Privacy Policy – Lyuh Consulting

This document sets out the privacy policy of Lyuh Consulting, Inc. and its affiliates (together referred to as “Lyuh Consulting”, “we” or “us“) and explains how we collect and use your personal information in connection with your relationship with us as a customer or potential customer including;

through your use of https://www.lyuhconsulting.com (the “Site“),
through your use of and applications for our products and services and participation in our program(s);
by interacting with our content and/or services such as online training; or
by contacting our team members.

This policy also applies to information held about suppliers and possible future suppliers, contacts and all other people we hold information about.

This Privacy Policy also sets out your rights and who you can contact for more information. If you are a customer based in the EU, please see the EU Users for additional information that is relevant to you.

Information

“Personal Information” means data that allows someone to identify or contact you (e.g. your name, address, telephone number, e-mail address, credit/debit numbers, expiration date and other billing information; people to whom purchases have been shipped, including addresses and phone number). “Non-Personal Information” means data that is not associated with or linked to your Personal Information.

Depending on the particular circumstances, we may collect and hold different Personal Information about you. For example, this may include:

your name;
your occupation and professional qualifications;
your contact information such as your home or work address, telephone and email contact details;
your payment details/financial information, such as your bank account or credit card details;
your postings on any social media applications and services that we provide;
your account security credentials, such as username and passwords;
information about how you use our products and services;
information in connection with communications you send us, for example to report a problem; and
where necessary, additional information as part of our user authentication process.

Automated collection of information

Each time you use the Site, we may automatically collect the following types of information:

Technical information: For example, the type of internet browser and the operating system. We use this information to help provide a good user experience on the Site.

Log information: For example, the details of the use of the Site by you, the visits to the Site and traffic data. We use this information to help us understand how users use the Site and to improve user experience.

If you fail to provide us with this information, or you object to us processing such information the consequences are that we may be prevented from conducting business with you and we may be unable to provide our products and services to you.

How Information is Obtained

Information you give to us when you purchase our products and services. If you purchase one of our products you will need to provide certain information including your name, address and card number in relation to the purchase.
Other information you give to us. We may receive and store information that you enter on the Site (e.g. when you register for a program) or give us in any other way (e.g., by telephone, email or other software platform). As a result of your use of the Site, you may supply us with such Personal Information such as your name and contact details.
Social Media. Depending on your settings or the privacy policies for social media and messaging services such as LinkedIn, Facebook, Twitter and Instagram you might give us permission to access information from those accounts or services.
Information we collect about you.

We may also collect information from you online using cookies and other analytical tools or when you visit the Site, including when you use our products and services. Like most websites, we use “cookies” to help us make our Site – and the way you use it – better. Cookies mean that a website will remember you. They’re small text files that sites transfer to your computer (or phone / tablet). They improve website use and speed – for example by automatically filling your name and address in text fields. There are more details in our section on Cookies below.
In addition, with regard to each of your visits to our Site we will automatically collect certain information e.g. your IP address used to connect your computer to the Internet.

How we hold your information

The Site has reasonable security measures in place to protect against the loss, misuse and unauthorized alteration of Personal Information in Lyuh Consulting’s possession and control. Although we endeavor to provide security for information in our possession and control, no security system can prevent against all potential security breaches, and we bear no liability for uses or disclosures of Personal Information or Non-Personal Information arising in connection with the theft thereof.

Links to Other Sites

Our Site may contain links to other sites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website. Once you link to another website from our Site you are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices. Please check these policies before you submit any data to these websites.

How the Information is used

Our primary purpose in collecting user information is to provide you with a safe, smooth, efficient, and customised experience and to provide the products and services that you have requested. We may also use the information that you have provided to ensure that the content on our Site is presented in the most effective manner for you and your computer. We may use and disclose your information for the following specific purposes:

to carry out our obligations arising from any contracts entered into between you and us and to provide you with the products, services and information that you request from us;
to assist you with enquiries, or to improve our customer service;
to communicate with you;
to send you marketing (where we have the right to do so – see marketing section below);
for our billing and account purposes;
to maintain our business relationships where you are a business partner, a user of our website and services, or a customer;
to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
as part of our efforts to keep our Site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our Site about services that may interest you or them;
to develop and improve our products and services;
to update our records;
to allow you to participate in interactive features of the Site or our programs, when you choose to do so; and
comply with legal and regulatory obligations.

