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PRIVACY POLICY

Last Updated: January 1st, 2020

We are delighted that you have shown interest in the services of Exclusv.Life which are provided via Exclusv.Life (the “Website”). Data protection is a particularly high priority for the management of Exclusv.Life.

Key aspects of our privacy practices described in this Privacy Policy include the following explanations:

  • The information we collect and why we collect it;
  • Know Your Customer (KYC) Policy;
  • How we use that information;
  • How we share information; and
  • The choices we offer.

  1. Personal Data That We Collect:
  2. Our services require you to provide us with Personal Data. If you choose to withhold any Personal Data requested by us, it may not be possible for you to gain access to parts of the Website and for us to respond to your query. We, as Controllers, use the information we collect to operate and maintain our Website and the Services offered, send you marketing communications and respond to your questions and concerns. The Personal Data which you may provide to us could include, but is not limited to:

    • Your First Name,
    • Your Last Name,
    • Your Gender,
    • Your Age and date of birth,
    • Your Email address,
    • Your phone number,
    • Your Website usage statistics,
    • Your behavior inside of the Website,
    • Your contact information;
    • Information stored on or shared in social media accounts (such as, by way of example but not limitation, Snapchat usernames);
    • Your identification documents;
    • Any other information or data required for the operation of the Website and Services provided through the Website.

  3. Non-Personal Data That We Collect:

    data from you, such as IP host address, pages viewed, operating system, referring service, search information, device type, page views, usage and browsing habits on the Service, and other similar data. We may also aggregate demographic information collected from our users (such as the number of users in a particular geographical location) in a manner which does not identify any one individual. We may also aggregate information collected offline in connection with the Service, obtain non-personal data from third party sources and develop aggregate information by anonymizing previously collected personal data.

    It is possible at times when collecting non-personal data through automatic means that we may unintentionally collect or receive personal data that is mixed in with the non-personal data. While we will make reasonable efforts to prevent such incidental data collection, the possibility still exists. If you believe that we have inadvertently collected your personal information, please notify us at [email protected]


  4. Know Your Customer Policy (KYC Policy)

    • Know Your Customer (KYC) means identifying the customer (which includes both Members and Content Creators) and verifying his/her identity by using reliable, independent source documents, data or information.
    • Exclusv.Life shall obtain sufficient information necessary to verify the identity of each new customer, whether regular or occasional.
    • KYC to be carried out at different stages: while carrying out a financial transaction (or), when there is a doubt about the authenticity/veracity or the adequacy of the previously obtained customer identification data.
    • For customers that are natural persons, it would be necessary to verify the identity of the customer, his/her address/location and also his recent photograph, documents for verifying signature.
    • For customers that are legal persons or entities, it would be necessary to
      1. verify the legal status through proper and relevant documents,
      2. verify that any person purporting to act on behalf of the legal person/entity is so authorized and identify and verify the identity of that person,
      3. understand the ownership and control structure of the customer and determine who are the natural persons who ultimately control the legal person,
      4. to verify identity card, Tax Numbers etc.

  5. Information Usage:

    We will only use your personal data as described below, unless you have specifically consented to another type of use, either at the time the personal data is collected from you or through some other form of consent from you or notification to you:

    • We may share your personal data collected in connection with providing the Service.
    • We may use your personal data to process payments.
    • We may use your personal data to respond to your inquires or requests, or to request feedback and to enable us to develop, customize and improve the Service.
    • We may use your personal data to conduct marketing analysis, to send you surveys or newsletters, to contact you about services, products, activities, special events or offers from Exclusv.Life or our partners and for other marketing, informational, product development and promotional purposes.
    • We may share personal data, with third party service providers who perform various functions to enable us to provide our Services and help us operate our business, such as website design, sending email communications, telephone communication, text messaging, advertising, fraud detection and prevention, customer care, third party surveys or performing analytics. These companies are authorized to use your personal information only as necessary to provide these services to us. Our contracts with these third parties require them to maintain the confidentiality of the personal information we provide to them, only act on our behalf and under our instructions, and not use personal information for purposes other than the product or service they are providing to us or on our behalf. We urge you to read privacy practices of all third-party vendors before submitting any personal data through the Service.
    • We may share aggregated demographic information about our customers, sales, and traffic to our partners and advertisers. We will not give, sell, rent, share, or trade any of your personal information or any data that you store using our services to any third party except as outlined in this Privacy Policy or with your consent. We may disclose information to a third party to
      1. comply with laws or respond to lawful requests and legal process,
      2. to protect Exclusv.Life, agents, customers, and others including to enforce our agreements, policies and terms of use or,
      3. in the good faith belief that disclosure is needed to respond to an emergency, or protect the personal safety of any person.
    • We may disclose personal data as required by law or legal process.
    • We may disclose personal data to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the terms or policies for our services or our sponsors.
    • We may transfer your personal data in connection with the sale or merger or change of control of Exclusv.Life or the division responsible for the services with which your personal data is associated.
    • We may share your personal data with an affiliate of Exclusv.Life who is in the same corporate family as us as long as their privacy practices are substantially similar to ours.
    • We may use your personal data to send you a welcoming email and to contact you about your use of the Website and services; to respond to your emails, submissions, comments, requests or complaints; to perform after-sales services; to anticipate and resolve problems with our service; to respond to customer support inquiries, for assistance with our product and service development; and to inform you of updates to products and services from Exclusv.Life that better meet your needs.


