"Alert” means the notification you receive after an Asset has been located through the Public & Dark Web Scanning Service.  
 
“Assets” means the personal data you upload to your Dashboard to be scanned under the Public Web & Dark Web Scanning Services. 
 
"Membership" means membership which is granted to you by LVL and which makes the provision of the Service available to you (as a “Member”). 
 
“Member Account” means the personal account made available as part of your Membership which allows you access to the Service. 

"Public Web & Dark Web Scanning Services" means the data scanning services where Members can upload personal data (Assets) to the Website to be continuously scanned against the public, deep and dark web. The Member can be alerted where there has been an unauthorised disclosure.  

"Service" means the services which will be provided to you by LVL and its subcontractor(s) as part of your Membership as specified in Part B of the Terms of Service, including the Website and VPN App. 

“VPN App” means the virtual private network application for compatible mobile devices made available to the Member as part of the Service, further described at Part B, clause 1.3 of the Terms of Service. 

"Website" means the website which the Member, by connecting to their Members Account, can access the Service: www.check-my-web.com

Personal data, processing, data recipients shall have the meaning to it as prescribed under the UK General Data Protection Regulation 2016/679. 

This Privacy Policy aims to explain how we process your personal data in respect of the Membership and provision of Services. In particular, the Privacy Policy explains: 

i.    the type of personal data LVL collects 
ii.   how that personal data is used 
iii.  to whom LVL may disclose your personal data to 
iv.  how you can correct or change the personal data WL holds about you; and 
v. how you can change your preferences to opt-in or opt-out of receiving marketing communications. 

LVL collects and uses your personal data for the purpose of providing you with the Services. Your personal data is collected at various stages, from the point of enrolment to your use of the Services and exchanges with LVL. 

Membership Enrolment 

To become a Member of CheckMyWeb, you will be asked to provide a basic profile about yourself by filling out an online registration form with your name, mailing address, email address and payment information (including credit and/or debit card number and expiration date).  
This personal data is necessary to authenticate your identity, register you as a Member to receive the Services, including the day to day servicing of your Membership and processing payment for your Membership. Without it, LVL is unable to register you as a Member and/or provide you access to the Services. As such, the lawful basis we are processing your personal data under (as required under Article 6 of the UK General Data Protection Regulation) is performance of a contract with you.  
Your personal data is also necessary to detect, and, if necessary, prevent you from re-enrolling where your Membership had been terminated due to a breach of the Terms of Service such as misuse of the Services and/or Membership. This constitutes a legitimate business purpose of LVL. 
 
Life of Membership

• Interactions with Customer Services 

From time to time, you may interact with our Customer Service team who may request personal data and/or other supporting documents for the purpose of verifying your identity before actioning any requests in relation your Membership (especially when a data subject access request has been made).  
You may also be asked to provide evidence of your age and country of residence to ensure your eligibility for the Service in accordance with the Terms of Service. 
Our legal basis for processing such data will be performance of a contract. 
 

• Feedback and Surveys 

From time to time LVL may provide you, as a Member, the opportunity to participate in surveys. If you participate, WL may request certain personal data from you such as name, email address and demographic information. Participation in these surveys is voluntary. The results of the survey will be to improve the Services and to assist in the development of new LVL programs and services based on your feedback.  
LVL may use a third party service provider to conduct these surveys and that company will be prohibited from using your personal data for any other purpose. The use of such third party service providers for surveys will be made aware to you before you choose to participate. 
Our legal basis for processing such data will be consent.  
 

• Anonymised data and Aggregated data 

Anonymisation is the process of converting personal data to unidentifiable data so that it does not identify an individual and will not allow an individual to be identified through its combination with other data. WL collect, use and share anonymised and aggregated data such as statistical or demographic data to improve the quality of LVL (and its group companies) existing products/services, develop new features, products/services and for overall research purposes.  
As this data is anonymised and does not identify you, LVL may share this data with its group companies as well as third parties and partners. However, if LVL combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, LVL treat the combined data as personal data which will be used in accordance with this Privacy Policy. 
 

• Public & Dark Web Scanning and Alert Services 

LVL will collect and process any personal data you register as an Asset for monitoring purposes as part of the Public & Dark Web Scanning Service.  
LVL will only process Assets in an encrypted format and the personal data you register as an Asset, is limited to the preset fields within the Website. You will be able to register up to a maximum of 10 credit and debit cards and 10 bank accounts to be scanned as well as other personal data such as address, email addresses and contact details. 
At the point of your enrolment into the Service, your Primary Email Address was also registered as an Asset to the Public & Dark Web Scanning Service.  
You can access, add and delete Assets being monitored through your Member Account at any time. However, throughout your Membership, you must keep, as a minimum, a Primary Email Address and name for scanning/alert purposes and use of the Services.  If you choose to delete an Asset, the relevant personal data (including any alerts identifying such personal data) will be deleted within 24 hours. 
 
