First, some definitions. When we say "we," "us," “Lyve” and "Givio,” we’re referring to Lyve, LLC, a State of Delaware limited liability company. When we say “you”, “User,” we’re referring to a person or entity that’s registered with us to use Lyve Products and/or Services, including Givio.
We provide tools and a platform (“Services”) that you may use to give and receive feedback and chart your progress. We offer these Services on our Givio website (“Website”) https://giv.io. In the course of providing these Services, we may collect Personal Information, which means information about a User. This information might be compiled to create a "Distribution List", for example a list of email addresses that a User has logged as part of the setup of their specific profile.
If you have any questions or comments, or if you want to update, delete, or change any Personal Information you’ve submitted on our Website, please use our contact form to get in touch. You may also contact us by postal mail at: Givio Privacy Department 2629 Quincy Adams Dr. Herndon, VA 20171
2. List and Email Information: When you create or add to an email Distribution List or create an email with the Services, we have access to the data on your list and/or the information in your email.
3. Information from your Use of the Service: We may collect information about how and when you use the Services. This information may include your IP address, time, date, browser used, the site you came from and/or move to, and actions taken by you within the application.
4. Cookies: When you register to use Givio, we store "cookies," which are strings of code, on your computer. We use those cookies to collect information about when you visit our Website, when you use the Services, your browser type and version, your operating system, and other similar information. You may turn off cookies that have been placed on your computer by following the instructions on your browser, but if you block our cookies, it may be difficult or impossible to use the Services. When you play one of the videos on the Websites, the Flash player may use local shared objects, which are also called Flash cookies. We don’t use these Flash cookies for anything, but we can’t stop the player from creating them (we tried).
We may use and disclose your Personal Information as follows:
1. To promote use of our Services. For example, if you leave your Personal Information when you visit our Website and don’t sign up for any of the Services, we may send you an email asking whether you want to sign up. And if you use any of our Services, and we think you might benefit from using another Service we offer, we may send you an email telling you about it.
2. To bill and collect money owed to us. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments. To learn more about the steps we take to safeguard that data, see Section 7 below.
5. To provide customer support.
6. To protect the rights and safety of our Members and third parties, as well as our own.
7. To meet legal requirements like complying with court orders and subpoenas.
8. To provide information to representatives and advisors, like attorneys and accountants, to help us comply with legal, accounting, or security requirements.
9. To prosecute and defend a court, arbitration, or similar proceeding.
10. To support and improve the Services we offer. This includes adding features we feel improve the Services.
11. To communicate with you about your account for informational, not promotional, reasons.
13. To send you informational and promotional content that you may choose (or "opt in") to receive. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email.
Subpoenas Occasionally, we may have to disclose information about our customers to meet legal requirements. Third-party disputes are a common example: If two parties have a dispute, and one of them used Givio in a way that’s relevant to the dispute, then we might get a request for user data. Whether we say “no way” or comply depends on the subpoena and the advice of council.
Unsubscribe Links It’s the law! Unsubscribe links are required by the CAN-SPAM act. Plus, making it easy for people to opt out is the right thing to do.
1. Social Media Widgets. Our Websites include social media features, like the Facebook Like button. These features may collect information about your IP address and which page you’re visiting on our site, and they may place a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with those features are governed by the privacy policies of the companies that provide them.
When you send email marketing, it may move from server to server as it crosses the internet. Along the way, server administrators can read what you send. Email wasn’t built for confidential information. If you have something confidential to send, please don’t use Givio.
Your subscriber lists are stored on a secure Givio server. We don’t, under any circumstances, sell your lists, contact people on your lists, market to people on your lists, steal your lists, or share your lists with any other party, unless it’s required by law. If someone on your list complains or contacts us, we may then contact that person. Only authorized employees have access to view Distribution Lists. You may export (download) your lists from Givio at any time.
We will use and disclose the information in your Distribution Lists only for the reasons listed under Use of Your Personal Information. It’s worth repeating: We respect your privacy and your subscribers’ privacy. We’d never sell your information or bother anyone on your mailing list.
No one is safe from hackers and wrong doers. If a security breach causes an unauthorized intrusion into our system that materially affects you or people on your Distribution Lists, then Givio will notify you as soon as possible and later report the action we took in response.
To protect your information, our credit card processing vendor uses the latest 128-bit Secure Socket Layer (SSL) technology for secure transactions. Our vendor is certified as compliant with card association security initiatives, like the Visa Cardholder Information Security and Compliance (CISP), MasterCard® (SDP), and Discovery Information Security and Compliance (DISC).
Givio accounts require a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. Because the information in your Distribution Lists is so sensitive, account passwords are encrypted, which means we can’t see your passwords. We can’t resend forgotten passwords either. We’ll only reset them and allow you to enter a new password.
Givio complies with the U.S.–E.U. and U.S.–Swiss Safe Harbor Framework, which is overseen by the U.S. Department of Commerce and covers the collection, use, and retention of personal data from European Union member countries and Switzerland. We certify that we follow the principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. A data processing agreement is available upon request, please contact [email protected] Safe Harbor Certification This section affects you if you do business in the EU or Switzerland.
We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do that. If your data changes (like a new email address), then you are responsible for entering those changes into the system.
We only store data about you for as long as it’s reasonably required to fulfill the purposes that gave us the right to access it in the first place. We keep some data indefinitely, relating to when and where emails were sent, which failed to be sent, which resulted in a complaint, or similar event.
We will give you access to any Personal Information about you that we hold within 30 days of any request for that information you make by emailing [email protected] Unless it’s prohibited by law, we’ll remove any Personal Information about you from our servers at your request. Complex requests may result in a charge for this service.
Draft: October 20, 2014