Information We Collect Directly From You

You can generally visit our Site without having to submit any personal information. If you request more information, or sign up for marketing communication and/or our Services, we will collect personal information as follows.

• Marketing Communications or Demo Requests. When you request a demo or sign up for marketing communications, we collect the following information:

• First and last name

• Business email address

• Job title

• Customer Account Information. When you register for a Lightup Customer account (including when you join for free), we request the following information:

• First and last name

• Email address

• Company name

• Title

• Communications. When you communicate with us, we collect information, including what’s contained in those communications.

Information We Process on Behalf of Our Customers

As noted above, our Services consist of data analytics for our Customers. These Customers may collect personal information from Customer End Users in connection with the products or services that they offer to Customer End Users and make some information – at their discretion – available to us in order to provide the Services. Such information is stored on our Customers’ systems or in the cloud, and our Customers are responsible for any personal information they collect.

Analytics

With the information that we collect (or that is collected by our third-party analytics services, such as Google Analytics), we generate and process aggregated information, such as statistical or demographic data (“Aggregated Information”). For example, we may track the total number of visitors to our Platform, track the number of visitors to each page of our Site. We aggregate this data to calculate the percentage of users accessing a specific feature of the Platform and analyze this data for trends and statistics. We do the same with the data that we process on behalf of our Customers. 

Aggregated Information may be derived from personal data, but is not considered personal data if it does not directly or indirectly reveal your identity. However, if we or our third-party analytics service providers combine or connect Aggregated Information with your personal data such that it can directly or indirectly identify or re-identify you, we treat the combined data as personal data.

Marketing and Advertising

We may partner with third-party ad networks to either display advertising on our Site or to manage our advertising on other sites. Our ad network partners use cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests, as also explained in our Cookie Policy.

If you wish to not have this information used for the purpose of serving you targeted ads, you may opt out by visiting  https://www.youronlinechoices.com/ or  https://optout.networkadvertising.org/?c=1 or set your browser to block cookies. Please note that opting out does not opt you out of being served generic ads.  

How We Use Personal Information That We Collect

We use your personal information for a number of different reasons, as further explained below.
In addition, for individuals located in the EEA and the U.K. and when we act as the data controller, we must have a valid legal basis in order to process your personal data. The main legal bases under the European Union’s General Data Protection Regulation (GDPR) that justify our collection and use of your personal information are:

• Performance of a contract – When your personal information is necessary to enter into or perform our contract with you.

• Consent – When you have consented to our use of your personal information via a consent form (online or offline).

• Legitimate interests – When we use your personal information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.

• Legal obligation – When we must use your personal information to comply with our legal obligations.

• Legal claims – When your personal information is necessary for us to defend, prosecute, or make a claim.

Below are the general purposes and corresponding legal bases (in brackets) for which we may use your personal information:

• Providing you access to and use of the Site and Services [depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims]

• Responding to your queries and requests, or otherwise communicating directly with you [depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims]

• Improving the content and general administration of the Platform, including system maintenance and upgrades, enabling new features, and enhancing both Site visitor and Customer experience [legitimate interests]

• Detecting fraud, illegal activities, or security, breaches [legitimate interests]

• Providing our Services to our Customers [depending on the context, performance of a contract, or legitimate interests]

• Ensuring compliance with applicable laws [compliance with a legal obligation]

• Conducting statistical analyses and analytics by monitoring and analyzing trends, usage, and activities in connection with the Platform [consent where required (e.g., third-party cookies), or legitimate interests]

• Increasing the number of customers who use our Platform through marketing and advertising, including sending commercial communications, in line with your communication preferences, [consent where required, or legitimate interests]

• Providing information to regulatory bodies when legally required, and only as outlined below in this Privacy Policy [legal obligation, legal claims, legitimate interests].

When We Share Information

We only disclose your personal information as described below.

Third-Party Service Providers
Lightup discloses users’ information to our third-party agents, contractors, or service providers who are hired to perform services on our behalf. These companies do things to help us provide the Site and Services. Below is an illustrative list of functions for which we may use third-party service providers:

• Hosting and content delivery network services 

• Analytics services 

• CRM providers

• Marketing and social media partners

• Functionality and debugging services 

• Professional service providers, such as auditors, lawyers, consultants, accountants, and insurers

Business Transfers

As we continue to grow, we may purchase websites, applications, subsidiaries, other businesses or business units. Alternatively, we may sell businesses or business units, merge with other entities and/or sell assets or stock, in some cases as part of a reorganization or liquidation in bankruptcy. As part of these transactions, we may transfer your personal information to a successor entity upon a merger, consolidation, or other corporate reorganization in which Lightup participates, or to a purchaser or acquirer of all or a portion of Lightup’s assets, bankruptcy included.