Public Web Scanning will start within 1 working day of the Assets you wish to be monitored, first being registered via the Website. Dark Web Scanning will start immediately of the personal data you wish to be monitored first being registered via the Website.  
 
If any Assets you register are detected, you will be notified immediately by an Alert to your Primary Email Address and to your Dashboard. The Alert will show you where the relevant Asset has been found (this forms part of the Detected Information) either as a URL address or general location.  
 
Your personal data contained within the Alert will be anonymised by masking certain characters to help prevent unauthorised access to this data. You will need to login to your Member Account to view the Alert in clear. 
 

• VPN App 

If you install the VPN App onto your mobile device, your IP address and device information (such as the type and version of your mobile, browser and operating system) will be collected by the application to provide the VPN App service and maintain security. In particular, the IP address will be used to identify the nearest server and will not be stored. 
Before using the VPN App, you will be asked to enter your username or Primary Email Address and password. These will be the same credentials you need to log into the Website. 
 

• Marketing 

LVL will ask you for your express consent before it shares your personal data with any company outside LVL’s group companies for marketing purposes. LVL will provide you with more information about the categories of these companies at the time of asking you for your express opt-in consent. This will typically be for products/services offered by other companies which may be of interest to you based on the product/service you have with us or may be for another purpose which will also be made clear to you at the time of obtaining your express opt-in consent. 
 
LVL will also ask you for your express consent before it sends you marketing communications about LVL group company products/services that are not similar to what you currently have with us. 
 
If you have provided your explicit consent to receive marketing communications but later change your mind, you can stop receiving them altogether by contacting LVL or updating your preferences in your Member Account. 

• Profiling 

LVL will use aggregated data and data collected from cookies and other similar technologies, including your online behaviour whilst using the Services and your personal data, to form a view on what LVL thinks you may want or need, or what may be of interest to you. Our legal basis for such processing is legitimate interest.  
This is how LVL decides which products, services and offers may be relevant for you. You will receive marketing communications from LVL about similar products and services if you have requested information from LVL or purchased goods or services from LVL or if you provided WL with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing by clicking the unsubscribe link in the email. Where these communications are sent to you as a result of automated decision making, we can confirm that i) any decision generated does not produce a legal or similarly significant effect, or ii) if the decision generated does produce such effects, appropriate measures to safeguard your rights, freedoms and legitimate interests have been previously implemented.  

• End of Membership

At the end of your Membership, we will retain certain personal data for the purpose of complying with legal and financial obligations and/or for the defence of legal claims relating to your Membership. Our legal basis for this processing is legitimate interest. 

LVL may disclose your personal data to: 

• to LVL’s group companies (including its employees), suppliers and service providers, to enable LVL to provide the Membership and Services to you, including to third parties who process payments from you on behalf of LVL, hosting companies, technical service providers, our VPN service provider and software and/or hardware vendors who may have access to LVL’s databases. 

• to your bank and/or the issuer of your bank card (such as VISA) and/or to one or more intermediaries who represent the aforementioned for the purpose of being be able to respond to requests or complaints.  

• to the marketing partner that provided you with details of LVL’s offer, for the legitimate business purpose of enabling them to track the offer you accepted from LVL, and enabling them to undertake market research and data analysis in relation to, but not limited to, your behaviours. This is used to determine the value of the Services for members. Data shared with the marketing partner may include name, address, email address, details on purchasing patterns and/or the status of your Membership, and will not be used for promotional or marketing purposes, and will not be disclosed by them to third parties, other than for the purposes stated above, who have undertaken in a binding agreement to process and maintain the confidentiality of your data in line with applicable law. 

LVL requires that its marketing partners and suppliers agree to process your Personal Information in accordance with instructions from WL, this Privacy Policy and any other appropriate confidentiality and security measures. These types of third parties are not permitted to use your information for any secondary purposes. 

LVL may also disclose your personal data to government, regulatory and law enforcement agencies to the extent disclosure is required or authorised by law and otherwise as LVL believes is necessary or appropriate to satisfy any law, regulation or other governmental request, to operate the Website properly, or to protect or defend the rights of LVL or the rights or well-being of LVL (and its group) employees, users or others and/or if you are involved (or are suspected of being involved) in any illegal activity (even without a subpoena, warrant or court order). 

If you provide explicit consent, LVL will also share your personal data with its group companies so that LVL and/or its group companies may send you information about other products and services which are not similar to the product and service you already have and which WL considers to be of interest to you. 

