This privacy policy ("PP") explains how LifeLee Ltd., and its affiliates (collectively, "the “Company") collect, receive, use, store and share your personal data in connection with theCompany’s mobile application, website and related services, the Company may operate (the "Product" and/or "Genie"). This PP constitutes an integral part of the Terms and Conditions Agreement available at www.lifesgenie.com (together with the PP the "Agreement").

 

For the purpose of this Privacy Policy "Personal Data" shall mean personal data or personal information pursuant to the Applicable Data Protection Law (as defined below).

 

For the purposes of this PP ”Applicable Data Protection Laws“ shall mean, to the extent applicable to Company's processing of Personal Data hereunder (with respect to each data subject): (i) applicable U.S data protection laws (ii) California Consumer Privacy Act of 2018, Cal. Civ. Code 1798.100 et seq. (“CCPA”), ; or (iv) Protection of Privacy Law 5741-1981 (Israel); (v) any rules or regulations that amend and/or replace any of the aforementioned Data Protection Laws.

 

1. APPLICABILITY.

1.1. User (as defined hereunder) is not under any legal obligation to submit Personal Data to the Company. If User chooses not to submit any Personal Data to the Company, User may not be able to use the Product, or certain parts thereof. “User” shall mean anyone accessing or using the Product

1.2. The Company may change this PP from time to time, therefore User should check back periodically. The Company will post a link to any changed PP in the Product. If the Company makes any changes to this PP that materially affect Company's practices with regard to the Personal Data Company previously collected from User, the Company will endeavor to provide User with notice in advance of such change via notification through the Product or email. Company will seek User's prior consent to any material changes, if and where this is required by Applicable Data Protection Laws.

1.3. Any capitalized terms which are not defined herein shall have the meaning assigned to them in the Company’s Terms and Conditions Agreement.

 

2. DATA COLLECTED BY THE COMPANY. The Company may collect and retain the following data:

2.1. Information provided by User voluntarily when using the Product, e.g. the User's contact information User submitted via the Product when registering or otherwise accessing to the Product, including but not limited to User's name, surname, email address, and phone number.

2.2. User's verification codes, password and other authentication and security credential information.

2.3. User’s feedback regarding The Product;

2.4. Any communication between User and Company, e.g., emails, phone conversations, chat sessions.

2.5. Audio recordings of phone calls of individuals communicating with the Product.

2.6. Transcript of all User’s suspicious communications targeted/screened/vetted by the Product

2.7. User’s mobile phone contacts or address book

2.8. User's payment information (e.g. credit card or bank account information)

2.9. In addition, the Company may automatically collect data when User visits, interacts with, or uses the Product, including but not limited to:

2.9.1. Identifiers and information contained in cookies;

2.9.2. Settings preferences and backup information;

2.9.3. Content User has viewed or searched for, page response times, and page interaction information (such as scrolling, clicks, and mouse-overs)

2.9.4. User’s Availability

2.9.5. Network and connection information, such as the Internet protocol (IP) address and information about User's Internet service provider;

2.9.6. Device information, such as, phone model, operating system, application version or time zone setting; settings of the mobile device; encounters with other mobile devices using the Product.

 

3. PERSONAL DATA COLLECTED BY THIRD PARTIES. This PP does not apply to any products, services, websites, links or any other content that are offered by third parties in connection with or as part of the Products. User should check the applicable third-party agreements, and/or other third-party policies. Company does not have any control over such third parties' privacy practices, or the technology used by such third parties in order to collect any personal data. User should thoroughly review such third parties' privacy policies before making any use of such third party's products and services.

 

4. COMPANY'S USE OF PERSONAL DATA.

4.1. The Company may process User's Personal Data to operate, provide, and improve the Product, including but not limited to:

4.1.1. contacting User and communicating with User via the Products or in any other means of communication. ;

4.1.2. sending notices or updates or offers relating to the Product;

4.1.3. providing assistance, notification and support;

4.1.4. fulfilling User requests; meeting contractual or legal obligations;

4.1.5. protecting Users security, e.g. preventing and detecting fraud;

4.1.6. marketing and promoting Company’s Products

4.1.7. internal purposes, e.g. trouble shooting, data analysis, training, testing and statistical purposes.

4.1.8. Claims handling, debt collection and legal processes;

4.2. Except as provided herein, the Company does not use any Personal Data other than as necessary to provide the Products, without obtaining User’s prior consent.

 

5. COOKIES AND THIRD-PARTY PRODUCTS.

5.1. The Company may use tracking mechanisms such as cookies in order to provide the Product. A cookie is a small text file that is stored on a User’s computer for record keeping purposes which contains information about that User. Most browsers automatically accept cookies, but User may be able to modify its browser settings to decline cookies. Please note that if User declines or deletes these cookies, some parts of the Product may not work properly.