Lightup Customers

When we act on behalf of our Customers (as a data processor), we may process Customer End Users’ personal information to our Customers in order to comply with their requests, Customer End Users’ requests and/or regulator requests, among others. We also provide our Customers with aggregated information that does not identify Customer End Users directly, in order to provide information about usage, demographics (such as location) or other general information.

Anonymized Information

We share aggregated, automatically collected or otherwise non-personal information with third parties for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our users’ interests, habits and usage patterns for certain programs, content, services, marketing and/or functionality available through the Platform. We do not share personal information about you in this case.

Legal Obligations and Security

Lightup will preserve or disclose your personal information in limited circumstances (other than as set forth in this Privacy Policy), including: (i) with your consent; (ii) when we have a good faith belief it is required by law, such as pursuant to a valid subpoena, warrant or other judicial or administrative order (as further explained below); (iii) to protect the safety of any person and to protect the safety or security of our Platform or to prevent spam, abuse, or other malicious activity of actors with respect to the Platform; or (iv) to protect our rights or property or the rights or property of those who use the Platform. 

In the unlikely case that we are required to disclose personal information by law, such as pursuant to a subpoena, warrant, or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States or via mutual legal assistance mechanism (such as a treaty). Note that if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis. 

Social Media Plugins

We use social media plugins on our Site and include icons that allow you to interact with third-party social networks such as LinkedIn and Twitter. For example, you may follow us on LinkedIn or Twitter. The third-party social plugin may set a cookie when your browser creates a connection to the servers of such social networks and the plugin may transmit your personal information to the social networks. Your use of these social plugins is subject to the privacy policies of the third-party social networks.

“Do Not Track” 

Lightup does not respond to Do Not Track (“DNT”) browser signals. For more information on DNT settings generally, please visit https://allaboutdnt.com.

How to Change Your Communication Preferences

To keep your information accurate, current, and complete, please contact us at info@lightup.ai. We will take reasonable steps to update any information in our possession that you have previously submitted via the Platform. 

Note that you may also manage your communications preferences and the receipt of any commercial communication by clicking the “unsubscribe” link included at the bottom of all emails from Lightup. You may also adjust your preferences through your account settings if you have a Lightup account, or send an email to info@lightup.ai.

How Long Do We Keep Your Personal Information? 

We use the following criteria to determine our retention periods: 

• The amount, nature, and sensitivity of your information

• The reasons for which we collect and process the personal data

• The length of time we have an ongoing relationship with you and provide you with access to our Platform

• Applicable legal requirements. 

We retain personal information for as long as needed to provide our Services. Note, however, that with respect to our Customers with active accounts, we may retain certain essential account information, but otherwise regularly delete other information that is less essential to the provision of our Services in order to minimize our storage of data. 

We also will retain personal information that we’ve collected from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax, or accounting requirements). Additionally, we cannot delete information when it is needed for the establishment, exercise or defense of legal claims (also known as a “litigation hold”). In this case, the information must be retained as long as needed for exercising respective potential legal claims.

When we no longer have an ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible. When we choose to anonymize personal data, we make sure that there is no way that it can be linked back to you or any specific user.

Data Security And Integrity

We take steps that are reasonably necessary to securely provide our Platform. We have put in place reasonably appropriate security measures designed to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. We limit access to personal data only to those employees, agents, contractors, and the third parties who have a business need-to-know.

Notwithstanding, no Internet or email transmission is ever fully secure or error-free. In particular, email sent to or from the Services may not be secure. Therefore, take special care in deciding what information you send to us via email. For any questions about the security of your information, please contact info@lightup.ai.

International Transfers

Lightup is a United States Delaware corporation with primary storage of your information in the United States and the EEA. To facilitate our global operations, we may process personal information from around the world, including from other countries in which Lightup has operations, in order to provide the Platform. 

If you are accessing or using our Platform or otherwise providing personal information to us, you are agreeing to the processing of your personal information in the United States and other jurisdictions in which we operate. If you are a Customer, you are responsible for informing your Customer End Users of how and where their personal data will be processed at the time of collection.