Privacy policy

Last updates: May 20, 2021

This Privacy Policy explains how we handle your data when you use our website loonomy.com, our email newsletters subscription or our pages/ads on social media networks (collectively, the Services). It explains our collection, use, storage, and sharing of the information that we collect or receive from you. You also find description of your right to control data use.

  1. The types of personal data we collect about you

The information we gather about you can personally identify you — either on its own or when combined with other information. We will only collect your personal data in line with applicable laws. We collect your personal data in various ways:

a) Information you voluntarily give us

When you place an order for our services (e.g., a contact form filling on our website), we collect your name and contact information. We also collect information from you over our further negotiations regarding the order.

When you sign up to receive marketing emails from us, we collect your email address.

b) Information collected automatically.

We use tracking technologies in your browser that include cookies, web beacons, pixels, tags and scripts, etc. We track and store data about how you visit and use the Services, particularly through our website loonomy.com. The items we log include:

– Your IP address.

– Your location.

– Your operating system.

– Your browser.

– Your browser language.

– The URLs of any pages you visit on our sites and apps.

– Device identifiers.

– Advertising identifiers.

– Other usage information.

We combine this data with other information we collect about you. For more information about tracking methods on the Services, and how to manage them, read Section 8 (Cookies and similar tracking technologies) of this policy.

c) Information collected from social media platforms.

Social media platforms include Facebook and LinkedIn. We receive information from you when you interact with our pages, groups, accounts or posts on social media platforms. This includes aggregate data on our followers (e.g., age, gender and location), engagement data (e.g., “likes,” comments, shares, reposts and clicks), awareness data (e.g., number of impressions and reach) and individual users’ public profiles.

 

  1. How we use your personal data

    A) We provide the Services.

We use your information to help you use Services, such as:

  • Making a Service available to you
  • Providing customer service
  • Responding to your inquiries, requests, suggestions or complaints
  • Completing your payments and transactions
  • Sending service-related messages

    B) We Develop Products and Services, and Do Analysis.

We analyze data on our users’ purchase and usage behaviors. This helps us make business and marketing decisions.

Google Analytics is one of the analytics providers we use. You can find out how Google Analytics uses data and how to opt out of Google Analytics.

C) We Advertise Times Services to You.

We market our properties to you. Sometimes we use marketing vendors to do this.

We serve ads through websites, locations, platforms and services operated and owned by third parties. Often these ads are targeted at people who have visited our website but have not purchased anything. The ads are also targeted at people with similar traits or behaviors to our customers.

We target our advertising to these users by uploading an encrypted customer list to a third party, or by incorporating a tracking technology from a third party onto our website. The third party then matches individuals who appear in both our data and their data.

D) We Aggregate Personal Information.

Sometimes we aggregate or de-identify information so that it can no longer identify you, under applicable laws. This helps us better understand and represent our users, such as when we measure ad performance, create advertising interest-based segments or compile survey results. We can use and disclose this aggregated or de-identified information for any purpose, unless an applicable law says otherwise.

 

  1. What is our legal basis

We only collect, use or share information about you when we have a valid reason. Specifically, this is one of the following:

  • The consent you provide to us at the point of collection of your information. This legal basis rely to processing your email address and tracking technologies for marketing purposes. You give us your consent by clicking on the “subscribe” in the email subscription form on our website or by clicking “I agree” in cookie notice form on, respectively. In the case of marketing emails, you can withdraw your consent by clicking on the “unsubscribe” link at the bottom of the email. In case of tracking technologies, you can withdraw your consent as it described in Section 8 (Cookies and similar tracking technologies) of this policy.
  • Performance of a contract with you (or in order to take steps prior to entering into a contract with you). Where you have filled contact form on our website or we need to use your contact details and payment data in order to process your order and deliver our services properly.
  • The legitimate interests. “Legitimate interest” is a technical term under international laws, including the European Union General Data Protection Regulation. It means that there are good reasons for the processing of your personal information, and that we take measures to minimize the impact on your privacy rights and interests. “Legitimate interest” also refers to our use of your data in ways you would reasonably expect and that have a minimal privacy impact. We have a legitimate interest in gathering and processing personal information: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business within us; (3) to prevent fraud; and (4) to conduct some of our marketing activities.

