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Privacy Policy
Privacy Policy
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Written by Javier Araya
Updated over 3 months ago

Welcome to Lilo! We are excited to have you here, and we hope that you are equally as excited to learn about how we protect personal information shared with us from our business partners. Just like hotel guests trust their preferred hotels to keep them comfortable and well rested, we want you to trust us with any personal information or business information you may supply to us. We are committed to being transparent about our privacy practices and to giving you control over how your information is collected, used, and shared.

This Privacy Policy and Notice ("Privacy Policy") covers all uses of our business-to-business procurement platform and corresponding mobile application (collectively, "Procurement Platform") and more specifically:

  • Businesses such as hotels, resorts, gyms and warehouses ("Customers") who use our Procurement Platform and related services; and

  • Product manufacturers, distributors, or other vendors and suppliers ("Vendors") who use our Procurement Platform and related services.

As used in this Privacy Policy, "Platform" refers to the Procurement Platform and "Services" refers to the aforementioned services related to the Platforms.

Please read this Privacy Policy carefully to understand the personal information we collect, how we use it, and the choices available to you. If you do not agree to this Privacy Policy, please do not use the Platforms or Services.

1. Scope

1.1. Jurisdiction and Applicable Laws

Our procurement platform does not have any locations outside of the United States ("U.S."), nor do we offer products or services, including purchase of any products through the Platform, outside of the U.S. As our products and services are intended for U.S. businesses and U.S. residents only, please do not attempt to use the Platform or Services if you are located outside of the U.S.

"Privacy Laws" as used in this Privacy Policy refers to the U.S. privacy laws currently in force, and that are binding upon us and applicable to you, which may include the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”) where you are a California resident.

“Personal Information” as used in this Privacy Policy means information which identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, as defined under the Privacy Laws as ‘personal information,’ ‘personal data,’ ‘personally identifiable information,’ or the like; however, it does not apply to: (a) publicly available information from government records; and (b) de-identified and aggregated information.

As used herein, the term “End Users” refers to those employees, agents, contractors, or other authorized users of a Customer or Vendor who use the Platform or Services and who have an established business relationship with us. The term “Consumer” as used in this Privacy Policy means a natural person, and includes End Users.

1.2. Out-of-Scope

Please note that information collected and used outside of what is stated in the above paragraphs is considered outside the scope of this Privacy Policy. For example, this Privacy Policy does not cover the following:

  • Your information collected directly from Vendors or other third parties, even where the information collected is in connection with your use of the Platform or Services. The applicable Vendor’s or other third party’s privacy policy covers the collection and use of information submitted by you to the Vendor, on or through the Vendor’s platform, or to the respective third party.

  • Business information that may be considered confidential or sensitive, but that is not Personal Information; for example, the credit card number for a business e.g., a hotel. Handling of such confidential and sensitive business information may be covered under a separate services agreement that we have with our Customers or the entity that represents them (such as hotel management groups).

1.3. Minors

The Platform and Services are not intended for children under eighteen (18) years of age. No one under the age of 18 may provide any information to, on, or through the Platforms or Services. We do not knowingly collect Personal Information from children under 18. If we learn we have collected or received Personal Information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us using any of the contact methods in the Contact Us section

2. Information We Collect

The information we collect about you depends on the Platform and Services you use, how you use them, and the information you provide to us. Depending on which Platform and Services you use, we collect different types of information about your business, company, hotel, group, or other entity you represent, as well as information about you, our End User.

We collect information in three main ways: (1) information you provide directly to us; (2) information we collect automatically through technology when you use the Platform and Services; and (3) information we collect from other sources.

2.1. Information You Provide Directly to Us

When you use our Services, you may provide certain information to us. For example, we collect information directly from you when you create or use a Lilo account, participate in Lilo surveys or research, purchase products and interact with the Services, engage with us through our sales and marketing efforts, or communicate and interact with us.

Some of the most common categories of Personal Information we collect directly from End Users include:

  • Contact and account information, such as your name, email address, login credentials, and your business contact information and title/role. For business staff submitting orders via the the platform, we may also collect certain identifying information, including for example your employee ID, your signature, and/or a unique PIN number.