As further described below, in limited circumstances we may disclose collected information, including Personal Information, to certain third parties in connection with providing the Services or as required by law.

We may use Non-Personal Information in a variety of ways, including, by way of example, to evaluate the performance of the Site and Services and the general preferences of users, or to generate anonymous statistics for our benefit or for our business partners. Because Non-Personal Information is entirely anonymous, and therefore can never be used by us to identify you, this policy does not limit our ability to use or disclose Non-Personal Information.

Information Shared with Third Parties

As a necessary part of providing our products and services, we may disclose information collected from you to the following categories of third parties for the purposes outlined in this Privacy Policy:

We may disclose certain Personal Information about you to our affiliates, third-party service providers, agents and contractors (e.g., our third party payment processors), if this is necessary to provide you with our products and services, respond to your inquiries or for any other related purposes and so long as they are only using the Personal Information to provide services to us. We will ensure that if we share information with, or provide access to, third party service providers or affiliates, any such disclosure or access is at all times in compliance with applicable data protection legislation.
If another company acquires our company, business, or our assets, that company will possess the Personal Information collected by it and us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.
Under certain limited circumstances, we may cooperate with legal investigations and/or we may be subject to legal requirements to disclose information collected through the Site or the Services, such as, by way of example, to a court or a governmental agency, and our policy is to provide such cooperation and comply fully with all such legal requirements.
We may also disclose Personal Information to protect or defend the rights or property of Lyuh Consulting or users of the Services and/or to investigate any violation or potential violation of the law, this Privacy Policy, or the Terms of Use. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
We may also share your Personal Information with third parties who support our information technology or handle mailings on our behalf and our professional advisers.

The disclosures contemplated by this paragraph (“Necessary Disclosures”) are necessary if you wish to use our products and services. As mentioned above, we may use and disclose Non-Personal Information without restriction. If you do not want us to make such Necessary Disclosures, or to use Non-Personal Information without restriction, you must not use the Services. We do not sell, rent or lease e-mail addresses or other Personal Information to third parties.

How long we keep your information

We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

If you close an account you have with us or you decide not to go ahead with participating in one of our programs, we may still keep your information.

Marketing

If you have subscribed to one or more of our products or services, communications or mailing lists, you may unsubscribe by following the instructions which are included in any email that you receive or by contacting info (at) lyuhconsulting (dot) com at any time.

Cookies

Cookies are small digital signature files that are stored by your web browser that allow your preferences to be recorded when visiting the Site. They may also be used to track your return visits to the Site. When using the Services, we may create “cookies” on your computer for purposes of facilitating and maintaining your current user session to help Lyuh Consulting understand your use of the Site and enable you to access, navigate and use the Services. Lyuh Consulting may collect Personal Information using those cookies in order to enable the Company to identify you in connection with the Services and to track use of the Services for purposes consistent with this policy.

To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, IP, which may vary from session to session), domain name, and/or a date/time stamp for your visit. Third party advertising companies may also use cookies for tracking purposes.

You may be able to block cookies via your browser settings, but this may prevent you from access to certain features of the Site. For information about blocking the use of cookies, please refer to the instructions/help screen on your browser.

Do Not Track

Lyuh Consulting does not currently take steps to respond to browsers’ “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.

Changes to Privacy Policy

If we change our privacy policy, we will post those changes on the Site so that users are always aware of what information we collect, how we use it, and under what circumstances, if any, we will disclose it. These changes will be effective immediately. In any event, changes to this Privacy Policy may affect our use of Personal Information that you provided us prior to our notification to you of the changes. Please check this Privacy Policy periodically to inform yourself of any changes. If you do not accept the changes made to this Privacy Policy you should immediately stop using the Site and our products and services.

Effective Oct 15, 2020. Lyuh Consulting may make changes to this policy in the future. Last updated Oct 15, 2020.

Questions

For any questions or comments on our privacy policy please contact info (at) lyuhconsulting (dot) com

EU Users

Introduction

This section applies to users in the European Union in addition to the terms set out above. In this section “Data Protection Legislation” means the EU General Data Protection Regulation 2016/679, together with all other applicable legislation relating to privacy or data protection, and where we use the terms “personal data”, “data subject”, “controller”, “processor” and “process” (and its derivatives), such terms shall have the meanings given to them in the Data Protection Legislation.