 

  1. With whom do we share your personal data

We provide your personal information to unaffiliated third parties if we believe in good faith that such disclosure is necessary to: (a) comply with any applicable law, rule, or regulation, or in response to a subpoena, court order, or other legal process; (b) protect the interests, rights, safety, or property of us or others; (c) monitor compliance with and enforce any terms of service on our website; (d) provide our services and products; (e) perform other activities related to such services and products, including billing and collection; (f) provide you with offers, promotions or advertisements from us; or (g) operate the systems that provide our services and products properly.

For example, we may employ service providers to process payments; host or store our data; deliver email messages; provide legal or other guidance; or analyze data.

We do not share in other way or sell your personal information.

 

  1. Using children’s personal data

We do not aim any of our services directly at children under the age of eighteen (18). Subsequently we do not knowingly collect personal data about children under eighteen (18) years old. If you know that we process personal data of user under eighteen (18) years old, please inform us by sending email at hello@loonomy.com or via telephone number + 44 20 4577 2151.

 

  1. International data transfers

We are headquartered in Ukraine. If you are located outside the Ukraine, your information is collected in your country and then transferred to Ukraine — or to another country in which we (or our affiliates or service providers) operate.

If we transfer your data out of the European Economic Area (E.E.A.), we implement at least one of the two following safeguards:

  • We transfer your information to countries that have been recognized by the European Commission as providing an adequate level of data protection according to E.E.A. standards (see the full list of these countries).
  • We take steps to ensure that the recipient is bound by E.U. Standard Contractual Clauses to protect your personal data. You can see a copy of these clauses.

In certain situations, the courts, law enforcement agencies, regulatory agencies or security authorities in those countries might be entitled to access your personal information.

 

  1. How long we keep your personal data

We keep your personal data for only as long as we need to. How long we need your personal data depends on what we are using it for, as set out in this privacy policy. For example, we may need to use it to answer your queries about a product or service and as a result may keep personal data while you are still using our product or services. We may also need to keep your personal data for accounting purposes, for example, where you have bought a subscription. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you. If we have asked for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data. Nevertheless, when you unsubscribe from marketing communications, we will keep your email address to ensure that we do not send you any marketing in future.

 

  1. Cookies and similar tracking technologies

We use cookies and similar tracking methods (such as pixels, SDKs, JavaScript, device identifiers, etc., which we refer to as “trackers”) when you visit our website. Four of the main types are explained below.

a) Cookies

A cookie is a small string of text that a website (or online service) stores on a user’s browser. It saves data on your browser about your visit to our website or other websites. It often includes a unique identifier (e.g., cookie #123). You can choose whether to accept cookies by editing your browser settings. However, if cookies are refused, your experience on our website may be worse, and some features may not work as intended.

b) Pixels

Pixels (also known as “web beacons,” “GIFs” or “bugs”) are one-pixel transparent images located on web pages or messages. They track whether you have opened these web pages or messages. Upon firing, a pixel logs a visit to the current page or message and may read or set cookies. Pixels often rely on cookies to work, so turning off cookies can impair them. But even if you turn off cookies, pixels can still detect a web page visit.

c) JavaScript

JavaScript is a programming language. It can be used to write trackers that, when embedded into a page, allow us to measure how you interact with our website and other websites.

d) ID Synching

In order to decide what type of ad might interest you, our digital and marketing vendors sometimes link data — inferred from your browsing of other websites or collected from other sources — using a method knowns as “ID synching” or “cookie synching.” To do this, they match the tracker ID they have assigned to you with one or more tracker IDs that are held in another company’s database and that are likely also associated with you. Any of the linked trackers may have certain interests and other demographic information attributed to it. That information is then used to determine which ad to show you.

 

Below is a list of the types of trackers that appear on our website.

Essential Trackers

Essential trackers are required for our site to operate. They allow you to navigate our site and use its services and features. Without essential trackers, our site will not run smoothly; in fact, our site (or certain services or features) might not even be available to you simply because of technical limitations.

Preference Trackers

Preference trackers allow us to store information about your choices, settings and preferences. They also help us recognize you when you return to our website, remember your language settings (among others) and customize our website accordingly. They are not essential to the functioning of our website.

Analytics Trackers

Analytics trackers collect or use information about your site use, which helps us improve our site. Among the uses of analytics trackers are to show us which pages are most frequently visited, help us record difficulties you have with our site, track subscription purchases and behaviors leading to subscription purchases, and measure how well ads perform.

These trackers add up our readers’ visits to show us larger patterns in our audience. We look at these larger patterns to analyze site traffic.

Marketing Trackers

These trackers help us determine which ads to show you for Times properties — both on our site and on other sites. To do this, these trackers use information about your behavior on various sites to target our ads.

