Last Updated: 23 Nov 2023
This Privacy Statement sets out how we collect, use, manage and protect the personal data or information (“Data”) that we may collect from or about you. It applies to all individuals whose Data may be handled, whether as controller or processor, by Litro Group (“we,” “us,” or “our”, being Litro International Limited, its subsidiaries, affiliates and associated companies), including without limitation, by using our website and microsites, such as https://www.litro.life (“Website”), our mobile applications available on Android and iOS devices (each, our “App”), and/or other services we provide (collectively, the “Services”), you agree to the practices set forth in this Privacy Policy.
We are committed to processing your Data in accordance with the required standards. This includes protecting your privacy and ensuring the security of your Data in compliance with, in particular and where applicable, the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong Special Administrative Region of The People’s Republic of China) (the “Ordinance”), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”) where applicable.
Before using and providing your Data for the purposes as set out in this Privacy Statement, we may be required by law to obtain your written consent, and in such cases, only after having obtained such written consent, may we use your Data in the manner as specified.
To better serve your needs and preferences, our web servers may automatically collect and store certain information about your computer or mobile device and your activities. We may also collect aggregated, anonymous, statistical data on the server’s usage so that we may better cater to the behaviour of users of our Services. We may use this and other information described in this Privacy Policy to infer information, such as your interests.
This information includes:
Facebook or Instagram - In order to register with certain Litro apps, you may be asked to sign in using your Facebook or Instagram login. If you do so, you are authorizing us to access and process certain Facebook or Instagram account information, including information about you and your Facebook friends or Instagram followers who might be common Facebook friends or Instagram followers with other Litro users. By allowing us to access your Facebook or Instagram account, you understand that we may obtain and process certain information from your Facebook account or Instagram account, including your name, email address, birthday, work history, education history, current city, pictures stored on Facebook, and the names, profile pictures, relationship status, and information about your Facebook friends or Instagram followers. We only obtain information from your Facebook account or Instagram that you specifically authorize and grant us permission to obtain.
Third-Party Services - We may receive the information described in this Privacy Policy from third party services, such as analytics providers and advertising partners.
Other users - Users of Litro may provide us with information about you, including through customer support inquiries.
We may collect, use and hold a range of different Data about you. For the purposes of carrying on our business (including the verification of your identity to detect, prevent and address fraud, security or technical issues, the registration, activation and management of your account with us, and the billing and charging of our Services and complying with laws, rules, guidelines, regulations and/or requests issued by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies,you may be requested to provide certain information, including, but not limited to, your telephone number , birthday, gender, and gender preference. We will also ask you to upload photos for your profile and may collect any information (including location metadata and inferred characterizations or data) contained in these files. You may provide additional information about yourself (such as your school, occupation, current city, etc.) in order to build your Litro profile. You may also provide “special categories of personal data” under applicable law, such as your ethnicity, religion, political views, and information relating to your sex life or sexual orientation. By affirmatively providing Litro with this information, you explicitly consent to our use of it for the purpose of fine tuning your match criteria with other Litro users. Any information that you provide in the non-personally identifiable section of your profile will be viewable by your match.
It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.
We recommend and encourage you to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ license details and other sensitive information which is open to abuse and misuse on your profile.
When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk.
Profile Verification Information - For safety and security and to ensure you have the best possible user experience, we may require Users to verify their accounts and, in some instances, we might also ask you to carry out photo verification, with the objective to verify you are not a robot to avoid fake Litro accounts being created which can be used for malicious activities and cybercrime – they may threaten the Litro network and spoil things for everyone. This verification might be required by us for the prevention of fraud. You can also verify your photo on a voluntary basis (to add the blue ‘verified’ badge to your profile).The selfie photo submitted to verify your profile is stored in the system along with any other photos you’ve uploaded. This photo would not be shown on your profile and it would not be visible to any of Litro users.
Payment information - When using Litro, you may also provide payment information (where required for the purpose of payment). We collect and process your messages with other Litro users as part of the operation of Litro.
Referring Your Friends - We encourage you to refer your friends to Litro by sending us your friends’ phone numbers or email. We will keep this information in our database, and enable you to send these friends a one-time email or text message from your device containing your name and inviting them to visit our site. This email will also include instructions on how to opt out and unsubscribe from our email list. You agree that you will not abuse this feature by entering the email addresses or phone numbers of those individuals who would not be interested in Litro.
SMS Messages - By providing your phone number to Litro, you consent to Litro sending you SMS messages with security codes.
Online Survey Data - We may periodically conduct voluntary member surveys. We encourage our members to participate in such surveys because they provide us with important information regarding the improvement of Litro.
If you permit us to do so, Litro may access your device’s address book solely in order to add someone to your contacts or access your device’s calendar solely in order to add/ update dating events.
When our Customer Support team via our App or Website, we may receive your email address, and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you) for 6 years after deletion of your account.
Pursuant to the terms of this Privacy Policy, we may use the information we collect from you for the following business purposes:
The information we collect is used to provide and improve the content and the quality of Litro, and without your consent we will not otherwise share your personal information to/with any other parties except: (a) to provide Litro, (b) when we have your permission, or (c) or under the following instances:
We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and information security measures in place and only provide them with the personal data necessary to the service they are providing. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible and our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits.
We take the required steps to ensure that these Organisations are bound by appropriate confidentiality and privacy obligations in relation to the protection of your Data and that they use your Data for the sole purpose of carrying out the services for which they have been engaged, and not for their own or other purposes (including direct marketing).
