Levell’s Privacy Policy

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Last Updated: 1 January 2021

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When you visit us through our website, or access Levell’s services, you trust us with your information. This Privacy Policy describes how Levell collects, uses and discloses information, and what choices you have with respect to the information. It is important, and a bit long, but we hope you will take the time to read it carefully.

 

This Privacy Policy explains

• The context for this Privacy Policy

• Applicability and scope of this Policy

• Who we are and how you can contact us, for the purposes of this Policy

• What information we collect and why we collect it

• How we use that information

• The choices you have and your rights, including how to access and update that information

• Changes we may make in the future to this Policy, and how we will inform you

 

Throughout this Privacy Policy, when we refer to “Levell”, “we”, “our” or “us” we mean Levell Holdings Limited (“Levell”). Levell is registered in England and Wales under company number 12435901 at 71-75 Shelton Street, London, WC2H 9JQ, United Kingdom. Levell’s VAT number is 345401132.

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Levell is the entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.

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The context for this Privacy Policy

 

The law in relation to data protection changed on 25 May 2018 when the General Data Protection Regulation comes into force in the United Kingdom and across Europe.

There may be further changes which we will be required to make to this Privacy Policy in the future. We will notify you of any significant changes. We may need to ask you to agree to certain changes where we have obtained your consent or refresh your consent to us using your personal information.

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Applicability and scope of this Policy

 

This Privacy Policy applies to Levell’s online management tools and platform (the “Services”) accessible through the Levell.io website (the “Website”), and to other interactions (e.g., customer service inquiries, user conferences, interactions through social media channels, etc.) you may have with Levell. If you do not agree with the terms, do not access or use our Services, Website or any other aspect of Levell’s business.

 

Individuals who wish to access Levell’s Services (the “End User”, e.g. you, if you are signing up, registering for, or joining Levell’s Services) are required to accept a separate Terms and Conditions, which governs the delivery, access and use of the Services by the individual (the “Terms and Conditions”), which includes specific sections that explain the processing of any personal information, messages, files or other content submitted through Services accounts (collectively, “User Data”).

 

Information We Collect and Receive
 

Levell may collect and receive User Data and other information and data (“Other Information”) in a variety of ways:

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• User Data. Individuals using Levell as End Users routinely submit User Data to Levell when using the Services.

• Other Information. Levell also collects, generates and/or receives Other Information on its End Users:

  1. Account Information. To create or update your Levell account, you supply Levell with an email address, name, password, and/or similar account details

  2. Usage Information.

     • Services Metadata. When an End User interacts with the Services, metadata is generated that provides additional context about the way End Users work. For example, Levell logs the Organisations, teams, End Users, features, content and links you interact with, the categories of information selected within certain features, and the information inputted within certain features (if any).

     • Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.

     • Device information. Levell collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.

     • Location information. We receive information from you other third-parties that helps us approximate your location. We may, for example, use an IP address received from your browser or device to determine approximate location. Levell may also collect location information from devices in accordance with the consent process provided by your device.

  3. Cookie Information. Levell uses cookies and similar technologies in our Website and Services that help us collect Other Information. For more details about how we use these technologies, please see our Cookie Policy.

  4. Additional Information Provided to Levell. We receive Other Information when submitted to our Website or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Levell.

 

Generally, no one is under a statutory or contractual obligation to provide any User Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Account details, is not provided, we may be unable to provide the Services.

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How We Use Information

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User Data will be used by Levell in accordance with our End User’s instructions, including any applicable terms in the Terms and Conditions, and End User’s use of Services functionality, and as required by applicable law. The End User is the controller and Levell is the processor of User Data. The End User may, for example, use the Services to join or remove themselves from an Organisation, accept Roles and configure settings, access, modify, share and remove their User Data and otherwise utilise the Services in accordance with their personal needs.

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Levell uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business.

 

More specifically, Levell uses Other Information:

• To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under the Terms and Conditions, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an End User’s request.

• As required by applicable law, legal process or regulation.

• To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.

