Limitless Platform - Privacy Policy

Last Update: May 23, 2018
Version 2.0

Welcome to the Limitless Platform privacy policy.

Limitless respects your privacy and is committed to protecting your privacy and personal data.

The information set out in this privacy policy will inform you as to how we look after your personal data when you visit and use the Platform (defined below) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy contains 15 sections. You may jump directly to any section by selecting the appropriate link below. The headings and sub headings below are for reference only and do not limit the scope of each section.

  Jump to section:

  1. IMPORTANT INFORMATION
  2. WHO WE ARE
  3. WHAT INFORMATION DOES LIMITLESS COLLECT ABOUT YOU?
  4. IF YOU FAIL TO PROVIDE PERSONAL DATA
  5. HOW DOES LIMITLESS COLLECT YOUR PERSONAL DATA?
  6. HOW DOES LIMITLESS USE INFORMATION ABOUT YOU?
  7. AUTOMATED DECISION MAKING
  8. LOCATION SERVICES
  9. COOKIES
  10. WILL LIMITLESS SHARE YOUR INFORMATION WITH THIRD PARTIES?
  11. WHERE DOES LIMITLESS STORE YOUR PERSONAL DATA?
  12. SECURITY/HOW DOES LIMITLESS PROTECT YOUR INFORMATION?
  13. DATA RETENTION
  14. YOUR LEGAL RIGHTS
  15. CONTACT DETAILS

1. IMPORTANT INFORMATION

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy policy supplements the other notices and is not intended to override them. If you do not agree with any of this privacy policy then you should not use the Platform.

Please note that Limitless may update and amend this privacy policy from time to time and any changes will be posted on the Platform. This version was last updated on 23 May, 2018.

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 your relationship with us.

The Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements and/or terms and conditions of use. When you leave the Platform, we encourage you to read the privacy policy and/or terms and conditions of use of every website you visit.

By accessing and continuing to use the Platform, you accept the terms of this privacy policy.

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2. WHO WE ARE

Limitless Technology Limited (Limitless) is the controller and responsible for your personal data (referred to as "Limitless", “we”, “us” or “our” in this privacy policy):

Limitless has developed a cloud based website / mobile app platform (Platform) through which we provide customer support services to a range of organisations. The Platform enables members of the public who are customers of these organisations (Customers) to ask questions in relation to the products and/or services of these organisations. We also enable individuals to use their expertise to answer questions and queries raised by Customers – these individuals are known as Ambassadors (Ambassadors) .

We are bound by applicable data protection laws in respect of the handling and collection of your personal data. Limitless is registered as a data controller in England and Wales, with the Information Commissioner's Office (ICO) under the ICO number ZA190183.

We have appointed a data protection officer (DPO), who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights as set out in section 12, please contact us using the contact details in section 15.

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3. WHAT INFORMATION DOES LIMITLESS COLLECT ABOUT YOU?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identifiers have been removed (anonymous data) or data relating to a corporate entity.

Customers

If you are one of the Customers using the Platform, we do not collect or process your personal data.

As a Customer we do not collect your personal data nor do we receive it from anyone else. It is not required by us for you to enjoy the use of the Platform. It is therefore your responsibility as a Customer not to share any of your personal data, or the personal data of other third party individuals (such as the names of any family members or friends), through your use of the Platform.

In the event you share any personal data through your use of the Platform, we consider this to be a potential security breach and the Ambassadors are required to report this to us immediately using the functionality in the Platform.

Upon becoming aware of any Customers' (or third party individuals') personal data being processed in the Platform, it is immediately and permanently deleted by us.

Ambassadors

If you are interested in becoming and/or become one of the Ambassadors of the Platform, Limitless may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy./p>

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.

Ambassadors must be 18 years of age or over. The Platform is not intended to be used by children and accordingly we do not knowingly collect or process the personal data of anyone under 18 years of age.

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4. IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Ambassador services). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

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5. HOW DOES LIMITLESS COLLECT YOUR PERSONAL DATA?

We use different methods to collect data from and about you including through:

Direct interactions:You may give us your Identity, Contact, Eligibility, Profile and Financial Data by filling in forms or by corresponding with us by email, telephone, post or otherwise. This includes personal data you provide when you:

Automated technologies or interactions: As you interact with our Platform, we may automatically collect Usage and Technical Data about your equipment, browsing actions and patterns of use. We collect this personal data by using cookies and other similar technologies.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

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6. HOW DOES LIMITLESS USE INFORMATION ABOUT YOU?

