Lutikey, LLC (“Lutikey,” “We,” and/or “Our”) respects the privacy of users of Our products and services.  This Privacy Policy is designed to inform you, as a user of our services, as to the type of information that we may gather or collect from you when you use Lutikey’s product and/or services.  It also covers whether and how that information may be shared and your rights and choices regarding the information you provide to us.  We use cookies and similar technologies.

By using the Services offered by Lutikey, you are acknowledging you have agreed to our Terms and Conditions of Service and that you have read and understood this Privacy Policy.

1. Information we collect and receive.  Lutikey must collect and process certain information in order for you to create an account on Lutikey and use our Services (set forth in the Policies and Procedures).  Depending on the use of the Services, this information may include, but is not limited to:

• Information you provide by completing forms on LutiKey’s website – your name, email and postal addresses, telephone number, country of residence, login, and password details, We may ask for this information if you register as a user of the services, subscribe to our newsletters, upload or submit content through LutiKey, or if you contact us;
• Details of any requests or transactions you make through the Services. LutiKey may use other companies for payment processing, and the payment information you submit may be used by them in accordance with their privacy policies; 
• Information about your activity on and interaction with LutiKey, including use of our mobile apps (such as your IP address, the type of device or browser you use, and your actions on the site);
• Information about the ways people visit and interact with our site, in the form of traffic analytics.  For more information about our use of data analytics to protect and Improve our services, please email us at support@lutikey.com;
• Communications you send to us (for example, when you ask for support, send us questions or comments, or report a problem); and
• Information that you submit on or to LutiKey in the form of comments, contributions to discussions, or messages.

If you decline to provide us with your information, this will limit your ability to register for an account or use our Services.  You may review, change or remove your information through your account settings.

2. Sharing and use of your personal information.  Lutikey will use the information we collect for the following purposes:

• To keep your account secure and protect our Services (including verification of user identities and prevention of fraud and abuse); 
• To enable Lutikey to provide you with our Services, and to improve and promote our Services;
• To create and administer your account, contact you, and better your experience on Lutikey; 
• To track and analyze use of the Services so that we can improve Lutikey’s performance;
• Your information may be made available to participating safety and emergency response services during specific emergency incidents, including without limitation, 9-1-1 or equivalent local emergency services including fire, police, emergency medical, emergency management, campus safety officials and public health services (collectively, “Emergency Service Providers”).
• Your information may be searchable to participating Emergency Service Providers for the purposes of emergency planning and/or response.
• Your name, address, phone number and/or email may be used by authorized users (“Users”) to send emergency and general Interest notifications to you via various communication methods (e.g. voice calls, text messaging, email, etc).
• We may release personal information when we believe in good faith that release is necessary to comply with laws including to comply with subpoenas, court orders, or other requests (including criminal and civil matters), or to enforce or apply our Terms of Service and other agreements: or to protect the rights, property, or safety of Lutikey, our employees, our users, or others. Notwithstanding anything to the contrary herein, we may retain personal information to comply with applicable law or as necessary in connection with legal proceedings.
• We may share non-personal information such as aggregated non-identifying information to third parties. Our Service may automatically collect usage information, such as the numbers and frequency of visitors to our site and users who use our Service.  We use this information in aggregate form and not in a manner that would identify you personally.
• We may store or archive snapshots of then-current Subscriber information as it’s made available to Emergency Service Providers, for the period of time dictated by Emergency Service Providers record keeping policies.
• If the ownership of all or a substantial part of our business changes, we may transfer your information to a new owner so that the Service can continue to operate.  In such a case, your information would remain subject to the terms of this Privacy Policy, unless you otherwise consent to the terms of a new or different policy.

3. Cookies and log files.  We may use cookies and web log files to track subscriber usage on aggregate and anonymous basis.  We do this for the purpose of continually improving our Service, and simplifying your use of the Services.  With both cookies and log files, the information that we collect and share is anonymous and not personally identifiable.  

