Our apps are designed to mask every aspect of your personal data from other users and third parties. We'll never sell your personally identifiable data.
We don't make any compromises here.
We'll always be transparent with you about your data. Just contact Lito and we'll tell you anything you'd like to know about your account.
Reach out to vbrznn@hotmail.com for inquiries.
See our California Policy.
Welcome to Lito’s Privacy Policy. We hope this information comes across as transparent and straightforward to all readers.
We'll discuss the information we collect, how we use it, and our commitment to securing it.
This Privacy Policy applies beginning May 23rd, 2020. This is the first version of our privacy policy.
Effective: May 23rd, 2020.
This Privacy Policy applies to websites, apps, and other virtual assistants that are operated by Lito.
LevelUp is an AI headshot generator app that creates professional pictures from your photos.
Q: What face data does your app collect? A: LevelUp collects images of your face, including details of your eyes, nose, hair, mouth, skin, and other facial features necessary to train an AI model.
Q: How do we use the collected face data? A: With this AI model, we create professional headshot photos that resemble your face and are hyper-realistic.
Q: Will the data be shared with any third parties? Where will this information be stored? A: Your facial data is not shared with any third parties and is securely stored on our servers using AWS and Google Cloud services for storage.
Q: How long will the face data be retained? A: Your facial data is discarded as soon as the AI model is finished with creating your headshot photos.
Lito is a holding entity designed to serve apps ranging from social discovery to utility functionality.
If you live outside the European Union, the entity responsible for your information is Lito.
We'll need some personal information from you, like your age and location. The only mandatory field to know from you is your age. You are free to choose a display name that is not your real name. Interests, personality traits, and other characteristics that describe you are optionally provided to help better find your matches. For our LevelUp app, we collect your photo information to create AI models of your face. We do not share these images with anyone and they are securely deleted from our servers when finished.
We may use personally identifiable information in the form of cookies to identify who you are.
Otherwise, all information will be asked for directly from you.
4. Your Personal Data and How We Use It
In this Section 4 we set out:
(a) the general categories of data and types of personal data that we may process;
(b) the source of that personal data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
4.1. We may process your registration data.
Registration data may include: your full name, photo (your “avatar”), ID, username and email address, gender, date of birth, country, region and city of residence as well as your social network account data. The source of the data is you. Registration data is required in order for you to be able to access and use the Service. The legal bases for this processing are consent and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
4.2. We may process your PC or software data.
All the personal data that is automatically sent by User’s installed software, including: the User’s IP-adress, cookies files content, personal data that is sent by browser or another software that allows you to access our Service, as well as date/time and your requested page URL, E-wallet ID, CSP name and exact date/time of the SMS-message sent and its content as well. If you buy products or services from us, we may collect your first and last name, partial credit card number and/or other payment information. The legal bases for this processing are consent and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We use our commercially reasonable efforts to make sure your credit card number and other payment information is kept strictly confidential by using only third-party billing services that are GDPR compliant and use industry-standard encryption technology to protect your credit card number from unauthorized use.
4.3. We may process your usage data.
Usage data is data about your use of the Service. Usage data is primarily non-personally-identifying information of the sort that web browsers, servers, and services like Google Analytics typically make available, such as the browser type, language preference, referring site, and the time of each visit. Other information that we might have access to includes how you use the Service (e.g. search queries), your approximate location, etc.
Usage data may include:
1) Data that we collect mainly for behaviour statistics, business intelligence and email campaigns ("analytics data"). We gather the Service traffic data with the help of Google Analytics.
2) Data that we collect mainly for technical, security and/or fraud prevention reasons or for tracking errors ("technical data").
The legal basis for this processing is our legitimate interests and/or by third-parties, namely to monitor the quality of the Service and improve the Service as well as to prevent, detect and investigate fraud, criminal activity or other misuse of the Service and to prevent security issues.
