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プライバシーポリシー

 

VALID AS OF 1 JANUARY 2021

This Privacy Policy tells you how we collect, use and disclose your Personal Data while you browse https://www.lepeto.com as well as when you interact with our different platforms.

For the purposes of this Privacy Policy, “Personal Data” means all data which is defined to be “personal data” or equivalent under applicable data protection laws, and all information the collection, use, disclosure or processing of which is subject to applicable data protection laws.

This Privacy Policy provides information on:

  • The different types of Personal Data we use (“Categories of Personal Data”)
  • The purposes of using your Personal Data;
  • Recipients of your Personal Data (“Data Recipients”);
  • How do we secure your Personal Data;
  • Your rights.

The Privacy Policy also does not affect any rights which we may have at law in connection with the collection, use and disclosure of your Personal Data.

Categories of Personal Data

These are the categories of Personal Data we collect directly or indirectly from you.

  1. Identity information - includes: name [first, last, initials], e-mail address, unique consumer identifier number (including your Lepeto Club membership number), password, social media identifiers and information passed along to us via your Facebook account and gift card codes that are assigned to you. We use it to verify your identity.
  2. Contact information - includes: your phone number, shipping and billing address, e-mail address, Messenger ID, social media handle, any other communication channel you have used to contact us for more information. We use it to contact you for different reasons depending on the purposes stated below.
  3. Location information - includes: your residential location, current log-in location [IP address], GPS location (if you wish to share us, for example through your mobile device settings), or the specific Lepeto site you have visited that might give us clues about where you are. We use it to help you find what you are looking for at your current location.
  4. Purchase information - includes: your payment information (credit card number), payment risk profile (provided to us by our payment risk solution), shopping cart (your ordered items), delivery details, shipping and billing address, customer order number, purchase history with Lepeto, transaction ID, and any other information related to your purchase. We use it to complete your order on Lepeto sites or other selling platforms.
  5. Behavioral and Profile information - includes: your shopping history, Wishlist items, your browsing behavior, your browsing preferences, your shopping preferences, in-store interactions, product reviews, social media interactions with us, and any other intelligence we have about you to help us learn you as a consumer better, including “Community information”. We use it to know you better as a consumer, so we can send you marketing messages containing only products and services that we think you might be interested in.
  6. Community information - includes: information provided by you when you participate in various Lepeto events and communities either as a participant or as a promotor of our events, including for example: pictures, videos, your nickname, your interests and preferences, your feedback, event participation, joined groups, and registration details. We use this information to organize the events and communities, and to know more about you as a consumer.
  7. Social Media information - includes: information obtained through your interaction with us on various social media channels such as Facebook, Instagram, Google, etc., including: any social media information that is publicly available such as your social media handles, social media interactions and public postings, your “Likes” and other reactions, your social media connections, your photos that are public, or those you send to us by mentioning us or following our social media posts by using “handles” or “hashtags”. We obtain this information from the social media network (e.g. Facebook, Snapchat, Instagram, etc.) directly or indirectly through third-party agencies we have agreements with.
  8. Device information - includes: Information about your browser that gives us an idea about your browsing behavior or device usage. Your browser information is collected by our cookies, tags, and pixels. This is often required for network security purposes. This includes, but not limited to: IP address, date and time of the visit, how long you remained on our website, the referral URL (if you came to our site via a different site or an advertisement), the pages visited on our site, your browser type, device type, versions, operating system.
  9. Correspondence - includes: the conversation we have when you contact customer service, the emails you write us about our products, the complaints you address to us via post, e-mail, fax, or call, notes we prepared on your feedback, call back from our Customer Service to you, and any other communication between you and Lepeto personnel. We record all Customer Service calls for quality assurance purposes.
  10. Preference information - includes: preferred language, log-in location, Wishlist items, preferred shipping address, browsing preferences, our correspondence with you, your Lepeto product reviews. We use it to give you convenience when you visit and/or shop on our sites.
  11. Lepeto Club information - includes: Unique Member Identifier (member ID) and date you became a member. All the information listed here will be kept for as long as you are a Lepeto Club

The Purposes for Using Your Personal Data

These are the categories of Personal Data we collect directly or indirectly from you. 

