Last updated - October 27, 2020
Types of Data collected
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Lyon’s website or mobile application (Lyon’s Apps).
Unless specified otherwise, all Data requested by Lyon’s Apps is mandatory and failure to provide this Data may make it impossible for Lyon’s Apps to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact Lyon or its Data Protection Officer.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to Lyon.
Mode and place of processing the Data
Methods of processing
Lyon takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Lyon, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Lyon’s Apps (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, by Lyon.
Legal basis of processing
Lyon may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual and contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which Lyon is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested to Lyon;
processing is necessary for the purposes of the legitimate interests pursued by Lyon (such as marketing, product enhancement, research and development, analytics, and others) or by a third party.
In any case, Lyon will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
Personal Data collected for purposes related to the performance of a contract between Lyon and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of Lyon’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by Lyon within the relevant sections of this document or by contacting Lyon.
Lyon may also be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Lyon may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users
Users may exercise certain rights regarding their Data processed by Lyon:
Right to Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Right to Access their Data. Users have the right to learn if Data is being processed by Lyon, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Right to Rectify. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Right to Erasure. Users have the right, under certain circumstances, to obtain the erasure of their Data from Lyon.
Other Rights: Users may also exercise any other rights as granted by any data privacy regulation of any country where Lyon has business operations.
How to exercise these rights
Any requests to exercise User rights can be directed to Lyon by contacting the following: at [email protected], through mobile +63 917 305 4308 or by telephone at +632 8524 4611.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
To receive information about your Personal Data, the purposes and the parties the Data is shared with, contact the Lyon’s Data Protection Officer at [email protected], through mobile +63 917 305 4308 or by telephone at +632 8524 4611.