LYMPO.IO PRIVACY POLICY

Last updated: 20-04-2023

This LYMPO.IO Privacy Policy (“Privacy Policy”) describes how the Company Processes Personal Data. Please read this Privacy Policy carefully before commencing the use of the Platform.

If you have any questions relating to Processing of your Personal Data or pertaining to this Privacy Policy, please, contact us at [email protected].

Definitions

Company – Latgala OÜ, registered address at Tornimäe tn 5, Tallinn, Estonia. In this Privacy Policy may also be referred to as “we” or “us”.

Data Subject – any natural person who uses or has used the Platform. In this Privacy Policy may also be referred to as “you”.

Data Controller – anyone who alone or jointly with others determines the purposes and means of the Processing of Personal Data. For the Processing described in this Privacy Policy the Company is the Data Controller.

Data Processor – a person or an entity who Processes Personal Data on behalf of the Data Controller.

GDPR – Regulation (EU) 2016/679 (General Data Protection Regulation).

Personal Data – any information relating to an identified or identifiable living natural person.

Platform – a platform, programming interface (API), applications, materials, any products, services, solutions and other items provided by or on behalf of the Company and available through website https://lympo.io/ and any affiliated mobile websites and mobile applications, owned and/or operated by the Company.

Processing – any operation or set of operations performed with regard to Personal Data, whether or not performed by automated means, for example collection, recording, organisation, storage, adaptation, alteration, retrieval, gathering, use, combination, erasure or destruction.

Recipient – a natural or legal person, public authority or another body, to whom Personal Data may be lawfully disclosed by the Company.

Terms – LYMPO.IO Terms and Conditions available through website https://lympo.io/.

Other terms used in this Privacy Policy have the meaning described in the Terms and GDPR.

What types of Personal Data we have and how we get it?

We currently Process the following information:

- Name and last name, contact number, email address, nationality, sport that you participate in, your Twitter page, Youtube channel, Instagram profile, Facebook page address (applicable only when you provide your information to us via the Platform in order to become a Lympo athlete and/or become one and we sign an agreement with you);

- Communication data, related to communication between you and the Company via email or by other means;

- Data that you provide to us via our social network pages (e.g. Facebook, Twitter, Linkedin, etc.).

- IP address (we may also derive your approximate location from your IP address)

- Blockchain wallet address, including related data used to detect cryptocurrency and NFT holdings

Legal grounds and purposes of Processing Personal Data

We only collect and process Personal Data about you where we have legal grounds. Legal grounds include consent (where you have given consent), contract (where processing is necessary for the performance of the Terms or contract signed with you), legal obligations applicable to us and our legitimate interests.

Performance of the Terms or agreement signed with you

The main purpose of Processing the Personal Data is to perform the Terms or an agreement signed with you. Example of purpose for such Processing is management of our legal (contractual) relationships with you.

Compliance with legal obligations

The Company needs to comply with legal obligations. Therefore, we are required to Process Personal Data in accordance with applicable laws. Examples of purposes for such Processing are:

- to comply with rules and regulations relating to accounting, legal investigations, etc.;

- to fulfil the obligations of applicable litigation laws.

Legitimate interests

The Company Processes Personal Data for our legitimate interests. This Processing is necessary for the purposes of a legitimate interest pursued by the Company, which we have considered outweighing the Data Subject’s interest of protection of the Personal Data. Examples of purposes for such Processing are:

- to develop, examine and improve the Platform and/or the Data Subject’s user experience by performing analyses, statistics, etc.;

- to prevent or investigate possible fraud or other violations of the Terms and/or attempts to harm other Platform users;

- to reply to the Data Subject’s requests;

- to establish and defend legal claims.

Consent

Some of the data may be Processed based on the Data Subject’s consent, e.g. when you subscribe to our newsletter. Where we rely on your consent to process Personal Data, you have the right to withdraw or decline your consent at any time by contacting us at [email protected].

Whom we disclose the Personal Data?

