Privacy Policy

Version 1.1

24th July, 2020

This privacy policy applies between you, the User of this web portal and Ulyfe Ltd, the owner and provider of this Website. Ulyfe Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at the legal section, in your Backoffice.

Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

Data Data collectively all information that you submit to Ulyfe Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Cookies a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
Data Protection Laws any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in Malta;
GDPR the General Data Protection Regulation (EU) 2016/679;
Ulyfe Ltd, or us Ulyfe Ltd, a company incorporated in Malta whose registered office is at Level 5, Smart City Malta, Ricasoli, Kalkara, Malta, SCM 1001;
Maltese and EU Cookie Law the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
User or you any third party that accesses the Website and is not either (i) employed by Ulyfe Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Ulyfe Ltd and accessing the Website in connection with the provision of such services; and
Website the website that you are currently using, www.Ulyfe.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

1. In this privacy policy, unless the context requires a different interpretation:

  • the singular includes the plural and vice versa;
  • references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
  • a reference to a person includes firms, companies, government entities, trusts and partnerships;
  • “including” is understood to mean “including without limitation”;
  • reference to any statutory provision includes any modification or amendment of it;
  • the headings and sub-headings do not form part of this privacy policy.
Scope of this privacy policy

3. This privacy policy applies only to the actions of Ulyfe Ltd and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

4. For purposes of the applicable Data Protection Laws, Ulyfe Ltd is the “data controller”. This means that Ulyfe Ltd determines the purposes for which, and the manner in which, your Data is processed.

Data collected

5. We may collect the following Data, which includes personal Data, from you:

  • name;
  • date of birth;
  • gender;
  • contact Information such as email addresses and telephone numbers;
  • financial information such as credit/debit card numbers;
  • IP address (automatically collected);
  • web browser type and version (automatically collected);
  • operating system (automatically collected);
  • a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
  • Your location (only when authorised by yourself).
  • a copy of the identity card or passport, and proof of address;
  • Your photos, and information you decide to post of your page.
  • in each case, in accordance with this privacy policy.
How we collect Data

6. We collect Data in the following ways:

  • data is given to us by you; and
  • data is collected automatically.
Data that is given to us by you

7. Ulyfe Ltd will collect your Data in a number of ways, for example:

  • when you contact us through the Website, by telephone, post, e-mail or through any other means;
  • when you register with us and set up an account to receive our products/services;
  • when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
  • when you enter a competition or promotion through a social media channel;
  • when you make payments to us, through this Website or otherwise;
  • When you post something on your profile whether written or photographic or video;
  • when you elect to receive marketing communications from us;
  • when you use our services;

In each case in accordance with this privacy policy.

Data that is collected automatically

8. To the extent that you access the Website, we will collect your Data automatically, for example:

  • We automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content. We may also collect the content, communications and other information you provide when you use our Products, including when you sign up for an account, create or share content, and message or communicate with others. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created. It can also include what you see through features we provide, such as our camera, so we can do things like suggest masks and filters that you might like or give you tips on using portrait mode.
  • Information and content you provide. The content, communications and other information you provide when you use our Products, including when you sign up for an account, create or share content, and message or communicate with others are automatically collected by the system. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created. It can also include what you see through features we provide, so we can do things like suggest masks and filters that you might like, or give you tips on using portrait mode. Our systems automatically process content and communications you and others provide to analyze context and what’s in them.
  • Networks and Connections: Information about the people, pages you visit, and accounts, and hashtags and any groups or activities you interact with whilst using our products are collected automatically.
  • How you use our products: We also may gather information on how you utilize our products, what kind of products you engage in, and the actions you take, and the time and frequency the duration of your activity whilst using our products. We may log the last time you utilized our products, and for how long you have used them.
  • Financial transactions: If you make any purchases on our platforms, or make use of any of our products, we will collect information about the purchase or transaction. this will include payment information, as like credit card information, the credit card number, and contact details, and any other relevant information relating to your transaction.
  • Things others provide about you: We also receive information and analyze content which relates to you. This is normally information coming from when people comment, of share a photo or send a message to you, people may also sync your contact information on our platforms or photos.
  • Information about your device: we collect information about the devices you use when utilizing our products, this to help you get a better user experience when utilizing our products from any other device. This may also include ads, which you might have been interested in on one of your computers, or any different device.

