LIVORA DIGITAL LTD
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Privacy Policy

Last updated: 1 January 2024

1. Introduction and Who We Are

LIVORA DIGITAL LTD ("LIVORA", "we", "us", "our") is a company registered in England and Wales. Our registered office is at 5 Brayford Square, London, E1 0SG, United Kingdom. We are a media technology, digital marketing and software development practice providing specialist services to businesses operating in the United Kingdom and internationally.

We are committed to protecting the personal data of all individuals who interact with our business, including visitors to our website at livora.ink, prospective clients who submit enquiries through our contact form, current and former clients, suppliers, contractors and other business contacts.

This Privacy Policy explains how we collect, use, store, share and protect personal data. It also sets out your rights under applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR), as retained and amended in UK law by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019, and the Data Protection Act 2018.

Please read this Privacy Policy carefully. By using our website or engaging with our services, you acknowledge that you have read and understood how we process your personal data as described in this document.

2. Data Controller Information

For the purposes of UK data protection legislation, LIVORA DIGITAL LTD is the data controller in respect of the personal data described in this Privacy Policy. This means we are responsible for determining the purposes and means by which personal data is processed.

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or would like to raise a concern about how we have handled your personal data, please contact us at:

  • Email: office@livora.ink
  • Telephone: +44 7911 123456
  • Post: LIVORA DIGITAL LTD, 5 Brayford Square, London, E1 0SG, United Kingdom

3. Personal Data We Collect

We collect personal data in several ways, depending on your relationship with LIVORA and how you interact with us. The categories of personal data we may collect include:

3.1 Data You Provide Directly

When you submit a contact form on our website, request a balance check or balance proposal, enter into a service agreement with us, or correspond with us by email or telephone, we may collect:

  • Full name and job title or professional role
  • Email address
  • Telephone number
  • Company or organisation name and address
  • The content of any message, enquiry or description of your digital environment that you share with us
  • Any additional personal or professional information you choose to include in communications with us

3.2 Data Collected Automatically

When you visit our website at livora.ink, we and our third-party service providers may automatically collect certain technical and usage data, including:

  • Your IP address and approximate geographic location derived from it
  • Browser type, version and operating system
  • Device type and screen resolution
  • The pages you visit on our website and the duration of your visit
  • Referring website or search query that brought you to our site
  • Date and time of access
  • Technical performance data relating to your browsing session

This data is collected through cookies and similar tracking technologies as described in our Cookie Policy, which is available at cookie-policy.html.

3.3 Data from Third Parties

In the course of providing services, we may receive personal data about individuals from our clients. In such cases, we process this data as a data processor acting on the instructions of our clients, who are the relevant data controllers. We may also receive professional information about business contacts from publicly available sources such as LinkedIn and company websites.

4. How We Use Your Personal Data

We use the personal data we collect for the following purposes, each of which is supported by a lawful basis under UK GDPR:

4.1 To Respond to Enquiries and Balance Requests

When you submit a contact form or enquiry, we use your name, email address and the content of your message to assess your requirements, prepare an appropriate response and follow up on your enquiry. The lawful basis for this processing is our legitimate interests in managing business relationships and providing information about our services, or in some cases, taking steps at your request prior to entering into a contract.

4.2 To Provide and Manage Our Services

When you engage LIVORA under a service agreement, we use your personal and organisational data to deliver the services agreed, communicate about project progress, issue invoices and manage the commercial relationship. The lawful basis for this processing is the performance of a contract to which you or your organisation are a party.

4.3 To Operate and Improve Our Website

We use technical and usage data collected from website visitors to monitor website performance, diagnose technical issues and improve the functionality and user experience of livora.ink. The lawful basis for this processing is our legitimate interests in maintaining a functioning and effective website.

4.4 To Send Service-Related Communications

We may send you communications directly related to services you have requested, including project updates, reports, invoices and other service administration communications. The lawful basis for this processing is the performance of a contract or, in pre-contractual situations, our legitimate interests.

