Your privacy is important to us “CONSORCIO LEVU S.A DE C.V.”, “LEVU EXECUTIVES SEARCH LLC” and its
subsidiaries and affiliates (“Levu Talent Hunters and Levu Executives”, “we” or “us”)
understand your concerns regarding how we use and share your information. This Privacy
Policy (“Policy”) describes how we collect, use, protect and disclose your Personal
Data in connection with your use of our websites, including without limitation
,
https://levuexecutives.com,
along with the features, functionalities, applications, browser extensions and other services available
through our
websites, (collectively, our “Websites”), your use of our products and services
(collectively, our “Services”), and Personal Data we obtain from any third party site
connected to our Websites or Services including, without limitation, LinkedIn (collectively,
“Third Party Sites”). We refer to our Websites, Services, and Third Party Sites
collectively as our “Levu Dashboard”.
By accessing and using the Levu Dashboard, you agree that you have read and understand this
Policy. This Policy does not apply to any other websites. You can access and interact with
our Levu Dashboard in many ways, including from a computer or mobile device. This Policy
applies regardless of how you access or interact with our Levu Dashboard. Depending on how
you interact with our Levu Dashboard, there may be some cases where we need to provide you
with additional information about how we use your Personal Data and/or what options you have
regarding our use of your Personal Data. We may provide this additional information via
notices on the Levu Dashboard or via direct communications with you. If we do this, unless
we tell you otherwise, the additional information will apply in addition to what is
described in this Policy.
Please read this Policy carefully. If you do not want us to collect, use or disclose your
Personal Data in the ways described in this Policy, please do not use our Levu Dashboard,
provide us with your Personal Data or authorize a third party to make your Personal Data
available to us. By using the Levu Dashboard, providing us with your Personal Data or
otherwise making your Personal Data available to us, you acknowledge that you understand
that we may use your Personal Data as described in this Policy. If you have any questions
about how we collect, use, protect, disclose or otherwise process Personal Data, including
whether we have received your Personal Data from a third party,
please contact us by email at
info@levuexecutives.com
.
WE COLLECT PERSONAL DATA AND USAGE INFORMATION
Personal Data
When we refer to “Personal Data” in this Policy, we mean information that
identifies, relates to, describes or is reasonably capable of being associated with, or
could reasonably be linked, directly or indirectly, to a specific person. This might be
information that directly identifies someone, such as their name, or it may be information
that identifies someone only when combined with other information available to us. Please
note, except as provided under applicable laws, Personal Data does not include information
that is publicly available through government records or information that has been
deidentified or aggregated in a way that it cannot be used to identify a specific
individual.
Our primary goals in collecting Personal Data are to provide and improve our Levu
Dashboard, conduct our operations, communicate with you and enable visitors to our Levu
Dashboard to enjoy and easily navigate it.
Categories of Personal
Data We Collect
Depending on the type of activity you are performing on the Levu Dashboard or how you use
or interact with our Levu Dashboard, we may collect and disclose the following Personal
Data:
- identifiers and contact information, such as your name, email address, telephone number,
postal address, physical address, date of birth, online identifier, IP address and other
similar information;
- identifiers and access to camera, microphone, files and documents, as well as references
and contact information of third parties;
- demographic information, such as your age, national origin, and other similar
information;
- financial information, such as your salary, benefits, wages, bonuses and commissions;
- internet and other similar network activity information, such as your browsing history,
search history, interactions with the online portions of our Levu Dashboard and online
advertisements and other similar information;
- professional or employment-related information, including current or past job history
and other similar information;
- online identifiers you use, such as your username, social media handles and other
similar information;
- communication information, such as information contained in voicemails, chats, emails
and other similar information;
- location information, such as where you live, where you are located and other similar
information; and
- other information you provide us or authorize us to collect about you.
Usage Information
In addition to Personal Data, we, or third parties acting on our behalf, may collect
certain information about the device you use when you interact with our Levu Dashboard
through the normal operation of our Levu Dashboard and through the use of cookies, pixels,
and other web technologies on our Levu Dashboard (collectively, “Usage Information”).