Information we may obtain from these devices includes:

  • Device attributes information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
  • Device operations: information about operations and behaviours performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
  • Identifiers: unique identifiers, device IDs, and other identifiers, such as from games, apps or accounts you use.
  • Device signals: Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.
  • Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.
  • Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network
  • Cookie data: data from cookies stored on your device, including cookie IDs and settings.
  • Information from partners.

These partners may provide information about your activities off our platforms and these include information about your device, websites you visit, purchases you make, the ads you see, and how you use their services—whether or not you have a an account or online. For example, a game developer could use our API to tell us what games you play, or a business could tell us about a purchase you made in its store. We also receive information about your online and offline actions and purchases from third-party data providers who have the rights to provide us with your information.

Partners receive your data when you visit or use their services or through third parties they work with. We require each of these partners to have lawful rights to collect, use and share your data before providing any data to us.

  • h. We will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.
Our use of Data

9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

  • To create your account with Ulyfe Ltd, to notify you with any changes which may occur, to facilitate communication, to provide you a better service, to provide you with personalised help and support,
  • User profile search data, is to provide you with fast and reliable service to connect and communicate with friends.
  • Profile data which is provided by you, as per the privacy which each user deems to share, which may be modified by each user in the privacy settings. This is important to be found by other users of the app, to develop new and improve existing services; to better understand how you access and use Ulyfe to maintain your Ulyfe account in accordance with your instructions and requests.
  • Chat Data. Content of communications between you and another user or group of users. This is stored on your device and the devices of the users that you have sent communications to. We do not permanently store this information on our servers and it only passes through our servers so that it can be distributed to the users you have chosen to send communications to.
  • The device contact list is necessary to connect you with your friends and help you make new connections.
  • Log in data It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.
  • In some regions, credit card information is collected and the card information verified via a third-party payment processing service for the purpose of verifying parental or guardian consent to use Ulyfe by an underage minor. This information is not permanently stored to Ulyfe’s servers and is immediately disposed after a verification request has been performed by the third-party payment processing service
  • internal record keeping; this may be required to keep as requested by law, for any fiscal, criminal or any other information which may be requested by authorities during the
  • improvement of our products/services;
  • Any information that you provide to our customer support team.
  • transmission by email of marketing materials that may be of interest to you;
  • contact for market research purposes which may be done using email, telephone, fax or mail.
  • Device Data: Media stored on your device, which you grant us permission to access, as to facilitate the sharing of such media on our platform with your friends.
  • Surveys. If you choose to participate in a survey, we may request certain Personal Information from you. We may use a service provider to conduct these surveys and this will be notified to you prior to you completing the survey.
  • Analysis of what features or actions are taken within the app in order to improve app experience, Fraud detection and account safety analysis, User demographic analysis on items such as region, phone model, operating system platform, system language, and Ulyfe in order to better understand how our users are using Ulyfe, Web and account traffic statistics of what content and services are used when users access third-party services on the Ulyfe Open Platform as a method for informing third-party service providers basic analysis of how their service is being used by Ulyfe users.
  • Such information may be used to customise or update the Website;

In each case, in accordance with this privacy policy.

10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).

11. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:

  • soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
  • for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
  • if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.

12. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

13. We may use your Data to show you Ulyfe Ltd adverts and other content on other websites. If you do not want us to use your data to show you Ulyfe Ltd adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed “Cookies” below).

