Privacy Policy

Effective date: 28th August, 2019

We at Live Photos Solutions PLT. ("Live Photos", "we" "our" or "us"), understand that our users are concerned about how information that can be used to individually identify a person ("Personal Data") is collected and used. Please be assured that we take privacy very seriously and are committed to safeguarding Personal Data. This notice describes our Privacy Policy, which covers the Personal Data that we collect when you access Livephotos' website (the "Site") and use our products, services and applications (together with the Site, the "Services"), but does not cover the practices of companies we don't own or control, or people that we don't manage. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies described in this Privacy Policy and you agree to the collection, use, and disclosure of your information in the following ways.

This Privacy Policy is formulated in accordance with the Malaysia Personal Data Protection Act 2010 ("Act"), which describes how your information (“Personal Data”) is collected and used and your choices with respect to your Personal Data.

Remember that your use of Live Photos' Services is at all times subject to the Terms and Conditions ("Live Photos Terms"), which incorporates this Privacy Policy. Any capitalized terms that are not defined herein shall have the definitions set forth in the Live Photos Terms.

Types of Personal Data We Collect
We collect and maintain Personal Data on our Services when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

Information We Collect Directly From You: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

  1. Membership Registration Information: We collect the information you supply when you become a Member of the Services, for example, your name, address, phone, fax or e-mail address, login name, screen name, nickname or handle, and the password you select. This information may be edited at any time by logging into your member page.
  2. Preferences and Suggestions: We collect information and suggestions that you give to us, including information about your preferences.
  3. User Content: We collect user content that you provide to or through our Services, for example, comments and posts you submit or photographs, videos, or files you upload, and such user content can include Personal Data if you include Personal Data in such content.
  4. Publicly Posted Information: We collect information you post on public portions of the Services, and information that would be otherwise accessible by anyone with Internet access.
  5. Financial Information: If you become a Content Provider with the Services or purchase certain Services, you are required to provide financial information in the form of a valid credit card number and billing address.

Information We Receive From Third Party Sources: Some third parties such as social media companies like Facebook, LinkedIn, and/or Twitter provide us with Personal Data about you, such as the following:

  1. Account Information For Third Party Services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Facebook Connect or Twitter OAuth), or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.
  2. Information From Our Advertising Partners: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.
  3. Information From Other Users: We receive information about you when you interact with other Live Photos users in certain ways, such as if a user provides us with your email address in order to grant you access to an album.

Information We Automatically Collect When You Use Our Service: Some Personal Data is automatically collected when you use our Services such as the following:

  1. IP address
  2. Live Photos ID
  3. Geolocation data
  4. Device identification
  5. Type of browser and/or device you’re using to access our Services
  6. Page or feature you requested
  7. Information gathered through cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.).
  8. Page view statistics
  9. Usage information
  10. Transaction information (e.g. transaction amount, date and time such transaction occurred)
  11. Log data (e.g. access times, hardware and software information)

Cookies: Like many websites and mobile application operators, we collect certain information through the use of “cookies,” which are small text files that are saved by your browser when you access our Service. Cookies can either be “session cookies” or “persistent cookies”. Session cookies are temporary cookies that are stored on your device while you are visiting our Website or using our Service, whereas “persistent cookies” are stored on your device for a period of time after you leave our Website or Service. We use persistent cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Service, and how your use of the Service varies over time. We also use persistent cookies to measure the effectiveness of advertising efforts. Through these cookies, we may collect information about your online activity after you leave our Service. For more information on cookies, including how to control your cookie settings and preferences, visit ec.europa.eu/ipg/basics/legal/cookies, ico.org.uk/for-the-public/online/cookies and allaboutcookies.org.

Some cookies are placed by a third party on your device and may provide information to us and third parties about your browsing habits (such as your visits to our Services, the pages you have visited and the links and advertisements you have clicked). These cookies can be used to determine whether certain third party services are being used, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. We do not control third party cookies.

