References to “you”, "your" mean our client, the person whose personal information we collect, use and process. It may refer to anyone who may contact us about the Services, or otherwise interact with us.
We have the purpose to guarantee you the Services of the highest quality. To make it possible, we strive to have both simple and accurate identification procedure in place, just like a manner of communication and provide you with the option to make a choice.
Under EU data protection law, with regards to the processing of our direct clients’ personal data we act as a "controller", i.e. the person responsible for information you provide. According to General Data Protection Regulation (EU) 2016/679 of 27 April 2016 ("GDPR") controller is a person that determines the purposes and the means of processing of your personal data. With regards to the processing of personal data of your customers we act as a processor, which means a person, that processes personal data on your behalf (you act as a controller in this regard). Please note that we shall not engage another processor without your prior specific or general written authorization.
This Policy covers the personal data we collect: (1) about you as a user of our Services and Leeloo Software; (ii) about your customers (generally recipients of messages sent through Leeloo Software); and (ii) through our Website and in the usual course of our business, including in connection with our events, recruitment, sales and marketing activities. So, we ask you to spend some time reviewing this Policy very carefully since it contains important information about how we will collect, store and process your and your customers' personal data.
Would you have any questions concerning this Policy or our processing of your personal data, please email us at firstname.lastname@example.org.
We do not have any relationship with your customers, and we process any information relating to them solely for the purposes of providing our Service to you.
With respect to the information of your customers, including personal data that you provide to Leeloo, we act a data processor; but with respect to your own customers, you are a data controller, and if any of your customers is a citizen or a resident of a country in the European Union (EU), then you must ensure that you comply with legal requirements and your obligations as a data controller under the GDPR; namely, you must ensure that you afford your customers the rights identified in GDPR. Also, you are responsible for seeking proper legal basis according but not limited to GDPR terms & conditions from your customers in order to use their data.
Please note that we will process personal data of your clients only based on instructions from you as a controller.
Our Website and our Services are not intended for children under thirteen (13) years of age. No one under age thirteen (13) may provide any personal information to us. We do not knowingly or intentionally collect personal information from children under thirteen (13). If you are under thirteen (13), do not use or provide any information on this Website or through our Services, purchase Subscription on the Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under thirteen (13), we will delete that information. If you believe we might have any information from or about a child under thirteen (13), please contact us at email@example.com.
We collect, store and process your personal data based on different legal grounds (i.e. "legal basis" for the purposes of GDPR) which depends on the purpose for which this data is processed. If we have a contract with you, we use your personal data for performance of such contract. Also, your personal data may be processed on the basis of our legitimate interest, your consent or in order for us to fulfil certain legal obligations. In any case such legal basis is depend on certain purposes of processing your personal data which is described below. Please note that in case your consent is required, we will separately ask for it.
Personal data we may collect from you for the performance of a contract with you may include:
Contact details: such as your name, your email address, your telephone number associated with your profile.
Profile information: such as your contact details (as above) and other any information you share when purchasing a Subscription on our Website.
Payment and transaction information: we will keep the payment method you use for the transaction with us. We may work with certain third parties as payment service providers and we also may receive some information about you from them. We do not view or store your payment card information. Third-party service providers (namely, FC WayForPay LLC, LLC non-bank credit organization "Yandex.Money", LLC "WEBMANIYUAY", PJSC CB "PRIVATBANK"),
your payment card holder name;
email registered, and
We require information set forth in this Section to provide you with our Services, including to verify your identity and maintain a record of your transactions and interactions with us. Mostly this is the information which we receive directly from you.
We also have a legitimate interest for processing of certain your personal data which may include:
Website login information: your log-in (email) and password. You may also choose to sign in to our Website through third-party services (e.g., Facebook, Google+, VK, Telegram, Viber etc). As always, you will be asked whether you want that such third-party services provide us with information about you. If choose to do this we will receive your login details and profile information such as your log-in, user name and photo (avatar) and other information from that service as permitted by you and that service.
We may need this information to protect the security of your account (profile) and provide you with alternative methods to sign in to your account (profile).
Personal data which we collect when, and for the purposes of communicating with you for the purposes related to our Services:
your contact details (email address, telephone number);
information which you may provide us with when you interact with our customer support or use our messaging system;
to improve our Service and customer support we may also record your conversations with our customer support representatives.
