Privacy and Cookie Policy
Introduction
Who are we?
We are Levellr Ltd, a company incorporated and registered in England and Wales with address 2, Television Centre Soho Works, Wood Lane, London, England, W12 7FR and company number 12909887. Where we decide the means or purpose of processing your personal data, we are the data "controller."
What’s this policy about?
This policy explains how we process your personal data as a data controller. We update this policy from time to time so please check back in.
The policy applies to your use of our website levellr.com and messaging groups on platforms like Telegram and Discord that you access via that website (together the “Services”).
Please note that other websites/services not mentioned here are not operated by us, and you should refer to the privacy policies on those sites to understand how your data is used.
How do you contact us? (if you have questions about this policy or to exercise your rights)
Write to us: [email protected].
If we can’t resolve your issue, you can also get in touch with the Information Commissioner’s Office in the UK at: https://ico.org.uk/concerns.
(or if you live outside the UK in a European country, you can submit a complaint to the supervisory authority in your country).
What are your rights?
You have the following rights, although these rights may be limited in some circumstances:
- Ask us to send a copy of data to you or someone else
- Ask us to restrict, stop processing, or delete your data
- Object to our processing of your data
- Object to use of your personal data for direct marketing
- Ask us to correct inaccuracies
If we rely on consent to process data, or send direct marketing, you can withdraw consent by contacting us via the email address above.
Your personal data and how we use it
1) Enquiry data
This is information we receive when you get in touch with questions or instructions including:
- Name
- Contact details
- Other personal data you send to us as part of enquiries or instructions.
How long we keep it
6 years from when our relationship with you ends.
How we use it
We process this information to respond to your enquiries, for example by email or via our live chat support.
Legal basis
We process this information in accordance with the terms of our contract with you (where we need this information to provide our Services to you) or to take steps at your request prior to entering into a contract.
We also use this to pursue our legitimate interests in responding to enquiries, and in order to understand our customers and improve our Services.
You may be required to provide us with certain information in order for us to respond to your enquiries.
Sources
We collect this information from you.
Recipients
We may share aspects of your queries with Customers (i.e. third-party high-profile individuals or entities who typically host communities using Levellr technology) where necessary for us to action your enquiry.
2) Platform data
This is information we receive when you register for, or use, our web-based platform and communities in which our software is used, including:
- Name
- User IDs (e.g. your Telegram or Discord user ID)
- Usernames (e.g. your Telegram or Discord usernames)
- Your order and transaction history
- Communications through our Services or the communities in which our software is used
- Usage data and telemetry based on your use of our Services or the communities in which our software is used
- Your feedback and survey responses
How long we keep it
Up to 6 years from when our relationship with you ends.
How we use it
We share platform data relating to a specific community with the Customer that operates the community. The Customer uses this data to operate and manage their community. They can also access this data via the platform hosting the community (such as Discord or Telegram).
Legal basis
We process this information in accordance with the terms of our contract with you in order to enable you to login to and use our web-based platform and access our Services.
We also use this to pursue our legitimate interests in obtaining feedback and survey responses from you to understand market trends, our customers, how they use our Services, and to improve our Services, and to monitor compliance with our terms of service.
You may be required to provide us with certain information in order for us to provide our Services.
Sources
We collect this information from you and from the third-party platforms you use to access communities (e.g. Telegram or Discord).
If someone is purchasing something for you through our platform, for example a subscription as a gift, we may collect this from the purchaser. If you provide any information relating to a third party when using the Service, please ensure that you share a copy of this privacy notice with them and that they are happy for their details to be shared.
Recipients
Where necessary for us to provide our Services we may share certain information (such as details of your orders) with relevant Customers.
Where necessary for us to provide our Services (e.g. where we need to grant you access to a Telegram or Discord community) we may share the access levels to be granted for your username or roles to be granted to your user account with the relevant third party platform.
We may share this data with the Customer who hosts the community using our Services. These organizations may access your data from international locations including the USA.
We may process this information using Google (our cloud services provider) or Stripe (our payment processor). These organizations may access your data from international locations including the USA.
For communities created before September 2021, we may process this information using Shopify (our previous e-commerce platform) or InviteMember (our previous Telegram service provider). These organizations may access your data from international locations including the USA.
3) Mailing list opt-ins
This information includes:
- Name
- Email address
- User IDs (e.g. your Telegram or Discord user ID)
- Usernames (e.g. your Telegram or Discord usernames)
- Country of residence
How long we keep it
Until you indicate that you no longer wish to receive marketing messages from us or our Customers.
How we use it
Where we have your consent and/or you have opted-in to receive marketing messages from us, we will send you emails and/or direct messages via Telegram or Discord with news about our company and services.