Usage Information, by itself, generally does not identify the specific person using the
device that generated it. This means that unless required pursuant to applicable law, Usage
Information usually will not be considered Personal Data and the ways we use Usage
Information may differ from what is described in this Policy. However, if we link Usage
Information directly with your Personal Data or other information that could identify you,
we will treat the linked Usage Information as Personal Data and use the linked Usage
Information as described in this Policy.
Depending on how you access, interact with, or use our Levu Dashboard, the Usage
Information that we, or third parties acting on our behalf, collect may include:
- device information, such as the IP address, general geographic location, operating
system, browser type, language preferences, mobile phone number, device identifier and
other similar information associated with a computer or mobile device used to access or
interact with our Levu Dashboard;
- information about your interactions with our Levu Dashboard, such as links that are
clicked, pages or screens that are viewed, access and session times, interactions with
emails we send and other similar information associated with activities on our Levu
Dashboard;
- information about Internet and network activity, such as websites visited, search engine
results and other similar information associated with a computer or mobile device that
accesses or interacts with our Levu Dashboard;
- information automatically collected by cookies and other technologies on our Levu
Dashboard; and
- any other information that a computer or mobile device automatically sends whenever
connected to a website or an online application.
For more information about how we collect Usage Information, please see the “How We Collect
Usage Information” section below.
HOW WE COLLECT YOUR PERSONAL DATA
A large portion of the Personal Data we, or third parties acting on our behalf, collect is
collected directly from you. In some cases, we may collect Personal Data from third parties
in the ways described in this Policy.
Directly From You.
When you engage with us in connection with our Levu Dashboard, such as requesting
information, creating an account, communicating with us or otherwise interacting with us, we
may ask you to provide certain Personal Data. Some of the Personal Data we request may not
be required, however, we will specifically indicate what Personal Data is required to engage
in such activity.
From Third Parties.
We, or third parties acting on our behalf, may collect Personal Data about you from third
parties, including, without limitation, online and offline sources, entities and individuals
affiliated with us, our service providers, social media Levu Dashboards, advertising
networks and other public or commercial sources (collectively, “Third Party Sources”). The collection of
Personal Data from these Third Party Sources can occur in
a variety of ways, including, without limitation:
- When you access, use or interact with our Levu Dashboard through Third Party Sites,
associate your access, use or interaction with our Levu Dashboard with Third Party Sites
or share our content via Third Party Sites, you acknowledge that you are authorizing use
to collect, share, store and use any Personal Data we receive from those Third Party Sites
about you. In some cases, you may be able to revoke our access to your Personal Data and
other content and information we receive from Third Party Sites by changing the
appropriate settings for your account with the applicable Third Party Site.
- When you use single sign-on tools. Some of the features of our Levu Dashboard may
provide you with the ability to register and sign into our Levu Dashboardthrough the
accounts you have with certain third parties, such as Google (“Third Party Single Sign On Providers”).
When you use these features, we, or third parties acting on our
behalf, gather the data necessary to create an account on our Levu Dashboard from the
applicable Third Party Single Sign On Provider, which may include, without limitation,
your name, email address, IP address, device model, device operating system and web
browser, time zone, carrier, screen size, processor cores, total disk space and remaining
disk space. Your data associated with the applicable Third Party Single Sign On Provider
will not be sold, redisclosed or edited through this process. Your ability to use this
option may be limited where the applicable Third Party Single Sign On Provider requires
you to use a device or operating system that meets that Third Party Single Sign On
Provider’s requirements. Please note, by using these features, the applicable Third Party
Single Sign On Provider will know that you are signing into our Levu Dashboard and that
you are a user of our Levu Dashboard.
- We, or third parties acting on our behalf, may receive Personal Data about you from
third parties that provide services to us through or in connection with our Levu Dashboard
(“Service Providers”). Service Providers may include, without limitation, third
parties that host our Levu Dashboard, parties that provide us services related to the
communications we send and receive, and other financial institutions and financial
services companies that we partner with to provide our Services.
Our collection, use, disclosure, and storage of the Personal Data we receive from Third
Party Sources will be as described in this Policy.
Please note, we may combine the Personal Data and other content and information we receive
about you from multiple sources, including, without limitation, Personal Data we collect
directly from you and one or more Third Party Sources.