 Purpose

1. Site (Lepeto Domain) Operation

2. Domain And Network Security And User Authentication

3. Global Credential To All Lepeto Platforms – User Experience

4. Sales Of Lepeto Products

5. Payment Fraud Detection

6. Product Delivery

7. Electronic Delivery Tracking

8. Business Operational Analytics

9. Customer Service

10. Personalised Marketing Messages Via Email (Newsletter Sign-Up And Existing Contract)

11. Targeted Messages On 3rd-Party Advertising Platforms

12. Lepeto Club Membership Administration - Where Applicable

13. Private Event Registration

14. Open Event Registration

15. Product Research And Development

16. Legal Obligation - Cooperation With Law Enforcement And Regulatory Authorities (Including Courts)

17. Collecting Your Device Information On Our Website Using Cookies, Pixels, Tags, And Similar Technologies ("Cookies Notice")

18. User-Generated Content (UGC) Acquisition From Social Media

 In this section, we explain:

  • When and why do we need your Personal Data (“Purpose”)?
  • What do we do to your Personal Data for each Purpose (“Processing”)?
  • Which of your Personal Data do we need for each Purpose (“Categories of Personal Data”)?
  • With whom (types of service providers) do we share your Personal Data to achieve the purpose (“Data Recipients”)?
1. SITE (LEPETO DOMAIN) OPERATION AND APP OPERATION

    PROCESSING

    To run the sites that are connected to the Lepeto domain, fix bugs to make sure you always see the site the way we intended, and monitor compliance with our Terms and Conditions, we screen all traffic to our site and analyze data that is received by our servers.

    Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels and tags to collect your device information.

    More information is available in “17. COLLECTING YOUR DEVICE INFORMATION ON OUR WEBSITE USING COOKIES, PIXELS, TAGS, AND SIMILAR TECHNOLOGIES”.

    CATEGORIES OF PERSONAL DETAILS

    Device information

    Identity information

    Behavioral and Profile information

    Preference information

    DATA RECIPIENTS

    Lepeto

    Site Administration Support Providers

    2. DOMAIN AND NETWORK SECURITY AND USER AUTHENTICATION

    PROCESSING

    To protect our domains, detect unusual activities, and prevent security threats and protect our site-visitors from unauthorized accesses (such as hackers), we screen all traffic to our sites, and authenticate user log-in information using tokens to verify the details you provide to us and compare it with other available information, such as the credentials you have provided directly to Lepeto or other platforms (such as Facebook) or information that is available in the public domain to ensure only “authorized” users have access to our sites.  

    Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels and tags to collect your device information.

    More information is available in “17. COLLECTING YOUR DEVICE INFORMATION ON OUR WEBSITE USING COOKIES, PIXELS, TAGS, AND SIMILAR TECHNOLOGIES”.

    CATEGORIES OF PERSONAL DETAILS

    Device information

    Identity information

    Behavioral and Profile information

    Preference information

    DATA RECIPIENTS

    Lepeto

    Site Administration Support Providers

    3. GLOBAL CREDENTIAL TO ALL LEPETO PLATFORMS - USER EXPERIENCE

    PROCESSING

    We know you don’t like to remember usernames and passwords, or having to register multiple times.

    To enable our users to log on to all platforms and communities operated by or on behalf of Lepeto, we store your Lepeto Log-In in our global authentication platform. When you use your Lepeto Log-In to enter any Lepeto Platform, we will use a token to verify your identity from our global authentication platform. This also further ensures our network and domain security.

    Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels and tags to collect your device information.

    More information is available in “17. COLLECTING YOUR DEVICE INFORMATION ON OUR WEBSITE USING COOKIES, PIXELS, TAGS, AND SIMILAR TECHNOLOGIES”.

    CATEGORIES OF PERSONAL DETAILS

    Identity information (username, password, email)

    Lepeto Club information (for Lepeto Club members only)

    Preference information

    DATA RECIPIENTS

    Lepeto

    Site Administration Support Providers

    4. SALES OF LEPETO PRODUCTS

    PROCESSING

    To process your online orders, make sure your payment is received, comply with the requirements under our Terms and Conditions (for selling you the products) including invoice processing, delivery, personalization services, exchanges and refunds. Your order cannot be completed if our payment fraud detection solutions flag your transaction as suspicious and potentially fraudulent. 

