Privacy Policy

This privacy policy (this “Policy”) explains how LassWho? uses the personal data we collect from you when you use our Platform as well as information that we may collect offline. LassWho? is the data controller for the personal data collected in connection with use of LassWho?’s Services and Platform.

Unless a contrary indication appears below or in the Glossary, terms and expressions defined in the Terms found on our Platform shall have the same meanings where used in this Policy. Please also review the Terms, which also apply to use of our Platform.

1 What data do we collect?

1.1 LassWho? collects data as follows:

1.1.1 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

(a) Identity Data includes first name, last name, username, date of birth, email or similar identifier.

(b) Contact Data includes delivery address, email address and telephone numbers.

(c) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

(d) Device Data includes the type of mobile device or other device you use.

(e) Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

(f) Usage Data includes information about how you use our Platform, products and services.

(g) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

(h) Location Data includes your current location disclosed by GPS technology once express permissions have been granted as part of operating the LassWho app.

1.1.2 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

1.2 We also collect analytic data through your use of the LassWho app including metrics such as phone type and how often and how you use the service. You may also be required to provide explicit consent for LassWho? to access your photos and camera on your phone and your geolocation.

1.3 LassWho? does not sell user personal data with third parties, except with users’ consent.

2 How do we collect your data?

2.1 We collect data in six main ways. We collect data and process data when you:

2.1.1 Register your interest in signing up to LassWho via lasswho.com.

2.1.2 Register and create an Account for our Platform.

2.1.3 Use and interact with the Platform including but not limited to engaging in Video Chats.

2.1.4 Make a purchase through the Platform.

2.1.5 Contact our customer services through the Platform.

2.1.6 Use social media with the Platform.

3 How will we use your data?

3.1 LassWho? collects your data so that we can:

3.1.1 Verify that you are over 18 years of age and are able to use our Platform.

3.1.2 Verify your identity to keep the Platform safe for all to use.

3.1.3 Share your information with a Speaker or Host who you engaging with.

3.1.4 Allow you to build a profile that makes engaging with Speakers and a Host easier.

3.1.5 Allow Speakers and Hosts to message.

3.1.6 Send reminders, updates, feedback, push notifications, comments and email notifications relating to speaking engagements or promotions.

3.1.7 Perform analytics on usage of the Platform to make the Platform even better.

3.1.8 Use rating or review content for marketing the service and Platform.

3.1.9 Provide information to third parties in connection with payment services.

3.1.10 Contact you about administrative matters, such as the applicable Terms.

3.1.11 Assist you in connection with your participation in our Platform, offering and providing Video Chats and other offerings.

3.1.12 Use it for other reasons that we disclose when you provide your information, with your consent, and as described in this Policy.

3.2 LassWho? also collects your data so that we can:

3.2.1 Prevent money laundering, tax evasion and fraud.

3.2.2 Enforce the Terms.

3.2.3 Perform due diligence checks against databases and other information sources, to the extent permitted by applicable laws and with your consent where required.

3.2.4 Comply with our legal obligations.

3.2.5 Use it to assist to resolve any disputes and enforce our agreements.

3.2.6 Enable you to access and use the payment services.

3.3 We have summarised how we will use your data below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a User	(a) Identity(b) Contact	Performance of a contract with you
To process and deliver your engagement including managing payments, fees and charges	(a) Identity(b) Contact (d) Transaction (e)Marketing and Communications	Performance of a contract with you
To manage our relationship with you which will include:(a) Notifying you about changes to our Terms or this Policy (b) Asking you to leave a review or take a survey	(a) Identity(b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how Users use our products/services)
To administer and protect our business and the Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity(b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation
To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how Users use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Platform, products/services, marketing, customer relationships and experiences	(a) Technical(b) Usage	Necessary for our legitimate interests (to define types of Users for our products and services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	(a) Identity(b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

3.4 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3.5 We may share your personal data with the parties set out below for the purposes set out in the table above:

3.5.1 Service providers who provide IT and system administration services, ID verification services, payment or other necessary services.

3.5.2 Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

3.5.3 Professional advisers or courts or government agencies where it is necessary to secure or enforce our legal rights.

3.5.4 Third parties when you request that we share your information with them.

3.6 We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law and via data processing agreements. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

4 What are your data protection rights?

4.1 LassWho? would like to make sure you are fully aware of all of your data protection rights. Each user is entitled to the following:

4.1.1 The right to access – You have the right to request LassWho? for copies of your personal data.

4.1.2 The right to rectification – You have the right to request that LassWho? correct any information held in respect of you which you believe is inaccurate. You also have the right to request LassWho? to complete the information you believe is incomplete.

4.1.3 The right to erasure – You have the right to request that LassWho? erase your personal data, under certain conditions.

4.1.4 The right to restrict processing – You have the right to request that LassWho? restrict the processing of your personal data, under certain conditions.

4.1.5 The right to object to processing – You have the right to object to LassWho?’s processing of your personal data, under certain conditions.

