Privacy policy
Last updated: January 17, 2024
Welcome to Letpy! We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains what personal data we process, how, why and where we process it, and your rights as the data subject. Please read this Privacy Policy before accessing or using the website located at https://letpy.io (the “Website”).
The Website is owned and operated by Kotov Labs Siarhei Kotau, in accordance with the laws of the Republic of Poland. Any reference in this Privacy Policy to “user,” “you,” or “your” refers to you, an individual who registers a user account and makes use of the Platform, and all references to the “Company,” “Kotov Labs,” “we,” “us,” or “our” refer to Kotov Labs Siarhei Kotau.
The Website and all resources, materials, and services available therein are hereinafter collectively referred to as “Service,” the “Platform,” or “Letpy”. By accessing or using the Platform, you represent that you have read this Privacy Policy and agree to be bound by it. Please do not use the Platform if you do not agree with our privacy practices as outlined in this Privacy Policy.
1. Scope
This Privacy Policy applies to the personal data we process when you access/use our Platform.
2. Definitions
Any reference to “controller”, “data subject”, “personal data”, and “processing” in this Privacy Policy shall have the same meaning as specified in EU General Data Protection Regulation 2016/679 (“GDPR”).
3. Controller
The Company is the controller of all the personal data collected during your access/use of the Platform. You can write to us at:
Kotov Labs Siarhei Kotau
Gliniana 52A, 91-336 Łódź,
Poland
Email: privacy@letpy.io
4. What personal data do we collect from you?
The information we collect from you includes the following:
- Email address;
- Password;
- Full name;
- Profile photo;
- Country;
- All communication you have with the Company;
- Your User Content (as defined in our Terms of Use);
- Information that you provide us when you participate in our surveys or promotions;
- Your log data, including your browser type, time and pages you visit, your IP address, etc.; and
- Device data, including the mode and make of your device, operating system, and unique device identifiers.
5. How do we collect and use your information?
5.1. Platform visitors’ data
When you visit our Platform, we may collect and retain your IP address for purposes including but not limited to determining your country, providing our Service, recording your preferences to personalise and improve your user experience and for our internal statistics. We may also collect some anonymous usage data, such as the pages the visitor visited, the duration of their stay, their device and browser type for our internal business analysis (“Platform visitors’ data”).
Legal basis
Our legal basis for processing the Platform visitors’ data is our legitimate interest to secure and improve the performance of our Platform.
5.2. Account Registration Data
When you sign-up for a user account and complete your profile, we collect personal data you voluntarily provide us, including your full name, email address, password and profile photo ('Account Registration Data').
We use your Account Registration Data for the following purposes:
- To create your user account and enable you to securely sign in;
- To verify your user account and help with recovering your lost password;
- To enable you to use the Platform;
- To communicate with you as and when required; and
- To serve relevant content to you.
Legal basis
Our legal basis for processing the account registration data includes the performance of our contract.
5.3. User Content Data
When you create your user profile and participate in the social forum on the Platform, we collect the information contained in your User Content.
We use this information for the following purposes:
- To publicly display your profile and contribution to other users in the social forum;
- To enable you to use the Service efficiently;
- To detect and prevent any unauthorised activities on the Platform.
Legal basis
When you post your User Content on the Platform, we rely on our legitimate interest as the legal basis for processing your personal data.
5.4. Communication Data
We process your personal data when we communicate with you through email.
We use this information to:
- Respond to your inquiries and offer customer support services; and
- Send you system-related updates and other important notices about our Services.
Legal basis
When you send us an email enquiry or when we send you system-related information, we rely on our legitimate interest as the legal basis for processing your personal data.
When you opt-in to receive marketing communication from us, we rely on your consent as the legal basis for processing.
5.5. Participation Data
We collect your personal data when you subscribe to receive marketing material from us, such as your name and email address or any personal data you provide when participating in our surveys/promotions.
We use this information to:
- Send you marketing material that we think you will find interesting;
- Create new Service offerings or improve our existing Services;
- Fulfil any other purpose specified at the time we collect your information.
Legal basis
Your consent is our legal basis for processing your personal data when you participate in our surveys and promotions.
5.6. Cookies
We collect some data through cookies, pixels, and tags when you visit our Platform. We use cookies to improve our understanding of how you interact with our Website and your user experience. Please note that we only use cookies with your consent except for strictly necessary cookies that do not require your consent (ePrivacy Directive 2002/58 EC).
You can decline cookies from our Website by clicking the decline button in the cookie banner on the Website or changing your browser settings to decline all third-party cookies.
Legal basis
Your consent is our legal basis for processing any personal data we receive through the use of cookies.
6. Retention of personal data
We do not retain our users’ personal data for longer than required for the initial purpose for which we collected it, and we will delete all your personal data within six months of the date of your user account termination. We may retain any user data by anonymising it so it cannot be linked back to an individual.
