Liv Lowry

Privacy Policy

Updated

1. Privacy at a Glance

General Information

The following notes provide a brief overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. Detailed information can be found in the sections below.

Data Collection on This Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find the operator's contact details in the section “Notice Regarding the Responsible Party” in this privacy policy.

How do we collect your data?

On the one hand, your data is collected when you provide it to us. This may, for example, be data you enter into a contact form.

Other data is collected automatically by the systems of our content delivery network provider when you visit the website. This is primarily technical data (e.g. IP address, internet browser, operating system, or time of the page request) that is technically required to deliver the website.

What do we use your data for?

The data is collected to ensure error-free and secure provision of the website, and to process your inquiries and, if you have signed up, your newsletter subscription.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipients, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time with effect for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and any other questions on the subject of data protection.

2. Hosting and Content Delivery Network

We host the contents of our website with the following provider:

Bunny.net (Content Delivery Network)

The provider is BunnyWay d.o.o., Cesta komandanta Staneta 4A, 1215 Medvode, Slovenia (hereinafter “Bunny.net”).

Bunny.net is a globally distributed content delivery network (CDN). The transfer of information between your browser and our website is technically routed through the Bunny.net network. Static content such as images, fonts, scripts, and page content is delivered via regionally distributed servers. This allows us to improve the global availability and performance of our website.

When our website is accessed, technical connection data of the server request is processed, in particular the IP address, date and time of access, the requested page, and browser and device information (user agent). This data is processed exclusively transiently for the delivery of the content; no access logs are stored, as logging is disabled with our CDN provider.

In addition, api.livlowry.com is configured as its own pull zone with Bunny.net. Requests to this address, including messages submitted via the contact form and requests to verify download access tokens, are first routed through Bunny.net’s network to our origin server at Hetzner before being processed there. The files made available for download are themselves held in a Bunny.net storage zone and delivered from there (see section “Download Area for Newsletter Subscribers”).

Retailer redirect: When you click a purchase link, our service reads the country code provided by Bunny.net (CDN-RequestCountryCode) to automatically redirect you to the appropriate country-specific store (e.g. Amazon). The country code is used solely for this immediate redirect and is not stored. This processing is based on Art. 6(1)(f) GDPR; we have a legitimate interest in directing you to the appropriate retailer.

The use of Bunny.net is based on Art. 6(1)(f) GDPR. We have a legitimate interest in providing our website in a manner that is as error-free, secure, and performant as possible.

The provider is based in Slovenia and therefore within the European Union. Further information on data protection at Bunny.net can be found here: https://bunny.net/privacy/.

Data Processing Agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that this provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

Hetzner (Server Hosting)

Our own transmission service for contact form messages and for verifying download access tokens (api.livlowry.com), as well as our self-operated email server, are run on servers of Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany (hereinafter “Hetzner”). Requests to this service technically arrive first via the network of our CDN provider Bunny.net (see section “Bunny.net”). Messages addressed to us (including messages submitted via the contact form) are stored on the email server until they are deleted.

When this service is accessed, technical connection data (in particular the IP address) is processed transiently to the extent technically required for delivery. Our software does not store any access logs; neither IP addresses nor names nor message contents are logged.

The processing is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the secure and reliable provision of these functions. The provider is based in Germany; no transfer to a third country takes place.

Data Processing Agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that this provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

3. General Information and Mandatory Disclosures

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

Only a small amount of personal data is processed when you visit this website. Personal data is data that can be used to personally identify you. The only data collected automatically is the connection data technically required for delivery. We process further data only if you provide it to us yourself, for example via the contact form or when signing up for the newsletter; when you sign up for the newsletter, we process your email address, and in addition your IP address as well as the time of sign-up and confirmation are logged for verification purposes. We additionally collect anonymized usage statistics through our own analytics service (see section "Plausible Analytics"). This privacy policy explains which data this is in detail and for what purpose we process it.

Please note that data transmission over the internet (e.g. when communicating by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

Notice Regarding the Responsible Party

The party responsible for data processing on this website is:

Olivia Lowry
c/o Block Services
Stuttgarter Str. 106
70736 Fellbach
Germany

Email: contact@livlowry.com
Contact form: https://www.livlowry.com/contact/

The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).

