As of : 07/25/2019
What kinds of information do we collect?
To provide the Services, we must process information about you. The type of information that we collect depends on how you use our Services. You can learn how to access and delete information we collect by visiting your settings in the app or write to us at firstname.lastname@example.org.
Things that you and others do and provide.
- Information and content you provide. We collect the content, communications and other information you provide when you use our Services, including when you sign up for an account and select matching criterions, create or share content and message or communicate with others. This can include information in or about the content that you provide (e.g. metadata), such as the date a file was created. Our systems automatically process content and communications that you and others provide to analyze context and what's in them for the purposes described below.
- Data with special protections: You can choose to provide information about your political views, who you are "interested in" or your health. This and other information (such as racial or ethnic origin, philosophical beliefs or trade union membership) is subject to special protections under EU law.
- Networks and connections. We collect information about the people, and groups that you are connected to and how you interaccontat with them across our Services, such as people you communicate with the most or groups that you are part of. We also collect contact information if you choose to upload, sync or import it from a device.
- Your usage. We collect information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, the people or accounts you interact with and the time, frequency and duration of your activities. For example, we log when you're using and have last used our Services, and what posts or other content you view on our Services.
- Things others do and information that they provide about you. We also receive and analyze content, communications and information that other people provide when they use our Services. This can include information about you, such as when others send a message to you or upload, sync or import your contact information.
As described below, we collect information from and about the computers, phones, connected TVs and other web-connected devices you use that integrate with our Services, and we combine this information across different devices you use. For example, we use information collected about your use of our Services on your phone to better tailor the content or features that you see when you use our Services on another device, such as your laptop or tablet, or to measure whether you took an action in response to an ad that we showed you on your phone on a different device.
Information we obtain from these devices includes:
- Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
- Device operations: information about operations and behaviours performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
- Identifiers: unique identifiers, device IDs and other identifiers, such as from games, apps or accounts that you use.
- Device signals: Bluetooth signals, information about nearby Wi-Fi access points, beacons and mobile phone masts.
- Data from device settings: information that you allow us to receive through device settings that you turn on, such as access to your GPS location.
- Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network, so we can do things such as help you stream a video from your phone to your TV.
How do we use this information?
We use the information that we have (subject to choices you make) as described below, and to provide and support the Services and related services described in the TOS.
Provide, personalize and improve our Services.
We use the information we have to deliver our Services, including to personalize features and your feed. To create personalized Services that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data that we collect and learn from you and others (including any data with special protections that you choose to provide where you have given your explicit consent); how you use and interact with our Services; and the people, places or things that you're connected to and interested in on and off our Services.
- Location-related information: We use location-related information – such as your current location, where you live, the places you like to go, and the businesses and people you're near – to provide, personalize and improve our Services, for you and others. Location-related information can be based on things such as precise device location (if you've allowed us to collect it), IP addresses and information from your and others' use of our Services (such as check-ins or events you attend).
- Product research and development: We use the information we have to develop, test and improve our Services, including by conducting surveys, and testing and troubleshooting new Services and features.
Provide measurement, analytics and other business services.
We use the information we have (including your activity off our Services, such as the websites you visit and ads you see) to help our partners to measure the effectiveness of their services, and understand the types of people who use their services and how people interact with their websites, apps and services.
Promote safety, integrity and security.
We use the information that we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Services, and promote safety and security on and off our Services. For example, we use data that we have to investigate suspicious activity or violations of our Terms or Policies, or to detect when someone needs help.
Communicate with you.
We use the information that we have to send you marketing communications, communicate with you about our Services and let you know about our TOS and Policies. We also use your information to respond to you when you contact us.
How is this information shared?
Your information is shared with others in the following ways:
Sharing on our Services
People and accounts that you share and communicate with
When you share and communicate using our Services, you choose the audience for what you share. For example, when you post on LEEPSE, you select the audience for the post, based on several criterion.
Content that others share or reshare about you.
You should consider who you choose to share with, because people who can see your activity on our Services can choose to share it with others on and off our Services, including people and businesses outside the audience that you shared with. For example, when you send a message to a person or people, they can download, screenshot or reshare that content to others across or off our Services.
If the ownership or control of all or part of our Services or their assets changes, we may transfer your information to the new owner.
Sharing with third-party partners
We work with third-party partners who help us provide and improve our Services which makes it possible to operate our companies and provide the best services to people around the world. We don't sell any of your information to anyone. We also impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties that we share information with:
- Partners who use our analytics services.
We provide aggregated statistics and insights that help people and businesses understand how people are engaging with their posts and other content on and off our Services.
We share information about you with companies that aggregate it to provide analytics and measurement reports to our partners.
