Last Updated: May 14, 2022
At Lavngarde, PBC (“Lavngarde”, “Company”, “we”, “our” or “us”), we believe in being clear and open about how we collect data related to you when you visit our website at www.lavngarde.com (“Website”) and/or download, access and /or use our mobile application (“App”), subscribe to our newsletter, participate in surveys, interact with us, participate in online advertisements or marketing emails, or engage with any other websites, pages, features, or content we own, operate and/or provide (collectively, the “Services”).
This Privacy Notice (“Privacy Notice”) is designed to help you understand how we collect, use, share and safeguard the information you provide to us and to assist you in making informed decisions when using our Services.
Company’s App is a mobile application that makes available to the user information about individuals that the user may encounter online. The App enables the user to perform background checks, schedule a time and location for a personal meeting with an individual and provide feedback after any meeting. The Website provides general information about the App, Company and other products and services offered by Company.
By accessing and using the Services, you consent to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Notice. The Services are intended for users located in the United States only, and you hereby expressly acknowledge and agree that if you are accessing and/or using the Services that you reside in the United States and will only access and/or use the Services in the United States. The use of the App is subject to the Mobile Application Terms of Service located at https://lavngarde.com/terms-%26-conditions.
Types of Data We Collect
We collect “Non-Personal Information” and “Personal Information” and the information we collect from you depends on how you use the Services. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. “Personal Information” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. This includes:
Types of Data
Primary Purpose for Collection
and Use Data
Website Visitor Information
We collect the name and email of our users if you contact us through the Website.
We have a legitimate interest in contacting our customers and communicating with them in relation to the Website.
User Account Information
We collect your name, mailing address, phone number, email address, date of birth, driver’s license information, profile photo, and location data, if you download and set up an account through the App.
We have a legitimate interest in contacting our customers and communicating with them in relation to the App.
Cookies and first party tracking
We have a legitimate interest in making the Services operate efficiently.
Cookies and Third Party Tracking
We participate in behavior-based advertising, this means that a third party uses technology (i.e.: a cookie, pixel or ‘LAL’) to collect information about your use of the Service so that they can provide advertising about products and services tailored to your interests.
We have a legitimate interest in engaging in behavior-based advertising, capturing website and mobile application analytics and engaging third parties to assist with providing Services to you.
We collect personal data from you contained in any inquiry you submit to us regarding the Services, such as completing our online forms, calling or emailing for the purposes of general inquiries, support requests, or to report an issue.
When you communicate with us over the phone, your calls may be recorded and analyzed for training, quality control and for sales and marketing purposes. During such calls we will notify you of the recording via either voice prompt or script.
We have a legitimate interest in receiving, and acting upon, your feedback, issues, or inquiries.
We collect information from your mobile device such as unique identifying information broadcast from your device when using the Services.
We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.
We collect information, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.
We have a legitimate interest in monitoring networks and the visitors to our Website, App and access and use of the Services to provide the Services and enhance the Services.
We collect personal information, such as your age or location.
We have a legitimate interest in understanding our users and providing tailored Services.
When you use our Website, App and/or Services we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location to better serve you.
We have a legitimate interest in understanding our users and providing tailored Services. In some contexts, our use is also based upon your consent to provide us with geo- location information.
Surveys and Questionnaires
We have a legitimate interest in understanding your opinions and collecting information relevant to our organization and the Services.
We collect public records information only with consent and in order to provide the Services.
Children’s Online Privacy Protection Act (“COPPA”)
Our Services are intended for use by individuals at least 18 years of age. Our Services are not designed for children under 18, and we do not intentionally or knowingly collect Personal Information from users who are under the age of 18 or from other websites or services directed at children. If we discover that a child under 18 has provided us with Personal Information, we will delete such information.
Information You Provide to Us
Collected via Technology
Use of Your Personal Information
In general, Personal Information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Information in the following ways:
Use of Non-Personal Information
In general, we use Non-Personal Information to help us improve the Services and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Services. This Privacy Notice does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion.