HOW WE COLLECT USAGE
INFORMATION
We, and third parties acting on our behalf, collect Usage Information in a variety of ways.
Some Usage Information, such as the IP address of a device attempting to access, use or
interact with our Levu Dashboard, is necessary for us to make certain portions of our Levu
Dashboard available. Other Usage Information, such as information about which features of
our Levu Dashboard are popular, helps us improve and advertise our Levu Dashboard. The
primary systems and technologies used to collect Usage Information in connection with our
Levu Dashboard are:
- the systems we use to make our Levu Dashboard available to you, including the systems we
use to help us identify and address technical issues and errors. When you access, use, or
interact with our Levu Dashboard, these systems automatically record certain information
that your browser or device sends whenever you visit a website or utilize an online
application as well as information about how long your device is connected to our Levu
Dashboard and the activities that device engages in while connected. These systems also
automatically collect information about your actions and activities on our Levu Dashboard.
-
cookies, which are small data files that are uploaded to the hard drive or other storage
on devices that access, use, or interact with portions of our Levu Dashboard. Among other
things, cookies help us improve our Levu Dashboard and our users’ experience. We use
cookies to see which areas and features are popular and to understand usage of our Levu
Dashboard. We use first party cookies, served directly by us to the devices that access
our Levu Dashboard, to recognize those devices when they revisit. We also use third party
cookies, which are cookies that are placed by other parties we work with, such as Google
or LinkedIn. These third parties may upload unique cookies to your device to collect
information about your use of our Levu Dashboard and potentially other online activities
you engage in over time across different Levu Dashboard and other online applications. The
Options/Settings section of most internet browsers will tell you how to manage cookies and
other technologies that may be uploaded to your device, including how to disable such
technologies. You can disable our cookies, or all cookies, through your browser settings,
but please note, disabling cookies may impact some of the features of our Levu Dashboard
and prevent them from operating as intended. You can learn more about cookies, including
how to see what cookies have been uploaded to your device and how to manage and delete
them,
by visiting
https://www.allaboutcookies.org/.
- other tracking technologies, such as web beacons, clear gifs, and pixel tags. These
technologies may be used on or in connection with our Levu Dashboard, including, without
limitation, in emails we send. We may use these technologies to deliver cookies, count
visits, understand usage, and observe data on email delivery, open rates, click rates,
bounces, unsubscribes and other information.
-
Third party analytic tools, such as:
-
Google Analytics. Google Analytics is a web analytics service provided by Google,
Inc. (“Google”), to assist us in understanding how our Levu Dashboard is used. Google
Analytics will place cookies on your computer or mobile device that will generate
information that we select about your use of the Levu Dashboard, including your
computer’s or mobile device’s IP address. That information will be transmitted
directly to and stored by Google. The information will be used for the purposes of
evaluating use of our Levu Dashboard, compiling reports on activity on our Levu
Dashboard for our use and providing other services relating to activity on, and usage
of, our Levu Dashboard. Google may also transfer this information to third parties
where required to do so by law, or where such third parties process the information on
Google’s behalf. You may refuse the use of cookies by selecting the appropriate
settings on your browser. Please note that by doing so, you may not be able to use the
full functionality of our Levu Dashboard. The use of cookies by Google Analytics is
covered by Google’s privacy policy, available at
https://policies.google.com/privacy.
Google allows you to opt out of Google Analytics.
You may opt-out by visiting
https://tools.google.com/dlpage/gaoptout.
-
LinkedIn Insight Tag.
We may use Linked Insight Tag, a cookie placed by LinkedIn
that enables us to measure the effectiveness of advertising campaigns served on LinkedIn.
The information collected by that cookie will be transmitted directly to and stored by
LinkedIn. For more information about LinkedIn’s privacy practices,
please refer to
https://www.linkedin.com/legal/privacy-policy.
To opt-out, you can update your advertising preferences through your LinkedIn account. If you do not
have a LinkedIn account
,
LinkedIn allows you to opt-out
of applicable targeted advertising by visiting https://www.linkedin.com/psettings/guest-controls.
