Privacy Policy
Overview
Your privacy is important to Lightness, and UfficioEnergia S.r.l. (“Lightness”, “we” or “us”). It is our policy to respect the privacy of our users regarding all information we may collect while operating our Services (defined in our Terms and conditions). This privacy policy applies to our Services. This privacy policy sets forth what information we collect about users of the Services and explains how that information is used and protected. We are committed to protecting and respecting your data privacy. We make no compromises regarding your privacy and strive to be transparent in the way we are processing your data. We are in compliance with the EU’s General Data Protection Regulation (“GDPR”) and Italian’s data protection law. Any questions regarding data protection can be addressed to info@lightness.app
Lightness’ data privacy goals are:
- Classify all data for proper security, transparency and fairness
- Policy enforced data privacy
- Empower users to control via opt-in the use, collection and deletion of their Personal Information
- Ensure users always know for what purpose their Personal Information will be used
- Compliance with GDPR (General Data Protection Regulation 679/2016)
Lightness is encrypted via HTTPS, and we encrypt and/or hash all sensitive information while in motion or when stored at rest, including emails, passwords and private messages and payment data.
Lightness does not ask you for Personal Information unless it is required to provide certain features of the Services including, but not limited to user rewards, password reset, payments for Lightness Token/subscription sales data collection for certain purchasers.
Lightness does not will fully disclose the Personal Information of our users to anyone except to comply with applicable law or protect our rights.
Anonymity or Pseudonymity
As a cornerstone to our privacy policy, Lightness users have the right, to be anonymous or use a pseudonym. Certain features of the Services may require you to submit information (including Personal Information, which is defined below) as a condition to use certain features of the Services. We collect your Personal Information when voluntarily submitted by you. The Personal Information you provide is used to create user account and login credentials for the purpose of using certain features of the Services and/or fulfilling your specific requests, unless you give us permission to use it in another manner. We will not collect your Personal Information, except the email, birthdate, full name or nickname and your country for create your account, unless you give it to us. “Personal Information” means any information that is classified as sensitive because it is personally identifiable such as a verified name, fingerprints or other biometric data, street address, telephone number or social security number. Since anonymous data is de-identified by definition, and registration on Lightness can be anonymous or pseudonimous, Lightness classifies nearly all APP data as public. All non-public data is either encrypted or hashed.
Exceptions to the public default data classification include the following:
- Logged-in users. Data is accessible to logged-in users only
- Unlisted data. Data is classified as public, but it is not indexed and not accessible to anyone without knowledge of the URL.
- Personal data. Data that is personally identifiable such as email address, one to one chat history is classified as sensitive and therefore encrypted by policy when in motion or stored at rest.
Gathering of Personal Information
Certain visitors to Lightness’ app choose to interact with Lightness in ways that require Lightness to gather Personal Information. The amount and type of information that Lightness gathers depends on the nature of the interaction.
For example, we may ask visitors who engage in transactions with Lightness to provide additional information, such as necessary personal or financial information required to process those transactions. In each case, Lightness collects such information only insofar as is necessary or appropriate to fulfil the purpose of the user’s interaction with Lightness.
Lightness databases are architected store Personal Information in raw form or readable to anyone including Lightness staff. Lightness does not disclose Personal Information other than as described herein. And user may be anonymous on Lightness or opt-out and refuse to supply Personal Information under the caveat that they understand it may prevent them from engaging in certain app related activities.
There are four categories of sensitive information that is deemed Personal Information which may be collected and stored by Lightness:
- Email address. Lightness stores and uses your email address to provide secure access to the app. Lightness uses your email to facilitate the Forgot Password function and to keep users updated. Lightness may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with Lightness and our products.
In all promotional emails, you will be given the opportunity to opt-out of receiving such messages in the future by clicking on the link at the bottom of the email that says “unsubscribe.”
Even if you have unsubscribed from receiving promotional emails from us, we may send you other types of important email communications without offering you the opportunity to opt-out of receiving them, such as administrative notices, or Services-related communications (e.g., account verification, payment confirmations, technical and security notices). - Personal information. Full name and username, city and birth date.
- Chat history. Lightness messenger between users and their whole chat history.
- Machine dependent data. Lightness may require access to services on your mobile device such as a microphone or camera to record a video on the mobile application. We do not store IP addresses on Lightness, and we do not use any such data for anything other than the stated purpose of providing utility to deliver the stated Lightness Services.
Website and App Visitors
Lightness has a mission to become free from all dependencies on third-party, proprietary software and infrastructure. However, from time to time we may use one or more third-party services to improve certain services on our network. In order to provide you with the Services, we may share your Personal Information with certain authorised providers of third-party services (“Authorised Third Parties”) who are authorised to act on behalf of Lightness in connection with the Services. Our agreements with any such Authorised Third Parties states that they will not use any Personal Information received from us for any purpose other than performing services on our behalf.
Like most operators, Lightness also collects non-personally-identifying information of the sort that browsers and servers typically make available, such as the IP, the browser or device type, language preference, referring site, and the date and time of each visitor request. Lightness’ purpose in collecting non-personally identifying information is to better understand how Lightness’ visitors use its app. From time to time, Lightness may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website and application.
