1. THE LEGAL BASIS ON WHICH LIVECODE LTD COLLECTS YOUR PERSONAL DATA
LiveCode Ltd collects and processes your Personal Data on the basis of different legal grounds, depending on the nature of the Personal Data being provided and the type of processing involved. More information is provided on this here.
1.1 Performance of a Contract
Most of the Personal Data processing by LiveCode is performed on the basis that it is necessary for the performance of our agreement with you, or in order to take steps at your request prior to entering such an agreement. For example, if you download or purchase software from us, we need your contact details to fulfill that contract.
1.2 Legitimate Interest
A second ground relied upon by LiveCode Ltd. for other types of processing of your Personal Data is that it is necessary for the purposes of legitimate interests pursued by LiveCode Ltd. Such legitimate interests will include where we send you marketing about our products and services, where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, or where such processing is necessary for fraud detection and prevention.
1.3 Compliance with a Legal Obligation
A third ground relied upon for certain types of processing is that it is necessary in order to allow LiveCode Ltd comply with a legal obligation. An example of this would be where we are required to retain business records for fixed periods of time in order to comply with local legal requirements.
1.4 Consent
Finally, in certain limited situations, LiveCode Ltd may rely on your consent in order to process your Personal Data. Where we require your consent in order to collect and process certain Personal Data, we will seek your consent at the time of provision, and such processing will only be performed where consent is secured. For example, your consent would be sought if we were tracking specific actions within the LiveCode product, in order to analyze use patterns to improve the product.
2. USING YOUR PERSONAL INFORMATION
2.1 LiveCode Ltd. will use your personal information for the following purposes:
- to identify you when you contact us;
- to supply products and services you request or purchase from us
- to help identify accounts, services and/or products which you could have from us or selected partners from time to time;
- to help administer, and contact you about improved administration of, any accounts, services and products we have provided before, or provide now or in the future;
- to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information;
- to help to prevent and detect fraud or loss;
- to contact you in any way (including mail, email, telephone, text or multimedia messages) about products and services offered by us and/or selected partners.
2.2 We may allow other people and organisations to use information we hold about you for the purpose of providing services you have asked for, as part of the process of selling our business, or if we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings. From time to time, these service providers and organisations may be outside the European Economic Area in countries that do not have the same standards of protection for personal data as the UK. We will, however, always use every reasonable effort to ensure sufficient protections are in place to safeguard your personal information.
2.3 Specific partners we work with:
- Cleverbridge provide payment processing services for us. They are within the EU, subject to and compliant with the provisions of the GDPR directive. You may read their privacy policy here: https://www.cleverbridge.com/corporate/privacy-policy/
- Liquidweb provide servers for our LiveCode Hosting service. They are located in the US, and while they are not directly subject to the GDPR directive, they are compliant with it. You can read their privacy policy here: https://www.liquidweb.com/about-us/policies/privacy-policy/
- Mailchimp provide mailing services for us. They are located in the US, are GDPR compliant and you can read their privacy policy here: https://mailchimp.com/legal/privacy/. Note that the section that would apply to you as a customer of ours would be “Privacy for Contacts”.
- Survey Monkey provide survey services for us. They have a number of locations, are GDPR compliant, and you can read their privacy policy here: https://www.surveymonkey.com/mp/legal/privacy-policy/. The section relevant to your data would be “Respondents”.
- Tawk.to provide live chat services on our website. They are based in the US, and they have the following GDPR compliance addendum to their privacy policy: https://www.tawk.to/data-protection/dpa-data-processing-addendum/
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Third Party Processors
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
“Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.
2.4 We may check your details with fraud prevention agencies. If you provide false or inaccurate information and we suspect fraud, we will record this. We may use and search these records to trace debtors, recover debt, prevent fraud and manage your accounts.
2.5 Where you give us information on behalf of someone else, you confirm that you have provided them with the information set out in these provisions and that they have not objected to such use of their personal information.
2.6 Client Data Access in LiveCode
LiveCode Ltd does not and will never access or include tools to access any end user client data that is handled by LiveCode built apps. Any data used, accessed, transmitted or downloaded by such LiveCode built apps is the sole province of the creator of such apps, and LiveCode Ltd has no sight of it in any way. LiveCode Ltd does not accept any responsibility for the security or otherwise of such data.