How We Share Your Personal Information
As a general rule, we do not sell, rent, lease or otherwise transfer any information collected either automatically or through your voluntary action. We may disclose your Personal Information as described below and as described elsewhere in this Privacy Notice.
Third Party Service Providers. We may share your Personal Information with third party service providers to provide you with the Services that we offer you; to conduct quality assurance testing; to perform marketing; to run data analysis; to facilitate creation of accounts; to provide technical support; and/or to provide future services to you. The third-party service providers we are engaged with and/or third-party products and/or services we use to provide the Services include without limitation:
Process Payments. We transmit your Personal Information via an encrypted connection to our payment processor, ‘Apple Pay’. To learn more about the payment processor we use and their policies related to privacy, learn more at https://www.apple.com/legal/privacy/data/en/apple-pay/.
Business Transfers. If (i) Company is acquired by, merges with, or receives investment from another company or (ii) if any of the Company’s assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your Personal Information with lenders, auditors, attorneys and consultants.
Other Disclosures. Regardless of any choices you make regarding your Personal Information (as described below), we may disclose Personal Information if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on us; (c) to protect or defend our rights or property, or the rights or property of users of the Services; (d) to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person and/or (e) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Notice, or any agreements you may have with us, as applicable.
Links to Third Party Websites and Third Party Providers
Your Rights Regarding the Use of Your Personal Information
We may send periodic promotional emails to you. You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional email. Please note that notwithstanding the promotional preferences you indicate by unsubscribing, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Notice. You may unsubscribe to promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 30 business days for us to process unsubscribe requests. If you unsubscribe from receiving promotional emails, we may still send you emails about the Services.
Your Rights and Choices
If applicable privacy laws allow, you may have rights over your Personal Information. This includes, but is not limited to:
You can make the following choices regarding your Personal Information:
Security of Your Personal Information and Personal Data
We implement security measures designed to protect your information from unauthorized access, alteration, disclosure and/or destruction. Because the internet is not a completely secure environment, we cannot warrant the security of any information a user transmits to us or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. Any account you have on our App is protected by your account password and we urge you to take steps to keep your Personal Information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures; however, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. While we use reasonable efforts to protect your Personal Information, we cannot guarantee the Services are absolutely secure.
How we Retain Your Personal Information
We will retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. The precise periods for which we keep your Personal Information vary depending on the nature of the information and why we need it. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use and/or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with a user) for research or statistical purposes in which case we may use this information indefinitely without further notice. We may retain information (including without limitation your personally identifiable information) for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. In some cases, if you choose not to provide us with requested information, you may not be able to use the Services. You can request further details of retention periods for different aspects of your Personal Information by contacting us.
Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized, or de-personalized information which we may retain indefinitely.
If you are visually impaired, you may access this Privacy Notice through your browser’s audio reader.
Changes to This Privacy Notice
We reserve the right to change this Privacy Notice or any agreement you entered into with Lavngarde from time to time. We may notify you of significant changes to this Privacy Notice by sending a notice to the primary email address specified by you or by placing a prominent notice on the Website and/or App and such changes shall take effect immediately. You should periodically check the Website and/or App and this Privacy Notice for updates.
Lavngarde is located in the United States. The Services are hosted in, provided from the United States, and intended for those that reside in the United States. Personal information that you submit through the Services may be transferred outside of the jurisdiction in which you live. Your Personal Information may be transferred to other jurisdictions that do not have the same data protection laws as the jurisdiction in which you initially provided the information. The following provisions may apply to you depending on where you are located.
This notice is provided to you pursuant to state law. Nevada state privacy laws permit us to make marketing calls to existing users, but if you prefer not to receive marketing calls, you may be placed on our internal opt-out list by emailing us at firstname.lastname@example.org or you may also contact the Nevada Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Ste 3900, Las Vegas, NV 89101; telephone 702-486-3132; email: AGCinfo@ag.nv.gov.
