Lama A.I Ltd., on behalf of itself and its affiliates (“Lama”, “us” or “we”) respects the privacy of its website users (“User(s)” or “you”) and is committed to protect its Users’ personal information. We believe that you have a right to know our practices regarding the information we may collect and use about you when you use our website at https://www.lamabanking.com/ (the “Site”). Please read the following carefully to
understand Lama’s views and practices regarding your personal information and how Lama will treat it.
1. Your acknowledgment of this policy
2. Which information may we collect about Users?
We collect from Users of our Site, two types of data and information:
2.1. Non-personal Information.
The first type is non-identifiable and anonymous information. Non- personal Information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”). You may access and browse the Site without disclosing personal information, although, like most websites, we passively collect certain Non-Personal Information from your devices, including:
(i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc.; and
(ii) behavioral information which may include the User’s click-stream on the Site, the activities of the User on the Site and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may also use third-party service providers, such as Google Analytics, to obtain detailed analytics on the device and the User's behavior on the Site. Please note that we or our third-party service providers will collect such Technical and Behavioral Information by using certain tracking technologies, such as cookies, as further detailed below.
2.2. Personal Information.
The other type of information we collect is individually identifiable information. To put it simply, this information identifies an individual or is of a private and/or sensitive nature, such as
your contact information (“Personal Information”), including:
2.2.1. Personal Information which is provided voluntarily:
Communications with Lama: Personal Information you provide us as part of any communications with Lama, by any means, including by contacting us via the Site or email, or through our social network pages (such information may include marketing and communication data that includes your preferences in receiving marketing from us and your communication preferences). Please note that we may record calls for quality assurance purposes and in order to improve our services.
● Mailing list: you may voluntarily join our mailing list by providing us with your email address via our Site.
2.2.2. Personal Information collected via technology:
● Geolocation data: during your visit to the Site we will access, collect, process, monitor and/or remotely store "geolocation data", including through the collection of IP addresses and other similar information to determine your location for analytics, advertising and security purposes. Please note that we may also analyze your IP address and other similar data, using our third party service providers, in order to determine the name of the company whose IP address you have used to browse to our Site, for the purpose of locating prospects and in order to analyze our Site's traffic.
● Identifiers: such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), or other unique identifiers for security purposes, analytics and in order to provide you with targeted advertising of our products and services.
● Technical and Behavioural Information: to the extent that the Technical and Behavioural Information detailed above under Section 2.1 will be linked to or associated with a specific individual then such information will be considered as Personal Information.2.3. Please note:
● We may cross-reference your Personal Information with other Personal Information we may have about you. Any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
3. How do we collect information about our Users?
There are two main methods we use to collect information:
3.1. We collect information through your entry, connection, access and/or use of the Site
In other words, when you access or use the Site, we are aware of your usage of the Site, and may gather, collect and record the information relating to such usage. For example, when you use the Site, we gather your Technical and Behavioural Information.
3.2. We collect information which you provide us voluntarily
. For example, we collect Personal Information that you provide through email correspondence. We will inform you prior to collecting your Personal Information if it is requested on a voluntary basis and the consequences of not providing voluntary Personal Information.
4. What are the purposes of the collection and processing of information?
4.1. Non-personal Information is processed in order to:
● Enhance the User’s experience on the Site;
● Create statistical information and learn about the preferences of Users and general trendson the Site (e.g. understand which features are more popular than others); and
● Keep the Site safe and secured against fraudulent and criminal activity.
4.2. Personal Information is processed in order to:
● Enable the operation and constant improvement of the Site;● Register your interest in becoming a new customer;
● Contact you by telephone and/or by email with further information relating to our product sor services;● Add your contact details to our mailing list for the purposes of sending you information about our products and services by email, SMS, phone, through web-browser notification or through the post. You have the right to opt-out of marketing messages at any time by following the instructions in such messages or by contacting us at: firstname.lastname@example.org;
● Personalize your experience on the Site;
● Ensure that content on the Site is presented in an optimal way for you and for your device(e.g. tablet, mobile phone);
● Conduct internal operations, such as: troubleshooting, data analysis, testing, research, and statistical analysis;
● Keep the Site safe and secured against fraudulent and criminal activity;
● Comply with our legal obligations and provide us with the ability to protect our rights and legitimate interests;
● Maintain our data processing records and general administrative purposes; and
● Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails we reopened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.