  • Customer service interaction information, such as messages submitted to us through online forms or email, and summaries, transcriptions, or voice recordings of interactions with our customer service personnel. For End Users associated with Customers that use the platform, we may also collect communications and conversations with clients to or through the platform and related Services. For End Users associated with Customers on our Procurement Platform, we may also collect information from you when you submit forms, provide information or responses in discussion forums, or otherwise communicate or interact with us.

  • Information related to loyalty programs, redemption campaigns, sweepstakes, including information needed for you to participate in, and for us to fulfill, your prize or participation incentives (if any).

2.2. Information Collected Automatically

The information we automatically collect when you use the Platform and Services includes information about your access to and use of the websites and emails, such as your IP address, browser language, the state from which you accessed the Platform or Services based on the location of your device, software and hardware attributes (including device IDs, operating system, and browser type), referring and exit URLs, the links you click and the files you download, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our website, the date and time you accessed our websites or opened our emails, and other similar information.

To collect this information, we and our service providers also use technologies, including cookies, to automatically collect certain types of usage and device information when you use the Platform or Services. The Platform utilizes cookies to enhance the overall shopping experience by retaining information about which items have been added to carts and collecting general data on traffic and interactions on the websites. This data is used to improve the Platform’s functionality and to ensure that we are offering the best experience and tools to our End Users (including you!). For information on how to disable cookies, please see Section 6 (Your Rights and Choices) below.

We use third-party analytics services on the Procurement Platform and related Services to better understand End User online activity. These service providers collect information about End User’s use of our Procurement Platform and related Services and other websites and online services over time through cookies, device identifiers, pixel tags, or other tracking technologies. We and our third-party providers use this information to, among other things, analyze and track data, determine the popularity of particular content, and deliver advertisements based on your interests on our Procurement Platform, as well as to provide services to us, such as reporting, analytics, and market research.

2.3. Information We Collect from Other Sources

We may collect information about our Customers at the hotel-level from other sources to supplement the information we collect directly from you. For additional information regarding our collection and use of business information related to Customers, please see Section 9 (Additional Notes on Business Information).

3. How We Use Your Information

Lilo may use Personal Information we collect in the following ways:

  • To provide the services you have requested, such as to verify a purchase, offer customer support, facilitate cash-back and redemption offers in which you chose to participate, and investigate and respond to your inquiries.

  • To communicate with you, for example, keeping you posted on purchases, shipments, and changes to our terms, conditions, and policies.

  • For marketing and advertising purposes, including providing Customers with the latest and most relevant product announcements and promotions. For example, we may utilize information provided to us to ensure that we’re showing our Customers relevant ads on the Procurement Platform, and to measure the effectiveness and reach of those ads. We may also utilize Personal Information associated with End Users of a Customer to administer loyalty programs and cashback campaigns on behalf of our Vendors.

  • To improve our Services and Platform, including bug detection and error reporting, to understand how End Users interact with the Services and Platform, to improve the usability and effectiveness of our products, perform research and analytics, and to test and create new products, features, and services.

  • For security and other general business operations, such as to maintain the safety, security, and integrity of the Platform, detecting security incidents, and investigating and protecting against malicious, deceptive, fraudulent, or illegal activity. Please note that if, due to personnel changes or otherwise, your Lilo account needs to be transferred to a new authorized representative at your business, some account information may be shared with the new representative at the discretion of Lilo to preserve the integrity of the account.

  • To facilitate mergers and acquisitions, such as to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about users of the Platform and Services is among the assets transferred.

  • For legal and compliance, such as to comply with applicable laws including Privacy Laws, including verifying age and other legal requirements when necessary; facilitating any required reporting for substances designated as controlled at either the state or federal level; complying with legal processes; responding to requests from public and government authorities; meeting national security or law enforcement requirements; enforcing our terms and conditions applicable to you (“Terms of Use"); protecting our operations; protecting the rights, privacy, safety, or property of Lilo and users of the Platform and Services and other relevant individuals; and allowing us to pursue available legal remedies and limit the damages that Lilo may sustain.