    CATEGORIES OF PERSONAL DETAILS

    Identity information

    Contact information

    Location information

    Purchase information

    Correspondence

    Device information

    Lepeto Club information (for Lepeto Club members only)

    DATA RECIPIENTS

    Lepeto

    Selling Partners (where applicable)

    Manufacturing Providers

    Delivery Service Providers

    Payment Risk Solution Providers

    Payment Processing Providers

    IT Cloud Solution Providers

    5. PAYMENT FRAUD DETECTION

    PROCESSING

    We combine the purchase information you provide to us with other information we obtain through our third-party payment risk and fraud prevention service providers to ensure any purchases are legitimate, or you do not purchase our products in violation with our terms and conditions. This means depending on the outcome of the analysis of your information, we may reject your order, and decline your payment. This is an automated decision-making process that is required to conclude our sales contract with you.

    CATEGORIES OF PERSONAL DETAILS

    Identity information

    Contact information

    Behavioral and Profile information

    Purchase information

    Device information

    DATA RECIPIENTS

    Lepeto

    Payment Risk Solution Providers

    Payment Processing Providers

    IT Cloud Solution Providers

    6. PRODUCT DELIVERY

    PROCESSING

    Once you have successfully placed an order, we use your contact details (home and/or shipping address) and other purchase information to deliver the products you purchased to you.

    CATEGORIES OF PERSONAL DETAILS

    Identity information: Name

    Contact information: Shipping Address

    DATA RECIPIENTS

    Lepeto

    Delivery Service Providers

    IT Cloud Solution Providers

    7. ELECTRONIC DELIVERY TRACKING

    PROCESSING

    This is a service provided on request of the consumer by our Delivery Partners.

    You have the option to track your delivery using services provided directly by our delivery partners; however, we will only be able to share your information with our delivery partners for this purpose with your consent. The service is hosted on the Delivery Partner’s platform. You should read their Privacy Policy for the processing of your Personal Data for this purpose.

    CATEGORIES OF PERSONAL DETAILS

    Identity information

    Contact information

    Any other information you may directly and voluntarily provide to the Delivery Partner

    DATA RECIPIENTS

    Delivery Service Providers

    8. BUSINESS OPERATIONAL ANALYTICS

    PROCESSING

    We need to know how we do as a business. This is in the interest of our shareholders, our board members, our employees, and our partners. For this purpose, we need to analyse different categories of information to understand how our products are selling in different markets, what are the popular features of our products, what worked and what didn’t in terms of our marketing and advertising campaigns, our product designs and distribution strategy, our website design and overall user experience, so we can establish, implement, and evaluate our business strategy.

    This includes analyzing data to understand how users browse our site and use the app to improve our user experience design to make sure you will continue to purchase our products and interact with us on our sites and applications.

    To minimize the risk to you as an individual, we will only use either the unique consumer identifier or the IP address for this purpose.

    You can learn more about how our Data Analytics Solution Providers provide analytics services by using your data here:

    Adobe Analytics Data Collection: https://marketing.adobe.com/resources/help/en_US/reference/c_Privacy_Overview.html

    Google Analytics Data Collection:

    https://support.google.com/analytics/answer/6318039?hl=en

    CATEGORIES OF PERSONAL DETAILS

    Identity information: Unique Consumer Identifier (only)

    Purchase information

    Behavioral and Profile information

    Community information

    Activity information

    Device information

    Correspondence

    Lepeto Club information (for Lepeto Club members only)

    DATA RECIPIENTS

    Lepeto

    Prospective Buyers and Investors

    Business Consulting Service Providers

    Data Analytics Solution Providers

    IT Cloud Solution Providers

    9. CUSTOMER SERVICE

    PROCESSING

    We collect your Personal Data to tell you when the product you like is available upon your request and respond to your questions and concerns through various communications channels we make available to you.