If you provide explicit consent, LVL may also share your personal with third parties (who are not group companies) so that LVL and/or those third parties may send you information about any products and services considered to be of interest to you. Note that third parties may have different privacy practices and LVL encourages you to read their privacy policies. 
LVL may transfer your information to third parties as a result of or in connection with a sale, merger, consolidation, transfer of assets, reorganisation or liquidation, and LVL shall notify you of any such activity if your personal data becomes subject to a different privacy policy. 

As part of the Services, we may use the services of financial institutions or bank's (including their subcontractors) (acting as data controller), subject to legal reporting requirements. In such circumstances these financial institutions or bank's subcontractors may carry out identity checks before any financial transaction is processed. Any information, which is processed by way of transfer to said financial institutions or bank's subcontractors, is intended for their use only and for this specified purpose only. As a result, we may ask you to provide us with a copy of your proof of identity (ID/passport) as well as some additional information such as a banks statement, date and place of birth, occupation, country of residence, address and phone number. 

We inform you that your failure or refusal to provide the information requested will prevent us from providing the Membership and may result in the termination. We may also need to suspend Services as a result of completing these checks. 

The Website may contain links or references to third party websites and the privacy policies of these websites may differ from this Privacy Policy. Please be aware that LVL has no control over such websites (other than those controlled by LVL’s group companies) and this Privacy Policy does not apply to such websites. We encourage you to read the privacy policies of such websites.

In certain cases you may be presented with the opportunity to download software from LVL or its licensors and suppliers that may improve the Services. In such cases, you will be presented with, and required to agree to separate terms and conditions specifically related to the download application ("Download Application") prior to downloading the software. 
At any time you can stop your use of this Download Application by uninstalling the Download Application from your computer. The only authorised means to uninstall the software is to use the Add/Remove Programs facility in the Microsoft Windows Control Panel. After the removal of the Download Application, you will no longer be able to use the features of this Download Application. 

The security of your personal data is an important concern to LVL. All customer databases are held in a secure environment and (except for law enforcement authorities in limited circumstances), only those LVL (or group company) employees or other persons who need access to your data in order to perform their duties are allowed such access. Any of these employees or persons who violate LVL privacy and/or security policies may be subject to disciplinary action, including possible termination and civil and/or criminal prosecution. Where you are using LVL websites, LVL will take proactive steps to put safeguards in place to provide for the secure transmission of your data from your computer to LVL servers. However, due to the inherent open nature of the Internet, LVL cannot guarantee that communications between you and LVL, and LVL and you, will be free from unauthorised access by third parties, such as hackers. LVL have implemented all necessary and reasonable technical and organisational measures to protect your data including: 

• data minimisation and encryption of personal data at rest and in transit. We comply with commonly used security standards, including the use of encryption protocols i) TLS 1.2 when transmitting your personal between our IT systems ii) SHA 256 when the data is kept at rest, and the full encryption of Assets upon receipt; 

• the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; 

• the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; and 

• a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing. 

You agree not to hold LVL (or any of its group companies) responsible for any breach of security except as set out in the Terms of Service. In addition, unencrypted email is not a "secure" means of communicating with LVL, since email may be intercepted by a third party in the course of its delivery. 
 
You are responsible for maintaining the strict confidentiality of your Membership password, and you shall be responsible for any access to or use of the Website, Memerhship or the Services by you or any person or entity using a password provided to you, whether or not such access or use has been authorised by or on behalf of you, and whether or not such person or entity is your employee, relative or agent. You agree to (a) immediately notify LVL of any unauthorised use of your password or any other breach of security, and (b) ensure that you exit from your Membership Account at the end of each session. It is your sole responsibility to control the dissemination and use of your password, control access to and use of your Membership Account, and to notify LVL if you desire to cancel your Membership. 

As part of the Services offered to you, for example through our website, the information you provide to LVL will be transferred to and processed in countries outside of the UK, but operating within the European Economic Area (EEA). Your data will be hosted in Germany and Ireland. 

LVL may also transfer (or provide access to) all or part of your personal data, to data recipients located outside of the UK and EEA including; the United States (for the purpose of payment processing, ad hoc application maintenance and systems support and provision of the VPN App (as the provider is located in the US); India (for the provision of maintenance and second-line IT support) and; the Philippines for the purpose of providing customer service. 

If LVL transfer or store your personal data outside of the UK, WL will take steps with the aim of ensuring that your privacy rights continue to be protected, as outlined in this privacy policy and in accordance with the UK General Data Protection Regulation. 

Whenever LVL process or transfer your personal data out of the UK, LVL always ensure that an adequate level of protection is afforded to it. It is the case for example when LVL processes or transfers your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK. Whenever LVL transfers data to countries who are not considered to offer an adequate level of protection by the Information Commissioners Office (“ICO”), LVL shall 1) conduct a risk assessment before transferring your personal data to ensure the security of your data 2) include relevant mechanisms (such as International Data Transfer Agreement, approved by the ICO (“IDTA”)) in contracts with them and 3) implement additional technical and organisational measures if and when required with providers and/or affiliates based outside of the United Kingdom. 