5.2. This PP does not apply to any products, services, websites, links or any other content that may be offered by third parties on the Products. By clicking on a link to a third party website or service on the Products, a third party may also transmit cookies to User. This PP does not cover the use of cookies by any third parties, and the Company is not responsible for such third parties' privacy policies and practices. The Company does not have any control over any third parties' privacy practices, or the technology used by any third parties in order to collect any Personal Data. Each User is advised to thoroughly review such third parties' privacy policies before making any use of such third party's products and services.

5.3. Without derogating from the generality of the above, when clicking on certain social media links provided on the Products (e.g. Instagram, Twitter, Facebook, LinkedIn) User will be transferred to Company's sites on such social media ("Social Media Sites"). It shall hereby be clarified that such Social Media Sites are governed by the terms of use and privacy policy of the respective social media and not by the Company.

 

6. SHARING PERSONAL DATA OF USER.

6.1. The Company may be required to retain or disclose, without notification, Personal Data, any communications sent or received by each User, and any other information that Company has collected and/or was provided with, in order to:

6.1.1. Provide User with the Products;

6.1.2. To verify the information obtained by Company;

6.1.3. comply with applicable laws or regulations;

6.1.4. comply with a court order, subpoena or other legal process;

6.1.5. respond to a lawful request by a government authority, law enforcement agency or similar government body (whether situated in User's jurisdiction or elsewhere);

6.1.6. engage with third-party service providers and/or sub-contractors which provide services for the Company's business operations, a list of which can be received upon request;

6.1.7. disclose and/or transfer data to another entity if the Company is acquired by or merged with another entity, if the Company sells or transfer a business unit or assets to another entity, as part of a bankruptcy proceeding, or as part of any other similar business transfer;

6.1.8. The Company believes release is appropriate to comply with the law, enforce or apply the Company's terms and other agreements, or protect the rights, property, or security of the Company, Users, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction.

6.2. When the Company shares User's data with third parties as specified above, the Company makes reasonable efforts to require such recipients to agree to only use the Personal Data the Company shares with them in accordance with this PP and the Company's contractual specifications and for no other purpose than those determined by the Company in line with this PP.

 

7. SECURITY. The Company has taken appropriate technical and organizational measures to protect the information the Company collects about User from loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. User should be aware, however, that no data security measures can guarantee 100% security.

 

8. ACCESS TO INFORMATION.

8.1. Depending on Applicable Data Protection Laws, User may be entitled to request access and/or deletion of User's data held by the Company. If applicable in accordance with the relevant Applicable Data Protection Laws, User can send User’s request to the Company at Privacy@lifesgenie.com.

8.2. The Company will take reasonable steps to verify User's identity before granting User access or making corrections. Also, User’s request for access might be subject to a fee to meet the Company's costs in providing User with details of User’s data held by the Company.

8.3. If at all, the Company will retain Personal Data only for the time required for the provision of the Product under the Terms and Conditions subject to Applicable Data Protection Laws, and the Company will securely destroy such information thereafter.

 

9. USERS IN CALIFORNIA, USA.

9.1. The Company will at all times comply with all Applicable Data Protection Laws (including the CCPA) and only process Personal Data on User's behalf.

9.2. The Company will (i) not collect, retain, use, or disclose Personal Data for any purpose other than for the specific purposes set out in the Company terms of use; (ii) not sell Personal Data (as defined under the CCPA); and (iii) put in place appropriate technical and organizational measures to protect Personal Data against unauthorized or unlawful processing or accidental destruction, loss or damage.

 

10. INTERNATIONAL STORAGE. Each User is advised to be aware that Personal Data the Company collects may be transferred to, processed and stored outside User's jurisdiction, and that Data Protection Laws in the jurisdiction where the information is collected stored and/or processed may differ from User's jurisdiction. Each User hereby gives User's consent to this transfer, processing, and storage of User's information outside its jurisdiction.

 

11. CHILDREN'S PRIVACY. The Product is not intended for children. The Company does not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow such persons to register for the Products. In the event that the Company learns that it has collected Personal Data from a child under the age of 18 without consent from a parent or a guardian, the Company will delete that Personal Data as quickly as possible. If User believes that the Company might have any information from or about a child under 18, User should contact the Company at Privacy@lifesgenie.com.

 

12. QUESTIONS REGARDING USER'S PERSONAL DATA? If User has any questions about this PP or the Company's privacy and/or data protection practices in general, please contact us using the following information:

 

LifeLee Ltd.

 

Email: Privacy@lifesgenie.com

 

Last update: August 31, 2022.