1 Introduction
1.1 When you visit livetoplay.online, we will collect and process personal information about you, such as cookies and IP address. Below we have described what personal data we process about you, the purpose, the legal basis for the processing and your rights in connection therewith. This applies to you both as a consumer and as an employee of one of our partners and customers.
2 Data Controller
2.1 Livetoplay, Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 5, 10145, Estonia is the Data Controller (referred to herein as “we”, “us” or “our”). This means that we are responsible for your personal information.
3 The purpose and basis for collecting personal data
3.1 We will ensure that your personal information and data is collected and processed solely for the following purposes:
- (a) to promote and/or deliver products and services that you have ordered;
- (b) to answer any questions or objections you may have;
- (c) to prevent abuse and fraud;
- (d) to notify you of any changes in our services;
- (e) for you to be able to partake in competitions and campaigns;
- (f) if you consent to marketing, we may use both first-party data (e.g., your purchase history and website activity) and marketing cookies (third-party tracking) to provide you with relevant offers and recommendations. You can update your preferences at any time;
- (g) to provide you with information about the actual products and services as well as products and services similar to these, you have previously bought, redeemed to or contacted us about;
- (h) to be able to exchange and redeem a gift card;
- (i) if you consent to marketing cookies (cookies from third party) we transfer information about you, including your IP address, to partners and other third parties to be used for direct marketing;
- (j) to improve our website, products and services;
- (k) to improve on security;
- (l) if you consent to preference- and statistics cookies: To improve our website, products and services, and we transfer information about you, including your IP address, to third parties such as Google Analytics to compile statistics on i.e. your behaviour on our website;
- (m) to retain personal data to the extent necessary to comply with the Accounting Act, the Consumer Agreement Act and any other legal obligations livtoplay may have.
- (n) if you consent to marketing, we may use first-party data, such as your purchase history, browsing behavior on our website, and previous interactions with our services, to personalize and send you relevant marketing messages about our products and services;
- (o) to share your personal data, including your IP address, with our third-party service providers who assist us with website operations and payment processing. These providers are authorized to use your information only as necessary by law and to provide these services to us;
- (p) to disclose your information if required by law or to protect our legal rights. We never sell your personal information to third parties.
3.2 Our basis for processing is:
- (a) The processing is necessary to fulfil a contract, of which you are a party in the context of the purposes.
- (b) The processing is based on the consent you provide in connection with the purposes stated in Sections 3.1 e-g, i, l, and n, including the use of first-party data for personalized marketing.
- (c) The processing is necessary for us to be able to pursue our legitimate interests, in particular to improve user experience, security as well as prevent fraud and abuse in connection with the purposes described in Sections 3. c, j-k, o and p.
- (d) The processing is necessary for compliance with a legal obligation to which we are subject for the purposes described in Sections 3.1 h, m, o and p.
3.3 We store your personal information
- (a) up to five (5) years from the purchase of the gift or gift voucher from us, to be able to prove our compliance with Estonian Bookkeeping Act and the Estonian Consumer Contracts Act. This applies to name, address and international VAT number for business customers, as well as e-mail or telephone number for use in contact with the customer or exchange of gift cards.
- (b) If you withdraw your consent to marketing, we delete your personal information from our marketing lists, however, we keep documentation of your consents given for 2 years after the withdrawal.
- (c) Where processing is based on your consent to cookies, we store your personal information for as long as we process your personal information for this purpose. The storage period will depend on the type of cookies and the expiration of the individual cookies.
- (d) up to 90 days in connection with greetings, after which these are automatically deleted from the system. This is only relevant for orders where the buyer has attached a greeting to the order.
4 Categories of Personal Information Used
4.1 We will process and store personally identifiable information about you such as your name, address, telephone number, email address, financial and payment card information, IP address or other personally identifiable information which you voluntarily disclose when visiting/using our websites and using our services our services in general.
5 Your Rights
5.1 If you have any questions regarding our processing of your personal information, please contact us via the contact details.
5.2 You can access your personal information at any time and request us to correct, delete or change any incorrect personal information by contacting us via the contact details given in Section 10 below. You can also request us to limit the processing, for data portability or object to our processing of your personal information.
5.3 If you wish to appeal against our processing of your personal information, please contact the Estonian Data Protection Agency.
5.4 You have the right to object to the processing of your personal data for direct marketing purposes, including the use of first-party data for personalized marketing messages. You can unsubscribe from these communications via the link in our emails or by contacting us as set out in Section 10 below.
5.5 To the extent that our processing of your personal data takes place on the basis of your consent, you have the right to withdraw your consent at any time by contacting us via the contact information described in Section 10 below, or revoking or changing your cookie consent by updating your choices in the consent banner through the link “Update your cookie consent” found in the footer on livetoplay.com
6 Personal Information — Children
6.1 We only process personal information about children under the age of 15 if there is an adult user ordering gifts or a gift voucher for a child. In this case, the information is used solely for delivering the gift voucher.
7 Transfer of Personal Information
7.1 Transfer of personal information to affiliates and to professional advisers may take place in accordance with applicable data protection legislation.
7.2 Only trusted employees, agents and suppliers with work-related needs, in accordance with applicable data protection legislation, have access to your personal information to the extent that is necessary for providing a service to us or acting on our behalf.
7.3 We reserve the right to use or disclose information to the extent that is necessary for complying with the applicable legislation, carrying out investigations in relation to complaints, protecting the integrity of the site, responding to your requests or for investigative purposes.
7.4 Transfer of personal information is done in accordance with applicable data protection legislation, including the conclusion of data processing agreements with our data processor in order to ensure that personal data will be treated only for the specified purposes and ensure adequate security measures.
7.5 Personal information we have collected from you may be transferred to countries outside the EU/EEA (“EEA”). If personal information is transferred outside the EEA, we will ensure that it is either transferred to countries which the Commission has determined have a sufficient level of security or by entering into contracts between us and the non-EEA entity receiving the personal data.
8 Securing your Personal Information
8.1 We will take care of your personal information by taking the necessary technical and organisational security measures to prevent information being accidentally or illegally destroyed, lost or damaged, and to prevent unauthorised persons obtaining knowledge of this information or otherwise treating it in violation of the applicable data protection legislation.
9 Updating the Privacy Policy
9.1 We reserve the right to update or amend this Privacy Policy from time to time to reflect changes in our practices or other operational, legal or regulatory reasons without further notice. You are, therefore, encouraged to revisit this website on a regular basis to ensure that you are familiar with the content. Any updates or changes will take effect upon publication on the website. Your access, browsing or other use of the website constitutes your acceptance of the Privacy Policy.