PRIVACY POLICY

Effective Date: June 3, 2024

This Privacy Policy represents a statement of S.C. LITHIUM S.R.L. (“Lithium Network”,“Lithium”, “We”, “Us” or “Our”), doing business as Lithium Network and Lithium Safety App, regarding the confidentiality of your personal data but also our commitment to do all the diligence to protect the personal data of those who visit our website or use our services.

This Privacy Policy contains a description of how and why Lithium may collect, use, store and/or share (“Process”) the information you (“User”, “Users” or “You”) provide us when you use our services (“Services”), such as when:

You visit our website at https://lthn.org or any website of ours that links to the Lithium Privacy Policy;
You download and use any of our “use case” mobile applications, such as the Lithium – The People’s Sense (“Lithium Safety App”) or any other application of Lithium that links to this Privacy Policy;
You engage with Lithium in other related ways, including any events, marketing or sales.
Our Privacy Policy also describes the security procedure, so that your personal data is not used inappropriately or unauthorized, but also the options available to you when you want to access, update or delete this data.

The Lithium Safety App Terms of Use Agreement is a different document, so, please be sure you read, understand, and accept these terms before you use our website or service. You can find these Terms of Use on the Lithium website and linked within the mobile application.

When you provide us information by using our website or in any other way, this means that you agree with our Privacy Policy, Terms of Use Agreement, and our business practices, thus we understand doing all the diligence to protect your personal data but also to give you the opportunity to choose how you will manage your privacy.

Please note that our Privacy Policy is not applicable to any services or products that other companies, individuals, or business partners offer, and, also, is not applicable to personal data that you may provide, using our technologies, to other parties.

If you use our technologies to provide information to a third party, which may have its own privacy policy, please feel free to read our Privacy Policy carefully before using our website or services.

By going through our Privacy Policy and reading it very carefully, you will be able to understand what are the rights and choices you can make when using our website or services.

Obviously, if you disagree with this Privacy Policy, Terms of Use Agreement, or business practices we use, we encourage you and kindly ask you not to use our website or services.

However, if after reading this Privacy Policy, you still have concerns or questions, we encourage you to contact us at: dpo@lthn.org

Personal data

Personal data is information that is directly attributed or indirectly attributable to your person. Therefore, we would like you to consider the way we treat the protection of this data as closely related to the quality of our services and our business, with a strong customer orientation, privacy, and security.

Please note that are two data privacy laws similar in type, but different in their scope, GDPR, which uses the term “personal data” and CCPA, which uses the term “personal information”, both with extraterritorial scope, GDPR protects any natural person (data subject) located inside the European Union at the time of collection or processing (exclusively individual), where the CCPA only protects individuals that fall under its definition of “a consumer” as being a California resident (includes data that is not specific to an individual but is categorized as household data).

Whenever we interact with you, we may collect and process personal data that will be used for the purposes detailed in this Privacy Policy.

When you visit our website, register on the site, download and use any of our “use case” mobile applications, such as Lithium – The People’s Sense (“Lithium Safety App”) or any other application of Lithium, purchase our services, or interact with us in any way, we and our third parties services providers may collect, use, maintains, discloses, store and/or share personal data that you provide to us, all this depending on the choices you make.

o Personal data that we collect

We collect the data that you, by your own will, provide to us when you contact us in any way when you register on our website, you show interest in our services and/or products, when you request the purchase of services and/or products through our website or applications.

In order to be able to use specific parts of our website or our applications you have to register first and when you do that you will have to provide us with certain information.

Depending on the context in which we/our services and you interact, the choices you make, or the products and their features you choose, we may collect the following:

email addresses;
passwords;
age (Please take into account the fact that Lithium does not address children under 13 years of age, and we do not deliberately collect any personal information from users under 13, so, it is up to you whether you provide us with this information about yourself).

o Sensitive personal data

Please note that we do not process sensitive personal information (for example, but not limited to, medical, educational, financial, or employment-related information).

o Information received from third parties

We may receive information from different sources such as the following: public databases, social media platforms, marketing partners, and other outside sources.

o Payment-related data

If you make any purchases, we may collect some data in order to be able to process your payment, such as

your payment instrument number;
the security code associated with your payment instrument
card expiration date
Please be aware that all payment data is stored and processed by our payment service provider, Stripe, and you may find their Privacy Policy link(s) here: http://www.stripe.com/privacy.

o Our application(s)

For individualized services adapted to your location, we may collect information if you use our application(s) and you choose to allow us access or permission to

geolocation information;
mobile device access;
mobile device data;
push notifications;
The provision of personal data is compulsory if you like to benefit from our listed services.