Storage Period

Unless a more specific storage period is stated within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the deletion takes place after these reasons cease to apply.

The processing of your personal data on this website is based on the following legal bases:

  • Art. 6(1)(a) GDPR (consent): for receiving our newsletter. Consent can be revoked at any time with effect for the future.
  • Art. 6(1)(b) GDPR (pre-contractual measures): insofar as your inquiry via the contact form is directed at entering into a contract.
  • Art. 6(1)(f) GDPR (legitimate interest): for the technically secure and error-free delivery of the website and for responding to general inquiries.
  • Art. 6(1)(c) GDPR (legal obligation): insofar as statutory retention obligations exist.

The legal basis applicable in each individual case is stated in the respective sections of this privacy policy.

Recipients of Personal Data

In the course of our business activities, we work with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only pass on personal data to external parties if this is necessary in the context of fulfilling a contract, if we are legally obliged to do so (e.g. passing on data to tax authorities), if we have a legitimate interest in the transfer pursuant to Art. 6(1)(f) GDPR, or if another legal basis permits the data transfer. When using processors, we only pass on personal data on the basis of a valid data processing agreement.

Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The lawfulness of the data processing carried out until the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

IF THE DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA ON GROUNDS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING SERVES THE ASSERTION, EXERCISE, OR DEFENSE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS ASSOCIATED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to Lodge a Complaint With the Competent Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, their place of work, or the place of the alleged violation. The right to lodge a complaint exists without prejudice to other administrative or judicial remedies.

Right to Data Portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only take place to the extent technically feasible.

Information, Correction, and Deletion

Within the framework of the applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of the data processing and, if applicable, a right to correction or deletion of this data. You can contact us at any time regarding this and any other questions on the subject of personal data.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

  • If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
  • If the processing of your personal data was/is carried out unlawfully, you can request the restriction of data processing instead of deletion.
  • If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
  • If you have lodged an objection pursuant to Art. 21(1) GDPR, a balancing of your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may, apart from its storage, only be processed with your consent or for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the European Union or a member state.

No Automated Decision-Making

No automated decision-making, including profiling within the meaning of Art. 22(1) and (4) GDPR, takes place on this website.

SSL and TLS Encryption

For security reasons and to protect the transmission of confidential content, such as inquiries you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

4. Data Collection on This Website

Cookies

This website is a static website and does not set any cookies itself. We use neither session cookies nor permanent cookies, nor comparable recognition technologies (e.g. local storage or device fingerprinting) that would allow you to be tracked across sessions or websites. For anonymized usage statistics we use Plausible Analytics, which operates entirely without cookies (see below).

Since no cookies requiring consent and no access to information on your device within the meaning of § 25(1) of the German TDDDG takes place, this website does not require a consent banner.

When the website is accessed, only the connection data technically required for delivery is processed by our content delivery network provider (see section “Bunny.net”). This processing is based on Art. 6(1)(f) GDPR for the secure and error-free provision of the website.

Plausible Analytics

For anonymous analysis of usage behavior, we use the self-hosted, open-source web analytics service Plausible Analytics (analytics.livlowry.com), operated on our own servers at Hetzner (see section "Hetzner"). No data is transmitted to third parties.

Plausible does not use cookies or any other persistent recognition features. To determine unique visitor counts, a hash is generated from the IP address, user agent, date, and domain, which rotates daily; the IP address itself is not stored. For approximate geographic identification (country), a local, offline geolocation database is used; no data is transmitted to external services in this process.

Only aggregated, non-personal statistics are collected and stored, such as pages viewed, referrer, device and browser type, and country of origin.

Since no cookies are set and no individual profiles are built over time or across websites, the use of Plausible does not require consent under § 25 TDDDG. The processing is based on Art. 6(1)(f) GDPR; we have a legitimate interest in the anonymized analysis of website usage in order to improve our offering.

Contact Form

If you send us a message via the contact form, your details from the form, including the contact data you provide there, are forwarded via our own transmission service operated at Hetzner (see section “Hetzner”) exclusively by email to our own, self-operated mail server. The transmission service does not store your message, your contact data, or your IP address. No storage in a database on the website takes place. Your message remains in our email mailbox until it is deleted there. We do not pass this data on to third parties without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR, insofar as your inquiry is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of inquiries addressed to us (Art. 6(1)(f) GDPR).