We may use this information from you to communicate with you about our Services and Leeloo Software (including to inform you about any changes made to our Services and/or Leeloo Software) and to provide you with quality customer support.
When you use our Services or access our Website, we may automatically collect non-personally identifiable information but which potentially may be used to identify you personally. This includes data about your device, browser, OS, your IP-address and general location information (country) and time zone.
This information may be collected through your browser and/or various technologies, including server logs, cookies and similar technologies (web beacons, for example).
Certain analytical data which we may receive about you from third-party providers like Google Analytics and similar services.
We utilize trusted third-party vendors like Google to track your activity on our Website, track site usage using Google Analytics, and show ads about the Website around the Internet. If you have chosen to enable Google to associate your web and/or app browsing history with your Google account, and to use information from your Google account to personalize ads, Google will use your data from your Google account together with our Google Analytics data to build audience lists for cross-device remarketing purposes. This means that by using signed-in user data, ads can be shown to you across any device which is linked to your Google account.
In order to support this feature, two things will happen:
first, for users on our Website, Google Analytics will collect Google-authenticated identifiers associated with users’ Google accounts (and therefore, personal information);
second, Google Analytics will temporarily join these identifiers to our Google Analytics data in order to support our audiences.
We only use remarketing to provide you with additional information and promotions that align with past behavior on our Website.
With your prior opt-in consent we may process the following information for the following purposes:
your contact details (email address, telephone number) which we may process for direct marketing purposes, including sending you marketing information about our Services and/or services or products of our partners which may be of interest to you. The legal basis on which we may process your personal data for marketing purposes is your express consent, except you are already our existing client and the marketing message concerns Services similar to those you have already purchased from us. In such a case, our legal basis for this processing is our legitimate interest to develop and grow our business.
We use this information to provide you with information about our and/or third parties' products, services, promotions and special offers that may be of interest to you. We will never provide any third parties with your personal data for direct marketing purposes without your prior consent.
information about how you use and connect to our Website.
how you use the Website such as the pages and links you access, the time you access the Website and duration you are on it, the website you come from or go to after leaving the Website and selections and choices you make when using the Website.
information about the computer or other electronic devices you use to connect to the Website such as details about the type of device (it may include identification of unique number of the device), its operating system, browser and applications connected to the Website through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).
Typically, the information we collect about how you use or connect to the Website is associated with your device and not you as a named individual. Yet, in case you are logged into a registered account at our Website, then this information may also be associated directly with you.
Information about your location: other than information you choose to provide to us, we never collect any information of where you are located. Your device’s IP address on your electronic device may help us determine only your approximate location but this will be no more precise than the city, state or country you are using your device in.
We require this information to ensure that content from our Website is presented in the most effective manner for you and for your computer (device), and to help us analyze how you and other visitors use our Website. You may read more about cookies we use on our Website from our Cookies Policy.
You mostly submit all the information personally. But we may get information on our own with your consent. Information can be submitted once you:
fill any questionnaires or any forms;
communicate with us in any way;
identify your personality.
We may also get information by means of:
observing your activities and interactions on our Website;
tracking your transactions on this Website;
using cookies or any similar technologies.
We never get information which concerns or reveals your:
ethnic or racial origin;
philosophical, religious or any other beliefs of the similar kind;
your mental or physical condition or health;
How Long We Can Keep Your Information
We may disclose your personal data to third parties, including in the following circumstances:
Service Providers. We use a variety third parties to provide services to us or to carry out a certain type of activities on our behalf involving the processing of your personal data. These third-party providers have access to your personal data on a “need-to-know” basis only, solely for the purposes to perform these tasks and to the extent necessary to provide their services.
Our affiliates. To enable and support us in providing the Services or access to our Platform, we may share your personal data between our affiliate companies.
Third parties (in case of change of control). We may sell, disclose, or transfer information about you as part of a corporate business transaction, such as an acquisition or a merger, financing, corporate reorganization, joint venture, including sale of company assets, or in the unlikely event of bankruptcy, receivership or insolvency, in which such information could be disclosed to any third-parties as a business asset in the transaction.