The Company may share some Personal Data with Recipients, such as competent authorities. The Company does not disclose more Personal Data than necessary for the purpose of disclosure. Recipients may Process the Personal Data acting as Data Processors and/or as Data Controllers. When Recipient is Processing Personal Data on its own behalf as a Data Controller, the Recipient is responsible for providing information on such Processing of Personal Data to the Data Subject.

The Company may disclose Personal Data to Recipients, such as:

- Data Processors invoked by the Company for development and/or maintenance of the Platform or our services;

- competent authorities, such as law enforcement agencies;

- financial and legal consultants, auditors, other service providers and affiliates of the Company, to whom disclosing of the Personal Data is necessary and lawful.

How and how long we store the Personal Data?

As a general rule Data Subject’s Personal Data are Processed within the EU/EEA. The transfer and Processing of Personal Data outside of the EU/EEA could only take place if there is a legal basis and appropriate safeguards are taken.

We keep Personal Data for a limited time period and in any event no longer than necessary for the purposes for which the Personal Data were collected. The retention periods are defined by the laws or legitimate interests of the Company. After retention period comes to an end the Company will then delete the Personal Data.

Direct Marketing

We may use your personal data for direct marketing purposes to provide you with offers and information about our goods and (or) services. We will only use your personal data for this purpose with your consent.

By granting the right to process your personal data for the purpose of direct marketing, you also allow us to contact you for this purpose by appropriate means of communication (e.g. e-mail, telephone, etc.).

If you consent to the use of your personal data for direct marketing purposes, we may use your personal data for targeted advertising, i.e. to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and (or) location and to measure its effectiveness, other marketing and sales purposes of the Company.

Even if you have given your consent for the processing of your personal data for direct marketing purposes, you can easily revoke this consent at any time for all or part of the processing of personal data.

To do this, you can:

(i) notify the waiver in the manner indicated in the newsletters and (or) offers received by e-mail (for example, in newsletters and (or) offers by clicking on the link "unsubscribe from newsletters, offers", etc.), or

(ii) send us a request by email [email protected].

If you withdraw your consent, we will immediately stop processing your personal data for direct marketing purposes.

We may use your personal data for the marketing of our own similar goods and (or) services, based on our legitimate interest, in accordance with the conditions set out in the relevant legislation. You have the right at any time to object, disagree to this processing by contacting us by e-mail address [email protected] and (or) using the instructions provided in each marketing message.

Use of Cookies

We collect information about you using cookies and similar technologies. Cookies are small files that are temporarily stored on your device's hard drive and allow to identify you during other visits to the Platform, save your browsing history, options, customize content, speed up searches on the Platform, create a convenient and friendly Platform environment, make it more efficient and reliable. Cookies are common web browsing practices that make it easier to use the website (Platform).

In this Privacy Policy, we use the term ‘cookies’ to describe cookies and other similar technologies, such as for example pixel tags.

We use cookies as described in the table below.

Strictly Necessary cookies

Performance cookies

Unclassified cookies

In order for us to use cookies and other technologies, except cookies that are purely technical and necessary for the proper functioning of the Platform, we need your separate and specific consent, which you can give to us by clicking on the ‘Agree’ button in the ‘cookie banner’ on the Platform. Thus, you can freely choose whether you want to accept cookies.

You can configure your browser to decline, delete some or all cookies or to ask for your permission before accepting them. Please note that by deleting cookies or disabling future cookies you may be unable to access certain areas or features of our website. For information on how to adjust or change your browser settings, visit www.aboutcookies.org or www.allaboutcookies.org .

For the information on, policy and control options for the third-party cookies, please read cookie policies of such third parties.

Use of Google Analytics

Google Analytics is integrated on our website https://lympo.io/.

Google Analytics is a website analysis service provided by the US company Google Inc. Google Inc. also has access to the statistical data collected by Google Analytics tool.