Where we have your explicit consent or you have opted-in to receive marketing messages from one or more of our Customers, we will share this information with those Customers. (Customers are third parties who operate the messaging groups and are, typically, the company who operates the Levellr community to which you have either registered or subscribed.)
Legal basis
- Consent; or
- “Soft opt-in” or B2B: In some instances (such as with existing customers, or if you are a corporate subscriber) the law may permit us to process your personal data to send you marketing by email or Telegram/Discord direct message that we think is of interest on the basis of our legitimate interests, being our legitimate interest to promote our business, or process your personal data to share with third parties “Soft opt-in” or B2B: In some instances (such as with existing customers, or if you are a corporate subscriber) the law may permit us to process your personal data to share with third parties so that they can send you marketing by email or Telegram direct message that they think is of interest on the basis of our legitimate interests, being their legitimate interest to promote their business.
Opting out
If you would like to be removed from marketing lists please let us know by clicking unsubscribe at the bottom of any marketing email you receive.
Sources
We collect this data from you if you decide to sign-up.
Recipients
We use Mailchimp, Postmark, Telegram, and Discord to help manage our email lists and send marketing messages.
4) Analytics (information about how users interact with our Services which might be associated with a unique identifier)
This information includes:
- browser type and version, IP address (which is swiftly processed and anonymized), approximate location and time zone, access logs, device type and settings, operating system, and other information provided by browser or device;
- use you make of our Services, including the content you visit, links you click, terms you search for, websites you have come from, how long you spend on our Service and how you interact with it.
How long we keep it
After 26 months underlying data is deleted, but we may retain some anonymous, aggregated statistics generated from that data.
How we use it
We use third party services like Google Analytics, Fathom, Mouseflow and Mixpanel to collect anonymous information about visitors to our website and/or users of our platform, to understand how many people visit, where they come from, and how they interact with our Services, and to help us improve and maintain our Services and address bugs.
Legal basis
To the extent that our analytics involve storing or accessing information on your device other than as strictly necessary for us to provide our Service to you, we obtain your prior consent.
Otherwise, we process this information, to the extent it is personal data, on the basis of our legitimate interest to understand how you use our Services, and to improve those Services.
More information
You can find out more about how Google Analytics uses data by clicking here, how Fathom uses data by clicking here, how Mouseflow uses cookies for analytics by clicking here, and how Mixpanel treats your data by clicking here.
You can opt-out of all non-essential cookies by .
✅ You have opted out of all non-essential cookies.
Sources
We use Google, Fathom, Mouseflow and Mixpanel’s services to collect this data from you when you visit our Services.
Recipients
Google in the USA and Ireland, Fathom in the USA, Mouseflow in the USA, and Mixpanel in the USA collect and process analytics information on our behalf.
5) Advertising
This information includes:
- ad identifiers and other information collected from your device (including non-permanent identifiers such as the Android advertising ID and/or Apple's ID for advertising);
- country and region.
How long we keep it
We hold data for as long as necessary bearing in mind the purpose for which it was collected. To determine the appropriate period, we consider the amount, nature, and sensitivity of the data, the potential risk of unauthorised access, and legal requirements.
How we use it
We use features of “Google Ads Manager” called conversion tracking and remarketing. Through Google Ads Manager’s technology, users who have already visited our website and have shown interest, can be approached through digital ads on Google and other third-party websites. Users that have procured services from Levellr can also be identified to avoid unnecessary advertisements. Users are typically identified through the use of cookies.
Legal basis
We obtain your prior consent.
More information
You can find out more about how Google Ads Manager uses data by clicking here.
You can opt-out of all non-essential cookies by .
✅ You have opted out of all non-essential cookies.
Sources
We use Google Ads Manager to collect this data from you when you visit our Services.
Recipients
Google in the USA and Ireland collect and process this information on our behalf.
Where explicit retention periods are not described above, we hold data for as long as necessary bearing in mind the purpose for which it was collected. At the end of the retention period, we assess whether it is necessary to continue to retain information to achieve the purposes for which it was collected. To determine appropriate retention periods, we consider the amount, nature, and sensitivity of the data, the potential risk of unauthorised access, and legal requirements.
Cookies, analytics and similar technologies
Cookies, pixels and other technologies store and access data on your device to help websites and apps work. This table explains their purpose, how long they last, and who else can access their data. We get your consent to use them unless they’re essential for our sites, apps or services.
Most browsers allow control over cookies. For more information see:
Cookie/data
We use Mouseflow for analytics, which sets cookies with ID mf_user that may be stored for up to 3 months.