Third parties (in case of protecting our rights). We may disclose your personal data if we consider this is necessary in order to protect our legitimate rights and interests
Courts, law enforcement agencies and governmental authorities. We may pass your personal information to third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation (including in connection with a court order).
Partners. We may share non-personal aggregate statistics (group) data about visitors to our Website, sales and traffic patterns with our partners and other parties.
Other third parties. We may disclose personal information about you to third-parties with your consent. We may obtain your consent in writing; online, through "click-through" agreements; when you accept the terms of disclosures for certain Services; orally, when you interact with our Customer Support Representatives.
We may transfer the personal data we gather about you with to third parties located in countries other than the one you are located for the purposes for which they have been collected. This also includes countries which are not regarded as part of the EEA and which may not offer the same safeguards to personal data protection as within the EEA.
Any such transfer will only occur in cases where, at least:
The third-party recipient is located in a country which, according to the European Commission, provides an adequate level of protection for your personal information; and/or
Under an agreement which satisfies EU requirements for the transfer of personal data to data processors or data controllers outside the EEA, such as standard contractual clauses approved by the European Commission.
If you are a natural person (individual), you have the following rights under the GDPR in respect of any of your personal data we keep on you:
a right to access the personal data we have on you. Please note that your right to access to your personal data may be restricted by certain legislation restrictions, protection of another persons’ privacy.
a right to request correction of incorrect and/or incomplete data. If the data you provided are incorrect and/or incomplete, you are entitled to request us to correct, change, update and/or rectify your personal data. Before making such request please note that some of your data can be updated through your account.
a right to request erasure ("a right to be forgotten"). You have the right to ask us to delete some or all of your data in case;
the personal data are no longer necessary in relation to the purposes for which it was collected and/or processed
you withdraw your consent to the processing and there is no other legitimate reason for processing;
you object to the processing and there are no overriding legitimate grounds for the processing;
you object to processing for direct marketing,
your personal data have been unlawfully processed, or
children personal data have been processed.
We may, however, retain some of your personal data for legal compliance purposes, or where we have a legitimate interest in doing so.
a right to restrict processing of your personal data. You have the right to restrict the processing of your data in certain circumstances (for example, you have the right to limit us in processing of your data for a period of enabling us to verify the accuracy of your personal data in case you are contesting the accuracy of your personal data)
a right to object to processing of your personal data which is based on our legitimate interest. You can at any time object to the processing of your personal data for direct marketing which includes profiling to the extent that it is related to such direct marketing.
a right to data portability. If your personal data was processed on the consent basis and by automated means, you have a right to receive personal data which you have provided to us in a structured, commonly used and machine-readable format. If technically feasible your data can be transmitted to another data controller.
In all cases, you can make your request by sending us an email at firstname.lastname@example.org.
For some purposes and in certain situations, we may require your consent to process your personal data. Examples of such situations are processing of your data for marketing purposes (with certain exceptions). If you have previously given us your consent to a processing of your personal data you can freely withdraw such consent at any time by emailing us at email@example.com.
If you withdraw your consent, and if we do not have another legal ground for processing, then we will stop processing your personal data.
Please note that if we need to process your personal data in order to operate the Website and/or provide our Services, and you object or do not consent to us processing your personal data, the Website and/or those Services may not be available to you.
YOU HAVE THE RIGHT AT ANY TIME TO ASK US TO STOP PROCESSING YOUR INFORMATION FOR DIRECT MARKETING PURPOSES. If you wish to exercise this right, you should contact us by sending an email to firstname.lastname@example.org or through the unsubscribe link at the bottom of our marketing emails.
If you have any concerns about how we collect or process your data you have the right to file a complaint with a supervisory authority, which is the Information Commissioner’s Office:
Representative of the Authorized Person for the Protection of Personal Data
Secretariat of the Ukrainian Parliament Commissioner for Human Rights
We will take reasonable efforts to ensure your safety and prevent third-party access to the personal information collected. We shall keep our employees duly trained and instructed to maintain your information safe.
Reports and notices under this document shall be considered as read within 1 day since the moment the notice or report has been sent.
This document may be altered, modified or amended at our sole and absolute discretion without issuing any warning or notices.
Any questions about the operation of this Policy or any concerns related the Policy should be firstly referred to us at email@example.com.