Please be aware of the fact that all information that you provide to us is mandatory to be correct (faithful), complete, and accurate, and, if you want to make changes to the information provided, please notify us in advance.

o Automatically collected information

When you visit, browse, use or navigate our services, even if we will not ask you for identification information such as your name or other contact information, please note that certain information is automatically collected, such as the following:

Internet Protocol (IP) address;
browser characteristics;
device characteristics;
your operating system
the name of the network provider
what language do you prefer
date and time of access;
URL’s (of the accessed file and Referrer – URL);
location
country you come from;
what device do you have
when and how you use our services;
other technicalities.
Please note that this data is needed both to offer you our operational and safe services and also for internal analytics and reporting purposes.

o Cookies

Also, we collect information through cookies and alike technologies, such as web beacons and pixels, in order to improve the user experience, so, please find and read carefully our Cookie Policy: https://lthn.org/cookie-policy-eu/. Thus, we may collect information related to the following:

log and usage data;
device data;
location data;
A cookie is a small file placed on your device or computer. It is possible that you may not agree to the acceptance of cookies by choosing the appropriate setting in your browser or mobile device, but if you choose this setting, you may not be able to access certain parts of our website or service.

We used cookies and similar technologies in order to collect and store when you interact with the services or products we offer you.

Please note that you have the right to refuse certain cookies, and information about how can you do this and how we use tracking technologies is all set out in our Cookie Policy: https://lthn.org/cookie-policy-eu/.

Most Web browsers are set to accept cookies by default. You can usually choose to set your browser to remove and reject cookies. If you choose to remove or reject cookies, this could affect certain features or some of our services. To opt out of interest-based advertising by advertisers on our services, visit http://www.aboutads.info/choices/.

If you have any questions or comments about your privacy rights, you may email us at dpo@lthn.org

o Information collected from other sources

Thus, we may use public databases, joint marketing, and advertising partners or other sources. The mentioned sources could provide us, but not limited to, information about:

the postal address;
e-mail address;
telephone number;
IP address or URL address;
information regarding the user’s behavior;
customer profile;
other information used for the purpose of advertising or promotional events.
Please be aware that we collect all this information in order to be able to offer you relevant services that meet your expectations, but also for the purpose of permanently updating our records or marketing, we may also use other sources to obtain information about you.

Processing your personal data

The personal data you provide us will be processed in order to be able to offer you our services, and to administer and improve these services. We also process the information obtained in the above ways for good communication with you, for the security of the interaction with you, to prevent fraud, and to comply with the legal provisions. If situations arise in which it will be imperative to process other information, we will do so only after obtaining your consent and only if we have a valid legal reason to do so.

Lithium collects your personal data for a diversity of reasons.

With your consent and depending on the choices you make when you interact with us and our services, we may process your personal data for many reasons, including

to help you create an account, to be able to connect to it, and to keep it in working order;
to be able to provide and facilitate the provision of the requested services;
in order to be able to answer to any questions you may have and to provide assistance if problems arise in using our services;
to send you more details regarding our services and the changes that we might make to Terms of Use, policies as well as the like;
to send you emails for marketing and promotional purposes if they are in accordance with your preferences, and discover which of our marketing and promotional campaigns are relevant for you. Please note that you can always refuse to receive these emails through a notification (please consult the section regarding your privacy rights in this Privacy Policy);
to protect our services in order to do all the diligence to protect your personal data and preserve our services safe and secure and also to monitor and prevent fraud;
to understand you from the way you use our services in order to continuously improve these services so that they meet your expectations;
to protect an individual’s vital interest, like preventing damage or loss.
Legal bases for the collecting and further processing of your personal data (Lawfulness of processing)

Lithium operates in the European Union, under EU law, so, if you choose to send any personal data to our website or any Lithium owned service or product, and you are an EU citizen, this information will be transferred to the EU, and its service providers, subjects to EU law. If you choose that you do not want the information provided to us to be subject to the law applicable in the EU, please do not send any personal information to Lithium or Lithium owned services and products.

Moreover, if you choose to send any personal data to our website, to Lithium or Lithium owned services and products, and you are a US or Canadian citizen, this information will be transferred to the US and its service providers, subject to US law. If you choose that you do not want the information provided to us to be subject to the law applicable in the US, please do not send any personal information to Lithium.

Please be aware that Lithium operates especially under the European Union GDPR (General Data Protection Regulation regarding “the protection of natural persons with regard to the processing of personal data and on the free movement of such data”).

Lithium’s intention is in no way to offer services or products in places/to entities where/for which offering such services or products fails to comply with the applicable law or contravenes applicable local law.

Related to the processing of personal data, under GDPR, the protection of natural persons is a fundamental right.

