Effective Date: Monday, May 11th 2020
Leap may collect the following information, which may include personal information, about you in connection with your use of the Site:
- Your contact information, including title, forename and last name
- Your username or email address
- Your phone number
- Your address
We collect this information:
- Directly from you when you provide it to us by your interactions with the Site
- When you subscribe to receive our publications, newsletters and updates
- When you fill in surveys on the Site; or
- When you contact us for another purpose through the Site
Additionally, certain technical information relating to you and your device are collected automatically when you use the Site, such as your internet log information, including Internet Protocol (IP) address, browser type and version, and page interaction information.
When using the Site, Leap and third parties do not collect information about your online activities over time and across third-party websites or other online services, and the Site does not respond to “Do Not Track” signals.
We may use your information, including personal information:
- To respond to requests that you make in your interactions with the Site
- To send you notifications, with your agreement by email providing you with news, information and publications that you have requested
- To maintain the security of the Site
- in the case of technical information collected when you use the Site, for site administration and internal operations (i.e. troubleshooting, data analysis, testing). This enables us to improve the Site to ensure content is presented in the most effective manner for you and your device, and that the Site is safe and secure and
- For any other purpose with your consent
We rely on the following lawful bases to process your personal information for these non-exhaustive purposes:
We may obtain your consent to process your personal information in certain circumstances, which may include when you opt-in to subscribe to publications, newsletters and updates, or you contact us to register an interest in Leap. We may also rely upon our legitimate interest in developing our business as a basis for sending you marketing information and information about Leap (see below).
You have the right to withdraw your consent at any time by using the ‘unsubscribe’ option in the emailed publications sent to you.
We rely on this lawful processing ground when we process your personal information to provide you with information about Leap, and engaging users of the Site to inform them about Leap and its aims. We also rely on this lawful processing ground to respond to specific requests, to manage our business operations, to manage our relationships with you and with third parties in connection with our business, and when we provide you with marketing information or other information in relation to Leap which we believe may interest you.
If you wish to have more information regarding the legitimate interests we rely on, please contact us at firstname.lastname@example.org.
We may disclose information, including personal information:
- To our affiliates and service providers
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety Leap, our stakeholders, or others
- For any other purpose disclosed by us when you provide the information
- With your consent
We may disclose aggregated information and de-identified information without restriction.
In particular, we share your personal data with Mailchimp, the marketing platform which manages our marketing services https://mailchimp.com. Mailchimp provides us with the on-line marketing platform to enable us to send you publications, news and updates.
If you live in the EEA, you may have the right to (1) request access to, rectification, or erasure of your personal information or restrict the processing of your personal information; (2) object to processing; (3) data portability (receive and transfer your personal information); (4) lodge a complaint with a supervisory authority; and, (5) where processing of your personal information is based on consent, withdraw your consent at any time without affecting the lawfulness of the processing of personal information that occurred before you withdraw consent. To make such a request, please email us at email@example.com.
Our servers are either located in the United States or, if located in other countries, may be accessed from the United States. You should also note that Mailchimp, our on-line marketing platform, also stores your personal data in the United States (see above). Please note that in countries outside your own country, and in particular outside the EU and EEA, a different standard on data protection might apply than you are used to in your own country.
By sending personally information to us, you acknowledge and consent that your data will be transferred across national borders, including to countries outside the EU/EEA.
If you live in the EEA, we may transfer personal information to countries for which adequacy decisions have been issued, use contractual protections for the transfer of personal information to third parties under applicable law, or rely on third parties’ certification to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks where applicable.
You may contact us at firstname.lastname@example.org to obtain more information about the safeguards we use to transfer personal information outside of the EEA.
When determining the appropriate retention period for personal information, we take into account various criteria, such as the amount, nature and sensitivity of the personal information, potential risk of harm from unauthorized use or disclosure, purposes for which we process your personal information, whether we can achieve those purposes through other means, and our business operations and legal requirements.
We have implemented measures designed to secure your personal information from unauthorized access, use, alteration, and disclosure. These include a variety of technologies and procedures to help protect the security of your personal information from unauthorized access, use, or disclosure. We also maintain standard physical and electronic procedural safeguards that limit access to your personal information to our employees (or people working on our behalf and under confidentiality agreements) who, through the course of standard business activities, need to access your personal information.
Please submit questions, concerns, or requests to exercise your applicable rights to Leap by email to email@example.com.
If you live in the EEA, Wellcome Link Inc is the entity responsible for the processing of your personal information. Please submit questions, concerns, or requests to exercise your applicable rights by email to firstname.lastname@example.org or write to:
601 South California Avenue
Palo Alto, CA 94304
You may also make a complaint to your local data protection authority.