We use YouTube for video content, which sets various cookies on your device to enhance user experience and video
functionality. The specific cookies set include C, APISID, HSID,
NID, OTZ, SAPISID, SID, SIDCC, SOCS,
SSID, and all cookies beginning with __Secure-. These cookies may be stored for durations
ranging from 1 month to 2 years, depending on the cookie. For more detailed information about each cookie, including
their specific purposes and storage durations, please refer to the
cookie section of Google's privacy policy.
We use Google Analytics’ _ga cookies for analytics purposes. These cookies may be stored for up to 2
years. We use Google Ads Manager’s _id cookies for advertising and remarketing purposes. These cookies may
be stored for 13 months in the European Economic Area (EEA), Switzerland, and the United Kingdom (UK), and 24 months
everywhere else.
We set cookies with IDs levellr-cookie-preferences to keep track of your cookie preferences, which may be
stored for up to 6 months.
We set leads cookies with IDs levellr-leads to keep track of your leads subscription status, which may be
stored for up to 6 months.
Finally, we use our own cookie with ID jwt to give you access to your dashboard and to keep you logged in.
Purpose
We use these cookies for the following purposes:
- To provide our Services and to collect information about how people interact with our Services & generate reports to help us identify problems, understand how people use our Services, and improve them.
- To serve and render ads, personalise ads (depending on your settings at myadcenter.google.com, and adssettings.google.com/partnerads), limit the number of times an ad is shown to a user, mute ads you have chosen to stop seeing, and measure the effectiveness of ads.
You can find out more about how Google Ads Manager and Google Analytics uses data by clicking here. You can find out more about how Mouseflow uses data by clicking here.
Consent
The respective cookies are only set if you have consented to their use in our cookie banner forehand.
You can opt-out of all non-essential cookies by .
✅ You have opted out of all non-essential cookies.
Storage, transfers and disclosure
Storage & Transfers
Save where indicated otherwise, your personal data is securely stored in the EU. Where we use data processors outside the UK and European Economic Area, and transfer personal data to a country which does not provide an adequate level of protection, we use contracts or other safeguards which give personal data the same or equivalent protection it has in Europe or the UK. For more information drop us a line using the contact details at the start of this policy.
Disclosure
We may disclose your personal data:
- Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
- With members of our corporate group, insurers, advisers, suppliers and subcontractors, as necessary for the purposes set out in this policy.
- With our service providers and subcontractors, provided that they only use that personal data on our instructions and not for their own independent purposes.
- If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.
Subprocessors
Under the GDPR, a subprocessor is any business or contractor customer data may pass through as a side effect of using Levellr's service. This definition is very broad and includes things some might simply consider "hardware", like cloud infrastructure.
We use partners for some business processes that are not core to our expertise but are critical to our customers having a quality experience. Here is a current list of subprocessors.
| Entity | Service Provided | Country | Address |
|---|---|---|---|
| Email, collaboration, office, video, hosting, platform, AI, advertising and remarketing services | US | Google LLC, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA | |
| Mailchimp | Marketing email | US | The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA |
| Postmark | Transactional email | US | ActiveCampaign LLC, 1 N Dearborn St, 5th Floor, Chicago, IL 60602, USA |
| Mixpanel | Usage analytics | ES | MIXPANEL S.L., Avenida Diagonal, 442 - P. 3 PTA. 1 08037, Barcelona, Spain|
| Typeform | Forms and surveys | ES | Typeform S.L., Bac de Roda, 163, 08018, Barcelona, Spain|
| Fathom | Analytics | CA | Conva Ventures Inc., BOX 37058 Millstream PO, Victoria, British Columbia, V9B 0E8, Canada |
| Mixpanel | Analytics | CA | Mixpanel, San Francisco, One Front Street, Floor 28, California, United States |
| Hubspot | Customer relationship management software | US | Hubspot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141, USA |
| Elastic | Service monitoring and error reporting | NO | Elasticsearch AS, Postboks 539, 1373 Asker, Norway |
| Slack | Workplace communications platform | IE | Slack Technologies Limited, Salesforce Tower, 60 R801, North Dock, Dublin, Ireland |
The following subprocessors are only used for paid communities created before January 2022.
| Entity Name | Service Provided | Country |
|---|---|---|
| Uploadcare Inc | Content delivery network | US |
| Stripe | Payment processing | US |
The following subprocessors are only used for paid communties created before July 2021.
| Entity Name | Service Provided | Country |
|---|---|---|
| Shopify | Payment processing | US |
| Paypal | Payment processing | US |
| Klaviyo | Transactional email | US |
Data is stored in the following locations:
- Google Cloud Platform: Germany and the Netherlands