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Privacy and Cookie Policy

Purpose

 

We at Lapasa are providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we receive through our Services. This Privacy Policy is incorporated by reference into the Lapasa Terms of Service (the “Terms”). The terms “Lapasa,” “we,” and “us” include ASAS, Inc. and our affiliates and subsidiaries. This Privacy Policy explains our online information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt out of a use or correct or change such information. Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Service. So, please make sure that you have read and understand our Terms of Service.

 

Scope

 

This Privacy Policy applies to Personal Information that is Processed by Lapasa in the course of our business, including on Lapasa websites (each a “Site”), mobile applications, forums, blogs, and other online offerings (together with any and all future online offerings operated by or on behalf of Lapasa, the “Services”). This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. All individuals whose responsibilities include the Processing of Personal Information on behalf of Lapasa are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

 

Transparency/Notice – Types of Personal Information We Collect and How We Use It

 

Our primary goal in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services. The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Lapasa and the requirements of applicable law. Some of the ways that Lapasa may collect Personal Information include:

 

You may provide Personal Information directly to Lapasa through interacting with the Services, making online purchases, participating in surveys, during events such as sweepstakes, and requesting Services or information.

 

As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.

 

We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

 

Types of Personal Information We Collect

 

Lapasa collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and Employees. (collectively “Individuals”).

 

  1. Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an Account with Lapasa, making an online purchase, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:

  2. To create an Account, we’ll collect certain information that can be used to identify you, such as your email address, name, postal address, as well as other optional information you may provide like your gender, your phone number etc..Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, create an account, register for Lapasa’s newsletter or a loyalty program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.

  3. Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or services and in any manner consistent with the policies provided herein.

  4. Posting on the Site. You may post your idea or opinion on Lapasa’s site.You should be aware that, when you disclose information about yourself in on Lapasa’s Site, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.

  5. Automatic Data Collection. Our servers automatically record certain information about how Individuals use our Services (we refer to this information as “Event Data”). Event Data may include information such as an Individual’s Internet Protocol (IP) address, cookie identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, operating system, browser type and language, hardware type, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Event Data to administer the Services and we analyze (and may engage third parties to analyze) Event Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to Individuals’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used.

  6. Location Information. We may collect and store information about your location by converting your IP address into a rough geo-location. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.

  7. Information Submitted Via Services. You agree that Lapasa is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Lapasa will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of the Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.

 

How Lapasa Uses Your Information

 

We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:

 

  1. To Provide Products, Services, or Information Requested. Lapasa may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:

    • Generally manage Individual information and Accounts;

    • Respond to questions, comments, and other requests;

    • Provide access to certain areas, functionalities, and features of Lapasa’s Services;

    • Contact you to answer requests for customer support or technical support;

    • Allow you to register for events.

  2. Administrative Purposes. Lapasa may use Personal Information about you for its administrative purposes, including to:

    • Measure interest in Lapasa’s products and Services;

    • Develop new products and Services;

    • Ensure internal quality control;

    • Verify Individual identity;

    • Communicate about Individual Accounts and activities on Lapasa’s Services and systems, and, in Lapasa’s discretion, changes to any Lapasa policy;

    • Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;

    • Process payment for products or services purchased;

    • Process applications and transactions;

    • Prevent potentially prohibited or illegal activities;

    • Enforce our Terms.

  3. Marketing Lapasa Products and Services. Lapasa may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Lapasa may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:

    • To tailor content, advertisements, and offers;

    • To notify you about offers, products, and services that may be of interest to you;

    • To provide Services to you and our sponsors;

    • For other purposes disclosed at the time that Individuals provide Personal Information; or otherwise with your consent

  4. Research and Development. We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes. We may contract with third parties who provide us with other information about you, which we may then combine with the information we receive from you. We use this information to better provide our Services, to customize our advertisements to you and other customers, and to provide direct marketing to you, including by mail.

  5. From time to time, Lapasa may perform research via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.

  6. Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Lapasa’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.

  7. Sharing Content with Friends or Colleagues. Lapasa’s Services may offer various tools and functionalities. For example, Lapasa allows you to provide information about your friends through our referral services, such as “Invite a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Lapasa or any other Third Parties for any other purpose.

  8. Other Uses. Lapasa may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

 

Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

 

We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

 

Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.

 

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

 

Social Media Widgets: Our Website includes social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

 

Our uses of such Technologies fall into the following general categories:

 

  1. Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as saved search, or similar functions;

  2. Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;

  3. Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;

  4. Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

 

If you would like to opt out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

 

Third-party websites, Social Media platforms, and Software Development Kits

 

The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Lapasa does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

 

Lapasa’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

 

Onward Transfer—Lapasa May Disclose Your Information

 

Opt-Out (RIGHT TO RESTRICT PROCESSING)

 

General

 

We offer you choices regarding the collection, use and sharing of your Personal Information, and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Information we request, you may not be able to access all of the features of the Services. You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Lapasa’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting support@lapasa.ca. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

 

Email and Telephone Communications

 

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Lapasa and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

 

We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

 

"Do Not Track"

 

Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

 

Data Retention

 

Lapasa retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

 

Security of Your Information

 

We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your PII) from unauthorized access, use, or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

 

By using the Site or 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 the Site. 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 email to you. You may have a legal right to receive this notice in writing.

 

Redress/Compliance and Accountability

 

If you have any questions about our privacy practices or this Privacy Policy, please contact Lapasa by email at support@lapasa.ca. We will address your concerns and attempt to resolve any privacy issues in a timely manner.