• To develop and provide search, sharing, coaching, and management tools and additional features. Levell tries to make the Services as useful as possible for its End Users. For example, we may use Other Information to improve search functionality by using Other Information to help determine and rank the relevance of content to an End User, or we may use Other Information to make Services suggestions, to customize a Services experience or create new management features and products.

• To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Levell. These are marketing messages and we only send marketing messages to End Users who have opted in to receive them.

• To investigate and help prevent security issues and abuse.

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If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Levell may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

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Data Retention

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Levell will retain User Data in accordance with the End User’s instructions, including any applicable terms in the Terms and Conditions and End User’s use of Services functionality, and as required by applicable law.

Levell may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Levell to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

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How We Share And Disclose Information

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This section describes how Levell may share and disclose Information. End Users determine their own policies and practices for the sharing and disclosure of Information, through their specific choices during their use of the Services, and Levell does not control how they choose to share or disclose Information.

• End User’s Instructions. Levell will solely share and disclose User Data in accordance with an End User’s instructions, respectively, including any applicable terms in the Terms and Conditions and End User’s use of Services functionality, and in compliance with applicable law and legal process.

• Displaying the Services. When an End User submits User Data or Other Information, it may be displayed to other End Users. For example, an End User’s name may be displayed with their Account profile, or specific messages an End User has submitted may be displayed to other End Users, with the initial user's consent.

• Collaborating and Sharing with Others. The Services provide different ways for End Users to collaborate and share information. User Data and Other Information, such as an End User’s profile Information, may be shared among End Users for the End Users’ collective benefit, subject to consent of the End User(s) involved.

• Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services, or website analytics. Additional information about the subprocessors we use to support delivery of our Services is set forth at Levell Subprocessors.

• During a Change to Levell’s Business. If Levell engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Levell’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.

• Aggregated or De-identified Data. We may disclose or use aggregated or de-identified User Data, and Other Information for any purpose. For example, we may share aggregated or de-identified User Data or Other Information with prospects or partners for business or research purposes, such as telling a prospective Levell customer the average amount of time spent by a typical End User on the platform, or to provide prospective End Users with examples of how other End Users may use the service.

• To Comply with Laws. If we receive a request for information, we may disclose User Data or Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.

• To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of Levell or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.

• With Consent. Levell may share User Data or Other Information with third parties when we have consent to do so.
   

Security

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Levell takes security of data very seriously. Levell works hard to protect User Data and Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the User Data and Other Information we collect, process and store, and the current state of technology. Levell has received officially-recognized security certifications, including CyberEssentials, a programme developed by the UK government. Given the nature of communications and information processing technology, Levell cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.

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Age Limitations

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To the extent prohibited by applicable law, Levell does not allow use of our Services and Websites by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us and we will takes steps to delete such information.

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Changes To This Privacy Policy

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Levell may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Levell will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account.

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Data Protection Officer

 

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 in relation to this Privacy Policy, including any specific requests for information about how data is processed, or requests to express your rights, please email support@levell.io with the subject “DPO” in the subject line. If you wish, you can also write us at our registered office address mentioned above.

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Identifying The Data Controller And Processor

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Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, the End User is the controller of User Data. In general, Levell is the processor of User Data and the controller of Other Information.

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Your Rights

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Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access your Information.

To do this, please email the Data Protection Officer at support@levell.io and request the Levell Data Access Request Form.

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You also have the right to seek to update, delete or correct this Information. You can amend some information using the settings and tools provided in your Services account. If you need further help, contact support@levell.io for additional access and assistance, including the right to delete your data from our systems.

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To the extent that Levell’s processing of your Personal Data is subject to the General Data Protection Regulation, Levell relies on its legitimate interests, described above, to process your data. Levell may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Levell’s use of your Personal Data for this purpose at any time.

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Data Protection Authority

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Subject to applicable law, you also have the right to (i) restrict Levell’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the Information Commissioner’s Office, through their website https://ico.org.uk.

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Contacting Levell

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Please also feel free to contact Levell if you have any questions about this Privacy Policy or Levell’s practices, or if you are seeking to exercise any of your statutory rights. You may contact us at support@levell.io with the subject “Feedback” in the subject line or at our mailing address below:

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Levell Holdings Limited
71-75 Shelton Street
London
WC2H 9JQ
United Kingdom