4.1.6 The right to data portability – You have the right to request that LassWho? transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

4.1.7 The right to withdraw consent – You may withdraw your consent at any time to LassWho? processing your data. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

4.2 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month for example if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

4.3 If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us via the details below.

5 How do we store your data and for how long?

5.1 Your data is stored securely in encrypted format in a securely hosted database owned by LassWho?. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

5.2 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

5.3 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

5.4 Our Platform is intended for a general audience and not for use by anyone younger than the age of 18. We do not knowingly collect personal information from children younger than the age of 18 without the consent of a parent or legal guardian; if we learn that we have done so, we will promptly remove the information from our active databases. If you are a parent or legal guardian who believes that we have collected or used their child’s personal information, please contact us. If you believe that a child under the age of 18 may have provided us with personal information, please contact us.

6 Billing

6.1 For billing purposes, we require our Users to provide their full name and billing address. Payments by and to LassWho? are made through third party payment providers selected by LassWho?. You should review the payment provider’s privacy policy before providing your personal information, as it is responsible for personal information in its own right, and its privacy practices may vary from ours.

6.2 You can view the privacy policies of our payment processors here:

6.2.1 https://wise.com/gb/legal/privacy-policy-eea;

6.2.2 https://stripe.com/en-in/guides/general-data-protection-regulation;

6.2.3 https://www.paypal.com/en/webapps/mpp/ua/privacy-full; and

6.2.4 https://www.braintreepayments.com/je/legal/braintree-privacy-policy

7 Marketing

7.1 LassWho? would like to send you information about using the Platform that we think you might like and that will help you use LassWho?’s Services.

7.2 Other than rating and review content we will not provide information to any third party for commercial or marketing purposes.

7.3 You have the right to opt out of communications by selecting your communication preferences within the Platform or by contacting us at [email protected].

8 What are cookies?

8.1 Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our Platform or use our Platform, we may collect information from you automatically through cookies or similar technology. You can turn cookies off at any time.

8.2 Small graphic images or web programming code called web beacons, embedded scripts or similar technologies may also be included in our Platform.

9 How do we use cookies?

9.1 We use cookies to:

9.1.1 keep you logged in; and

9.1.2 understand how you use our Platform.

10 What types of cookies do we use?

10.1 There are a number of different types of cookies, however, our Platform uses:

10.1.1 Functionality – LassWho? uses these cookies so that we recognise you on our Platform and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

10.1.2 Advertising – LassWho? uses these cookies to collect information about your visit to our Platform, the content you viewed, the links you followed and information about your browser, device, and your IP address.

11 How to manage your cookies

11.1 You can set your preferences not to accept cookies. However, in a few cases, some of our Platform features may not function as a result.

11.2 We may allow outside companies to display advertisements on LassWho?. These advertisements may contain cookies whose data is collected by external advertising companies.

12 Changes to our privacy policy

12.1 LassWho? keeps its Policy under regular review and places any updates on this web page. This Policy was last updated on 12 March 2021. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Platform or the Services.

12.2 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

13 Data Protection Laws

The data privacy policy of LassWho? is based on the provisions of the Data Protection (Jersey) Law 2018 (“DPJL”). We voluntarily extend the individual’s rights granted under DPJL to apply to all of our Users, worldwide.

14 Miscellaneous

14.1 Whenever you voluntarily post information to the public profile you show on LassWho?, or the public comment areas on the Platform or any other public forums, the information you post can be accessed by the public. We are not responsible for any information that is disclosed publicly through LassWho?.

14.2 We have the right, but no obligation, to monitor the content you post on LassWho?. We reserve the right to remove any such information or material for any reason or no reason, including without limitation if, in our sole opinion, such information or material violates, or may violate, any applicable law or our Terms and Conditions, or to protect or defend our rights or property or those of any third party. We also reserve the right to remove information upon the request of any third party.

14.3 Users subscribing to our services receive service-essential messages at the e-mail address they have provided to us. These messages are strictly limited to communication necessary to use our services. For example, we send new users an automated message with their username and password and send an automated message confirming Users’ purchases, etc.

14.4 To stop receiving promotional communications from LassWho?, click on the “unsubscribe” link in the footer of the promotional email. We may send you email communications relating to your account or use of the Platform even if you have unsubscribed.

15 How to contact us

15.1 If you have any questions about this Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

15.1.1 Email us at: [email protected]

15.1.2 Write to us at: LassWho?, Suite 6, Augres House, 16 Dumaresq Street, St Helier, Jersey, JE2 3RL, Channel Islands.

15.2 You have the right to make a complaint at any time to the Office of the Information Commissioner (“OIC”) in Jersey, the Jersey supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the OIC so please contact us in the first instance:

Jersey Office of the Information Commissioner
Telephone: +44 (0)1534 716530
Email: [email protected]
Address:
Jersey Office of the Information Commissioner
2nd Floor, Castle Street
St Helier Jersey JE2 3BT