3. THE INTERNET
3.1 If you communicate with us using the Internet, we may email you about our services and products. When you first give us personal information through our website, you will be asked to confirm your consent to being on our mailing list by a double opt-in process. You can opt out of promotional mailings at any time by clicking the unsubscribe link in the emails, or by contacting us at support@livecode.com. We may still send you communications relating directly to products you have purchased from us eg information about a new release you are entitled to, or information relating to your subscription.
3.2 Please remember that communications over the Internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered – this is the nature of the Internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
3.3 We may use ‘cookies’ to monitor how people use our site. This helps us to understand how our customers and potential customers use our website so we can develop and improve the design, layout and function of the sites.
A cookie is a piece of information that is stored on your computer’s hard drive, which records how you have used a website. This means that when you go back to that website, it can give you tailored options based on the information it has stored about your last visit. You can normally alter the settings of your browser to prevent it from accepting cookies.
3.3.1 Google Cookies
1. Analytics : This allows us to see information on user website activities including, but not limited to page views, source and time spent on website. The information is depersonalized and is displayed as numbers, meaning it cannot be tracked back to individuals. This will help to protect your privacy. Using Google Analytics we can see what content is popular on our website, and strive to give you more of the things you enjoy reading and watching.
2. AdWords : Using Google AdWords code we are able to see which pages helped lead to contact form submissions. This allows us to make better use of our paid search budget.
3. Remarketing : We use remarketing code to log when users view specific pages, allowing us to provide targeted advertising in the future. This data is retained for 30 days.
4. YOUR RIGHTS
LiveCode Ltd. users that provide their Personal Data in the EU, and those that provide their Personal Data in any other jurisdictions that adopt laws affording equivalent protections to those in the EU, may avail themselves of the rights detailed below.
4.1 The Right to Rectify Your Personal Data
You are able to edit and update most of your Personal Data held by LiveCode Ltd. by logging in to your account on livecode.com. If you have any queries or complaints we encourage you to contact us at support@livecode.com
Alternatively, if you do not wish to do this you may make a formal request to have LiveCode Ltd rectify any inaccurate Personal Data on your behalf by sending an email to support@livecode.com from the email address associated with your account.
4.2 The Right to Object to or Restrict the Processing of Your Personal Data
If you have any queries or complaints about how we process your Personal Data please contact us at support@livecode.com
4.3 The Rights of Access to and Portability of Your Personal Data
You are able to edit and update most of your Personal Data held by LiveCode Ltd. by logging in to your account on livecode.com. If you have any queries or complaints we encourage you to contact us at support@livecode.com
Alternatively, if you do not wish to do this you may make a formal request to access your Personal Data held by LiveCode Ltd. In order to do so, please send an email to support@livecode.com from the email address associated with your account, and put “I am requesting to access my personal data.” in the subject line. LiveCode Ltd. will provide your Personal Data to you in a portable format to allow it to be transmitted to third parties.
4.4 The Right to Delete Your Personal Data
You may make a formal request to delete your Personal Data held by LiveCode Ltd. In order to do so, please email support@livecode.com from the email address associated with your account, with “I am requesting to delete my personal data” in the subject line. Once your request has been confirmed, LiveCode Ltd. will initiate the necessary steps to execute this exercise, including the deletion of your LiveCode account. PLEASE NOTE: by requesting the deletion of your Personal Data, any products or services associated with the account will also be deleted, you will lose the right to access them.
4.5 Some Limitations
Such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. For example we may still retain information in our records for tax and accounting purposes, if you have purchased a product from us.
Individual requests will be completed within the time allotted by relevant regulations, which starts to run from the point of LiveCode Ltd. confirming your request.
5. CHILDREN
LiveCode Ltd. does not aim products and services at children under 13. Any users under this age limit must seek parental consent to create an account on our website.
6. LINKS
This website may contain links to other sites or recommended suppliers. Please remember that we are not responsible for the privacy practices of these other sites. This privacy policy applies only to information collected on this website.
If you would like any more information or you have any comments about our privacy policy, please email webmaster@livecode.com.
Or you can write to us at:
LiveCode Ltd
9-10 St Andrews Square
Edinburgh
Scotland
UK
EH2 2AF
7. Our European Representative is Panagiotis Merakos, based in Athens, Greece. You can contact him by emailing support@livecode.com.