    CATEGORIES OF PERSONAL DETAILS

    Identity information

    Contact information

    Location information

    Purchase information

    Correspondence

    Lepeto Club information (for Lepeto Club members only)

    DATA RECIPIENTS

    Customer Service Provider

    Lepeto

    Selling Partners (where applicable)

    Delivery Service Providers

    Payment Risk Solution Providers

    Payment Processing Providers

    IT Cloud Solution Providers

    10. PERSONALISED MARKETING MESSAGES VIA EMAIL (Newsletter Sign-Up And Existing Contract)

    PROCESSING

    We send you marketing messages that we think you would be interested (“personalized”) to the email address you provide to us because you signed up to our email newsletters. To send you “personalized” messages, observe your online behavior, and analyze your behavior using analytics to best estimate what product lines you might be interested in, and you can benefit from. This requires us to collect various categories of Personal Data from you. We use different analytics tools to understand what your behavior means in terms of your like and dislike of our various product lines, and to understand the impact (success rates) of the messages delivered to you.

    Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels and tags to collect your device information. More information is available in “17. COLLECTING YOUR DEVICE INFORMATION ON OUR WEBSITE USING COOKIES, PIXELS, TAGS, AND SIMILAR TECHNOLOGIES”.

    CATEGORIES OF PERSONAL DETAILS

    Identity information

    Contact information (if available to Lepeto)

    Location information

    Purchase information (if available to Lepeto)

    Behavioral and Profile information (if available to Lepeto)

    Community information (if available to Lepeto)

    Social Media information (if available to Lepeto)

    Activity information (if available to Lepeto)

    Device information

    Preference information (if available to Lepeto)

    DATA RECIPIENTS

    Lepeto

    Email Marketing Support Providers

    IT Cloud Solution Providers

    11. TARGETED MESSAGES ON 3RD-PARTY ADVERTISING PLATFORMS

    PROCESSING

    We use third-party advertising platforms, such as Facebook, Google, YouTube, Instagram, etc. to send you messages that are targeted at you, based on your behavior and browsing pattern, at specific times and locations of these platforms to increase the efficiency of our advertising campaigns. We use third-party solutions such as Google Audience and Facebook Custom Audience to help us do a better job at targeting our campaigns and messages for our consumers. Your Personal Data is shared with the third-party advertising platforms, and they will attempt to match your profile in their database to determine the optimal time and place (the page you are browsing) to show you an advertisement from Lepeto. We also need to analyze the necessary information to understand the impact of our campaigns. If you don’t accept that we track you for this purpose, you will still see Lepeto advertisements on other platforms at random.

    You can learn more about how our Advertising Partners help us achieve this purpose by visiting their sites:

    Google Personalised Advertising: https://support.google.com/adspolicy/answer/143465?hl=en

    Google Advertising Policies: https://support.google.com/adspolicy/answer/6020956

    Facebook Lookalike Audiences: https://www.facebook.com/business/help/164749007013531

    Facebook Custom Audience Terms: https://www.facebook.com/legal/terms/customaudience

    Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels and tags to collect your device information.

    More information is available in “17. COLLECTING YOUR DEVICE INFORMATION ON OUR WEBSITE USING COOKIES, PIXELS, TAGS, AND SIMILAR TECHNOLOGIES”.

    CATEGORIES OF PERSONAL DETAILS

    Identity information

    Contact information (if available to Lepeto)

    Location information

    Purchase information (if available to Lepeto)

    Behavioral and Profile information (if available to Lepeto)

    Community information (if available to Lepeto)

    Social Media information (if available to Lepeto)

    Activity information (if available to Lepeto)

    Device information

    Preference information (if available to Lepeto)

    Lepeto Club information (for Lepeto Club members only)

    DATA RECIPIENTS

    Lepeto

    Advertising Agency Partners

    Social Media Platforms

    Targeted Marketing Service Providers

    IT Cloud Solution Providers

    12. LEPETO CLUB MEMBERSHIP ADMINISTRATION – WHERE APPLICABLE

    PROCESSING

    Please note this section only applies if you are joining Lepeto Club to become a Lepeto Club member.

    When you become a Lepeto Club member, we use the information specified above to maintain and administer your membership as described in the Lepeto Club Terms and Conditions.

    In particular, your Personal Data is used for:

    a) calculating your club points to provide you rewards;

    b) providing you access to special offers and promotions;

    c) sending you invitations to exclusive events;

    d) allowing you access to limited edition products;

    e) storing your shipping address and payment details to shorten check-out time online and in the app;

    f) storing your complete order history so you can access it at any time; and

    g) allowing you to track your order delivery from your account.