4.4. We may process your communication data.
Communication data is information contained in or relating to any communication that you send to us or generate through the use of our Service.
Communication data includes:
1) All your messages, requests and other communication with our Customer Support which may happen during the dispute review process or via support tickets, emails, or by means of any other communication tool; and
2) All your communications and file attachments or other data that you generate mainly by communicating to other Users.
Communication data may include email address, username, avatar, IP address, full name, audio and video files and in the case of manual ID verification: photo of the User’s personal ID, photo of the User and photo of the User’s utility bill or related document. Our system may also randomly take screenshots of your communications with other Users. The communication data may be processed for the purposes of communicating with you, record-keeping, in order to review and resolve disputes, prevent illegal and objectionable behavior, serve our customers better and improve our Service. The legal bases for this processing is our legitimate interests, namely the proper administration of our Service and business, prevention of illegal and/or immoral behaviour.
4.5. We may process your notification data.
Notification data is information that you provide to us for the purpose of subscribing to our email notifications, SMS notifications and/or newsletters. The notification data may include your email address, phone number, username and full name. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal bases for this processing is consent. You can unsubscribe at any point by contacting us, unchecking a box in your Profile Settings or by clicking the unsubscribe link in the email.
4.6. We may process any of your personal data when necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or outside the court procedure.
This may include using information for legal compliance, litigation or pre-litigation, security monitoring and investigation. You agree that your personal data may also be used as evidence that the Service was actually used by you in case a dispute arises between us and the User. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary in order to protect your vital interests or the vital interests of another natural person.
The company does not determine the validity of the personal data provided by you, we assume that you provide the accurate personal data and keep it updated. Please try to avoid supplying any unnecessary personal data to us.
Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services in some cases, legal authorities. Read on for more details about how your information is shared with others.
You share information with other users whom you are matched with. The information shared is voluntarily provided by you.
You can partially adjust what is shared in your settings.
We use third parties to help us operate and monitor our product for assurance.
We may disclose your information if found necessary to comply with a legal process, such as a court order, subpoena or search warrant, government or law enforcement investigation or other legal requirements
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
Sharing of information may involve international data transfers, for instance to the United States of America and other jurisdictions. An example of this would be video packets sent to other users so that you may video chat with them.
7. Your Rights
we have summarised the principal rights that you have under data protection law. Some of the rights are complex, might contain restrictions depending on the legal basis for processing the data and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.1 Your principal rights under data protection law are:
(a) the right to access;
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can ask for your personal data by contacting our Customer Support.
(b) the right to rectification;
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
(c) the right to erasure;
You have the right to the erasure of your personal data. We have described our policy for retaining and deleting personal data above in Section 9.
(d) the right to object to processing;
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
(e) the right to restriction;
You can request that your data no longer be processed in certain cases, for instance, when you exercise your right to object as described above, or when you contest the accuracy of your personal data processed by us.
(f) the right to data portability;
To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
(g) the right to complain to a supervisory authority;
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
(h) the right to withdraw consent.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
Without prejudice to the aforementioned, if we have reasonable doubts concerning the identity of a user exercising their rights referred to in Section 10.1 or if we otherwise due to security reasons deem it necessary, we may request the provision of additional information and otherwise use all reasonable measures necessary to confirm the identity of the user.
You may exercise any of your rights in relation to your personal data by contacting our Customer Support. Concerning "Right to erasure" users are also able to request the deletion of their account through our Service.
If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request to vbrznn@hotmail.com.
We work hard to protect you from unauthorized access to or alteration, disclosure or removal of your personal information.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us at vbrznn@hotmail.com.
Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. Please report all instances of underage use to Lito.
We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law.
We delete or anonymize your information upon deletion of your account, except when:
1. we must keep it to comply with applicable law.
2. there is an outstanding issue or claim making it necessary to contain your information.
If you have questions about this Privacy Policy, reach out to vbrznn@hotmail.com
We'll notify you prior to any material changes in this privacy policy.