Please note, we have not yet developed a response to browser “Do Not Track” signals, and do
not change any of our data collection practices when we receive such signals. We will
continue to evaluate potential responses to “Do Not Track” signals in light of industry
developments or legal changes.
HOW WE USE YOUR
PERSONAL DATA AND USAGE INFORMATION
This section describes the primary purposes for which we use the Personal Data we, or third
parties acting on our behalf, collect.
- Operational Purposes – we may use the Personal Data we, or third parties acting on our
behalf, collect for non-marketing purposes, including: (1) operating and improving our
Levu Dashboard, which may include, without limitation, presenting content to you and other
users to fulfill our business purposes and to facilitate your use of features you elect to
use on our Levu Dashboard, such as engaging in transactions with other users through our
Levu Dashboard; (2) validating your identity; (3) carrying out our obligations and
enforcing our rights arising from any contracts we have entered into, including, without
limitation, any contracts between you and us; (4) notifying you about issues with, or
changes to, our policies, terms, and agreements; (5) sending you emails to provide you
with alerts and updates about your engagement with our Levu Dashboard, including without
limitation informing you if relevant job postings would be a good fit for your contacts;
(6) providing customer service; (7) conducting statistical or demographic analysis; (8)
complying with legal and regulatory requirements; (9) customizing your experience with our
Levu Dashboard; (10) protecting and defending us against legal actions or claims; (11)
preventing fraud; (12) cooperating with law enforcement or other governmental agencies for
purposes of investigations, national security, public safety or matters of public
importance when we believe that disclosure of Personal Data is necessary or appropriate to
protect the public interest; (13) registering your account; (14) any purpose for which you
authorize or instruct us to use your Personal Data; and (15) other business purposes
permitted under applicable law.
- Marketing Purposes – we may, either on our own or jointly with our third party marketing
partners (“Marketing Partners”), use the Personal Data we, or third parties acting
on our behalf, collect for marketing purposes, including notifying you of special
promotions, opportunities, offers and events via push notifications, e-mail and other
means, all subject to our compliance with applicable laws (“Marketing Purposes”).
We may also link Personal Data (including your name, mobile phone number, and email
address) with other information (including information we automatically collect as
described in this Policy) and use such linked information for Marketing Purposes. Our
Marketing Purposes may include using Personal Data collected through cookies and other
tracking technologies to facilitate the delivery of promotions, and offers to you, on
behalf of ourselves and our Marketing Partners on and off our Levu Dashboard.
We will not collect additional categories of Personal Data or use the Personal Data we, or
third parties acting on our behalf, collect in connection with our Levu Dashboard for
materially different, unrelated or incompatible purposes without providing you notice.
Anonymized Data.
Please note, we may use and disclose aggregated, anonymized or de-identified information
collected in connection with our Levu Dashboard and other information that does not identify
any individual (“Anonymized Data”) for any lawful purposes, which may include, without
limitation, purposes not described in this Policy. Except as otherwise required under
applicable laws, our use and disclosure of such Anonymized Data is not subject to this
Policy.
HOW – AND WHY – WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES
To operate our Levu Dashboard and provide our Services, we may share certain Personal Data
that we, or third parties acting on our behalf, have collected, with certain third parties
under the following circumstances:
-
With your consent.
Except for as outlined below, we only share your information with third parties when
you have directed us to do so.
-
With our Service Providers.
We may share your Personal Data with our Service
Providers as needed to complete any transaction or provide any Service you have requested
or in connection with the services they provide to us, including, without limitation,
order fulfillment, marketing of our products and services, data hosting, fraud protection
and prevention, and as otherwise provided in this Policy. We require these Service
Providers to exercise reasonable care to protect your Personal Data and restrict their use
of your Personal Data to the purposes for which it was provided to them.
-
For mergers and acquisitions.
We may share your Personal Data with applicable
third parties in connection with a merger, acquisition, bankruptcy or other sale of all or
a portion of our assets. We reserve the right, in connection with these types of
transactions, to transfer or assign your Personal Data and other information we, or third
parties acting on our behalf, have collected to third parties or to authorize such third
parties to use any such information. Except as ordered by a bankruptcy or other court, the
use and disclosure of all transferred Personal Data will be subject to this Policy.