  • In accordance with your consent. We may also use your Personal Information for a specific purpose that we communicate to you. We will ask for your consent to process your Personal Information for such purpose in accordance with applicable legal requirements. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

  • For the purposes discussed in this Privacy Policy, we may combine the Personal Information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

4. How We Disclose Your Information

Lilo may disclose Personal Information for a business purpose in the following ways:

  • Authorized third-party service providers. We use select third-party service providers to help us provide the Services and to operate our business. They provide a variety of services to us, including fulfillment, shipping and delivery, customer service, web hosting and design, payment processing, sales and marketing, data storage, analytics and related services, security, fraud prevention, research, and legal advising or consulting services. We share information with vendors and our fulfillment partners for the purpose of ensuring the delivery of the purchased product or requested services.

  • Vendors. We may disclose the information we collect about you to vendors that have a business relationship with us and whose products you purchase through the Platform and Services. For example, for orders with vendors through the Procurement Platform, we may share your account information, including, for example, your business details, with the respective vendor to process and ship the order, as well as to communicate directly with you for troubleshooting, order issues, errors, or other investigations. For free samples, we may share your Personal Information with the vendor providing those samples, so that the vendor can communicate with you regarding your experience with their product(s).

  • Customers. For End Users associated with a Customer, this includes providing the owner or manager of the associated Customer with information regarding redemption rewards or cashback redeemed by End Users; account information for modifying user access and permissions; clarifying or removing duplicate accounts; confirming the account information associated with a purchaser for certain orders placed on the Procurement Platform.

  • Legal purposes. We may disclose information we collect about you if required to do so by law or applicable regulations, or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (for example, a subpoena or court order); (b) enforce our Terms of Use, this Privacy Policy, or other contracts with you, including investigation of potential violations; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of us or others.

  • Regulatory purposes. We may be required to share certain information with third parties to fulfill our regulatory obligations. This may include, but is not limited to, providing information to manufacturers for reporting product issues or to assist any of our manufacturer or vendor partners in the event of a product recall. Additionally, we may need to provide information to regulatory authorities or compliance bodies as required by law or regulation. This ensures that we meet all legal requirements and maintain the safety and integrity of the products we supply to our clients.

  • Business transfers. As we continue to develop our business, we may engage in transactions with other companies regarding the purchase or sale of a business. We may disclose your information to the extent necessary and under confidentiality obligations as part of, or in contemplation of, such transactions.

5. Security and Retention of Your Information

5.1. Security of Your Information

We are committed to protecting your information. We use a variety of technical, physical, and organizational security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of information. However, no security measures are perfect or impenetrable. As such, we cannot guarantee the security of your information.

When creating an account on the Platform, it is important that you select a strong and unique password and do not disclose it to others. Alert us immediately if you have any concerns about unauthorized use of your account.

5.2. Retention of Your Information

We retain information for different periods of time depending on the purposes for which we collect and use it, as described in this Privacy Policy. We will delete or de-identify information when it is no longer needed to fulfill these purposes unless a longer retention period is required to comply with applicable laws. The criteria we use to determine our retention periods include the following:

  • The length of time we have an ongoing relationship with you and provide the Platform and Services to you (for example, for as long as you have an account with us or continue using the Services).

  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)

  • Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations).

Subject to the foregoing, when you delete your account, we may delete or anonymize content you have posted on the Platform, such as your reviews or Q&A activity

6. Your Rights and Choices

We provide you with the ability to exercise certain controls and choices regarding our collection, use, and disclosure of your information. Your legal rights to exercise such controls and choices vary based on the applicable Privacy Laws, such as the laws of your jurisdiction.

You may adjust the following controls:

  • Account Profile: You may update certain account profile information by logging into your account. For example, you may modify your personal information, position, password, address, and payment information through the Account tab of the Procurement Platform. To deactivate your account, you may email customersupport@lilohotelsupplies.com. You may also modify or manage user accounts or permissions for other End Users within your company.

  • Communication preferences You may modify or update your communication methods via your account on the Platform. You may also delete certain communication methods within your account.

