YOUR PRIVACY IS IMPORTANT TO US
In this policy, the “Company”, “we”, “us”, “our” means Lukka, Inc. “You”, “your” or “yours” means the persons or entities to whom this policy applies, including, without limitation, a “Customer” of our Services, which is an individual or entity who has entered into a Services Agreement for use of our Services or an individual or entity added as a user to an account provided under a valid Services Agreement. Customers of our Services are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals with whom our Customers interact. If you are an individual who interacts with a Customer using our Services, then you will be directed to contact our Customer for assistance with any requests or questions relating to your personal information. The use of personal information collected through our Service shall be limited to the purpose of providing the Service for which the Customer has engaged.
The security of your personal data is important to us. The Company has in place safeguards to protect the personal data stored with us. This policy describes how we may collect, use, disclose, process and manage your personal data.
This policy applies to any individual’s personal data which is in our possession or under our control.
1 What personal data we collect
“Personal data” is data that can be used to identify a natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, email address, an identification number, location data, and online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity.
Some examples of personal data that we may collect are:
- personal particulars (e.g. name, contact details, residential address, date of birth, identity card/passport details, and/or education details)
- financial details (e.g. income, expenses, and/or credit history);
- images and voice recordings of our conversations with you;
- employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits);
- tax and insurance information;
- information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets;
- financial transactions;
- banking information (e.g. account numbers and banking transactions); and/or
- personal opinions made known to us (e.g. feedback or responses to surveys).
2 Usage of your personal data
We may use your personal data for our core business purposes, such as:
- developing and providing facilities, products or services (whether made available by us or through us);
- transactions and clearing or reporting on these transactions;
- carrying out research, planning and statistical analysis;
- creating analytics for the purposes of developing or improving our products, services, security, service quality, and advertising strategies;
- assessing and processing applications, instructions or requests from you or our Customers;
- communicating with you, including providing you with updates on changes to products, services and banking facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and banking facilities and their terms and conditions;
- managing our infrastructure and business operations and complying with internal policies and procedures;
- responding to queries or feedback;
- addressing or investigating any complaints, claims or disputes;
- verifying your identity for the purposes of providing facilities, products or services;
- conducting credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive;
- complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
- enforcing obligations owed to us;
- monitoring products and services provided by or made available through us;
- complying with obligations and requirements imposed by us from time to time by any credit bureau or credit information sharing services of which we are a member or subscriber;
- creating and maintaining credit and risk related models;
- financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
- enabling any actual or proposed assignee or transferee, participant or sub-participant of the Company’s rights or obligations to evaluate any proposed transaction;
- enforcing obligations owed to us; and/or
- seeking professional advice, including legal advice.
We may also use personal data for purposes set out in the terms and conditions that govern our relationship with you or our Customers generally.
3 Use of personal data for marketing purposes
We may use your personal data to offer you products or services, including special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes, including, but not limited to, electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. In doing so, we will comply with the Gramm Leach Bliley Act of the United States (the “GLBA”) and other applicable data protection and privacy laws.
You may at any time request that we stop contacting you for marketing purposes via selected or all modes.
To find out more on how you can change the way we use your personal data for marketing purposes, please contact us.
Nothing in this section shall vary or supersede the terms and conditions that govern our relationship with you.
4 Disclosure and sharing of personal data
We may from time to time and in compliance with all applicable laws on data privacy, disclose your personal data to any personnel of the Company or to third parties, whether located in New York or elsewhere, in order to carry out the purposes set out above. Please be assured that when we disclose your personal data to such parties, we require them to ensure that any personal data disclosed to them are kept confidential and secure.
For more information about the third parties with whom we share your personal data, you may, where appropriate, wish to refer to the agreement(s) and/or terms and conditions that govern our relationship with you or our Customers generally. You may also contact us for more information (please see the “How to contact us” section below).
We wish to emphasize that the Company does not sell personal data to any third parties and we shall remain fully compliant of any duty or obligation of confidentiality imposed on us under the applicable agreement(s) and/or terms and conditions that govern our relationship with you or our Customers generally or any applicable law.
If you live outside of the United States, you understand and agree that we may transfer your information to the United States. Our websites are subject to United States laws. United States laws may not afford the same level of protection as those in your country. If you are located in the European Economic Area and you contact us, information you provide is transferred to the United States.
5 Standard security measures
We use standard security measures to secure your personal information. We encourage you to use caution when using the Internet. This includes not sharing your passwords. We cannot promise that your use of our site will be completely safe. You use our sites at your own risk.
6 Cookies and related technologies
You may set up your web browser to block cookies from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies you may not be able to use certain features and functions of our websites.
7 Other websites
8 Retention of personal data
Your personal data is retained as long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes.
9 Access and correction
You may request access or make corrections to your personal data held by the Company. The Company may charge a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.
Please contact us (please see the “How to contact us” section below) for details on how you may request such access or corrections.
10 Access by children
Our websites are meant for adults. Please note that we do not knowingly collect any personally identifiable information from children under 13 without permission from a parent or guardian. We reserve the right to limit participation in particular programs or promotions to adults. If you are a parent or legal guardian and think your child under 13 has given us information, you can contact us (please see the “How to contact us” section below). Please mark your inquiries “COPPA Information Request.”
11 How to contact us
To contact us on any aspect of this policy or your personal data or to provide any feedback that you may have, please contact us at [email protected] or by visiting our web page at https://www.lukka.tech.
We may amend this policy from time to time to ensure that this policy is consistent with any developments to the way the Company uses your personal data or any changes to the laws and regulations applicable to the Company. We will make available the updated policy on our websites. All communications, transactions and dealings with us shall be subject to the latest version of this policy in force at the time.