However, any Personal Data you submit or that is collected after this type of transfer may
be subject to a new privacy Policy adopted by the successor entity.
-
For legal reasons.
We may share your Personal Data with government and law
enforcement officials or private parties where necessary to enforce and comply with the
law. To the extent permitted under applicable law, we may disclose any Personal Data and
other information to government or law enforcement officials or private parties as we
believe is necessary or appropriate to investigate, respond to and defend against legal
claims, for legal process (including subpoenas), to protect our property and rights of
those of a third party, to protect us against liability, for the safety of the public or
any person, to prevent or stop any illegal, unethical, fraudulent, abusive or legally
actionable activity, to protect the security and integrity of our Levu Dashboard and any
equipment used to make our Levu Dashboard available or to comply with applicable laws.
THIRD PARTY INFORMATION COLLECTION
Based on the nature of our Levu Dashboard, third parties may collect information from or
about you through or in connection with our Levu Dashboard. In addition to other information
provided in this Policy, including, without limitation, the section titled “How We Collect
Usage Information” the categories of third parties that may collect information about you
through or in connection with our Levu Dashboard include:
- Third parties whose content is linked to on our Levu Dashboard. Any links to other
websites, applications or other third party content on our Levu Dashboard, are not an
endorsement, authorization, or representation of our affiliation with that third party and
we are not responsible for the content, privacy and security policies and practices of any
third party. We encourage you to read the privacy policies or statements applicable to any
third party websites, applications, or content you access.
-
Other users of our Levu Dashboard. Depending on how you interact with our Levu
Dashboard, other users may collect information about you that is published or otherwise
generally made available on our Levu Dashboard. All users of our Levu Dashboard are
subject to our Terms of Service which are available at
https://levuexecutives.com/conditions-of-service.
While we place restrictions on what our users are allowed to do with information made
available to them on our Levu Dashboard, we are not responsible for any misuse of any
information, including your Personal Data, by any user. If you believe that another user
has misused your Personal Data or any other information available on our Levu Dashboard,
please contact us at
info@levuexecutives.com
-
Third party Levu Dashboards. Certain features of our Levu Dashboard use services
provided by third parties. These third parties may collect certain Personal Data about you
and your interactions with us and our Levu Dashboard.
MANAGING YOUR PERSONAL DATA
We offer you several choices with respect to how we use your Personal Data.
-
To update or correct any Personal Data you have provided us, update your preferences, or
otherwise contact us about our use of your Personal Data
,
please email us at
info@levuexecutives.com
- For marketing and other promotional email communications you receive from us, you can
opt-out of receiving such communications by following the unsubscribe instructions
contained in most email messages from us. Your unsubscribe request or email preference
changes will be processed promptly, though this process may take several days. During that
processing period, you may receive additional marketing and other promotional emails from
us. Please note, opting out of these communications will only apply to marketing and other
promotional emails and will not apply to any email or other communications we send to you
for non-marketing purposes, including, but not limited to, emails and other communications
about your interactions with our Levu Dashboard.
- You may review or modify much of the Personal Data you provide to use through the Levu
Dashboard at any time by logging into your account and using the Levu Dashboard’s account
editing functions. Please note that information you remove through such means may still
remain in backup copies for a reasonable period of time.
-
To request deletion of your Personal Data,
please submit a request to us by emailing us at
info@levuexecutives.com
.
Only you, or a party that you authorize to contact us on your behalf, may make a request related to the
deletion of your Personal Data. You may also make a request on behalf of your minor child. Your request
for deletion must:
- Provide sufficient information that allows us to reasonably verify you are the
person about whom we collected Personal Data or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand,
evaluate, and respond to it.
We cannot respond to your request or delete your Personal Data if we cannot verify your
identity or authority to make the request and confirm the Personal Data relates to you.
Making a request does not require you to create an account with us and we will only use
Personal Data provided in connection with a request for deletion to verify the requestor’s
identity or authority to make the request.
We endeavor to respond to deletion requests within a reasonable time period after we
receive a deletion request. If we are unable to fully comply with your request to delete
your applicable Personal Data, our response will explain the reasons why we are unable to
fully fulfill your request.
