and pages visited, and other details such as your occupation and title.
- Certain Services can only be offered to you if you provide personal information to the Company, and accordingly the Company may not be able to offer you the Services if you choose not to provide it with required personal information.
- Annex 1 attached hereto sets out the categories of personal information we collect about you and the purposes for which we collect and use your personal information. The table also lists the legal basis which we rely on to process the personal information, the categories of recipients to whom we may lawfully disclose the personal information and details as to how we determine applicable retention periods in respect of the personal information we collect about you.
- We also automatically collect personal information about you indirectly about how you access and use the Services and information about the device you use to access the Services. We may link or combine the personally identifiable personal information we collect about you directly and the information we collect about you indirectly. This allows us to provide you with a personalized experience regardless of how you interact with us.
- The Company strives to limit the amount of personal information we collect to such personal information that is necessary and appropriate for the purposes identified in Annex 1 attached hereto. The Company will not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as permitted or required by applicable law.
- We may anonymise and aggregate any of the personal information we collect, including information about individuals that are your subscribers, website visitors or customers (so that it does not directly identify you or them). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Services and developing new products and features. We may also share such anonymised information with third parties.
CUSTOMER DATA WE MAY COLLECT THROUGH THE PROVISION OF OUR SERVICES
- During the provision of the Services, we may also collect personal information about individuals that are subscribers, website visitors or customers of our customers (the “Customer Data”).
- By submitting or causing to be submitted Customer Data to us, you hereby grant, and represent and warrant that you have all rights necessary to grant, all rights and licenses to the Customer Data required for the Company and its subcontractors and service providers to provide the Services. If the Company shares or publicly discloses information (including in marketing materials or in application development) that is derived from Customer Data, such data will, to a commercially reasonable extent, be aggregated or anonymized to reasonably avoid identification of a specific individual. You further agree that the Company will have the indefinite right to use, store, transmit, distribute, modify, copy, display, sublicense, and create derivative works of the above mentioned anonymized, aggregated data.
- In connection with Customer Data, you hereby represent, warrant and agree that: (a) you have obtained or will obtain the Customer Data lawfully and/or have not engaged in material misrepresentation, deception or other fraudulent or improper means to cause the Customer Data to be collected by the Company; (b) the Customer Data does not and will not violate any applicable laws or any person or entity’s proprietary or intellectual property rights; (c) all Customer Data has and will be collected by you in accordance with a privacy policy that permits the Company to collect, use, and disclose such Customer Data as contemplated under and in accordance with, this Privacy Policy, and if required by applicable law, pursuant to consents obtained by you to do each of the foregoing; (d) you are solely responsible for ensuring compliance with all privacy laws in all jurisdictions that may apply to Customer Data; (e) the Company may exercise the rights in Customer Data granted hereunder without liability or cost to any third party; and (f) the Customer Data complies with this Privacy Policy. For purposes of clarity, we take no responsibility and assume no liability for any Customer Data, and you will be solely responsible for Customer Data and the consequences of collecting or sharing it hereunder. You may not submit, or cause to be submitted, any Customer Data that includes a social security number, passport number, driver’s license number, or similar identifier, credit card or debit card number, employment, financial or health information, or any other information which may be subject to specific data privacy and security laws.
- In the event that Customer Data is disclosed to or accessed by an unauthorized party, the Company will promptly notify you and use reasonable efforts to cooperate with your investigation of the incident. In the event we have a reasonable, good faith belief that an unauthorized party has accessed Customer Data, we will promptly notify you and will use reasonable efforts to cooperate with your investigation of the incident. If such incident triggers any third-party notice requirements, you (not the Company) shall be solely responsible for the timing, content, cost and method of any such notice and compliance with applicable laws. You (not the Company) bears sole responsibility for adequate security, protection and backup of Customer Data when in your or your representatives’ or agents’ possession or control. We are not responsible, and you are fully responsible, for what your authorized Users do with Customer Data.