4.5 To Send Marketing Communications

Where you have provided explicit consent, or where we have an existing business relationship with you and you have not objected to receiving such communications, we may send you information about LIVORA's services, industry insights and company updates. The lawful basis for such processing is either your consent or our legitimate interests, subject always to your right to object or withdraw consent at any time. You may opt out of marketing communications at any time by contacting us at office@livora.ink.

4.6 To Comply with Legal Obligations

We may be required to process personal data to comply with applicable legal and regulatory obligations, including financial record-keeping requirements, obligations under the Companies Act 2006 and responses to lawful requests from regulatory authorities or law enforcement. The lawful basis for this processing is compliance with a legal obligation.

4.7 To Protect Our Legal Rights and Interests

We may process personal data where it is necessary for the purpose of establishing, exercising or defending legal claims or where processing is necessary to protect the vital interests of any individual. The lawful basis for this processing is our legitimate interests or, where applicable, legal obligation.

5. How We Share Your Personal Data

We do not sell personal data to third parties. We share personal data only in the following circumstances and only to the extent necessary for the stated purpose:

5.1 Service Providers and Processors

We engage a limited number of carefully selected third-party service providers who process personal data on our behalf and in accordance with our instructions. These include:

  • Cloud infrastructure and hosting providers who host our website and data storage systems
  • Email and communication platform providers
  • Accounting and financial software providers for invoicing and record-keeping
  • Analytics service providers who help us understand website usage
  • Project management software providers used to coordinate client work

All such providers are required to maintain appropriate technical and organisational security measures and are prohibited from using personal data for any purpose other than providing services to LIVORA.

5.2 Professional Advisers

We may share personal data with our legal, financial and accounting advisers where disclosure is necessary for the provision of professional advice to LIVORA, including in connection with any dispute, legal claim or regulatory investigation.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of LIVORA's business, personal data may be transferred to the relevant acquiring or successor entity. Where such a transfer is planned, we will inform affected individuals in advance where practically possible and where required by law.

5.4 Legal and Regulatory Requirements

We may disclose personal data to law enforcement agencies, regulatory bodies, courts or other public authorities where we are required to do so by applicable law, court order or legal process, or where we believe in good faith that disclosure is necessary to protect the rights, property or safety of LIVORA, our clients or others.

6. International Data Transfers

LIVORA is based in the United Kingdom. Some of our service providers may process personal data in countries outside the United Kingdom. Where such transfers occur, we take steps to ensure that appropriate safeguards are in place to protect the personal data transferred, in accordance with UK GDPR requirements. These safeguards may include the use of International Data Transfer Agreements (IDTAs) or reliance on adequacy decisions made by the UK Government in respect of certain countries.

For further information about the specific safeguards applicable to transfers of your personal data, please contact us at office@livora.ink.

7. Data Retention

We retain personal data for as long as is necessary for the purposes for which it was collected and as required by applicable law. Our general retention periods are as follows:

  • Contact and enquiry data: retained for a period of two years from the date of the last meaningful interaction, unless the enquiry progresses to a client relationship
  • Client data relating to active and completed service agreements: retained for a period of seven years from the end of the contractual relationship, to comply with financial record-keeping obligations and to address any legal claims that may arise
  • Website analytics data: retained in accordance with the settings of the relevant analytics platform, typically for a period of up to twenty-six months
  • Marketing communication records: retained until you withdraw consent or successfully opt out, plus a reasonable period to document compliance

At the expiry of the applicable retention period, personal data is securely deleted or anonymised. Where anonymisation is not technically feasible, the data is securely destroyed.

8. Data Security

We implement and maintain appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures include:

  • Encryption of data in transit and, where appropriate, at rest
  • Access controls limiting personal data access to authorised personnel on a need-to-know basis
  • Regular review of our information security practices and those of our third-party providers
  • Staff training on data protection responsibilities
  • Procedures for detecting, assessing and reporting personal data breaches in accordance with UK GDPR requirements

While we take reasonable steps to protect your personal data, no security system is completely impenetrable. We cannot guarantee the absolute security of data transmitted over the internet. You transmit personal data to us at your own risk.

