Last updated 09.12.2024
1) General
At Luups we are committed to protecting and respecting your privacy. This privacy policy provides general information concerning how we process personal data about our customers, visitors to our website and natural persons that send us inquiries using the contact information available on our website. You will find information about which personal data we may process and the purpose of such processing in this privacy policy.
Upon processing of your personal data as described within this privacy policy, Luups acts as the data controller, meaning we are responsible for processing your personal data in a responsible manner and ensuring that you are able to invoke your rights under chapter III of the General Data Protection Regulation - GDPR - Regulation (EU) 2016/679.
Personal data means any information concerning a natural person - hereinafter referred to as the data subject - e.g. name, e-mail address, telephone number or evaluations that may be linked to a natural person.
If you have any questions or concerns about how we process your personal data, your rights or how to invoke those rights, you may contact us for assistance at chb@luups.no or by using the contact information provided below.
2) Categories of personal data we may process
Luups may process the following personal data about you:
- Name
- E-mail address
- IP address
- Geolocation
- Any other personal data you actively disclose to us
3) How personal data is collected
Personal data may be freely provided by you upon visitation to our website or by contacting Luups directly, either by using the contact information provided on our website or within this privacy policy.
Luups also uses analytic tools to analyse the traffic to our website and generate statistics. These processes do not include any processing of personal data or other information that may be linked to an IP-address or an identifiable person. We use this intel to better understand the use of our website and improve our services.
4) Legal basis and the purpose of our processing of personal data
All processing of personal data - as described in this privacy policy - serves one or more dedicated purposes and is conducted in accordance with the GDPR article 6 as described below. Luups will not further process your personal data in a manner that is incompatible with those purposes.
5) Direct inquiries
Inquiries addressed to the provided contact information on our website or within this privacy policy will result in Luups processing your contact information and any other information you provide to us. The legal basis for such processing is our legitimate interest in responding to your inquiry and providing good customer service, cf. GDPR article 6.1 letter f). We sincerely ask that you confine the provided information to what is necessary for us to address your inquiry and undertake appropriate actions.
6) Registration and use of user accounts
Upon registration to use Luups’ services, the customer will provide personal data relating to a designated contact person, i.e. name, country code and phone number, which is used to verify his or her identity by text message and to generate a unique user ID within our systems. The administration of your customer account includes processing of personal data you have provided relating to the account and transactions conducted to pay for our services. The legal basis for this processing is GDPR article 6.1 letter b) as it is necessary for Luups to honour our obligations according to the general terms and conditions. If you choose to terminate your account, we will make sure to delete your personal data, provided that we are not legally obliged to further process your personal data.
7) Retention time
Luups will not process your personal data beyond what is necessary to fulfill the purpose of collecting your personal data in the first place and will respect the limitations of all legal bases allowing us to process your personal data. All processing of personal data shall cease upon the withdrawal of your consent to such processing, provided that we are not legally obliged to further process your personal data.
Once the retention period expires, personal data will be deleted. Therefore, you may not be able to invoke the right to access, erasure, rectification and data portability after the retention period has expired. If you have any questions or concerns regarding the retention of your personal data, please contact us by using the contact information provided below.
8) Media projects on our platforms
Luups acts as a data processor with regards to all creations of, participations in, and contributions to media projects that are made available on our platforms, unless Luups is the one organizing the project. Therefore, the project owner will be responsible for the processing of your personal data, and Luups will not control how your personal data is processed.
All processing of your personal data will be based on the agreement you concluded with the owner of the media project when you submitted your media contribution, cf. GDPR article 6.1 b).
By submitting photos, videos and other media content, you have transferred an unlimited and perpetual right to use the media content to the project owner. Therefore, your media content may be freely used for public purposes as defined by the project owner, including use in marketing.
Luups does not control for how long your personal data will be processed, and we are not in a position to affect how the personal data will be used. If you have any questions or concerns, we ask that you contact the project owner directly. If you are not able to reach the project owner, please let us know and we may be able to assist you.
9) Disclosure of personal data and data processors
Luups takes appropriate security measures to prevent unauthorised access to your personal data as well as to avoid unwarranted disclosure, modification and/or unauthorised destruction of your personal data.
Luups will not disclose personal data to third parties, unless the third party is engaged as a data processor governed by a data processor agreement ensuring that appropriate technical and organisational measures have been implemented.
10) Rights of the data subject
You have the following rights in accordance with the GDPR:
- You are entitled to a confirmation as to whether or not Luups processes your personal data and to access any personal data Luups processes about you, as well as the purpose of said processing.
- You have the right to verify and where applicable rectify any inaccurate personal data concerning you and to have incomplete personal data completed.
- You have the right to obtain restrictions on processing of personal data concerning you.
- You have the right to object to the processing of personal data and to withdraw any previously given consent. Please note that the withdrawal of a consent does not affect the lawfulness of any processing performed previous to the withdrawal.
- You have the right to erasure of personal data concerning you. Upon request of erasure Luups will be obliged to delete your personal data unless Luups otherwise has legal grounds to further process the data.
- You have the right to lodge a complaint and to bring a claim before the competent data protection authority. Information regarding when and how to lodge a complaint may be found here.
If you wish to exercise any of the above mentioned rights or have questions about them, please let us know by using the contact information provided below.
11) Location of processing and transfers to third countries outside the EU/EEA
Luups processes personal data at our operating offices and in any other locations where the parties involved in the processing are located. Depending on your location, data disclosure between you and Luups may involve transferring your personal data to a country other than the country you are currently located in. If you want to know more about how this may affect the processing of your personal data, do not hesitate to contact us using the contact information provided below.
Luups will not transfer your personal data to third countries outside the EU/EEA, unless we have ensured a valid legal basis for transferring your personal data, and that your personal data is protected in compliance with GDPR chapter V. This way, we will ensure that your personal data is subject to a level of security that is essentially equivalent to the one granted by GDPR.
12) Security
Luups has implemented the necessary organisational and technical measures to ensure that your personal data is processed in a secure manner emphasising the importance of integrity, confidentiality and availability of personal data. Luups strives for compliance with the principle of data minimization by reducing the amount of personal data we process to what is absolutely necessary.
Luups processes your personal data under strict confidentiality on servers with limited access located in secured facilities. Access rights are protected with two-step verification systems and are solely granted to personnel who need such access to conduct their job. We also monitor and evaluate our security measures on an ongoing basis to identify necessary adjustments.
13) Legal action
Your personal data may be used for legal purposes by Luups in court or in the stages leading up to potential legal actions arising from improper use of this website or the related services.
14) Disclaimer
Luups gives no warranty and accepts no responsibility or liability for content obtained or created through our services. We do not control how the content is used and cannot be held liable for any claims, damages, losses, expenses, costs, or liabilities arising from the use of this website or our services.
15) Changes to this privacy policy
Luups reserves the right to make changes to this privacy policy at any time. Changes will be updated and published on this website and Luups may also send you a notice by using contact information available to us.
We recommend that you check this page regularly and verify the date of last modification to ensure that you are acquainted with the latest and applicable privacy policy.
Provided that we change any of our processing activities performed on the legal basis of consent, we will collect new consents to secure legal bases for the continuation of the processing activity.
16) Contact
If you have any questions regarding this privacy policy or the GDPR, do not hesitate to contact:
Chris-Håvard Berge, +47 473 24 204, chb@luups.no
You also have the right to contact the competent data protection authority. Information regarding when and how to lodge a complaint may be found here.