We only may collect and further process your personal data if:
you give us explicit consent or permission to use your personal data for one or more specific purposes. Please note that you are able to withdraw the consent at any time through a notification (please consult the section regarding your privacy rights in this Privacy Policy);
processing is necessary for the performance of a contract between us or our services and you or, at your request, to follow the necessary steps in order to conclude a contract between us and you;
processing is necessary for our legitimate business interest requires it or the legitimate interest of a third party, except when these interests are exceeded by your interests or fundamental rights and freedoms, especially if the data subject is a child. We may process your personal data for specific purposes, such as: sending periodic emails in order to inform the users of our services about discounts or/and special offers, for the purpose of analysis of our services in order to be able to continuously improve the services offered, to improve our site, for marketing purposes, in order to identify problems and/or avert fraudulent activity;
the processing is necessary in order to be compliant with a legal obligation;
the processing is necessary in order to protect any individual’s or yours vital interest, for example, a situation involving a threat to safety.

Sharing personal data with a third party

We may share personal data with third parties only under special situations, such as

Business Transfers in the event of any merger or negotiation regarding the sale of our business, financing, divestiture, restructuring, reorganization, dissolution or acquisition for all or a part of our business;
When we use Google APIs (such as Google Maps Platform API, Google Places API, etc.);
Share your personal data with our affiliates (our parent company and subsidiaries, joint venture partners, or other companies that we have in control or any other company that are under common control with Lithium). Please note that our affiliates must respect this Privacy Policy;
Share your personal data with business partners in order to be able to offer you certain services, discounts, and promotions.
We may share your personal data only with certain third parties such as vendors, consultants, service providers, contractors, agents, or other companies to market or sell non-Lithium services or products (“third parties“) who provide services to us or on our behalf and in order to do this require access to this kind of data. Our third parties are committed to protecting your personal data, and we have in place contracts that are designed to help safeguard your personal data, meaning that this third party cannot do anything with or share your personal data unless we have instructed them to do it. These third parties are obligated to protect the data they process on our behalf accordingly to our policies and the applicable law, including Google Analytics Advertising Feature.

The third parties we may share personal data (for the period we instruct them) as follows:

Cloud Computing Services (Google Cloud Platform);
Communicate and Chat with Users (Discord, Firebase Cloud Messaging and MailChimp);
Content Optimization (Google Fonts, MailChimp widget plugin and YouTube video embed;
Data Backup and Security (Google Drive Backup);
Functionality and Infrastructure Optimization (Cloud Firestore);
Invoice and Billing (Stripe);
Social Media Sharing and Advertising (Facebook advertising, Instagram advertising, LinkedIn advertising, Pinterest advertising and Twitter advertising);
User Commenting and Forums (Facebook Comments);
Web and Mobile Analytics (Facebook Analytics, Google Analytics, Google Tag Manager, Hotjar, WordPress Stats, TestFlight and Google Analytics for Firebase);
Website and Service Performance Monitoring (Uptime Robot);
Website and Service Testing (Google Play Console and TestFlight).
The period of keeping your personal data

We will only keep your personal data for as long as it is necessary for the purposes set out in this Privacy Policy unless a longer keeping period is required or permitted by law (legal requirements, taxation, or accounting purpose), no longer than the period of time in which users have an active account with us. We only process your personal data for the purposes of the legitimate interests of the business, and when this legitimate purpose stops, we will either delete or anonymize such information. If this is not possible (because your personal data has been stored in backup archives or for any other reason), then we will securely store your personal data and isolate it from any further processing until this deletion is possible.

The security of your personal data

In the unlikely case of a data breach, we do take all the technical measures to protect the data stored by us, using appropriate tools, such as but not limited to, backups, firewalls, DOS mitigation/absorption mechanism, etc.

Moreover, according to the GDPR, Lithium will notify the competent supervisory authority, not later than 72 hours after having become aware of the data breach, unless the data breach is unlikely to result in a risk to the rights and freedoms of natural persons. If the data breach is likely to result in a high risk to the rights and freedoms of natural persons, Lithium will also notify the affected users/persons without undue delay, in clear and plain language, unless the data breach contains information that is properly covered by protection measures, such as, but not limited to data encryption, or if measures were taken to stop the high risk to the rights and freedoms of data subjects to be materialized, or if the effort is disproportionate. In the latter case, there shall instead be a public communication or similar measure whereby the data subjects are informed in an equally effective manner.

Please be aware that in order to protect your personal data, we do all the diligence, but we cannot guarantee one hundred percent the security of your personal data, considering the fact that their transmission is done through the Internet and the storage technology provided by it, therefore, we cannot guarantee or promise one hundred percent that unauthorized third parties could outside the law to process your data. It can happen that even as we do all the diligence in order to protect your data, the transfer of personal data to and from our services it is done at your own risk. Considering the risks, you must access our services only in a secure environment.