These trackers allow us to limit the number of times you see our ad across your devices. They help us personalize the ads we show you. They also enable us to measure the effectiveness of our marketing campaigns (e.g., measure if you subscribe after seeing our ads).

 

How you able to manage trackers

When you first come to our website, you may receive a notification that trackers are present. By clicking or tapping “accept,” you agree to the use of these trackers as described here.

You can manage your tracker settings by opting out of specific (or all) trackers.

In addition to the options above, you can refuse or accept trackers from our website (or any other site) in your browser’s settings. If you refuse trackers, you might not be able to use some tracker-dependent features of our website.

Most browsers automatically accept cookies, but this is typically something you can adjust. Information for each browser can be found in the links below:

  • Safari on desktop and Safari Mobile (iPhone and iPads): Note that, by default, Safari is engineered to protect you from being tracked from site to site unless you disable Intelligent Tracking Prevention (ITP).
  • Firefox: By default, Firefox protects you from cross-site tracking so long as you have not disabled Enhanced Tracking Protection (ETP). There is therefore less need to manage cookies to protect your privacy.
  • Chrome
  • Microsoft Edge: Enabling tracking prevention with Edge will protect you from being tracked between sites, such that there will be less of a need to manage your cookies in order to protect your privacy.
  • Samsung Internet Browser
  • Brave: Brave has several mechanisms to keep you from being tracked online, but you can change your privacy settings if you wish to have greater control over its decisions.

For more information about other browsers, please refer to this “All About Cookies” guide.

To opt out of Google Analytics data collection, follow these Google instructions.

The third-party advertisers, ad agencies and other vendors with which we work may be members of the Network Advertising Initiative, the Digital Advertising Alliance Self-Regulatory Program for Online Behavioural Advertising and/or the European Digital Advertising Alliance. To opt out of interest-based advertising from the participating companies, please visit AboutAds.info or the European Digital Advertising Alliance. Note that opting out through these channels does not mean you will no longer see ads. You will still receive other types of ads from these companies, and any type of ad from nonparticipating companies. The sites you visit may still collect your information for other purposes.

 

  1. Your privacy and data protection rights

There is a scope of rights you may enjoy as to personal data protection with regard to data protection laws.

The list of rights protected under the law is as follows:

  • right of access (i.e. you may ask us to send you a copy of the data about you that we collected);
  • right to rectification (i.e. you may ask us to correct the outdated or false data, or complete the data which is missing or incomplete);
  • right to erasure (i.e. you may ask us to delete the personal data we retain);
  • right to restriction of processing (if processing may be restricted);
  • right to be informed (i.e. we inform you what data is being collected, how it’s being used, how long it will be kept and whether it will be shared with any third parties).
  • right to object to processing (i.e you may object as to certain kinds of processing or in certain circumstances);
  • right to data portability (i.e. you may ask us to transfer a copy of your data to another organization or to you).

We do not sell your data therefore opt out request option and disclosing of the categories of personal information that we sell or disclose for business purposes or categories of third parties to whom we have sold your information or disclosed it for business purpose are not applicable in the case at hand. If we decide to do so, we will notify you and give you the possibility to opt out from selling your personal data.

Please remember that we do not charge any fees in relation to exercising your rights. We may charge you a small fee to compensate the expenses that we incur due to the repetitive and excessive character of requests. We typically do our best to answer you as soon as possible or within the reasonable period taking into account the complexity of the request, but in case we are processing a large amount of requests, the answer may take us longer than you might expect.

You can send us the request via email. Please verify that your request comprises the details:

  • your name;
  • contact information;
  • right you want to exercise;
  • your personal data in our processing (where applicable);
  • reason/justification behind such request (where applicable).

To ensure that you who are making any of the aforementioned requests is the consumer we may ask you to verify your request. We will try to avoid requesting additional information for purposes of verification. Verification is completed once we verify the identity of the person making the request to a reasonably high degree of certainty. When you use an authorised person to submit any of the aforementioned requests we may require the authorised person to confirm its powers and its own identity.

 

  1. Contact us for information about how we use your personal data

Email: hello@loonomy.com

Phone number: + 44 20 4577 2151

Address: 3rd Floor, 86-90 Paul Street, London EC2A 4NE, United Kingdom.

 

  1. Changes to this policy

We may change this policy at any time. Check the “last revised” date at the top of this page to see when this policy was last revised. Any change becomes effective when we post the revised Privacy Policy on or through our website.

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