The data you submit remains with us until you request its deletion or the purpose for the data storage no longer applies (e.g. after your inquiry has been fully handled). Mandatory statutory provisions, in particular retention periods, remain unaffected.

Providing your data in the contact form is voluntary; there is no statutory or contractual obligation to do so. However, without this information we cannot respond to your inquiry.

5. Newsletter

Newsletter Data

If you would like to receive the newsletter offered on the website, we require an email address from you as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. No further data is collected, or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.

Providing your email address is voluntary; you are neither legally nor contractually obliged to provide it. However, without an email address, the newsletter cannot be sent. You will not suffer any disadvantage as a result.

Sign-up to our newsletter uses the so-called double opt-in procedure. This means that after signing up, you will receive an email asking you to confirm your sign-up. This confirmation is necessary so that no one can sign up with someone else's email address. Newsletter sign-ups are logged in order to be able to prove the sign-up process in accordance with legal requirements. This includes storing the time of sign-up and confirmation as well as the IP address. This log data is stored with our newsletter service provider MailerLite; no storage on our own systems takes place.

The processing of the data entered in the newsletter sign-up form is based exclusively on your consent (Art. 6(1)(a) GDPR). You can revoke the consent given to the storage of the data, the email address, and its use for sending the newsletter at any time, for example via the “unsubscribe” link in the newsletter. The lawfulness of the data processing operations already carried out remains unaffected by the revocation.

MailerLite

This website uses MailerLite for sending newsletters. The provider is UAB “MailerLite”, J. Basanavičiaus 15, LT-03108 Vilnius, Lithuania (hereinafter “MailerLite”).

MailerLite is a service that can be used, among other things, to organize and analyze the sending of newsletters. The data you enter for the purpose of receiving the newsletter is stored on MailerLite's servers.

Data analysis by MailerLite: With the help of MailerLite, we are able to analyze our newsletter campaigns. For example, we can see whether a newsletter message was opened and which links were clicked. In this way, we can determine, among other things, which links were clicked particularly often. This is generally recorded via so-called tracking pixels (web beacons) embedded in the newsletter message. If you do not want any analysis by MailerLite, you must unsubscribe from the newsletter. We provide a corresponding link in every newsletter message for this purpose.

The data processing is based on your consent (Art. 6(1)(a) GDPR). You can revoke this consent at any time by unsubscribing from the newsletter. The lawfulness of the data processing operations already carried out remains unaffected by the revocation.

The data collected for the purpose of receiving the newsletter is stored exclusively on MailerLite's servers; no storage on our own systems takes place.

If you unsubscribe from the newsletter, no further newsletters will be sent to you. Your data stored with MailerLite will initially be retained. At your request, we will delete your data completely; to do so, please contact contact@livlowry.com or use our contact form. Your data will then be completely removed from our newsletter service provider's system, including the sign-up logs and usage statistics.

The contracting party is based in Lithuania and therefore within the European Union. According to the provider, the subprocessors used by MailerLite are also based in the EU; accordingly, no transfer to a third country takes place. The current list of subprocessors is part of MailerLite's data processing agreement.

Further details can be found in MailerLite's privacy policy at: https://www.mailerlite.com/legal/privacy-policy.

Data Processing Agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that this provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

6. Download Area for Newsletter Subscribers

Subscribers to our newsletter receive a personal download link for exclusive content in the welcome email. This link contains a pseudonymous access token derived from the subscriber identifier of our newsletter service provider. When the link is opened, our service, operated at Hetzner (see section “Hetzner”), verifies the validity of the token. The requested file itself is then delivered via a signed, time-limited URL from a storage zone of our CDN provider Bunny.net (see section “Bunny.net”).

The service does not store any subscriber data in the process: no separate subscriber database is maintained, no access logs are created, and no cookies are set. The token is verified computationally without any storage.

The processing is based on Art. 6(1)(b) GDPR, as the provision of the content is part of the service associated with the newsletter sign-up. Token verification takes place on our service at Hetzner, while file delivery takes place via Bunny.net; both providers are based within the European Union.