You can contact WL's Data Protection Officer if you want further information on the mechanisms used by us when transferring your personal data out of UK. 

LVL takes reasonable steps to ensure that the personal data it collects and processes is accurate, complete and current, but LVL depends on its members to correct or keep up to date their personal data. When returning to the Profile and Billing section of the Website, you can review and update your personal data. You can also change your password from your Profile page. If you make a change to your Member Profile we will notify you by email to your Primary Email Address.

We will retain your personal data collected as part of your Membership and use of the Services, including browsing data and use of VPN App, for as long as necessary to be able to provide the Services in a secure manner.   

However: 

• We will automatically delete, within a maximum period of twenty-four (24) hours, any Assets (and associated Alerts) you remove from the Public Web & Dark Web Scanning Service.  

• We will automatically delete, within twelve (12) months, the browsing data collected during your use of the Website and VPN application. Browsing data includes the IP address, type of terminal, operating system and browser used. 

Upon termination of your Membership:  

• All  Assets (and associated Alerts) will be deleted within twenty-four (24) hours; 

• Browsing data will be deleted within twelve (12) months from the date of collection on the Website and/or the VPN App; 

• We will retain your personal data (in a secure database) for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices you have made such as to receive marketing communications that you provided your consent to. In particular, we will retain the data you supplied when joining the product, including complaints, claims and any other data you supplied during the duration of your contract with us for your product/service for a period of 7 years from termination or expiry of your service in line with industry standards and UK statutory limitation periods for the defence of contractual claims. 

Protecting the privacy of children is very important to LVL. Membership is not open to anyone under 18 years of age.

Rectification

You can update and amend your data held by LVL if inaccurate or incomplete by emailing WL at customerservice@check-my-web.co.uk, or visiting your Member Account.

Access, restriction of processing, portability and erasure

If you would like to see the data LVL process on you, restrict the processing of your data, exercise your right to data portability or have it deleted you can contact LVL’s Data Protection Officer who will investigate the matter and take you through the necessary steps to provide you with the data you requested or to delete it. If you would like it deleted, in particular any data which is necessary for LVL to process to provide you with the product/service, you will no longer be able to use the product/service. If applicable, LVL’s Data Protection Officer will explain any circumstances where LVL are not be able to erase your data such as the exercise or defence of a legal claim and situations where you can restrict the processing of your data. LVL’s Data Protection Officer will respond to your query within 30 days of receiving your request.

Object

You can make choices about how your personal data may be shared by LVL with third parties for marketing purposes and/or how your personal data may be used by LVL for purposes not related to your Membership. LVL enables Members to opt into email marketing and to opt in to marketing from third parties through their Member Profile. If you have provided LVL with your explicit consent to receive marketing communications via email, you will find an unsubscribe link at the bottom of the marketing emails you receive. If you elect to opt out, such election (a) will not apply to communications that are directly related to your Membership or Alerts; (b) shall not preclude LVL, including its employees, contractors, agents and other representatives, from accessing and viewing your personal information to provide the Services, support or for any other purpose relating to your Membership and (c) shall not preclude LVL from disclosing your personal data as described in this Privacy Policy for purposes other than sending you promotional and marketing materials not related to your Membership.

LVL has appointed a Data Protection Officer responsible for privacy matters. If you believe your personal data has been used in a way that is not consistent with this Privacy Policy or your specified preferences, or if you have further questions related to this policy. Please contact the Data Protection Officer by email at dpo@check-my-web.co.uk. If you are not happy with the response you received or believe your data has not been used in accordance with this policy and therefore not processed in line with applicable laws, you may lodge a complaint with the Information Commissioner's Office (ICO), the UK Supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 
 
LVL shall assume responsibility for the personal you submit if LVL fails to honour its duty to provide reasonable protection of your personal information. It should be borne in mind, however, that you cannot hold LVL accountable for a security violation unless if LVL is at fault, in which case LVL’s liability shall be subject to the limits as set out in the Terms of Service. 

LVL reserves the right to modify this Privacy Policy at any time, so please review it frequently on the Website. If LVL makes any changes, you will either be notified by email or LVL will post a notice on the Website's homepage. LVL will also summarise any material changes to the Privacy Policy on the Website. LVL encourages you to read any revised Privacy Policy. 
 
If LVL is going to use your personal information in a manner different from that stated at the time of collection, you will be notified via email, and you will have a choice as to whether or not LVL uses your personal data in this different manner. 

By using the Website and/or the Services, you signify your acceptance of this Privacy Policy.