Limitless will only use your personal data when the law allows us to. The types of lawful basis for processing personal that we rely on are:

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means agreement which must be freely given, specific, informed and be an unambiguous indication of your wishes by which you, by a statement or by a clear positive action, signify agreement to the processing of personal data relating to you.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending our newsletters and/or marketing to you via email or text message. You have the right to withdraw consent to newsletters and other marketing at any time by contacting us.

We have set out 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:

Purpose/Activity Type of Data Lawful basis for processing (including basis of legitimate interest)
To register you as an Ambassador on the Platform Identity Data

Contact Data

Eligibility Data
Performance of contract

Necessary to comply with a legal obligation
To carry out Limitless' obligations arising from any contracts entered into between you and us Identity Data

Contact Data
Performance of contract
To monitor, develop and improve the Platform, services and your experience Identity Data

Contact Data

Usage Data

Technical Data

Profile Data

Financial Data

Transaction Data
Performance of contract

Necessary for our legitimate interests to continually improve our Platform
To ensure that content from the Platform is presented in the most effective manner for you and your computer Identity Data

Contact Data

Usage Data

Technical Data

Profile Data
Performance of contract

Necessary for our legitimate interests to continually improve our Platform
To measure and calculate credits you may earn from your use of the Platform to provide advice Identity Data

Contact Data

Usage Data

Technical Data

Profile Data

Financial Data

Transaction Data
Performance of contract

Necessary to comply with a legal obligation
To process (via our third party payment service providers) any redemption of credits requested by you Identity Data

Contact Data

Usage Data

Financial Data

Transaction Data
Performance of contract

Necessary to comply with a legal obligation
To compile and maintain a user profile for you and to automatically calculate and generate a "reputation score" for you based on data inputs such as feedback from customers, client businesses, the Limitless Community Success team and other users Identity Data

Contact Data

Usage Data

Technical Data

Profile Data
Performance of contract

Necessary to comply with a legal obligation
To allow you to participate in the interactive features of the Platform, when you choose to do so Identity Data

Contact Data

Usage Data

Technical Data

Profile Data
Performance of contract

Necessary for our legitimate interests to provide you with the best Platform experience possible
To process and deal with any complaints or enquiries made by or about you Identity Data

Contact Data

Eligibility Data

Usage Data

Necessary to comply with a legal obligation
Necessary for our legitimate interests to provide you with the best Platform experience possible
To investigate any suspected breach of the Terms and Conditions or the breach of other terms and conditions otherwise relating to you and to monitor compliance including by way of checking postings or submissions via the Platform and using keyword triggers to investigate usage that may be inappropriate Identity Data

Contact Data

Technical Data

Usage Data
Performance of contract
Necessary to comply with a legal obligation
To send you and keep you updated with information by email, telephone or mail about existing and new services and about special offers from us or about products and services from selected third parties that may be of interest to you. Identity Data

Contact Data

Profile Data

Marketing and Communications Data
Consent
To provide information to Customers who want to keep you updated with information and promotions about their products Identity Data

Contact Data

Profile Data

Marketing and Communications Data
Consent

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7. AUTOMATED DECISION MAKING

As part of our operation of the Platform certain decisions may be solely based on the automated processing of your personal data. If you do not agree with these decisions, you may wish to express your views and to contest the decision. In which case, please do get in contact (please see section 15)

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8. LOCATION SERVICES

When you download our mobile app or use the mobile browser to access your Platform account and have consented to location services, we will collect:

This information will be collected only when you consent to location services. We need this information to provide you with location-based services or other personalized content. Some of our services may not function as designed if location services are disabled.

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9.COOKIES

Limitless may obtain information about your use of the Platform by using cookies or other such devices. A cookie is a small file of letters and numbers that we store on your browser or on the hard drive of your computer. This helps us to improve the Platform and to deliver a better and more personalised service.

If you disable or refuse cookies when using our Platform, please note that some parts of our Platform may become inaccessible or not function properly.

Cookies and other such devices which are strictly necessary for the operation of the Platform:

Some of the cookies and other such devices Limitless uses are essential for parts of the Platform to operate and are already set. These are strictly necessary for the use of the Platform by you and without them the Platform cannot operate as intended.

