Privacy Policy

What is the scope of this Privacy Policy and our role?

With this document (“Privacy Policy”) we would like to transparently inform you about how we may collect, use, and share Personal Data in connection with the interaction and use of the services, tools and features of The Origin website and website pages (“The Origin”). When we refer to “we”, “Company,” “us,” “our“, we refer to Login Establishment, Kirchstrasse 1, 9490 Vaduz, Liechtenstein and its subsidiaries and affiliates, which collects and processes Personal Data as a Data Controller.

The Origin as defined herein shall mean the website, https://theorigin.logineko.com/, all its content and links that lead to this website, encompassing QR code and Services, as defined in the applicable Terms of Service.

We reserve the right to change this Privacy Policy. In case of material changes affecting your rights, we will notify you in advance. You agree to the new version of this Privacy Policy if you continue using The Origin, QR Code and other services defined in this Privacy Policy after a new version of the Privacy Policy is published.

What types of Personal Data we Process?

For the purpose of this Privacy Policy, expressions “Processing”, “Personal Data”, “(Data) Controller”, “(Data) Processor” shall have the meaning given to them in the EU General Data Protection Regulation (2016/679) (GDPR).

We may Process Personal Data about The Origin Visitors and Users (as defined in our Terms of Service) which is submitted to us, provided to us, or otherwise collected by us through The Origin. In this regard, we may collect the following types of Personal Data during use of Services, registration of the account, log-in process and by contacting us:

• Your basic contact data such as name, surname and e-mail address;
• Basic data about the company, organisation or other legal entity you work for (company name, business address, state, VAT, name and surname of the authorized representative, contact details such as email address and phone number);
• Information about actions and activities you initiate through The Origin, that may contain Personal Data other than specified herein; or
• Information you provide to us voluntarily when you contact us, that may contain Personal Data other than specified herein.

The above Personal Data is collected directly from you through your activities, interactions, registration/log-in or correspondence with us.

What purposes do we use Personal Data for, and what are the related legal bases?

We use the collected Personal Data for the following purposes:

• To provide you with our Services through The Origin, as well as with support, maintenance and other related services concerning your use of The Origin, to message you for informational purposes (new features, updates, releases, fixes and similar information) necessary for the proper use of The Origin as well as to communicate with you, including responding to any of your requests, feedback, or questions. In all such cases, Processing of your Personal Data is necessary to perform a contract with you (Article 6(1)(b) GDPR), your employer, service provider or business partner regarding the use of The Origin;
• To implement measures and initiatives necessary to protect our or others’ rights, privacy, safety, or property including reducing fraud, software and IP piracy, and protecting confidential information. We do all this as a result of *compliance with (our) legal obligations (*Article 6(1)(c) GDPR).

How long do we store your Personal Data?

We store your Personal Data in accordance with applicable legislation and (i) only for as long as it is necessary to achieve the purpose for which the Personal Data is Processed, or (ii) for a period prescribed by law, or (iii) for a period that is necessary to complete a contract, including period for establishing and defending legal claims.
Personal Data acquired based on your consent is stored permanently or until you withdraw your consent However, Personal Data collected based on your consent will be deleted even before you withdraw your consent if the purpose for which the data were collected has been achieved.

How do we transfer your Personal Data?

Your Personal Data may be transferred to or accessed by certain third parties. Each authorized user with whom we share the Personal Data may Process the Personal Data only for the purposes for which they were collected. Additionally, all authorized users are required to follow applicable data protection legislation.

Your Personal Data may be transferred to:

• our affiliates, subsidiaries, and other related companies;
• professional advisors providing us with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters;
• to law enforcement, government authorities in order to conform to legal requirements, or to respond to lawful court orders, subpoenas, warrants, or other requests;
• third parties who perform services on our behalf that are necessary for the orderly operation of our business. For example, we work with service providers that help us perform website hosting, cloud services, maintenance services, database management, analytics, fraud protection, marketing, customer relationship management, finances, and other purposes.

In most cases, Personal Data we collect is stored in the European Economic Area (EEA) or in countries where an adequate level of data protection has been established. In some limited cases, your Personal Data, to the minimum extent necessary to ensure the delivery of the Origin Services, support, maintenance, and related services to you, may be transferred outside of the EEA. In such cases, we endeavor to take additional steps to ensure the security of your Personal Data in compliance with the GDPR.

What security measures do we apply?

Company has taken the appropriate technical and organizational measures to protect your Personal Data. All measures we take are within our technical capacities (including the costs of taking certain measures) and at the discretion of the effects they have on your privacy. However, please remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. In the event of a Personal Data breach, the Company will inform the competent supervisory authority about the breach without hesitation.

What are your rights?

• Access to Personal Data: You can request information from the Company about whether We Process your Personal Data. If We do, you can request access to your Personal Data and information about the Processing
• Rectification of Personal Data: You can request that the Company rectifies or amends imperfect or inaccurate data about you which is being Processed;
• Restriction of Processing of Personal Data: You can request that the Company limits the Processing of your Personal Data (e.g. when the accuracy or completeness of your Personal Data is being verified);
• Erasure of Personal Data: You can request from the Company to erase your Personal Data but note that we cannot erase the Personal Data that We need to keep due to legal obligations or based on a contractual relationship;
• Copy of Personal Data: You can request the Company to provide a copy of provided Personal Data;
• Withdrawing consent: You have the right to withdraw your consent for the use of Personal Data that the Company Processes with your consent at any time. You can withdraw consent by sending email to: theorigin@logineko.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented, unless there is another legal ground for the processing and unless we are obliged by the applicable law. Withdrawing consent has no drawbacks, but it is possible that the Company will not be able to provide certain services to you after you withdraw your consent.
• Objecting to Processing of Personal Data: Not applicable in our case as we currently do not Process Personal Data for the purpose of direct or indirect marketing.

If you have any concerns or requests in relation to your personal data and its protection, please contact us via: theorigin@logineko.com.

If you are unsatisfied with how we process your Personal Data, or if you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.