9. Your Rights Under UK GDPR

You have the following rights in respect of your personal data under UK GDPR. These rights are subject to certain conditions and limitations set out in applicable law:

9.1 Right of Access

You have the right to request a copy of the personal data we hold about you. We will respond to such requests within one calendar month of receipt, or notify you if an extension of this period is required.

9.2 Right to Rectification

You have the right to request that we correct any inaccurate personal data we hold about you or complete any incomplete personal data, without undue delay.

9.3 Right to Erasure

In certain circumstances, you have the right to request that we erase your personal data. This right applies where, for example, the data is no longer necessary for the purpose for which it was collected, you withdraw consent and there is no other lawful basis for processing, or the data has been processed unlawfully.

9.4 Right to Restrict Processing

You have the right to request that we restrict the processing of your personal data in certain circumstances, for example where you contest the accuracy of the data or where you have objected to processing and we are assessing your objection.

9.5 Right to Data Portability

Where processing is based on your consent or a contract and carried out by automated means, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have it transmitted to another controller where technically feasible.

9.6 Right to Object

You have the right to object to processing of your personal data where that processing is based on our legitimate interests. You also have the right to object to processing of your personal data for direct marketing purposes at any time, without the need to provide any reason.

9.7 Rights in Relation to Automated Decision-Making

We do not engage in automated decision-making or profiling that produces legal or similarly significant effects on individuals.

9.8 Exercising Your Rights

To exercise any of the rights listed above, please contact us at office@livora.ink with a clear description of your request. We may need to verify your identity before processing your request. We will respond without undue delay and within the timeframes required by UK GDPR. We will not charge a fee for processing your request unless the request is manifestly unfounded or excessive.

10. Cookies

Our website uses cookies and similar tracking technologies. For full details of the cookies we use, the purposes for which they are used and your choices in relation to them, please see our Cookie Policy at cookie-policy.html.

11. Third-Party Links and Services

Our website may contain links to third-party websites or services. This Privacy Policy applies only to our website and services. We have no control over and accept no responsibility for the privacy practices of any third-party websites or services. We encourage you to review the privacy policies of any third-party sites you visit.

12. Children's Privacy

Our website and services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that personal data has been collected from a child without verifiable parental or guardian consent, we will take steps to delete that information as promptly as possible. If you believe that a child has provided personal data to us, please contact us at office@livora.ink.

13. Complaints and Supervisory Authority

If you are dissatisfied with the way in which we have handled your personal data or responded to your data subject rights request, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the supervisory authority for data protection in the United Kingdom. The ICO can be contacted at:

  • Website: ico.org.uk
  • Telephone: 0303 123 1113
  • Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

We would, however, appreciate the opportunity to address any concern you may have before you contact the ICO, and we encourage you to contact us in the first instance at office@livora.ink.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law or our business operations. When we make material changes, we will update the "Last updated" date at the top of this document and, where appropriate, notify individuals affected by the changes directly. We encourage you to review this Privacy Policy periodically to remain informed about how we handle your personal data.

Continued use of our website or services following the publication of an updated Privacy Policy constitutes your acknowledgement of the updated terms. Where we are required by law to obtain fresh consent for any new processing activity, we will do so.

15. Contact Us

For any questions, concerns or requests relating to this Privacy Policy or our data protection practices, please contact us at:

  • LIVORA DIGITAL LTD
  • 5 Brayford Square, London, E1 0SG, United Kingdom
  • office@livora.ink
  • +44 7911 123456
  • livora.ink
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LIVORA DIGITAL LTD LIVORA DIGITAL

Media technology, digital marketing and software development. London, UK.

office@livora.ink +44 7911 123456
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