Your rights and the exercise of these rights

Depending on your geographical location, from the point of view of the protection of personal data, you have the rights arising from the applicable law. The easiest way to exercise your rights is by contacting us about this Privacy Policy, using the email address dpo@lthn.org. We will take into consideration and act upon any request from you in compliance with applicable data protection laws.

If you are located in the EEA or UK and are concerned about your personal data processing, you have the right to complain to your local data protection supervisory authority. Please find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index/en.htm.

Also, please note that The European Commission has the power to determine, on the basis of article 45 of Regulation (EU) 2016/679 whether a country outside the EU offers an adequate level of data protection.

So far, The European Commission has recognized the following (please find here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en) as providing adequate protection.

Under GDPR, in order to empower and give you control over your personal data, you have certain rights that may include, in certain circumstances, the right:

to obtain confirmation whether personal data concerning him or her are being processed, and, where that is the case, access to the personal data;
to rectification and erasure („right to be forgotten”);
to restriction of processing;
to data portability;
to object;
not to be subject to a decision based solely on automated processing.
You can make a request in order to exercise these rights by contacting us using the contact details provided in this Privacy Policy, and we act about such a request in accordance with applicable laws concerning personal data protection.

Please note that you also have the right to withdraw your consent at any time, also by contacting us using the contact details provided in this Privacy Policy.

Moreover, please note that will not be affected the legality of the processing of your personal data before the withdrawal of consent when the applicable law allows this, and also the processing of your personal data based on other legal reasons for the processing, except for the consent, will not be affected.

You can also unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us by using the contact details provided in this Privacy Policy. After this, you will be removed from the marketing lists. However, we may still communicate with you (for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes).

Concerning the data account, if you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account through the technical means made available by Lithium, either in the form of a web or a mobile application feature.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may keep some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Do-not-track features control

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

Specific privacy rights under CCPA (The California Consumer Privacy Act of 2018)

If you are a California resident please note that you are allowed to request and obtain from Lithium once a year and free of charge, information about categories of personal information, if any, we disclosed to a third party for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the past 12 months. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided in this Privacy Policy.

If you are under 18 years of age, reside in California, and have a registered account with our services, you have the right to request the removal of unwanted data that you publicly post on our „Services”. To request the removal of such data, please contact us using the contact information provided in this Privacy Policy and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on our „Services”, but please note that the data may not be completely or comprehensively removed from all our systems (for example backups, etc.).

We may have collected the following categories of personal information in the past twelve (12) months:

Identifiers: contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name;
Internet or other similar network activity: browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements;
Geolocation data: Device location;
Inferences drawn from other personal information: inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
We may also collect other personal information outside these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

Receiving help through our customer support channels;
Participation in customer surveys or contests;
Facilitation the delivery of our services and to respond to your inquiries.
About how we use and share your personal information, Lithium collects and shares your personal information through:

Targeting cookies/Marketing cookies;
Beacons/Pixels/Tags
About our data collection and sharing practices, please find more information in this Privacy Policy and our Cookie Policy: https://lthn.org/cookie-policy-eu/.

Also, you may contact us by email at dpo@lthn.org, or by referring to the contact details at the bottom of this document.

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be „selling” your personal information.

Lithium has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. The categories of the third party to whom we disclosed personal information for a business or commercial purpose can be found in this Privacy Policy under „Sharing personal data with a third party”.

Your rights with respect to your personal data are the following:

Right to request deletion of the data (request to delete your data);
Right to know (request to know);
Right to Nondiscrimination for the Exercise of a Consumer’s Privacy Rights – no discrimination against you if you exercise your privacy rights;
Right to Opt-Out of Third-Party Sales and sharing;
Other privacy rights (for example, but not limited to the right to limit use and disclosure of sensitive personal information or right to correction).
To exercise these rights, you can contact us by email at dpo@lithium-app.com, or by referring to the contact details in this Privacy Policy. If you have a complaint about how we handle your data, we would like to hear from you.

Updates that we make to this Privacy Policy

We will update this Privacy Policy from time to time as necessary to stay compliant with relevant laws. The updated version will be indicated by an updated Effective date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

Contact us about this Privacy Policy

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Gabriel-Eugen Pintea-Dode, by email at dpo@lthn.org, or by post to:

S.C. LITHIUM S.R.L.
VAT Number: 49156747
TIN (C.U.I.): 46332377
Registration Number: J40/11708/2022

Splaiul Unirii 43, Apt. 19
030125
Bucharest, Romania, European Union

Administrator: Gabriel-Eugen Pintea-Dode

Review, update, or delete the data that we collect from you? Based on the applicable laws of your country, you may have the right to request access to the personal information that we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please send an email to dpo@lthn.org