Privacy Policy

Welcome to www.lightup.ai (“Site”), hosted by Lightup Data, Inc. (“Lightup”, “we”, “us” and/or “our”). Lightup provides data analytics services (“Services”). In order to provide our Site and Services (collectively, “Platform”), we collect personal data from our corporate customers (“Customers”).

Throughout this Privacy Policy, “personal information” or “personal data” refers to any information that is unique to an individual, such as name, address, email address, phone number, IP address and other information that can reasonably identify an individual.

This Privacy Policy, along with our Cookie Policy, covers how we collect, handle, and disclose personal data on our Platform, including any affiliated websites, software, or platforms owned or operated by Lightup on which this Privacy Policy appears.

We recommend that you read this Privacy Policy and our Cookie Policy carefully as both provide important information about your personal information and your rights under the law. If you have any questions, comments, or concerns regarding this Privacy Policy, our Cookie Policy and/or our data practices, or would like to exercise your rights, do not hesitate to contact us at info@lightup.ai or see our information below.

If you are an end user (“Customer End Users”) of a Customer website that is running services provided by Lightup, the Customer End Users section of this Privacy Policy applies to you.

Summary of Key Points

We collect and process personal information from visitors to our Site in connection with our Services.

• • This Privacy Policy only applies to Lightup’s collection and use of personal information. If you have questions about our Customers’ collection of personal information from Customer End Users in connection with your use of their respective website(s) or platform(s) and the Services, please contact them directly.

• • Lightup collects personal information when you visit our Site, sign up for marketing communications, register as a Customer, and/or otherwise share information with us.

• • Lightup uses the personal information that you share or that we collect to provide our Platform, to enhance our Site, to market the Services to you, for security purposes, and to comply with applicable laws, regulations, and other legal requirements. 

• • We share personal information with certain authorized third parties (including our Customers), in connection with providing our Site and Services. Third party ad networks also collect certain personal data, which is deemed the sale or sharing of that personal data in some cases.

• • Lightup uses cookies and other tracking technologies to track your use of our Site and your use of our Services. Our Cookie Policy describes how you can opt out of our use of these technologies.

• • If you are located in a jurisdiction that provides data subject rights (such as European Economic Area (“EEA”), the United Kingdom (“U.K.”), Switzerland and certain US states), the Section titled “Additional Information Regarding Data Subject Rights” below, provides more detailed information about which rights you have regarding the processing of your personal data.

• • California law and potentially laws in other jurisdictions require disclosure of the categories of personal information we have collected in the past 12 months, the categories of data sources from which we collected personal information, and the categories of recipients to which we have disclosed, sold or shared personal information. That information is provided in the relevant sections of this policy below.    

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Who We Are and How To Contact Us

Lightup is a Delaware corporation with the following contact information:

Lightup Data, Inc.
548 Market St., PMB 172070 , San Francisco, California 94104-5401
info@lightup.ai 

We may collect your personal data as a ‘data controller’ or a ‘business’ (and equivalent terms under other applicable laws) when we determine the means and purpose of processing, such as when we process the personal data of our Site Visitors and/or Customers.

We otherwise process personal data as a ‘data processor’ or ‘service provider’ when we collect and process End User personal data on behalf of our Customers who use our Services. In other words, with respect to personal information that we process in order to provide Services to our Customers, we are acting as a service provider. Customer End Users may click here for more information.

To Whom Does This Policy Apply

This Privacy Policy does not cover our Customers’ websites or platforms. Each Customer is responsible for posting its own terms, conditions and privacy policies, and ensuring compliance with all applicable laws and regulations.

This Privacy Policy applies to:

• Customers: as noted above, this includes any individual who registers individually or on behalf of an entity or organization in order to use the Services.

• Site Visitors: visitors to our Site, including those who request a demo or opt in to receive commercial communications from Lightup. This does not include any visitors to our Customers’ individual websites.

Customer End Users

This Privacy Policy does not apply to the data that Lightup processes on behalf of our Customers in our capacity as a processor. Lightup may process Customer End User data on behalf of its Customers, however our Customers are responsible, as data controllers, for how and why they collect and process their End User personal data. Our privacy practices will be governed by the contracts that we have in place with our Customers, not this Privacy Policy. Please review Customers’ respective privacy policies, which will contain further details regarding the processing of your personal data by Lightup. If an End User sends a request to Lightup to access, correct, update, or delete his/her information, or no longer wishes to be contacted by a Customer that uses our Services, we will direct that End User to contact the Customer directly and/or advise the Customer of the request, and cooperate with our Customers as required by applicable law in order to ensure that our Customers satisfy their Customer End Users’ requests.

Children’s Privacy

Lightup does not knowingly collect information from children under the age of 18. If you are under the age of 18, please do not submit any personal data through the Platform. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal data on our Platform without their permission. 

If you have reason to believe that a child under the age of 18 has provided personal data to Lightup through the Platform, please contact info@lightup.ai and we will endeavor to delete such information from our systems. Customers are responsible for ensuring compliance with applicable rules where the personal information of children is collected and transmitted.

Categories of Sources of Personal Data

We collect personal data about data subjects from the following categories of sources:

• Directly from you, when you provide it to us digitally or physically when you use the Platform, or contact us via email, instant messaging, telephone, or by any other mean
  
  
• As well as from:
  • your employer, when your employer is a Customer; and
  • service providers and third parties who provide it to us (for example marketing partners).