Who are we?

Lyuh Consulting acts as data controller for the purpose of Data Protection Legislation and is responsible for processing your personal data under this Privacy Policy unless otherwise notified to you in connection with a particular product or service.

Legal grounds for using your personal information

Our processing of your personal information is necessary:

for the performance of contracts to which you will be a party to and in order to take steps at your request prior to you entering into those contracts;
for the purposes of legitimate interests pursued by us; or
in order to comply with a legal obligation to which we are subject.

In relation to any processing of special categories of personal information such as information about your ethnicity, we will generally rely on obtaining specific consent from you at the time unless there is otherwise a legal requirement for us to process such information.

Legitimate interests

Where our processing is based on the legitimate interest grounds described above, those legitimate interests are: (i) collecting personal information to provide you with a smooth and efficient customer experience; (ii) running our business; (iii) to provide the products and services you have requested; (iv) to prevent fraud; (v) to update you and keep you informed about relevant products and services, unless you indicate at any time that you do not wish us to do so; and (vi) for our own marketing, research and product development.

Your rights

At any time, you have the right:

to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from which it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
to request access to or a copy of any personal data which we hold about you;
to rectification of your personal data, if you consider that it is inaccurate;
to ask us to delete your personal data, if you consider that we do not have the right to hold it;
to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
to ask us to stop or start sending you marketing messages at any time by using the below contact details;
to restrict processing of your personal data;
to data portability (moving some of your personal data elsewhere) in certain circumstances;
to object to your personal data being processed in certain circumstances; and
to not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.

Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.

We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.

Overseas Transfers

You acknowledge and agree any personal data that you provide to Lyuh Consulting will be transferred to and stored in the US in accordance with this Privacy Policy.

Contact us

If you wish to exercise any of the rights relating to your information set out above, or if you have any questions or comments about data protection, or you wish to raise a complaint about how we are using your information you can contact us using the following details, or any other details notified to you from time to time: write to Lyuh Consulting at info (at) lyuhconsulting (dot) com.

If you have any concerns about our use of your information, you also have the right to make a complaint to the relevant Data Protection Authority which regulates and supervises the use of personal data in the EEA.

Questions

For any questions or comments on our privacy policy please contact info (at) lyuhconsulting (dot) com.

California Users

Introduction

This section applies to users who are California residents in addition to the terms set out above. In this section “Data Protection Legislation” means the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199), together with all other applicable legislation relating to privacy or data protection, and where we use the terms “personal information”, “consumer”, “collect”, and “service provider” (and its derivatives), such terms shall have the meanings given to them in the Data Protection Legislation.

Your rights

At any time, you have the right to:

Request to know:
- to be informed about the collection and disclosure of your personal information (i.e. categories of information that are collected, categories of sources from which such information was obtained, for what purposes, to what recipients are such information disclosed, and whether such information has been sold);
- to request access to or a copy of any personal information which we retain about you;
Request to delete:
- to ask us and/or our service providers to delete your personal information in some circumstances;
Request to opt-out:
- to withdraw consent to our disclosure of your personal information (to the extent such disclosure is based on previously obtained consent), in some circumstances; and
- to ask us to stop sending you marketing messages, however you may still receive administrative communications regarding services we provide to you.

Financial incentives: We do not offer financial incentives to consumers for the collection or the deletion of personal information.

Non-Discrimination: You will not be discriminated against for exercising your rights under the Data Protection Legislation.

Collection of personal information from California Residents

We have listed below the personal information we may collect from California residents.

1) Category of personal information we may collect: Identifiers

Categories of sources from which we collect such personal information: Directly from the individual; public records from government entities; background checks; and/or social media profiles.
Purpose for collecting such personal information: client / service provider/portfolio/program participant records and communications; anti-money laundering & know your customer (AML/KYC) purposes; to improve our services; and/or marketing purposes.

2) Category of personal information we may collect: Personal Characteristics

Categories of sources from which we collect such personal information: Directly from the individual; public records from government entities; background checks; and/or social media profiles.
Purpose for collecting such personal information: To generate statistics on the makeup of our clients / service providers /program participants; anti-money laundering & know your customer (AML/KYC) purposes; and/or marketing purposes.