Who we share Data with

14. We may share your Data with the following groups of people for the following reasons:

  • any of our group companies or affiliates – to ensure the proper administration of our website, and for business marketing procedures; to fulfill their job responsibilities, and to provide you with the best possible service.
  • our employees, agents and/or professional advisors – for accounting purposes, to carry out customer verification, and for marketing research, and to provide you with any support you might require, to make sure that the service given is optimal, and to make sure that any usage of our platform is in accordance with the terms and conditions laid their in or other policies which from time to may be posted by the company which will regulate your usage of data.
  • third party service providers who provide services to us which require the processing of personal data – to help third party service providers in receipt of any shared data to perform functions on our behalf to help ensure the website runs smoothly; These may indicatively be professional advisors who provide banking, legal, compliance, insurance, accounting, introducers, brokers, or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.
  • third party payment providers who process payments made over the Website – to enable third party payment providers to process user payments and refunds;
  • relevant authorities – to facilitate the detection of crime or the collection of taxes or duties;
  • For the purpose of fulfilling its contractual and legal/regulatory obligation, of serving its legal interest as well as in cases where Ulyfe Ltd is authorized or has received your consent, recipient of your personal data may be the following:
  • The Ulyfe’s employees to fulfill their job responsibilities in relation of the evaluation of your request, the management and performance of the User Agreement with Ulyfe, the fulfilment of the obligation arising from it, as well as the relevant obligation imposed by law.
  • Entity to which Ulyfe delegates the performance of specific task on its behalf (Processor) which may indicatively be professional advisors who provide consulting services in order to complete third party financial, technical, audits, and any other check which may be required as to make sure to bring you the best possible service, and to provide you the the most safety possible when utilizing out platforms or otherwise comply with our legal obligations.
  • The service providers under contract who help with parts of our business operations. Examples of the types of service providers we may share personal information with include:
  • Network infrastructure;
  • Payment processing;
  • Transaction monitoring;
  • Security;
  • Document repository services;
  • Customer support;
  • Internet (e.g. ISPs);
  • Data analytics;
  • Information Technology;
  • Marketing.
  • The third party identity verification services in order to prevent illegal activities. This allows Ulyfe to confirm your identity by comparing the information you provide us to public records and other third-party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with the limits which are permissible as per Maltese Laws.
  • The law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the User Agreement or any other applicable policies.
  • The company or other entities that we plan to merge with or be acquired by. We may process any information regarding your Payment User Account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.
  • The NWK Independent Consultants/ Referral who invited you to join Ulyfe – the user who has introduced you to the system has access to your name and surname, and may identify you from the personal information you provide, for payment, and affiliate services reasons, and to make payments to such NWK Independent Consultants.

in each case, in accordance with this privacy policy.

Keeping Data secure

15. We will use technical and organisational measures to safeguard your Data, for example:

  • access to your account is controlled by a password and a user name that is unique to you.
  • we store your Data on secure servers.
  • payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.

16. We are certified to SOC 2. This family of standards helps us manage your Data and keep it secure.

17. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via the ticketing system.

18. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

19. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

20. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

21. You have the following rights in relation to your Data:

  • Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
  • Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
  • Right to erase – the right to request that we delete or remove your Data from our systems.
  • Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
  • Right to data portability – the right to request that we move or copy or transfer your data.
  • Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.

22. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: support@Ulyfe.com.

23. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For more information, please contact your local data protection authority in the European Economic Area (EEA).

24. It is important that the Data we hold about you is accurate and current. Please keep us informed if your data changes during the period for which we hold it.

Transfers outside the European Economic Area

25. Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which are located outside the EEA.

26. We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, e.g. by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission, or by signing up to the EU-US Privacy Shield Framework, in the event that the organisation in receipt of the Data is based in the United States of America.

27. To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with to ensure your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Links to other websites

28. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

29. Ulyfe Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Ulyfe Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

30. We may also disclose Data to a prospective purchaser of our business or any part of it.

31. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

32. This Website may place and access certain Cookies on your computer. Ulyfe Ltd uses Cookies to improve your experience of using the Website and to improve our range of services. Ulyfe Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

33. All Cookies used by this Website are used in accordance with current Maltese and EU Cookie Law.

34. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Ulyfe Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

35. This Website may place the following Cookies:

Type of Cookie Purpose
Strictly necessary cookies These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

36. You can find a list of Cookies that we use in the Cookies Schedule.

37. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

38. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

39. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

40. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

General

41. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

42. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

43. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

44. This Agreement will be governed by and interpreted according to the laws of Malta. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the Maltese courts.

Children’s Privacy

45. Our Service does not address anyone under the age of 14 (“Children”). The permission of the parent or guardian is always requested prior to the gaining of personal information of the minor.

46. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, without your permission please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to this privacy policy

47. Ulyfe Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the website following the changes.

Cookies

Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.

Strictly necessary

We use the following strictly necessary cookies:

Description of Cookie
We use this session cookie to remember you and maintain your session whilst you are using our website;

Analytical/performance

We use the following analytical/performance cookies:

Description of Cookie
We use this cookie to help us analyse how users use the website;

Functionality

We use the following functionality cookies

Description of Cookie
We use this cookie to identify your computer and analyse traffic patterns on our website;

Targeting

We use the following targeting cookies:

Description of Cookie
We use this cookie to enable us to show you adverts while you are browsing our website and other websites on the internet;