Changes To This Privacy Policy

This Privacy Policy was last updated on the date indicated below, but we suggest that you review it from time to time, as our Platform and our business may change. As a result, at times it may be necessary for Lightup to make changes to this Privacy Policy (and/or our Cookie Policy). We reserve the right to update or modify this Privacy Policy and/or our Cookie Policy at any time and from time to time without prior notice. However, if we make changes that we believe will materially impact this Privacy Policy, the Cookie Policy or your rights, we will promptly notify you of those changes. Your continued use of the Platform after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

What Information Do We Collect

What personal information we collect and process depends on how and why you use our Platform. Generally, we process personal information that we receive:

• Directly from you when you provide it to us, such as in connection with our Services.

• Indirectly, through automated technologies such as cookies, or from third parties. 

• On behalf of our Customers, when we process the personal data of their Customer End Users as part of our Services. 

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 Collect Indirectly

Device and Usage Information
When you use or interact with our Site, even if you do not have an account, we, or authorized third parties engaged by us, may automatically collect information about your use of the Site via your device, some of which is considered personal information. “Device and Usage Information” that we collect consists of:

• Information About your Device: information about the devices and software you use to access the Site – primarily the Internet browser or mobile device that you use, the website or source that linked or referred you to the Site, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, device screen size, and other similar technical information. 

• Usage Information: information about your interactions with the Platform, including access dates and times, hardware and software information, device event information, log data, crash data, cookie data. This information allows us to understand the screens that you view, how you’ve used the Site (which may include administrative and support communications with us), and other actions on the Site. We, or authorized third parties, automatically collect log data when you access and use the Platform, even if you have not created an account or logged in. We use this information to administer and improve the Services, analyze trends, track users’ use of the Platform, and gather broad demographic information for aggregate use. 

• Location Information: based on Device and Usage Information, we are also able to determine general location information (“Location Information”).

Cookies and Similar Technologies
Lightup uses cookies and similar technologies on its Site. Through our use of cookies (and similar technologies), we or authorized third parties collect some information Device and Usage Information. Some cookies are necessary to make the Site and our content available to you, while others are meant to improve the Site and enable us to analyze and measure audience and traffic. For more information on our use of cookies and the data that they collect, see our Cookie Policy.

In addition, when you visit or log in to our website, online data partners or vendors may use cookies and similar technologies to associate these activities with other personal information they or others have about you, including your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout

Information from Customers and Third Parties
We process personal information from third parties, which consists of data from our Customer End Users, as well as information from our CRM service. What we collect from Customer End Users, how we access the data, and how we use it are subject to our Customers' terms and privacy policies. 

Categories of Personal Information We Have Collected in Past 12 Months
In the past 12 months we have collected personal information in all the categories described in the sections above titled Information We Collect Directly From You, Information We Collect Indirectly From You, Cookies and Similar Technologies and Information from Customers and Third Parties.

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, Switzerland 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, business or commercial 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.

Categories of Recipients of Personal Data Disclosed for Business Purposes in Past 12 Months

In the past 12 months we have shared information in the categories below with certain third parties for business or commercial purposes, for the purposes described in the sections above.

Categories of Recipients of Personal Data Sold or Shared in Past 12 Months

We do not sell or share personal data as those terms are commonly understood. All customer data, including personal data, is maintained securely within the Platform. We do however, use third party advertising networks as described above, and those third parties’ collection of browsing and network information on our Site has been deemed a sale or share of the personal data collected and have shared personal data in those categories in the past 12 months. In addition, in the past 12 months we have disclosed personal data for business or commercial purposes as described above, which may be considered sale or sharing of that personal data. If we asked for your consent to sell or share personal data and you granted consent, we shared that personal data.

Global Privacy Control/ Do Not Track 

Global Privacy Control (GPC) is a technical specification that you can use to inform websites of your privacy preferences in regard to ad trackers. To set up GPC, you can visit the Global Privacy Control website at https://globalprivacycontrol.org. If you set up GPC, we will automatically turn off all non-required cookies on our websites for you. Please note that this may impact the functionality of the Service. [Do Not Track is a non-binding technical setting that Lightup will treat the same as GPC opt-out settings.]

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.

Additional Information Regarding Data Subject Rights

If you are located in a jurisdiction that provides data subject rights, such as EEA, the UK, Switzerland and certain US states, you may have certain rights in relation to your personal data:

• The right to be informed –  our obligation to inform you that we process your personal data (and that’s what we’re doing in this Privacy Policy)

• The right of access – your right to request a copy of the personal data we hold about you (also known as a ‘data subject access request’)

• The right to rectification – your right to request that we correct personal data about you if it is incomplete or inaccurate (though we generally recommend first making any changes in your Account Settings)

• The right to erasure (also known as the ‘right to be forgotten’) – under certain circumstances, you may ask us to delete the personal data we have about you (unless it remains necessary for us to continue processing your personal data for a legitimate business need or to comply with a legal obligation as permitted under the GDPR, in which case we will inform you)

• The right to restrict processing – your right, under certain circumstances, to ask us to suspend our processing of your personal data

• The right to object – your right to object to us processing your personal data (for example, if you object to us processing your data for direct marketing)

• Rights in relation to automated decision-making and profiling – our obligation to be transparent about any profiling we do, or any automated decision-making

• The right to opt out from the sale or sharing of your personal data
• The right not be discriminated against for exercising these rights

These rights are subject to certain rules around when you can exercise them. 

If you live in a jurisdiction that provides these rights to you and you wish to exercise any of the rights set out above, you may contact us at info@lightup.ai. 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request under those circumstances.

If we cannot reasonably verify your identity, we will not be able to comply with your request(s). We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. Note that this is especially true when you engage a third party to assist you in exercising your rights. 

We will respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated as required by law. In addition, we will always balance your rights against those of other data subjects in connection with any requests, and in some cases this may require us to redact our responses or deny a request.

Finally, you have the right to make a complaint at any time to the supervisory authority for data protection issues in your country of residence. We would, however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us directly first.