Privacy Policy
Effective date: January 1st 2020
At Lil w 12th, we take your privacy seriously. Please read the following to learn how we treat your personal information. By using or accessing Lil w 12th's Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.
Remember that your use of Lil w 12th's Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
What this Privacy Policy Covers
This Privacy Policy covers how we treat Personal Data that we gather when you access or use Lil w 12th's Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.
Sources of Personal Data
We collect Personal Data about you from:
- You:
- when you provide such information directly to us, and
- when Personal Data about you is automatically collected in connection with your use of Lil w 12th's Services.
- Our subsidiaries and affiliates (together, “Affiliates”), when they provide us with Personal Data about you.
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Third parties, when they provide us with Personal Data about you (“Third Parties”). Third Parties that share your Personal Data with us include:
- Service providers. For example, we may use analytics service providers to analyze how you interact and engage with Lil w 12th's Services, or third parties may help us provide you with customer support.
- Social networks connected to Lil w 12th's Services. If you provide your social network account credentials to us or otherwise sign in to Lil w 12th's Services through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your Account with us.
- Advertising partners. We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.
Categories of Personal Data We Collect
The following chart details the categories of Personal Data that we collect and have collected over the past twelve (12) months. For each category of Personal Data, these subsections also set out the categories of third parties with whom we share that Personal Data. More information regarding those sources and categories are set forth in the charts below.
Category of Personal Data |
Examples of Personal Data Collected |
Source |
Third Parties With Whom We Share Data for Business Purposes |
Personal identifiers |
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Web Analytics |
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Social Network Data |
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Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
- You
- When you provide such information directly to us.
- When you create an account or use our interactive tools and Services.
- When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
- When you send us an email or otherwise contact us.
- When you use the Services and such information is collected automatically.
- Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
- Third Parties
- Vendors
- We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
How We Use Your Personal Data
We use your Personal Data for a variety of purposes, where permitted by applicable law:
Commercial or Business Purposes for Collecting Data |
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Providing, Customizing, and Improving Lil w 12th's Services |
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Corresponding With You |
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Legal Requirements |
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We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
As noted in the chart above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve contacted us for customer support, we will send a response to that email address. If you do not want to receive communications from us, please indicate your preference by emailing us at lilwtwelfth+support@gmail.com.
How We Share Your Personal Data
In certain circumstances, we may disclose your Personal Data to the following categories of service providers and other parties:
Categories of Third Parties With Whom We Share Personal Data |
Business Purpose for Sharing Data |
Service Providers |
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Security and Fraud Prevention Consultants |
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Hosting, Technology and Communications Providers; Fulfillment Providers; Data Storage Providers; Analytics Providers; Staff Augmentation Personnel; Ad Networks |
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Parties You or a Third-Party User Sharing Your Personal Data With Us Authorizes, Accesses or Authenticates |
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Other Users |
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Social Media Services |
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Business Transfers
All Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Government Requests; Legal Process
Sometimes, we may be required to hand over information to the government or as part of a legal process (like a lawsuit or arbitration). If we are permitted to do so, we will notify you or the applicable Third-Party User that provided us with such information of any such requirement before we comply. We intend to defend our customers’ rights against unlawful search and seizure. However, we also refuse to support criminal activity.
More Information Regarding Automatic Collection of Personal Data and Cookies
The following sections provide additional information about how we collect your Personal Data.
Information Collected Automatically
Lil w 12th's Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use Lil w 12th's Services, to analyze trends, learn about our user base and operate and improve Lil w 12th's Services. For example, we use Cookies to tailor Lil w 12th's Services by tracking navigation habits, measuring performance, customizing user experiences with Lil w 12th's Services and for analytics and fraud prevention. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit Lil w 12th's Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Not all browsers offer a Do Not Track option and there is currently no industry consensus as to what constitutes a Do Not Track signal. For these reasons, Lil w 12th's Services, like many web service site operators, do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.
We use the following types of Cookies:
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Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of Lil w 12th's Services. Disabling these Cookies may make certain features and services unavailable.
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Functional Cookies. Functional Cookies are used to record your choices and settings regarding Lil w 12th's Services, maintain your preferences over time and recognize you when you return to Lil w 12th's Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
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Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use Lil w 12th's Services such as by collecting information about the number of visitors to Lil w 12th's Services, what pages visitors view on Lil w 12th's Services and how long visitors are viewing pages on Lil w 12th's Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and Lil w 12th's Services’ content for those who engage with our advertising. For example, Google, Inc. (“Google”) uses cookies in connection with its Google Analytics services, and we use Char Software Inc. (dba Localytics). Google’s ability to use and share information collected by Google Analytics about your visits to Lil w 12th's Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
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Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You may also be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. You can also delete all Cookies that are already on your computer. Although you are not required to accept Lil w 12th’ Cookies, if you block, reject, or delete them, you may have to manually adjust some preferences every time you visit a site and some of Lil w 12th's Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ or http://www.allaboutcookies.org/.