Website analysis refers to the collection, recording and analysis of data regarding the behaviour of visitors to the website. You can find more information about Google Analytics’ use of Personal Data here: https://policies.google.com/privacy?hl=en

Use of Venly

Our website https://lympo.io/ integrates the Venly solution, which allows users to sign up and log in with social accounts and create WEB3 wallets for use on the NFT platform. Venly is a third-party service provider, and as such, may collect and process Personal Data of our users in accordance with their own privacy policy. By using the Venly solution on our website, you acknowledge and agree that your Personal Data may be shared with Venly and processed in accordance with their privacy policy, which can be found here:https://www.venly.io/legal/privacy-policy. The Company assumes no responsibility or liability for the collection, use, or management of Personal Data by Venly.

Use of Swipelux

Our website https://lympo.io/ integrates the Swipelux payment solution, which enables users to buy cryptocurrency on the NFT platform using credit or debit card. As a data controller, Latgala OÜ may access some of your personal data, such as email address, phone number, wallet address, and order ID, through a provided dashboard. The personal data that is accessed by Latgala OÜ is used solely for the purpose of processing the transaction and providing customer support as necessary. By using the Swipelux payment solution on our website, you acknowledge and agree that your personal data may be shared with Swipelux and processed in accordance with their privacy policy, which can be found here: https://swipelux.com/privacy_policy. The Company assumes no responsibility or liability for the collection, use, or management of personal data by Swipelux.

Use of Other Technologies

We use pixels that are tiny snippets of code that allow us to gather information about visitors on the Platform, i.e. how they browse, what type of ads they click on and etc. Thus, pixels collect data that helps the Company track conversions from ads, optimize ads, build targeted audiences for future ads and remarket to visitor of the Platform.

We use the following pixels:

‘Facebook Pixel’ is used for remarketing purposes, so that we can contact you again. Also, this tool allows the information collected with its help to be analysed in the ‘Facebook Ads Manager' platform. This allows us to display interest-based advertising (‘Facebook Ads’) to you when you visit Facebook or other websites that also use this tool. In this way, we try to show you advertising that interests you, so that our Platform or offers are more interesting to you.

More information on how the Facebook Pixel works: https://www.facebook.com/business/learn/facebook-ads-pixel.

‘Twitter Pixel’ is used for remarketing purposes, so that we can contact you again. Also, this tool allows the information collected with its help to be analysed in the ‘Twitter Analytics’ and ‘Twitter Ads’ platform. This allows us to display interest-based advertising (‘Twitter Ads’) to you when you visit Twitter or other websites that also use this tool. In this way, we try to show you advertising that interests you, so that our Platform or offers are more interesting to you.

More information on how the ‘Twitter Pixel’ works: https://business.twitter.com/en/help/campaign-measurement-and-analytics/conversion-tracking-for-websites.html

‘Reddit Pixel’ is used for remarketing purposes, so that we can contact you again. Also, this tool allows the information collected with its help to be analysed. This allows us to display interest-based advertising to you when you visit Reddit or other websites that also use this tool. In this way, we try to show you advertising that interests you, so that our Platform or offers are more interesting to you.

More information about it can be found here: https://www.reddit.com/policies/cookies

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the section below.

Data Subject’s rights and how to contact?

Under GDPR, you have the following rights:

Your right of access – you have the right to ask us for copies of your personal information.

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.

Your right to restriction of Processing – you have the right to ask us to restrict the Processing of your information in certain circumstances.

Your right to object to Processing – you have the the right to object to the Processing of your information in certain circumstances.

Your right to data portability – you have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

If you make a request, we have one month to respond to you.

Please contact us at [email protected] if you wish to make a request.

You can also complain to the Estonian Data Protection Inspectorate (website address: https://www.aki.ee/en) if you are unhappy with how we Processed your Personal Data.

The Privacy Policy can be amended from time to time due to legislative changes, changes in the Platform, activities of the Company and other factors. We will inform you about the amendments by publishing the amended text of the Privacy Policy on the website https://lympo.io/ . We advise you to regularly review the relevant and applicable Privacy Policy.