3) Category of personal information we may collect: Payment Information

Categories of sources from which we collect such personal information: Directly from the individual.
Purpose for collecting such personal information: program fee collection; service fee payment; and/or expense reimbursement.

4) Category of personal information we may collect: Commercial Information

Categories of sources from which we collect such personal information: Directly from the individual; and/or background checks.
Purpose for collecting such personal information: Anti-money laundering & know your customer (AML/KYC) purposes; to improve our services and programs; and/or for business development & marketing purposes.

5) Category of personal information we may collect: Social Network Information

Categories of sources from which we collect such personal information: Directly from the individual; and/or social media profiles.
Purpose for collecting such personal information: Anti-money laundering & know your customer (AML/KYC) purposes; and/or for business development & marketing purposes.

6) Category of personal information we may collect: Internet & Electronic Activity

Categories of sources from which we collect such personal information: User access to our website.
Purpose for collecting such personal information: To improve user experience on our website; to improve our services; and/or to generate statistics on the makeup of our website users.

7) Category of personal information we may collect: Geolocational Data

Categories of sources from which we collect such personal information: Directly from the individual via office access application.
Purpose for collecting such personal information: To facilitate entry into Lyuh Consulting office; and for security purposes.

8) Category of personal information we may collect: Sensory Information

Categories of sources from which we collect such personal information: Photos and audio/video recordings of company related events and programs.
Purpose for collecting such personal information: For business development & marketing purposes; and/or for delivery of services.

9) Category of personal information we may collect: Professional Information

Categories of sources from which we collect such personal information: Directly from the individual; public records from government entities; background checks; and/or social media profiles.
Purpose for collecting such personal information: Anti-money laundering & know your customer (AML/KYC) purposes; to deliver and improve our services; to generate statistics on the makeup of our clients / service providers / program participants; and/or for business development & marketing purposes.

10) Category of personal information we may collect: Educational Information

Categories of sources from which we collect such personal information: Directly from the individual; background checks; and/or social media profiles.
Purpose for collecting such personal information: To deliver and improve our services; to generate statistics on the makeup of our clients / service providers / program participants; and/or for business development & marketing purposes.

11) Category of personal information we may collect: Inferences

Categories of sources from which we collect such personal information: Directly from the individual.
Purpose for collecting such personal information: For business development & marketing purposes.

Sharing of personal information from California Residents

We may share your personal information as necessary for the purposes described above. For example, we may share your personal information with the following parties:

Sharing of personal information

Categories of your personal information we may otherwise share:

Some or all categories of personal information listed above.

Categories of third parties we may otherwise share your personal information with:

Lyuh Consulting’s affiliates; existing and potential business/network partners and clients; government authorities and law enforcement (where applicable); professional advisors; and service providers.

Contact us

You can make requests related to your California privacy rights as follows:

Request to Know – Write to info (at) lyuhconsulting (dot) com.
Request to Delete – Write to info (at) lyuhconsulting (dot) com.
Other Requests to Opt Out – Write to info (at) lyuhconsulting (dot) com.

Please be aware that we do not accept or process requests through other means (e.g., via fax, social media, etc.).

If you have any questions or comments about data protection, or you wish to raise a complaint about how we are using your information you can contact us using the following details, or any other details notified to you from time to time, you may also write to Lyuh Consulting at info (at) lyuhconsulting (dot) com.

Any request to know, request to delete or request to opt-out must be in writing and we will endeavour to respond within a reasonable period and in any event within such period in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a consumer.

When you make a request, we may ask you to provide verifying information, such as your name, email, or phone number. We will review the information provided and may request additional information via email or other means to ensure we are interacting with the correct individual. Please also be aware that making any such request does not ensure complete or comprehensive removal or deletion of your personal information or content you may have posted, and there may be circumstances in which the law does not require or allow us to fulfill your request.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.

Children

Our services are not directed to children, and we do not knowingly collect personal information from children under the age of 16. If you learn that a child has provided us with personal information, then you may contact us as indicated above.

Questions

For any questions or comments on our privacy policy please contact info (at) lyuhconsulting (dot) com.