Information about Interest-Based Advertisements:
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through Lil w 12th's Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Internet-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on Lil w 12th's Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave Lil w 12th's Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through Lil w 12th's Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website http://www.youronlinechoices.eu/.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. For example, Lil w 12th's Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with Lil w 12th's Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Personal Data of Children
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 16; if you are a child under 16, please do not attempt to register for or otherwise use Lil w 12th's Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at lilwtwelfth+support@gmail.com.
California Resident Rights
If you are a California resident, you have the rights outlined in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at lilwtwelfth+support@gmail.com.
Access
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:
- The categories of Personal Data that we have collected about you.
- The categories of sources from which that Personal Data was collected.
- The business or commercial purpose for collecting or selling your Personal Data.
- The categories of third parties with whom we have shared your Personal Data.
- The specific pieces of Personal Data that we have collected about you.
If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient.
If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data purchased by each category of third party recipient.
Deletion
You have the right to request that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with Lil w 12th's Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Exercising Your Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
- Emailing us at: lilwtwelfth+support@gmail.com
Personal Data Sales Opt-Out and Opt-In
In this section, we use the term “sell” as it is defined in the CCPA. We sell your IDFA/AAID/IDFV advertising identifiers to third-party ad networks and Facebook, Inc. (“Facebook”) to (1) create a “seeding audience” for Facebook lookalike targeting so that we can acquire high-quality users and (2) generate a Facebook audience report to better understand the demographics of our users so that we can cater to their needs and interests.
You have the right to opt-out of the sale of your Personal Data. To do so, click the following link:
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months. However, you may change your mind and opt back in to Personal Data sales at any time by re-downloading the application.
If you are between 13 and 16 years of age, you must authorize us to sell your Personal Data, which you may do by clicking the Opt-In link above. If you are under 13 years of age, your parent or guardian must authorize us to sell your Personal Data, which your parent or guardian may do by clicking the Opt-In link above.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of Lil w 12th's Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Other State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at lilwtwelfth+support@gmail.com.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at lilwtwelfth+support@gmail.com with the subject line “Nevada Do Not Sell Request” and providing us with your name.
European Union Data Subject Rights
EU Residents
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Lil w 12th will be the controller of your Personal Data processed in connection with Lil w 12th's Services.
If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at lilwtwelfth+support@gmail.com.
Personal Data We Collect
The “Categories of Personal Data We Collect” section above details the Personal Data about you that we collect from you and from third parties.
Personal Data Use and Processing Grounds
The “How We Use Your Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
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Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with Lil w 12th's Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of Lil w 12th's Services that require such data.
- IP address
- Email and name (solely if a user contacts customer service)
- [Apple ID token]
- [User inputted nickname (future social feature allowing user inputted names)]
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Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
- IDFA/AAID/IDFV advertising identifiers
- Facebook data (if connected)
- IP address
- Apple ID token
Examples of these legitimate interests include:
- Operation and improvement of our business, products and Services
- Marketing of our products and Services
- Provision of customer support
- Protection from fraud or security threats
- Compliance with legal obligations
- Completion of corporate transactions
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Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
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Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Sharing Personal Data
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
EU Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at lilwtwelfth+support@gmail.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of Lil w 12th's Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about Lil w 12th's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
Transfers of Personal Data
Lil w 12th's Services are hosted and operated in the United States (“U.S.”) through Lil w 12th and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using Lil w 12th's Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Lil w 12th in the U.S. and will be hosted on U.S. servers, and you authorize Lil w 12th to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant toEU-U.S. or Swiss-U.S. Privacy Shield Frameworks, respectively, the details of which are further set forth below.
Lil w 12th has certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU and Switzerland to the U.S., respectively. For more information about the Privacy Shield Program, and to view Lil w 12th's certification, please visit www.privacyshield.gov. Lil w 12th is committed to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU and Switzerland in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Lil w 12th's compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Please contact us at lilwtwelfth+support@gmail.com with any questions or concerns relating to our Privacy Shield Certification. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through JAMS, an alternative dispute resolution provider located in the United States. You can visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.
How We Use Information that is not Personal Data
We may use information that is not Personal Data (including Personal Data that has been de-identified and/or aggregated) to better understand who uses Lil w 12th and how we can deliver a better experience, or otherwise at our discretion.
Changes to this Privacy Policy
We’re constantly trying to improve Lil w 12th's Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the https://www.Lilw12th.com website, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of Lil w 12th's Services, and you are still responsible for reading and understanding them. If you use Lil w 12th's Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
Contact Information:
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, please do not hesitate to contact us at:
- lilw12th.com
- lilwtwelfth+support@gmail.com
If you are located in the European Union, you may use the following information to contact our Data Protection Officer and our European Union-Based Member Representative:
represented by Prof. Dr. Christoph Bauer
Große Bleichen 21
20354 Hamburg
Germany
represented by Prof. Dr. Christoph Bauer
Große Bleichen 21
20354 Hamburg
Germany