Use of Personal Data
We use Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

  1. Communicate with you about the Services if you’ve provided us the means to do so. For example, if you’ve given us your email address we may contact you about promotions, products or services that we believe may be of interest to you, or email you about your use of the Services. If you prefer not to be contacted with this information, please send an e-mail to support@livephotos.my.
  2. Bill you for future membership fees and/or services in accordance with the Terms and Conditions.
  3. Track user activity so that we may better understand your preferences
  4. Personalize website content and communications based on your preferences
  5. Respond to user inquiries
  6. Create and manage user profiles
  7. Process and fulfill orders
  8. Contact you about Service announcements, updates or offers
  9. Provide support and assistance for the Services
  10. Meet contract or legal obligations
  11. Fulfill user requests
  12. Comply with our legal or contractual obligations
  13. Resolve disputes
  14. Protect against or deter fraudulent, illegal or harmful actions
  15. Enforce our Terms and Conditions

HOW, AND WITH WHOM, IS YOUR INFORMATION SHARED?
We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

  1. Credit card payment processing company to bill you for services
  2. Fraud prevention service providers
  3. Ad networks
  4. Analytics service providers
  5. Staff augmentation and contract personnel
  6. Hosting service providers
  7. Co-location/Dedicated Server/Cloud Hosting service providers
  8. Telecommunications service providers

We will not sell your Personal Data to any third party, provided certain Personal Data may be transferred in connection with business transfers as described below.

Business Transfers

Furthermore, if we choose to buy or sell assets, we may share and/or transfer Personal Data in connection with the evaluation of and entry into such transactions. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.

Aggregate Data

We provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person. We also, from time to time, de-identify your Personal Data so that you are not identified as an individual, and provide that information to our partners.

What Happens if You Disclose Your Personal Data in Public Areas on the Site?
We have no control over and cannot protect Personal Data that users disclose in public areas such as a photographer's or agency profile. If you disclose your Personal Data in public areas, it may be collected and used by third parties, without our or your knowledge.

SECURITY
Our Site uses Secure Sockets Layer (SSL) to ensure secure transmission of your personal data. You should be able to see the padlock symbol in the status bar on the bottom right hand corner of the browser window. The url address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your computer or device and the connecting server. Any data transmitted during the session will be encrypted or scrambled and then decrypted or unscrambled at the receiving end. This will ascertain that data cannot be read during transmission.

Furthermore, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Data by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

Is Your Personal Data Secure if You Link to Other Web Sites?
The Services contain links to sites operated by third parties that are not under the control or supervision of Live Photos. Neither Live Photos nor its directors, officers, employees, shareholders, members or representatives are responsible for the privacy policies and practices of these sites. Once you have left our Services, our privacy policy no longer applies. You must read the privacy policy of the other site to see how your Personal Data will be handled on the third party site.

DATA RETENTION
We retain Personal Data about you for as long as it remains relevant. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

We reserve the right to access, read, preserve and disclose any information we retain that we reasonably believe is necessary to comply with law or court order, to enforce or apply our Terms and Conditions and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others.

YOUR PRIVACY RIGHTS
As an individual you may exercise your right to access the data held about you by Live Photos by submitting your request in writing to the data controller.

Although all reasonable efforts will be made to keep your information updated, you are kindly requested to inform us of any change referring to the personal data held by the association.

In any case if you consider that certain information about you is inaccurate, you may request rectification of such data. You also have the right to request the blocking or erasure of data which has been processed unlawfully.

CHANGES TO THE PRIVACY POLICY
We may change and modify the Privacy Policy from time to time. We will alert you to changes by placing a notice on the Services, by email to your email address and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you continue to use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

CONTACT US
We invite you to contact us with any questions or comments regarding your Personal Data, our Privacy Shield Certification, or our data practices generally. Please contact us if you have any questions regarding your privacy.