  • Limit the information you provide to us. When you interact with us, you can choose to limit certain information you provide. However, if you choose to do so, you may not be able to take full advantage of the Platform and Services, and we may not be able to fulfill your requests.

  • Cookie controls Many web browsers are set to accept cookies and similar tracking technologies by default. If you prefer, you can set your browser to delete or reject those technologies. If you choose to delete or reject these technologies, this could affect certain features of our Services. If you use a different device, change browsers, or delete the opt-out cookies that contain your preferences, you may need to perform the opt-out task again.

For questions regarding your Personal Information, or if you would like to change or update your Personal Information, please contact us at customersupport@lilohotelsupplies.com. In some cases, we may be required to keep certain information for legal or business reasons.

7. Changes to Our Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes, we will post the updated version on the Platform and update the Privacy Policy’s revision or effective date on the top of the Privacy Policy. Your continued use of the Platform and Services following the posting of changes constitutes your acceptance of such changes.

8. Contact us

If you have any questions or comments about this Privacy Policy, the way in which Lilo collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights in relation to your Personal Information, please do not hesitate to contact us using any of the methods below:

Postal Address:

Torpedo Now, Inc.

Attn: Legal Department

99 Wyckoff street, Brooklyn, NY, 11201, USA

If you need to access this Privacy Policy in an alternative format due to having a disability, please contact us using any of the methods listed in this section.

9. Additional Notes on Business Information

De-Identified Information. We may de-identify information we collect so that it cannot reasonably identify you, your device, or your affiliated Customer, or we may collect information that is already in a de-identified form. For example, we share data analytics based on de-identified information with our industry partners. This includes data such as total sales of a product in a particular territory or region, or overall compliance or trends with specific products. Our use and disclosure of de-identified information are not subject to any restrictions under this Privacy Policy, and we may use and disclose it to others for any purpose, without limitation.

Business-to-Business Information. Lilo may obtain business information directly from you or from other third-party sources. For example, when a Customer connects with a vendor through the Procurement Platform, Lilo may receive from the vendor, or retrieve on the Customer’s behalf and as the Customer’s authorized agent, information about the Customer’s prior purchases (including products, quantities, and frequency of prior orders at the hotel level). Lilo may also collect information regarding your affiliated hotel’s purchasing and purchasing trends at the hotel level by virtue of End Users’ use of the Procurement Platform. Lilo may use or disclose such business information in the following ways:

  • Linked Vendors: Lilo may use and disclose information that pertains to Customers to facilitate vendor integrations on the Procurement Platform, including by sharing which items are added to or removed from carts, or changing desired quantities in shopping carts. Additionally, for products purchased from a particular vendor, we may share with that vendor hotel purchasing volume or sales volume for that vendor’s products to comply with contractual obligations or for marketing purposes. This may include sharing enrollment and participation in any cashback or loyalty programs, and the total amount of rewards or redemptions claimed on a per-hotel basis; sharing information for the purposes of determining eligibility for particular cashback or loyalty offers; providing reports to vendors regarding order data for the vendor’s products; and sharing information regarding past purchases and pricing of particular products with the manufacturing vendor of those products to confirm pricing accuracy. Beyond confirming pricing for select products with the vendor that manufactured those products, we will not share pricing information with any third parties (even if aggregated or de-identified). For non-direct checkout orders on our Procurement Platform, we may share the shipping and payment information associated with the Customer with the applicable vendor (and any third-party service providers, including UPS or FedEx) to fulfill the order.

  • Data Analytics: Lilo may share data analytics based on de-identified Customer information with vendors and other industry partners. This information may include data such as total product sales in a particular region or rate of lapse for particular products. The purpose of sharing this aggregated information is to identify market trends and improve overall service provided to hotels. In addition, we may share the fact that your affiliated Customers conduct purchasing through the Procurement Platform or otherwise use the Platform and Services with (a) vendors; or (b) in the event that your affiliated Customer is associated with a larger corporate group, with your associated corporate group.

For business-to-business information that does not constitute Personal Information as defined herein, nothing in this Privacy Policy shall be deemed to limit Lilo’s use or disclosure of such information, subject to the terms of any services or other agreement between Lilo and the applicable third-party business.

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