4. Security of your personal information.  Lutikey has security measures in place to protect against the loss, misuse, and unauthorized alteration of the information under out control.  However, Lutikey cannot guarantee the security of user account information or other personal information.  Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.  

5. European Union users.   Data protection law in Europe requires a “lawful basis” for collecting and retaining personal information from citizens or residents of the European Economic Area. Our lawful bases include:

• Performing the agreement we have with you: In certain circumstances, we need your personal data to comply with our contractual obligation to deliver the services.
• Legal compliance: Sometimes the law says we need to collect and use your data. For example, tax laws require us to retain records of pledges and payments made through our services.
• Legitimate interests: This is a technical term in data protection law which essentially means we have a good and fair reason to use your data and we do so in ways which do not hurt your interests and rights. We sometimes require your data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom or interests.

We use identity, device, and location information to prevent fraud and abuse and to keep the services secure. We may also send you promotional communications about our services, subject to your right to control whether we do so. 

We analyze how users interact with our site so we can understand better what elements of the design are working well and which are not working so well. This allows us to improve and develop the quality of the on line experience we offer all our users.

6. Information shared with third-party services.  We may share personally identifiable information that we collect with third-parties that perform functions on our behalf and our affiliate companies to develop and deliver targeted advertising on the website and on website’s of third-parties; provide analytic and site usage information; process transactions and payments; administer our promotions, contests, sweepstakes, and surveys; provide other marketing and promotional assistance; and provide other services related to the operation of our business.  When we share your personally identifiable information with our business partners and other authorized third-party service providers, these service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.  

Lutikey may share your personally identifiable information with its third-party business partners to enable these parties to offer their products and services to you.  These third-parties may send you information or marketing offers.  If we share your personally identifiable information with a third-party for the third-parties’ marketing purposes, your personally identifiable information will be subject to the privacy policy and business practices of that third-party.

We may also disclose information about you (a) if we believe that the law requires it or are required to do so by law or legal process; (b) to law enforcement authorities or other governmental officials; or (c) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

7. Links to other websites and services.  Our site may include links to other websites or services whose privacy practices may differ from LutiKey’s. When you use a link to an external site or service, the privacy policy and data processing disclosures for that site or service governs.

8. Retention.  We will retain your information as long as your account is active, as necessary to provide you with the services or as otherwise set forth in this policy. We will also retain and use this information as necessary for the purposes set out in this policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect LutiKey’s legal rights. 

We also collect and maintain aggregated, anonymized or pseudonymized information which we may retain indefinitely to protect the safety and security of our site, improve our services or comply with legal obligations.

9. Children’s Online Privacy Act.  The Children’s Online Protection Privacy Act (COPPA) protects the online privacy of children under the age 13 years.  Lutikey does not knowingly collect or maintain information from anyone under the age of 13, unless or accept as permitted by law.  Any person who provides information through Lutikey’s Services represents to us that he or she is 13 years of age or older.  If you are a minor, please do not register for Lutikey’s Services or provide any personal information about you to us.  If learn that we have collected personal information, including personal health information, from a minor without the appropriate consent, we will delete that information.

10. Data protection authority.  Subject to applicable law, if you are a citizen or resident of the European Economic Area, you also have the right to object to LutiKey’s use of your personal information and lodge a complaint with your local data protection authority or the United Kingdom Information Commissioner’s Office. 

United Kingdom Information Commissioner’s Office 
Wycliffe House, Water Lane, Wilmslow, Cheshire 
SK9 SAF, United Kingdom 
Telephone: +0303 123 1113 
Fax: 01625 524510 

Web: https://ico.org.uk/global/contact-us/ (https://ico.org.uk/global/contact-us/)

11.  Changes to Privacy Policy.   Lutikey reserves the right to modify and update this policy from time to time and will provide notice of same.  Any and all changes to this Agreement will be posted to Lutikey’s website.  You agree to be bound to any changes to this Agreement after any such modification becomes effective and/or by your continued access or use of Lutikey.