1. Introduction
LuluChat collects some Personal Data from its Users.
Users may be subject to different protection standards and broader standards may therefore apply to some. In order to learn more about the protection criteria, Users can refer to the applicability section.
This document contains a section dedicated to Brazilian Users and their privacy rights.
This document can be printed for reference by using the print command in the settings of any browser.
Owner and Data Controller
BLACK POCKET TECHNOLOGY SDN BHD
16-1, Jalan Puteri 2/4, Bandar Puteri 47100 Puchong, Selangor Malaysia.
Owner contact email: [email protected]
Types of Data collected
Among the types of Personal Data that LuluChat collects, by itself or through third parties, there are: Usage Data; Tracker; email address; phone number; first name; last name; various types of Data; password; Data communicated while using the service.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using LuluChat.
Unless specified otherwise, all Data requested by LuluChat is mandatory and failure to provide this Data may make it impossible for LuluChat to provide its services. In cases where LuluChat specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by LuluChat or by the owners of third-party services used by LuluChat serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published, or shared through LuluChat and confirm that they have the third party's consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner may process Personal Data relating to Users if one of the following applies:
• Users have given their consent for one or more specific purposes. Note: Under some legislations, the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular, whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquiring with the Owner using the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
The purpose of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Displaying content from external platforms, Tag Management, Contacting the User, Analytics, Managing contacts and sending messages, Handling payments, Infrastructure monitoring, Hosting, and backend infrastructure, User database management, Connecting Data, Content performance and features testing (A/B testing), Data transfer outside the EU, Registration, and authentication provided directly by LuluChat, Interaction with live chat platforms, Registration and authentication, Remarketing and behavioral targeting, SPAM protection and Platform services and hosting.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
• Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
• Google Analytics (Google Ireland Limited)
Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of LuluChat, to prepare reports on its activities, and to share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Attribution (Attribution, LLC)
Attribution is an analytics service provided by Attribution, LLC.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Facebook Ads conversion tracking (Facebook pixel) (Facebook Ireland Ltd)
Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook Ireland Ltd that connects data from the Facebook advertising network with actions performed on LuluChat. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
Zapier (Zapier, Inc.)
Zapier is a workflow automation service provided by Zapier, Inc. that automates the movement of data between (third-party) services.
Personal Data processed: Tracker.
Place of processing: United States – Privacy Policy.
• Contacting the User
Mailing list or newsletter (LuluChat)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning LuluChat. Your email address might also be added to this list as a result of signing up to LuluChat or after making a purchase.
Personal Data processed: Tracker.
Contact form (LuluChat)
By filling in the contact form with their Data, the User authorizes LuluChat to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: email address; first name; last name.
Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of LuluChat.
Google Optimize (Google Ireland Limited)
Google Optimize is an A/B testing service provided by Google Ireland Limited ("Google"). Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
• Data transfer outside the EU
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.
Data transfer abroad based on standard contractual clauses (LuluChat)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Personal Data processed: various types of Data.
• Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of LuluChat and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts (Google Ireland Limited)
Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows LuluChat to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
• Handling payments
Unless otherwise specified, LuluChat processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. LuluChat isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
• Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable LuluChat to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of LuluChat.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of LuluChat, in order to contact and be contacted by LuluChat‘s support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
Facebook Messenger Customer Chat (Facebook Ireland Ltd)
The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook Ireland Ltd
Personal Data processed: Data communicated while using the service; Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
Webflow (Webflow, Inc.)
Webflow is a platform provided by Webflow, Inc. that allows the Owner to build, run and host LuluChat. Webflow is highly customizable and can host websites from simple blogs to complex e-commerce platforms. Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy – Opt-out.
• Registration and authentication
By registering or authenticating, Users allow LuluChat to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, LuluChat will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Google OAuth (Google Ireland Limited)
Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Registration and authentication are provided directly by LuluChat
By registering or authenticating, Users allow LuluChat to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (LuluChat)
The User registers by filling out the registration form and providing the Personal Data directly to LuluChat.
Personal Data processed: Contact number: email address; first name; last name; password.