In accordance with Vermont law, we will not share information we collect about you with companies outside of Lavngarde except as described herein, or otherwise required or permitted by law.
This Section is only applicable to you if you are a resident of the state of Virginia (“Virginia Residents”). If you have a complaint, first contact us at email@example.com. We will respond within 45 days after receipt of your request, and such time may be extended for an additional 45 days if it is reasonably necessary. We will notify you of any extension within the initial 45-day period. If you are not satisfied with our responses, you have the right to appeal. We will respond within 60 days of receipt of your appeal. If you still have an unresolved complaint, please direct your complaint to the Virginia Attorney General at firstname.lastname@example.org or call (804)786-2071.
To the extent the California Consumer Privacy Act (“CCPA”) is applicable, this Section is only applicable to you if you are a resident of the state of California (“California Residents”) and only applies to Personal Information for which Company is a “Business” (as defined in CCPA), but does not apply to Personal Information we collect from you where you are an employee, owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit or government agency. It applies to Personal Information we collect from California Residents on or through our Services and through other means (such as information collected offline or in person).
Rights and Choices. Under the CCPA and subject to certain limitations and exceptions, if you are a California resident, you may have certain rights with respect to information we have collected about you that constitutes Personal Information under the CCPA as set forth herein. This Privacy Notice describes the Personal Information we collect about you. We collect this information for the purposes described herein and we share this information as described herein.
Exercising Your Rights. If you’re a California resident and desire to exercise your data protection rights, please contact us at email@example.com. You may be required to provide additional information necessary to confirm your identity before we can respond to your request, and we will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days from receipt of such request and will endeavor to respond within 45 days after receipt of your request, but if we require more time (up to an additional 45 days) we will notify you of our need for additional time. For requests that we not sell your information we will comply with your request within 15 days after receipt of such request. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm that the Personal Information relates to you. You may make a request for disclosure of our information collection practices, the information we collected about you, or our sharing practices up to twice within a 12-month period. You may make a request that we not sell information or for deletion of your information at any time. For requests for a copy of the Personal Information we have collected during the 12 months prior to your request we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your e-mail account on file, if you have an email address on file with us. For requests for deletion of your information, please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if (1) the information is necessary for us to (a) complete a transaction for you or otherwise perform a contract; or (b) detect, protect against, or prosecute security incidents, fraud or illegal activity; (2) we use the information only internally in ways reasonably aligned with your expectations as our customer, and (3) we are required to retain the information to comply with legal obligations. If we receive such a request from you, we will notify any service providers we have engaged and provided your information to delete your information as well.
Selling Information. We do not sell your information for monetary consideration, and we do not disclose your information for other valuable consideration. If, in the future, we enter into arrangements that fall within the definition of a ‘sale’ under the CCPA, we will update this Privacy Notice.
Using an Authorized Agent. You may submit a request through someone holding a formal ‘Power of Attorney’. Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorized the person to make the request on your behalf, (4) you verify your own identity directly with us, and (5) your agent provides us with proof that they are so authorized. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.
Categories of Information Collected. During the past 12 months we may have collected the following categories of information about California residents from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties. Please see more information below:
Categories of Personal Information That We Collect
To Whom We Disclose Personal Information for Business Purpose
Identifiers – this may include name, postal address, phone number, unique personal identifier, online identifier, IP address, device ID, email address, date of birth, profile picture, driver’s license information, location data or other similar identifiers.
Commercial information – this may include information about services purchased on the App, obtained, or considered, or other purchasing or consuming histories or tendencies.
Network activity data – this may include internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
Geolocation data – this may include precise physical location
Public Records – this may include traffic, criminal and arrest records
If you have any questions comments, or complaints concerning our privacy practices, please contact us by sending an email to firstname.lastname@example.org or send correspondence via mail to 2910 N. Powers Blvd., #346, Colorado Springs, CO 80922. We will attempt to respond to your request and to provide you with additional privacy-related information.
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Lavngarde PBC is proudly a Colorado company.