7. Disclosure and transfer of personal data
We respect our users’ personal data and do not engage in the practice of selling or renting our users’ personal data. We only disclose/share our users’ personal data as described hereunder:
7.1. Third-Party Service Providers
We may disclose your personal data to third-party service providers (“Service Providers”) who help us with the performance of our business operations, such as emailing tools, analytics, marketing, customer support, and other purposes for which your personal data is processed as described in Section 4 of this Privacy Policy.
7.2. Change of Ownership
If in the future, we enter into any sale/purchase negotiations or transactions with another business, our users’ personal data may be disclosed to such other businesses as part of negotiations and due diligence. If any commercial transaction results in a change in ownership of the Company, the personal data we process may be transferred to the new entity as part of the commercial transaction. Please note that in the aforementioned scenarios, your personal data will continue to be governed by this Privacy Policy, except in cases where you expressly consent otherwise.
7.3. To protect ourselves or our users
We may be required to disclose your personal data to law enforcement authorities and other government bodies to comply with the law, to enforce our Agreement with you, to defend ourselves in legal actions or to protect our users or others from threats posed by your actions by sharing your personal data with other organisations as part of fraud protection.
7.4. Lawful requests
If we receive a lawful request for your personal data from any law enforcement authorities or courts of law with jurisdiction over the Company, we will only disclose your personal data where we are legally obliged to provide it.
Your personal data may be transferred and processed outside of the country where you reside. If your personal data is transferred and processed in a jurisdiction that is not deemed adequate by the European Commission, we will only transfer your personal data to our Service Providers pursuant to appropriate Standard Contractual Clauses as required by the GDPR.
8. Security of data
Our Platform is designed with the security of personal data in mind. We collect limited personal data, which reduces the risk and impact of data breaches on our users. We have also implemented appropriate organisational and technical security protocols to prevent any unauthorised access or deletion of your personal data. We use encryption protocols and periodic data audits to ensure the security of the personal data we process. We also restrict access to personal data within our Company on a need-to-know basis to prevent unauthorised access. All user accounts are password-protected, and we restrict the use of an account by multiple users. We have also adopted data security policies in line with the industry’s best practices.
Despite all our efforts to ensure the security of your personal data, you acknowledge that data transmission over the internet is never one hundred percent secure. Thus, we cannot offer any guarantees regarding the absolute security of your personal data. You acknowledge that the transmission of your personal data during the use of our Platform is at your own risk.
9. Data subject rights
If you reside in the European Economic Area (EEA), you have the following rights as a data subject:
9.1. Right to access your personal data that we process
You have the right to request access to your personal data or a copy of your personal data that we process by contacting us at privacy@letpy.io. We will verify that you are the account holder before processing your data access request to prevent unauthorised access to your personal data.
9.2. Right to rectification of any incorrect or incomplete personal data
You can easily rectify your personal data by logging into your user account and accessing the settings.
9.3. Right to object to the processing of your personal data
In certain circumstances, you have the right to object to our processing of your personal data or request that we restrict processing your personal data by contacting us at privacy@letpy.io.
9.4. Right to request deletion of your personal data
You may request the deletion of your user account and associated personal data by contacting us at privacy@letpy.io. Please note that we will verify that you are the account holder before deleting your user account and related personal data. You understand that even after the deletion of your account, we may be required to retain some of your personal data on other lawful grounds, including compliance with our legal obligations.
9.5. Right to withdraw your consent
To the extent the legal basis of our processing of your personal data is your consent, you have the right to withdraw your consent at any time. You can opt out of receiving marketing communication from us by clicking the “unsubscribe” link at the bottom of our marketing emails. You can also block the use of our cookies to which you previously consented by accessing your browser settings.
9.6. Right to complain to a data protection authority
Individuals in the EEA have the right to file a complaint against any infringement of their data rights with their local data protection authority.
10. Children’s Privacy
We are committed to protecting children’s privacy. We do not allow users under the age of 18 years to sign up for a user account. Persons under the age of 18 years are strictly prohibited from submitting any personal data. If you have information that a child has provided his/her personal data to us, please contact us, and we will investigate the matter and take appropriate action to remove such information.
11. Do Not Track “DNT”
We currently do not respond to DNT signals.
12. Third-party links
Our Platform may contain links to third-party sites that are not owned or operated by us. Should you decide to click on any such third-party links, you will be directed to such a third party’s website. These third-party websites are governed by their own Terms and Conditions and Privacy Policy. We encourage our users to review the third-party Terms and Privacy Policy before using their services. The presence of any third-party links on our Website does not constitute an endorsement or recommendation of such a third party, and we cannot be held responsible for such a third party’s actions.
13. Amendments
From time to time, we may amend this Privacy Policy to reflect our new privacy practices and commitment to compliance with applicable privacy laws and regulations. We will post the updated Privacy Policy on this page and notify you of such updates by changing the last updated date on the top or by sending an email (if required by law). You should review this Privacy Policy regularly to ensure that you are familiar with any changes. You understand and accept that your continued use of the App after the updates become effective will be deemed as acceptance of such updated privacy practices.