If we determine that the request warrants a fee, as allowable under applicable law, we will
tell you why we made that decision and provide you with a cost estimate before completing
your request.
PROTECTING YOUR PERSONAL DATA
We are committed to protecting the security of your Personal Data. We use commercially
reasonable safeguards to maintain the security and privacy of Personal Data we collect and
use in connection with our Levu Dashboard. Nevertheless, when disclosing Personal Data, you
should remain mindful that there is an inherent risk in the transmission of information via
the internet and mobile Levu Dashboards. Although we take precautions to protect against the
risk of unauthorized access to your Personal Data, we cannot guarantee the security of any
information, including your Personal Data, that you disclose online and you do so at your
own risk.
If you become aware of any breach of Levu Dashboard security or this Policy, please notify
us immediately. To further protect yourself, you should safeguard your account user name and
password and not share the information with anyone. You should also sign off your account
and close your browser window when you have finished your visit to our Levu Dashboard. Note
that we will never ask you for your Levu Dashboard user name and password over email.
RETENTION OF PERSONAL DATA
We reserve the right to retain any Personal Data as long as it is needed to: (1) fulfill
the purposes for which we collected the Personal Data; and (2) comply with applicable law.
CHILDREN’S PRIVACY
We do not direct or target any piece of our Levu Dashboard to children under the age of 18.
If we learn that we have collected the Personal Data of anyone under the age of 18, we will
take appropriate steps to delete this information. If you are a parent or guardian of
someone under the age of 18 and discover that your child has submitted Personal Data to us
,
please contact us at
info@levuexecutives.com
.
We will make reasonable efforts to remove such information from our databases.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, under California’s Shine the Light Law (California Civil
Code Section 1798.83) you have the right to request the following information regarding our
disclosure of your Personal Data to third parties for direct marketing purposes: (1) the
categories of Personal Data we disclosed to third parties for their direct marketing
purposes during the preceding calendar year; (2) the names and addresses of the third
parties that received the information; and (3) if the nature of the third party’s business
cannot be determined from their name, examples of the products or services they marketed.
This information may be provided in a standardized form that is not specific to you.
You are permitted to obtain this information from us once a year, free of charge. To make
such a request, please submit your request in writing to:
LEVU EXECUTIVE LLC.
Attn: Administrative Department
Re: CA Privacy Rights Request
100 Park Ave 16'h Floor
New York, NY 10017
EUROPEAN USERS’ RIGHTS
If you are located in the EU or Switzerland, you have certain rights with respect to your
Personal Data. Following is a summary of those rights and additional information applicable
to our collection and use of your Personal Data.
Data Controller
When you provide us with your Personal Data through the Levu Dashboard, we serve as a data
controller. When we act as a data controller we determine how your Personal Data will be
utilized, in accordance with this Policy.
Legal Basis for
Processing Personal Data
If you are located in the EU or Switzerland, we rely on several legal bases to process
your
Personal Data. These legal bases include where:
- The processing is necessary to perform our contractual obligations, such as to provide
you with our Services;
- You have given your prior consent, which you may withdraw at any time (such as for
marketing purposes or other purposes we obtain your consent for from time to time);
- The processing is necessary to comply with a legal obligation, a court order or to
exercise or defend legal claims; and
- The processing is necessary for the purposes of our legitimate interests, such as in
improving, personalizing, and developing our Levu Dashboard and Services, marketing new
features or products that may be of interest, and promoting safety and security as
described above.
If you have any questions about or would like further information concerning the legal
bases on which we collect and use your Personal Data
,
please contact us by emailing
info@levuexecutives.com
.
Rights Under the
General Data Protection Regulation
If you are located in the EU or Switzerland, you have the following rights in respect of
your Personal Data that we hold:
- Right of access. The right to obtain access to your Personal Data.
- Right to rectification. The right to obtain rectification of your Personal Data without
undue delay where that Personal Data is inaccurate or incomplete.
- Right to erasure. The right to obtain the erasure of your Personal Data without undue
delay in certain circumstances, such as where the Personal Data is no longer necessary in
relation to the purposes for which it was collected or processed.