  6. Name and Address of Data Controller:

    Controller of data protection Snappy-Sites, a duly registered company in Queensland, Australia bearing ABN 15 336 779 273 and registered place of business located at 29, Timberlea Drive, Bentley Park, Queensland, Australia.

    Any users may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection: Zak Ozbourne, [email protected]

  7. Cookies:

    The Website use cookies. Cookies are text files that are stored in a device. Many applications use cookies. Through the use of cookies, Exclusv.Life can provide the users of the Website with more user-friendly services that would not be possible without the cookie setting. By means of a cookie, the services on the Website can be optimised with the user in mind. Cookies allow us, as previously mentioned, to recognise our users. The purpose of this recognition is to make it easier for users to utilise our Website. The Website user that uses cookies, e.g. does not have to enter access data each time the Website is accessed, because this is taken over by the Website, and the cookie is thus stored on the user’s device.


  8. Contact possibility via the Website:

    The Website contains information that enables a quick electronic contact to our enterprise, as well as the Content Creators (“Website Chat”). If you contact Exclusv.Life or Content Creators by Website Chat or via a contact form, the personal data transmitted by you is automatically stored. Such personal data transmitted on a voluntary basis by you to Exclusv.Life or Content Creators, are stored for the purpose of processing or contacting you. There may be transfer of this personal data to third parties.


  9. Protection for Children:

    The use of Website is intended for and directed to adults. Our Services are not directed to minors and we do not knowingly collect personal information from minors. If at any time in the future we plan to collect personal data from children under 13, such collection and use, to the extent applicable, shall, when required, be done in compliance with the children's online privacy protection laws and appropriate consent from the child's parent or guardian will be sought where required by law. When we become aware that personal data from a child under 13 has been collected without such child's parent or guardian's consent, we will use all reasonable efforts to delete such information from our database.


  10. Routine erasure and blocking of personal data:

    Exclusv.Life shall process and store the personal data of the users only for the period necessary to achieve the purpose of storage, or as far as this is granted by law.


  11. Third-Party Data Processors:

    In order for our Website and Services to function, we need to share limited user data with third-party services. Below is a list of third-party services that have access and permission to process certain user data. Each third-party service is reliable and has data protection guarantees approved by Exclusv.Life. Our commitment is, and always will be, to our user’s privacy.

    3rd Party Processor Purpose
    Mailgun To send users email updates and notifications (users can unsubscribe at any point).
    Mailchimp To send email newsletters and surveys (SurveyMonkey) Users can unsubscribe at any point.
    Amazon Web Services (AWS) To securely store all user data.
    Verotel To process Payments from Members to Exclusv.Life.
    Bitsafe For Sending Payments from Exclusv.Life to Content Creators.

  12. Changes to this Privacy Policy:

    We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time. However, if at any time in the future we plan to use personal data in a way that materially differs from this Privacy Policy, including sharing such information with more third parties, we will post such changes here and provide you the opportunity to opt-out of such differing uses. Your continued use of the Service and our services following the posting of any changes to this Privacy Policy means you accept such changes.


  13. Governing Law:

    This Privacy Policy and our legal obligations hereunder are subject to the laws of state of Queensland, Australia, regardless of your location. You hereby consent to the exclusive jurisdiction of and venue in the courts located in the state of Queensland, Australia in all disputes arising out of or relating to the Services or Website.


  14. Contact:

    Please contact us with any questions or comments about this Privacy Policy, our privacy practices, or your consent choices by email at [email protected]