Open Data
Lightness may collect statistics about the behaviour of visitors to its website and app. For instance, Lightness may monitor the most popular channels, groups or activity on the site and app. Lightness may display this information publicly or provide it to others as de-identified data. However, Lightness does not disclose Personal Information of any kind other than as described herein.
Disclosure and Protection of Personal Information
Lightness discloses certain potentially Personal Information only to those of its employees, contractors and affiliated organisations that (i) need to know that information in order to process it on Lightness’ behalf or to provide services to Lightness or its’ websites and app, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organisations may be located outside of your home country; by using Lightness’ websites, you consent to the transfer of such information to them.
Notification and Disclosure of Breach
Lightness will notify users immediately if we believe their Personal Information is disclosed in any unauthorised way.
Although Lightness provides reasonable administrative, physical and electronic security measures to protect Personal Information from unauthorised access, we cannot assure the security of any information you transmit or guarantee that this information will not be accessed, disclosed, altered, or destroyed.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted personal Information. To the extent the law of your jurisdiction allows for notification of a breach via e-mail or public posting, you agree to accept notice in that form.
If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users.
Cookies
A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Lightness requires cookies to identify and validate sessions, ensure security and to improve the experience of the end users. Lightness visitors who do not wish to have cookies placed on their computers should set their devices to refuse cookies before using Lightness’, with the drawback that certain features of Lightness’ websites may not function properly without the aid of cookies.
How Long We Keep Your Information
Personal Information that you provide to the Services may be retained indefinitely, to the extent it is consistent with the Terms of Use and applicable law. Lightness may in its discretion elect to retain Personal Information only while deemed necessary for business, legal and tax purposes.
Government, Regulatory Agencies, Courts, and Law Enforcement
We may access, preserve, and share any information about you, without your consent, to government or law enforcement officials or private parties if we believe in good faith that it is necessary or appropriate to respond to requests, claims and legal process (including, but not limited to, subpoenas), to comply with applicable laws, to protect the property and rights of Lightness, you or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to pose a risk of being, or is, illegal, unethical or legally actionable.
We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of audits, inquiries or investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
If you voluntarily share or submit any information (e.g., name) or content (e.g., pictures), or commentary (e.g., lanterns or chats) through the Services, or link it to any social media platforms, you acknowledge that the post and any content or information associated with it may become available to the public
Business Transfers
If Lightness, or substantially all of its assets, were acquired, or in the unlikely event that Lightness goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Lightness may continue to use your Personal Information as set forth in this policy. At any time users are able to delete all content and personally identifiable information from the site or app.
Children’s Privacy
Lightness does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Services. The Services and their content are not directed at children under the age of 13. In the event that we learn that we have collected Personal Information from a child under age 13 without parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact Lightness at info@lightness.app
All explicit or sensitive content exists behind multiple filters and it is strictly against the Terms for anyone under 18 to access such content.
Other Web Sites and Services
The Services may contain links to other websites or services that we do not own or operate. We are not responsible for the practices employed by any websites or services linked to or from the Services, including the information or content contained within them. Your browsing and interaction on any third-party website or service, including those that have a link on our Services, are subject to that third party’s own rules and policies, not ours. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorise to access your Personal Information. If you are using a third-party website or service and you allow them to access your Personal Information you do so at your own risk.
International Considerations
We have developed data practices designed to assure all Lightness information is appropriately protected, but we cannot always know where Personal Information may be accessed or processed. While our primary facilities are in Europe, we may transfer Personal Information or other information to facilities outside of the Europe. In addition, we may employ other companies and individuals to perform functions on our behalf. If we disclose Personal Information to a third party or to our employees outside of Europe, we will seek assurances that any information we may provide to them is safeguarded adequately and in accordance with this Privacy Policy and applicable privacy laws.
Your Data, your Rights
Adhering to the GDPR we rely on your consent in many instances to process your data. We fully acknowledge and enforce the following rights to your data:
- You may withdraw that consent to store your data at any time without providing a reason.
- You may request access to your personal data and receive copies (in a portable format if possible) of it.
- You may have inaccurate or incomplete data corrected or updated.
- You can limit or restrict our use of your data and you can stop us using all of your personal data.
- You have a right to be forgotten, in other words you can request that we delete your personal data. We will honour these requests unless we have to retain data to comply with any legal obligations or have an overriding interest to retain it.
You have the right to submit a complaint about the rights to your data to your local data protection authorities. In Italy the authority is Garante Per la Protezione dei Dati Personali, Piazza Venezia n. 11 – 00187 Roma – phone : (+39) 06.69677 – Fax: (+39) 06.69677.3785 email: protocollo@gpdp.it PEC: protocollo@pec.gpdp.it (only for PEC to PEC)
If you want to exercise any of these rights you can reach us via email at: info@lightness.app. For your protection, we may ask you to provide proof of identity before we can answer the above requests.
Privacy Policy Changes
Although most changes are likely to be minor, Lightness may change its Privacy Policy from time to time, and in Lightness’ sole discretion. Lightness encourages visitors to frequently check this page for any changes to its Privacy Policy. Your continued use of this site/APP after any change in this Privacy Policy will constitute your acceptance of such changes.
Contact
Lightness app by Ufficio Energia s.r.l.s.
Via Popilia 67 – 87100 – Cosenza (CS)
info@lightness.app
You can also reach us to our privacy compliance consultant at
info@gdpr-ok.it