Privacy Policy

At LivyApps (hereinafter, "Livy" or "we") we take the privacy and transparency with our users very seriously. This Privacy Policy explains how we collect, use, and protect personal data, as well as the rights available to users in relation to that information.

Using the Website implies acceptance of this Privacy Policy. If the user disagrees with any of the terms described here, they must refrain from using the Website and its services.

1. Data Controller

• Identity: PROMOTTY FIDELITY ES SL
• Tax ID (CIF/NIF): B16432841
• Postal address: Calle Gaviota 32, Mijas. Málaga, Spain.
• Phone: +34681943894
• Email: hola@promotty.com

2. Who This Policy Applies To

This Policy applies to the following types of users:

• Website visitors: people who browse livyapps.com without registering.
• Merchants: Shopify store owners who subscribe to LivyApps services.
• Merchants' customers: end shoppers who interact with the loyalty programs run through LivyApps on our merchants' stores.

Regarding the end customers' data processed on behalf of merchants, the merchant acts as data controller and LivyApps acts as data processor, in accordance with Article 28 of the GDPR.

3. Minimum Age

LivyApps does not provide its services to persons under 16 years of age. We do not knowingly collect personal data from children under 16. If we become aware that data from a minor has been provided without the required parental consent, we will delete it promptly.

4. Personal Data We Collect

Livy may collect the following categories of personal data:

• Usage and browsing data: information related to how the user interacts with the Website, such as pages visited, sections browsed, or general usage behaviour.
• Communication data: information provided by the user when contacting Livy through forms, email, or other support channels.
• Voluntarily provided data: any information the user consciously chooses to share while using the services.

Livy does not collect special category data or sensitive personal information.

5. Purposes of Processing

Users' personal data will be processed for the following purposes:

1. Customer support: handling queries, requests, incidents, or communications from users.
2. Service management and improvement: analysing Website usage for statistical and continuous improvement purposes.
3. Informational and marketing communications: sending information about news, updates, features, or improvements related to LivyApps, only when the user has given their consent.
4. Compliance with legal obligations: responding to legal, tax, or administrative requirements when necessary.

6. Data Retention Period

Personal data will be kept for as long as necessary to fulfil the purposes for which it was collected. As a general guideline:

• Browsing data and cookies: up to 24 months from the last visit.
• Contact and communication data: up to 2 years from the last contact.
• Merchant data: for the duration of the service agreement and up to 5 years thereafter to comply with legal and tax obligations.
• Merchants' end customer data (processed as data processor): in accordance with the instructions of the merchant acting as data controller.

Data will be deleted upon user request or when it is no longer necessary for the described purposes, unless a legal retention obligation applies.

7. Legal Basis for Processing

The processing of personal data is based on one of the following legal grounds:

• Performance of a contractual or pre-contractual relationship, where necessary to provide the services offered.
• User consent, in cases where it is expressly requested (for example, marketing communications).
• Compliance with legal obligations applicable to the data controller.

8. Data Recipients

Personal data will not be disclosed to third parties, except in the following cases:

• When necessary for the proper provision of the service.
• When a legal obligation requires it.
• When the user has given their express consent.

In the event of a merger, acquisition, restructuring, or asset sale involving PROMOTTY FIDELITY ES SL, personal data may be transferred to the new entity, which will be bound by the obligations set out in this Privacy Policy.

Personal data will never be sold to third parties.

9. International Data Transfers

Personal data may be transferred to and processed in countries outside the European Economic Area (EEA). In all cases, LivyApps ensures that such transfers are carried out with appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission or other mechanisms recognised under applicable law.

For further information on the safeguards applied to international transfers, please contact us at the email address indicated in the user rights section.

10. User Rights

The user has the right to:

1. Access their personal data.
2. Request the correction of inaccurate data.
3. Request the deletion of their data when it is no longer needed.
4. Request the restriction of processing of their data.
5. Object to the processing of their data, especially for commercial purposes.
6. Request data portability, where applicable.

To exercise these rights, the user may send a request to privacidad@livyapps.com, indicating in the subject line: "Exercise of data protection rights".

11. Data Security

Livy applies appropriate technical and organisational measures to ensure the security, integrity, and confidentiality of personal data, preventing unauthorised access, loss, or alteration of information.

12. Do Not Track Signals

The Website does not currently respond to Do Not Track (DNT) signals sent by browsers. Users can manage their tracking preferences through their browser settings or the cookie consent panel on the Website.

13. Changes to the Privacy Policy

The Owner reserves the right to modify this Privacy Policy to adapt it to legislative changes or changes in how the Website operates. Any relevant modifications will be duly communicated to users.

14. Applicable Law and Jurisdiction

This Privacy Policy is governed by Spanish and European data protection law. For the resolution of any dispute, the parties submit to the courts of Málaga, unless applicable law provides otherwise.