The types of cookies we use are set out below:

Performance Cookies (tracking website performance):

Other uses of cookies (where you have consented to such use):

We only use (and store) non-essential cookies on your computer's browser or hard drive if you provide your consent. Where you consent to us doing so, Limitless may also use such cookies and other such devices to compile anonymous, aggregated statistics that allows Limitless to understand how users use the Platform and to help Limitless improve the structure of the Platform (Limitless cannot identify you personally in this way). For example, Limitless may use such cookies and other such devices to allow Limitless to understand who has seen which pages on the Platform, to determine how frequently particular pages are visited, to determine the most popular areas of the Platform and generally in order to monitor usage of the Platform.

Where you consent to Limitless doing so, Limitless may also use cookies and other such devices to:

If Limitless currently uses any such non-essential cookies, these are set out below:

Functionality Cookies:(giving you a better online experience):

A general description of how we create and use our own cookies (specific to our Web apps) to support the functionality of those apps, specifically:

Other cookies outside of Limitless' control:

Limitless may use external services such as Facebook, Pinterest, LinkedIn, Twitter, Google+ or YouTube, to display certain "framed" content on the Platform. Limitless cannot prevent such websites from collecting information about your usage of their services on the Platform, for example, number of plays of a video.

Like many other organisations, Limitless may use an analytics service provided by Amazon or Google for tracking the performance of the Platform. Such analytics services may set a number of performance cookies in order to evaluate your use of the Platform and enable Limitless to carry out actions including (but not limited to):

If any cookies are set by an analytics service currently used by Limitless, this is set out in the non-essential cookies table above (as well as links for you to find out more about these services and how to reject or delete any such cookies).

Browser settings:

Most internet browsers are automatically set up to accept cookies, but you can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies or to show you where a cookie has been set up. Certain services are only activated by the presence of a cookie and, if you choose to refuse cookies, particular features of this Platform may not be available to you.

Find out how to disable/enable cookies by clicking on the “Manage Cookies” section of the Interactive Advertising Bureau UK website on the following link.

Unless you have adjusted your browser settings so that it will refuse cookies, or confirmed to Limitless that you do not accept Limitless' cookies, Limitless' system will issue cookies when you visit the Platform.

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10. WILL LIMITLESS SHARE YOUR INFORMATION WITH THIRD PARTIES?

For the purposes set out above, Limitless may have to share your personal data with the following parties:

Third parties to whom we may choose to sell, transfer or merge parts of our business or 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 privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.

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11. WHERE DOES LIMITLESS STORE YOUR PERSONAL DATA?

The data that Limitless collects from you will be stored on servers in the EU. The data that Limitless collects from you may be transferred to, and stored at, a destination outside the EU.

Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.

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12. SECURITY/HOW DOES LIMITLESS PROTECT YOUR INFORMATION?

Limitless endeavours to take all reasonable steps to protect your personal data. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Where possible Limitless uses industry-standard Secure Sockets Layer (SSL) technology to allow for the encryption of our personal data. Unfortunately, the transmission of information via the internet is not completely secure. Although Limitless will do its best to protect your personal data, Limitless cannot guarantee the security of your data transmitted to the Platform; any transmission is at your own risk. Once Limitless has received your information, Limitless will use strict procedures and security features to try to prevent unauthorised access.

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.

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13. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

We will generally retain your personal data for a period of 7 years after your engagement as an Ambassador with us has ended. This is to ensure that we are able to assist you should you have any questions or feedback in relation to your time as an Ambassador or our services or to protect or defend our legal rights.

Where we have processed your personal data to provide you with marketing communications with consent, we may contact you at least every 12 (twelve) months, to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our marketing lists (but will be added to a "do not contact" list.

Where we have processed your data for any other reason (such as where you have contacted us with a question in connection with services), subject to paragraph 3, we will retain your data for 12 (twelve) months.

In some circumstances you can ask us to delete your data: see section 14 below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

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14. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are detailed below

If you wish to exercise any of the rights set out above, please contact us directly/

No fee usually required. 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.

Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.

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15. CONTACT DETAILS

Our full details are:

Full name of legal entity: Limitless Technology Limited

Company Number: 10056048

Data Protection Officer: Megan Neale

Email address: info@belimitless.io


Postal address: 1-2 Hatfields, Waterloo, London, SE1 9PG, United Kingdom.

Telephone number: + 44 07946322405

You can also email us with any questions, queries or complaints at info@belimitless.io

You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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Last Update: 23 May 2018

Version 2.0