    When you use your Lepeto Club membership ID, we receive the information to calculate reward points for you. Your data will be shared with Lepeto Club Partners who provide certain rewards according to Lepeto Club Terms and Conditions.

    You will receive email marketing messages from Lepeto as a Lepeto Club member. If you wish to unsubscribe from our marketing messages, please refer to “Your Rights” section.

    CATEGORIES OF PERSONAL DETAILS

    Lepeto Club information

    Purchase information (if available to Lepeto)

    Behavioral and Profile information (if available to Lepeto)

    Community information (if available to Lepeto)

    Social Media information (if available to Lepeto)

    Activity information (if available to Lepeto)

    Device information (if available to Lepeto)

    Preference information (if available to Lepeto)

    DATA RECIPIENTS

    Lepeto

    Prospective Buyers and Investors

    Business Consulting Service Providers

    Data Analytics Solution Providers

    Lepeto Club Partners

    13. PRIVATE EVENT REGISTRATION

    PROCESSING

    When you sign up for an event we organize that have limited spots, we use the Personal Data you provide to reserve a spot for you. Your Personal Data will be used according to the Terms and Conditions associated with the event.

    CATEGORIES OF PERSONAL DETAILS

    Identity information

    Contact information

    Location information

    Activity information: any information we may collect from you on the day of the event.

    Lepeto Club information (for Lepeto Club members only)

    DATA RECIPIENTS

    Lepeto

    Event Partners (where applicable)

    IT Cloud Solution Providers (where applicable)

    14. OPEN EVENT REGISTRATION

    PROCESSING

    We often also organize events that are open to everyone. We use the Personal Data you provide to keep you inform of the events you are interested in.

    CATEGORIES OF PERSONAL DETAILS

    Identity information

    Contact information

    Location information

    Activity information: any information we may collect from you on the day of the event.

    Lepeto Club information (for Lepeto Club members only)

    DATA RECIPIENTS

    Lepeto

    Event Partners (where applicable)

    IT Cloud Solution Providers (where applicable)

    15. PRODUCT RESEARCH AND DEVELOPMENT

    PROCESSING

    We conduct analysis to research improve our products and services. This includes asking you questions in surveys, asking you for feedback, asking you to test our products and provide us with a review, asking other service providers to conduct market and product research for us, try new technologies in our product that might collect Personal Data to stay ahead of the competition.

    CATEGORIES OF PERSONAL DETAILS

    Identity information (only if required by the project)

    Contact information (only if required by the project)

    Location information (only if required by the project)

    Purchase information (only if required by the project)

    Behavioral and Profile information (only if required by the project)

    Community information: this is the response you provided whichever format agreed at the time of the project.

    Social Media information (only if required by the project)

    Activity information (only if required by the project)

    Device information (only if required by the project)

    Correspondence (only if required by the project)

    Preference information

    Lepeto Club information (for Lepeto Club members only)

    DATA RECIPIENTS

    Lepeto

    Prospective Buyers and Investors

    Business Consulting Service Providers

    Data Analytics Solution Providers

    Manufacturing Providers

    IT Cloud Solution Providers

    16. LEGAL OBLIGATION - COOPERATION WITH LAW ENFORCEMENT AND REGULATORY AUTHORITIES (INCLUDING COURTS)

    PROCESSING

    When we are legally required to provide your Personal Data for national and public security reasons, crime prevention, investigation and prosecution, anti-money laundering, judicial proceedings, protection of other individuals’ rights and freedoms, and enforcement of civil claims, we will provide information as requested by the authorities or parties once we are satisfied that the request is mandated by law.

    CATEGORIES OF PERSONAL DETAILS

    All Categories of Personal Data as requested by the enforcement authority.

    DATA RECIPIENTS

    Lepeto

    Local and national government authorities, including tax authorities

    Local and national law enforcement agencies

    Local and national judiciary

    17. COLLECTING YOUR DEVICE INFORMATION ON OUR WEBSITE USING COOKIES, PIXELS, TAGS, AND SIMILAR TECHNOLOGIES (“COOKIES NOTICE”)

    PROCESSING

    When you visit the Lepeto site, we store data collectors such as cookies, tags, pixels, tag containers, beacons, among others, in your browser to obtain certain information about your current browsing session. These technologies are often referred to as “Cookies” collectively by other websites. Cookies also enable our website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another. We use Cookies for different purposes. Please review the information below to understand how we use different types of Cookies to fulfill different purposes.