Unless otherwise stated in this Privacy Policy, Litro does not sell personal information to third parties. Litro does permit third parties to collect the personal information described above through our service and shares personal information with third parties for business purposes as described in this Privacy Policy, including but not limited to providing advertising outside of our service based on users’ online activities over time and across different sites, services, and devices (so-called “interest-based advertising”). The information practices of these third parties are not covered by this Policy.
You may review or edit your profile as you wish, by logging into your Litro account using the information supplied during the registration process. If you would like to have us delete your account information, we may do so by deactivating your account first and then permanently deleting your account. Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Litro services, or to respond to any inquiry or request made by you, as applicable. To opt out of receiving messages concerning Litro, you must cease requesting and/or utilizing services from Litro, and cease submitting inquiries to Litro, as applicable.
In accordance with applicable law, you may have the right to:
If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws.
If you have a concern about how we have processed your request or your personal data, you should contact us in the first instance via the contact details listed above.
Litro may contain links to other websites and services. If you choose to click on a third party link, you will be directed to that third party’s website or service. The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites or services. These third parties may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you visit to understand the ways in which your Data may be used by those third parties
Litro will retain your Data in accordance with our internal policies. Our policies are in compliance with the Ordinance and the GDPR where applicable, and cover the following principles:
At times it may be necessary and/or prudent for us to transfer your Data to places outside of Hong Kong Special Administrative Region of The People’s Republic of China or the country in which you receive our Service(s) (“your Country”), for instance, for the prevention, detection or investigation of crime or for storage, processing and other purposes for which the Data were collected. In the event that we do transfer your Data outside of Hong Kong Special Administrative Region of The People’s Republic of China or your Country, we will do so in compliance with the prevailing requirements of the Ordinance, the GDPR where applicable and all other applicable privacy and data protection laws and regulations of your Country.
All required efforts are made to ensure that any Data held by us is stored in a secure and safe place and is accessible only by our authorised employees or other Organisations referred to in this Privacy Statement.
When we pass your Data to third party Organisations for them to process, we seek to ensure that they have appropriate security measures in place to keep your Data safe and to comply with applicable principles in relation to data protection. Some of the people we share your Data with may process it overseas. You can contact us for more information about the safeguards we use to ensure that your Data is adequately protected in these circumstances.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure. By providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of Litro and our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail or SMS to you. You may have a legal right to receive this notice in writing.
You may link your Litro account with your Instagram, Facebook or Spotify accounts. This allows you to share some information from those accounts directly to your Litro account (for example, Instagram photos, or your top Spotify artists). We only receive the limited information that Instagram, Facebook or Spotify permits to be transferred (as detailed by Instagram/Facebook/Spotify and agreed by you when you first connect your account from such platforms with your Litro account). If you no longer want to link your Litro account to your Instagram, Facebook or Spotify account, please visit the settings in your Instagram, Facebook or Spotify account and follow the instructions to remove the Litro app access permissions. Please note that any information already added to your Litro account from those platforms will not be deleted unless you delete it within your Litro account as well.
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Litro has collected about them and whether Litro disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:
| Category of Personal Information Collected by Litro | Categories of Third Parties Personal Information is Disclosed to for a Business Purpose |
|---|---|
| Identifiers | 1. Other users 2.Service providers 3.Advertising partners |
| Personal information categories listed in Cal. Civ. Code § 1798.80(e) | 1. Other users 2.Service providers |
| Protected classification characteristics under California or federal law | 1. Other users 2.Service providers |
| Commercial information | 1. Other users 2. Service providers 3. Advertising partners |
| Internet or other electronic network activity | 1. Service providers 2. Advertising partners |
| Geolocation data | 1. Service providers |
| Sensory data | 1. Other users 2. Service providers |
| Professional or employment-related information | 1. Other users 2. Service providers |
| Inferences drawn from other personal information to create a profile about a consumer | 1. Service providers 2. Advertising partners |
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.
If you would like such a list, please contact us at [email protected]. For all such requests, you must put the statement “Shine the Light Request” on your request, as well as your name, street address, city, state, and zip code. Please note that we will not accept these requests by telephone or fax, and are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
From time to time, as part of a joint promotion with a third party, we may, if you participate in such a promotion, disclose your contact information to the third party to allow them to market their products or services to you. Where this is a condition for participation in a promotion, we will always let you know before you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their messages.
In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online services when using the App.
We keep your personal information only as long as we need it for the legal basis relied upon and as permitted by applicable law.
You may permanently delete your Account at any time. When your Account is deactivated, we take reasonable efforts to make sure it is no longer viewable on the App. After 30 days, we begin the process of deleting your personal information from our systems, unless:
Where Litro uses machine learning, for example, to help us detect and prevent fraudulent card transactions, and to detect and prevent spam communications on the App (as explained above), we may need to keep personal information for a longer period than the retention periods explained above, to enable the machine learning to work properly. Where this is the case, we always seek to minimise the amount of personal information that is used and we ensure that it is ring-fenced and kept securely from other User personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.
To prevent abuse and/or misuse of Litro by a User following termination or deletion of a profile/Account we shall retain such information as we deem in our sole discretion may be necessary to ensure that User does not open a new Account and profile in breach of our Terms and Conditions of Use and to ensure compliance with all laws and regulations.
Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.
We may update this Privacy Policy from time to time. If there are any material changes to this Privacy Policy, Litro will notify you electronically by posting a notice on the Site or sending an e-mail or SMS to you, or as otherwise required by applicable law. When we post changes to this Privacy Policy, we will revise the “last updated” date at the top of this Privacy Policy. We recommend that you check our Website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.
If you have any questions about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact us by email at [email protected].