• Remarketing and behavioral targeting
This type of service allows LuluChat and its partners to inform, optimize and serve to advertise based on past use of LuluChat by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt-out by visiting the Network Advertising Initiative opt-out page.
Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Google Ads Remarketing (Google Ireland Limited)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of LuluChat with the Google Ads advertising network and the DoubleClick Cookie. Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Facebook Remarketing (Facebook Ireland Ltd)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of LuluChat with the Facebook advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
SPAM protection
This type of service analyses the traffic of LuluChat, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA (Google Ireland Limited)
Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
• Tag Management
This type of service helps the Owner to manage the tags or scripts needed on LuluChat in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.
Segment (Segment Inc.)
Segment is a tag management service provided by Segment.io, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
• User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to LuluChat, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks profiles) and used to build private profiles that the Owner can display and use for improving LuluChat. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on LuluChat.
HubSpot CRM (HubSpot, Inc.)
HubSpot CRM is a User database management service provided by HubSpot, Inc.
Personal Data processed: email address; phone number; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Further information about Personal Data
• Push notifications
LuluChat may send push notifications to the User to achieve the purposes outlined in this privacy policy. Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for LuluChat, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of LuluChat.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights apply to them.
In particular, Users have the right to do the following:
• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract of which the User is part, or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner, or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Applicability of broader protection standards
While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.
Such broader protection standards apply when the processing:
• is performed by an Owner based within the EU;
• concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
• concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU.
Cookie Policy
LuluChat uses Trackers. To learn more, the User may consult the Cookie Policy.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of LuluChat or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, LuluChat may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, LuluChat and any third-party services may collect files that record interaction with LuluChat (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within LuluChat and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
• your consent to the relevant processing activities;
• compliance with a legal or regulatory obligation that lies with us;
• the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
• studies conducted by research entities, preferably carried out on anonymized personal information;
• the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
• the exercising of our rights in judicial, administrative or arbitration procedures;
• protection or physical safety of yourself or a third party;
• the protection of health – in procedures carried out by health entities or professionals;
• our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
• credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why do we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests if we are in the position to do so.
In the event that you file access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization, or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves a disproportionate effort on our side.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
User
The individual using LuluChat who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of LuluChat. The Data Controller, unless otherwise specified, is the Owner of LuluChat.
LuluChat (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by LuluChat as described in the relative terms (if available) and on this site/application.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to LuluChat, if not stated otherwise within this document.
Targeting & Advertising
LuluChat uses Trackers to deliver personalized marketing content based on User behavior and to operate, serve and track ads.
• Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts, or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
• Remarketing and behavioral targeting
This type of service allows LuluChat and its partners to inform, optimize and serve to advertise based on past use of LuluChat by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Google Ads Remarketing (Google Ireland Limited)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of LuluChat with the Google Ads advertising network and the DoubleClick Cookie. Users can opt-out of Google's use of cookies for ad personalization by visiting Google's Ads Settings.
Personal Data processed: Tracker and Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Facebook Remarketing (Facebook Ireland Ltd)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of LuluChat with the Facebook advertising network.
Personal Data processed: Tracker and Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
How to manage preferences and provide or withdraw consent
There are various ways to manage Tracker-related preferences and to provide and withdraw consent, where relevant:
Users can manage preferences related to Trackers directly within their own device settings, for example, by preventing the use or storage of Trackers.
Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences widget, if available.
It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent.
Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.
With regard to any third-party Trackers, Users can manage their preferences and withdraw their consent via the related opt-out link (where provided), by using the means indicated in the third party's privacy policy, or by contacting the third party.
Owner and Data Controller
THE BLACK POCKET TECHNOLOGY
16-1, Jalan Puteri 2/4, Bandar Puteri 47100 Puchong, Selangor Malaysia.
Owner contact email: [email protected]
Since the use of third-party Trackers through LuluChat cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document.
Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by LuluChat.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through LuluChat (or third-party services employed in LuluChat), which can include: the IP addresses or domain names of the computers utilized by the Users who use LuluChat, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using LuluChat who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of LuluChat. The Data Controller, unless otherwise specified, is the Owner of LuluChat.
LuluChat (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by LuluChat as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