    “REQUIRED” – site functionality and business operation.

    We use “Required Cookies” to operate our site. This includes storing a unique identifier to manage and identify you as a unique visitor to our site, to provide a consistent and accurate service to you. This includes making sure that we remember the products you have placed in your cart, or your language preferences. These Cookies are stored for the duration of your browsing session. Without these Cookies, you will not be able to view our site properly.

    “FUNCTIONAL” – website improvement and performance

    We use “Functional Cookies” to continuously improve our website performance. This includes using the data we collected from you to do the following:

    Web analytics —Based on your browsing behavior, we will analyze the data to improve the functionality and design of our site.

    Ad response rates— Based on how you come to our site, we will measure our ad response rates by analyzing our ad click-through rates to improve the effectiveness of advertising purchased on a site external to ours.

    Affiliate tracking— We need to let our affiliate marketing partners, or service providers have certain information if you came to our site, and purchased products, through a visit to theirs. This is required as we may need to provide them a fee for such services. For this purpose, we will share information about your visit, including the products you have purchased.

    Error management— We measure errors presented on a website, to make sure we fix bugs or any issues promptly.

    Testing designs— We need to use A/B testing or multivariate testing, to ensure a consistent look and feel is maintained for the user of the site in the current and subsequent sessions.

    “MARKETING”

    We use “Marketing Cookies” provided by our advertising partners to make sure our advertising messages are shown to you at the right time and in the right place. These Cookies are persistent but time-limited cookies. These Cookies contain a unique key to distinguish individual users’ browsing habits. We also use these Cookies to limit the number of times a user sees a particular ad on a website and to measure the effectiveness of a particular campaign. The identifier stored by these Cookies are provided by our partners. We cannot use the same identifier in our own systems. We also use these cookies to serve ads that are relevant to your immediate geo-location, for example to provide you with the nearest store where the product you are browsing may be available.

    CATEGORIES OF PERSONAL DETAILS

    Device information

    Location information

    Behavioral and Profile information: this is collected through observing your browsing behavior

    Preference information (if available to Lepeto)

    DATA RECIPIENTS

    Lepeto

    Site Administration Support Providers

    Business Consulting Service Providers

    Data Analytics Solution Providers

    Advertising Agency Partners

    Social Media Platforms

    Targeted Marketing Service Providers

    You can change your browser settings to delete or prevent certain cookies from being stored on your computer or mobile device without your explicit consent. The ‘help’ section in your browser should provide information on how to manage your cookie settings.

    Find out how this works for your browser here:

    Internet Explorer: https://support.microsoft.com/help/17442/windows-internet-explorer-delete-manage-cookies

    Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies

    Google Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647

    Safari: http://support.apple.com/kb/PH5042

    Opera: http://www.opera.com/browser/tutorials/security/privacy/

    Adobe (flash cookies): http://www.adobe.com/privacy/policies/flash-player.html

    Google Chrome App: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DAndroid&hl=en

    These websites will also help you understand more about how Cookie-based advertising works and how you can manage your Cookie Settings:

    http://www.aboutads.info/choices

    http://www.youronlinechoices.eu/

    Network Advertising Initiative opt-out page: http://optout.networkadvertising.org/?c=1

    You can learn more about the laws governing the use of “Cookies” here: http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm

    18. USER-GENERATED CONTENT (UGC) ACQUISITION FROM SOCIAL MEDIA

    PROCESSING

    We invite you to provide your images to us via social media platforms by following specific instructions such as “#yeslepeto”. We will be using the images you provide for our campaign communications. We will obtain rights to your image through a license agreement in the form of our terms and conditions. By submitting your images via social media platforms to us, you will agree for us to use your images as described in the license agreement.