5. Sharing Personal Information with Third Parties
● Lama Personnel: Personal Information that we collect and process may be transferred to or accessed by personnel of Lama for the sole purpose of enabling the operation of the Site and to contact you (as detailed in Section 4 above). Please note that all Lama personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.
● Service Providers: we share Personal Information with vendors, commercial software providers, consultants and data processors who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host the Site. Please note that we collect, hold and manage your Personal Information through a third party's cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction.
● In addition, we may share Personal Information in the following cases:
(a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
(c) to detect, prevent, or otherwise address fraud, security or technical issues;
(d) to protect the rights, property, or personal safety of Lama, its Users or the general public; and
(e) when Lama is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Lama (while such acquired company or investor may be located in countries outside of your jurisdiction).
5.3. For avoidance of doubt, Lama may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site.
6. Your Rights
Lama acknowledges you have the right to access and change the Personal Information we collect and process. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: email@example.com and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.
7. Location of Your Data
The Site is intended for Users over the age of sixteen (16). Therefore, Lama does not intend and does not knowingly directly collect any Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Site.
9. Third Party Service Providers
9.3. Note, that we collect, hold and/or manage your Personal Information through Lama's authorized third party vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes, as follows: AWS, Salesforce, Hubspot, Mailchimp, Marketo, Webflow.
9.4. Such vendors may be located in countries that do not have the same data protection laws as the laws applied in your jurisdiction.
10.1. When you access or use the Site, we and/or our third party service providers may use industry- wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies) (collectively, "Cookies") which may enable us, amongst others, to recognize your device from those of other Users of the Site, to improve the Site's performance, to deliver a better and more personalized service according to our Users' individual interests and the device or browser used, to track Users' use of the Site, to gather information about the Users; approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern and perform other analytics, to develop our Site and to serve targeted advertisements.
10.3. Most devices and browsers will allow you to erase Cookies from your device’s hard drive, block acceptance of Cookies, or receive a warning before a Cookie is stored on your device. However, if you block or erase Cookies, your experience of the Site may be limited.
10.4. For detailed instructions regarding the blocking of Cookies, please refer to your browser's 'help';, 'tool'; or 'edit'; sections or see http://www.allaboutcookies.org/manage-cookies/. Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers: Chrome, Internet Explorer and Microsoft Edge, Mozilla Firefox and Safari.
10.5. It is possible to opt-out of having your browsing activity within the Site recorded by performance cookies. Please note that we use Google Analytics as our service provider in order to track Users' activities on the Site, including by use such services' persistent cookies. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout.
10.6. You can opt out of receiving interest-based advertising on your device by visiting the following sites: www.aboutads.info/choices/, www.networkadvertising.org/choices/, choices.ghosteryenterprise.com/global-opt-out.html, and preferences-mgr.truste.com/. If you wish to opt out of receiving interest-based advertising on your mobile device, please see the advertising preferences information on support.apple.com for iOS devices or support.google.com for Android devices.
11. Links to Third Party Websites
12.1. We take appropriate measures to maintain the security and integrity of our Site and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures.
12.2. Your Personal Information is hosted on third party servers, which provide advanced strict security standards (both physical and logical)
.12.3. Some of the security measures that we employ include, without limitation: the application of highly secure design and implementation methods to all our Services, including state of the art encryption mechanisms and secure architecture design to all storage and transmission mechanisms used for the processing and transmission of your Personal Information, as well as access control and auditing systems (including firewall and identity management solutions), that restrict access to your Personal Information to authorized personnel only, based on their roles and their need-to-know requirements, needed to process your Personal Information on Lama’s behalf.
12.4. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.
12.5. Lama will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach as required by applicable law.
12.6. TO THE EXTENT THAT LAMA IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, LAMA SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.
13. Data Retention
Lama will retain the Personal Information for as long as we are confident that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which it was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.
15. Have any Questions?