- Right to restriction. The right to obtain the restriction of the processing undertaken
by us on your Personal Data in certain circumstances, such as where the accuracy of the
Personal Data is contested by you, for a period enabling us to verify the accuracy of that
Personal Data.
- Right to portability. The right to portability allows you to move, copy or transfer
Personal Data easily from one organization to another.
- Right to object. You have a right to object to processing based on legitimate interests
and direct marketing.
If you wish to exercise one of these rights, please email us at
info@levuexecutives.com.
You also have the right to lodge a complaint to your local data protection authority. Further
information about how to contact your local data protection authority is available at
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
.
Retention of
Personal Data
When reserve the right to retain any Personal Data as long as it is needed to: (1) fulfill
the purposes for which we collected the Personal Data; and (2) comply with applicable law.
Transfers of
Personal Data
If you are located in the EU, the personal information we collect may be stored and
processed in any country in which we or our affiliates, suppliers, third party electronic
payment processors and/or financial institutions or agents maintain facilities, including,
but not limited to, the United States of America. YOU CONSENT TO ANY AND ALL PERSONAL
INFORMATION YOU PROVIDE AND SUBMIT VIA THE Levu Dashboard AND SERVICES BEING SENT TO THE
UNITED STATES OF AMERICA. The United States of America has not sought nor received a
finding of “adequacy” from the EU under Article 45 of the GDPR. We rely on derogations for
specific situations as set forth in Article 49 of the GDPR. YOU ARE ALSO INFORMED THAT
THE UNITED STATES OF AMERICA PRESENTLY DOES NOT HAVE AN ADEQUATE LEVEL OF PERSONAL DATA
PROTECTION AS DETERMINED BY THE EUROPEAN COMMISSION’S ADEQUACY DECISION ON OCTOBER 6, 2015
(CASE C-362/14) AND ARTICULATED IN THE EUROPEAN UNION’S GENERAL DATA PROTECTION REGULATION
AND HAS NOT RECEIVED A SIMILAR DESIGNATION OF ADEQUACY BY ANY OTHER FOREIGN DATA
PROTECTION AUTHORITY. YOU AGREE TO THE TRANSFER OF YOUR DATA AND PERSONAL INFORMATION TO
THE UNITED STATES OF AMERICA, HOWEVER, TO BE USED IN ACCORDANCE WITH THIS POLICY.
Obligations to Data
Protection Authorities (DPAs)
We will respond diligently and appropriately to requests from DPAs about this policy or
compliance with applicable data protection privacy laws and regulations. We will, upon
request, provide DPAs with names and contact details of the individuals designated to handle
this process. With regard to transfers of Personal Data, we will (1) cooperate with
inquiries from the DPA responsible for the entity exporting the data and (2) respect its
decisions, consistent with applicable law and due process rights. With regard to transfers
of data to third parties, we will comply with DPAs’ decisions relating to it and cooperate
with all DPAs in accordance with applicable legislation.
INTERNATIONAL TRANSFERS
Personal Data collected in connection with the use and operation of our Levu Dashboard is
stored and processed in the United States. If you access, use or otherwise interact with our
Levu Dashboard or otherwise engage with us from outside the United States, please be advised
that your personal information may be initially collected by servers located in the United
States or, if initially collected outside the United States, transferred to the United
States. Please note, the United States has not been assessed as having adequate privacy laws
by some countries and economic regions.
CHANGES AND UPDATES TO THIS POLICY
Because the methods used to protect your Personal Data and the Services we provide are
continually evolving, this Policy may change at any time. Unless otherwise noted, those
changes will be effective as soon as they are posted. If changes are made to this Policy, we
will make it known on our Levu Dashboard or by email and will indicate the last date it was
updated above. Please check back periodically to see if our Policy has been updated.
Your continued use of our Levu Dashboard after any changes to this Policy become
effective,
constitutes your continued acknowledgement that you understand that we may continue to use
your Personal Data as described in this Policy.
CONTACT US
If you have any questions, concerns, complaints or suggestions regarding our Policy or
otherwise need to contact us, please, email us at
info@levuexecutives.com