    CATEGORIES OF PERSONAL DETAILS

    Identity information: your social media handler

    Community information: images, videos, comments, sound recordings and other files provided through the social media platform promoting Lepeto

    Social Media information

    DATA RECIPIENTS

    Lepeto

    Event Partners (where applicable)

    UGC Support Partners

    Advertising Agency Partners

    Social Media Platforms

    IT Cloud Solution Providers (where applicable)

    Data Recipients

    We may disclose your personal data to the following parties (“Data recipients”):

    1. agents, sub-contractors, vendors or third party service providers, such as courier services, telecommunications, technical services, debt recovery, market research and data analytics services;
    2. any other party to whom you authorize us to disclose your personal data to;
    3. our marketing and business partners in connection with marketing promotions, products and services;
    4. our corporate clients;
    5. amongst the Lepeto corporate group and its related corporations or affiliates;
    6. our professional advisers, such as our lawyers and accountants;
    7. banks, payment processing service providers, financial institutions and their respective service providers;
    8. our successor-in-title, prospective seller or buyer of any part or the whole of our business, in connection with a merger, acquisition or sale of any part or the whole of the Lepeto business; and
    9. social media sites such as Facebook, Twitter or Google.

    Where your personal data may be used by third party Data Recipients via Lepeto platforms or elsewhere for their own purposes, please consult the privacy notice of such third parties for more information about how they handle your personal data.

    Secure Your Personal Data

    We implement appropriate technical and organizational measures to address the risks corresponding to our use of your Personal Data, including loss, alteration, or unauthorized access to your Personal Data, and empowering you to exercise your rights. We require our service providers to do the same through contractual agreements. However, you should be aware that any transmission of your Personal Data through the internet is at your own risk. We can only protect your Personal Data when we have it.

    Your Rights

    You have the rights listed and explained below. We also provide you instructions on how to exercise each right. We need to confirm your identity before we can handle your requests. When we refuse your request for legal reasons, we will tell you why. 

    YOUR RIGHT

    HOW TO EXERCISE YOUR RIGHT

    Get a copy of your Personal Data 

    You may request for a copy of your Personal Data, in accordance with your rights under the applicable data protection laws, provided that it is still within our possession or control when we receive your request. We reserve our rights to charge a reasonable fee for this request.

    Contact Customer Service for support.

    Reason: Privacy and Data Handling.

    Subject: A Copy of My Personal Data.

    Access to information about your Personal Data

    Subject to the provisions of and any exceptions under applicable laws, you have the right to know about the ways your Personal Data has been or may have been used by us within a year before the date of your request.

    We reserve our rights to charge a reasonable fee for this request.

    Please review the Lepeto Privacy Policy.

    If you have any questions about the Privacy Policy, please contact the Lepeto Privacy Team.

    Make sure your Personal Data are correct

    You have the right to make sure we are using the accurate details about you. We shall, as required under applicable data protection laws and unless exceptions apply, send such corrected data to every other organization to which the data was disclosed by us within a year before your request.

    Log in to your account and make the corrections yourself; or

    Contact Customer Service for support.

    Reason: Privacy and Data Handling.

    Withdraw your consent

    When we use your Personal Data based on your consent, you have the right to change your mind and withdraw your consent at any time. We shall cease collection use and disclosure of your Personal Data after receiving your request, unless we are otherwise permitted to do so under applicable laws. If you withdraw your consent to any and all purposes and depending on the nature of your request, we may not be in the position to continue to provide our products and services to you. Other legal consequences may also potentially arise in respect of such withdrawal, vis-à-vis your existing contracts and agreements with us.

    Unsubscribe from our Newsletters:

    Click ‘Unsubscribe’ at the bottom of the newsletter or marketing email that you want to unsubscribe from; or update your communication preferences in your account if you have one.

    If there are any technical issues:

    Contact Customer Service for support.

    Reason: Privacy and Data Handling.

    Subject: Unsubscribe Me from Emails

    Withdrawing other consent:

    Contact us for support.

    Subject: Privacy – Withdraw My Consent

    Contact

    For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us:

    Lepeto Customer Service: https://lepeto.com/pages/contact-us

    Updates and Notification of Updates

    We review and update the Privacy Policy periodically to reflect any changes resulting from our day-to-day business operations. You can always check the date of the Privacy Policy to find out when we last made any changes. We will notify you when we make significant changes that you must be aware of.  

     

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