We share information with our IT Developers in order for them to operate and improve our software products.
- Law enforcement or legal requests.
We share information with law enforcement or in response to legal requests in the circumstances outlined below.
What is our legal basis for processing data?
We collect, use and share the data that we have in the ways described above:
- as necessary to fulfil our engagements according to our TOS and Policies;
- consistent with your consent, which you may revoke at any time through the settings;
- as necessary to comply with our legal obligations;
- to protect your interests;
- as necessary in the public interest; and
- as necessary for our (or others') legitimate interests, including our interests in providing an innovative, personalized, safe and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
How can you exercise your rights provided under the GDPR?
Under the General Data Protection Regulation (the "GDPR"), you have the right to access, rectify, port and erase your data. You also have the right to object to and restrict certain processing of your data. This includes:
- the right to object to our processing of your data for direct marketing, which you can exercise by using the "unsubscribe" link in such marketing communications, and
- the right to object to our processing of your data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party.
Under European law, companies must have a legal basis to process data. You have particular rights available to you depending on which legal basis we use, and we've explained these below. You should know that no matter what legal basis applies, you always have the right the right to be forgotten or to request access to, rectification of and deletion of your data under the GDPR. To exercise your rights, visit your settings or write us at email@example.com. We process data as necessary to perform our contracts with you. The uses of core data, which are necessary for the provision of our contractual services, are:
- To provide, personalize and improve our Services;
- To promote safety, integrity and security;
- To transfer, transmit, store or process your data outside the EEA, including to within the United States and other countries;
- To communicate with you, for example, on product-related issues.The other legal bases that we rely on in certain instances when processing your data are:
- BY SIGNING UP WITH LEEPSE, YOU GIVE US YOUR CONSENT TO PROCESS YOUR PERSONAL DATA, I.E. ALL INFORMATION RELATED TO YOU. YOU HEREBY ACKNOWLEDGE THAT YOU HAVE BEEN DULY INFORMED ABOUT THE KIND OF DATA WE COLLECT, HOW WE PROCESS IT AND WHAT ARE YOUR RIGHTS REGARDING OUR PROCESSES.
- IT IS YOUR FREEDOM OF CHOICE TO GIVE US SENSIBLE DATA ABOUT YOURSELF SUCH AS RACIAL OR ETHNIC ORIGIN, POLITICAL OPINIONS, RELIGIOUS OR PHILOSOPHICAL BELIEFS, TRADE UNION MEMBERSHIP, DATA CONCERNING HEALTH OR DATA CONCERNING YOUR SEX LIFE OR SEXUAL ORIENTATION IN ORDER TO IMPROVE YOUR EXPERIENCE WITH OUR SERVICES. IF YOU DECIDE TO GIVE US SENSIBLE DATA AS DESCRIBED ABOVE, YOU ALSO GIVE US YOUR EXPRESS CONSENT TO PROCESS THEM.
- YOU MAY REVOKE YOUR CONSENT IN WHOLE OR IN PART AT ANY TIME. TO REVOKE YOUR CONSENT, VISIT YOUR SETTINGS OR CONTACT US AT PRIVACY@LEEPSE.COM. PLEASE NOTE THAT REVOCATION OF YOUR CONSENT IN WHOLE OR IN PART CAN IMPACT YOUR USE OF OUR SERVICES AND CAN LEAD TO DELETION OF YOUR ACCOUNT (SEE SECTION 6)
Our legitimate interests or the legitimate interests of a third party, where not outweighed by your interests or fundamental rights and freedoms:
- For people under the age of majority (under 18, in most EU countries) who have a limited ability to enter into an enforceable contract only, we may be unable to process personal data on the grounds of contractual necessity. Nevertheless, when such a person uses our Services, it is in our legitimate interests to:
- Provide, personalize and improve the Services. For people under their Member State's age of consent, we modify our Services to ensure special protections, and with some restricted feature. This includes processing information that people under the age of consent allow us to receive through device-based settings that they enable, to provide the features and services covered by those settings.
- Promote safety, integrity and security, including through tools focused specifically on threats to people under the age of majority; and
- Provide non-marketing communications for product or customer service-related issues.
The legitimate interests we rely on for this processing are:
- To create, provide, support and maintain innovative products and features that enable people under the age of majority to express themselves, communicate, discover and engage with information and communities relevant to their interests, build community and use tools and features that promote their well-being.
- To secure our platform and network, to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, keep our Services free of harmful or inappropriate content and investigate suspicious activity or breaches of our terms or policies; and to protect the safety of people under the age of majority, including to prevent exploitation or other harms to which such individuals may be particularly vulnerable.
For all people, including those under the age of majority:
- For providing measurement, analytics and other business services where we are processing data as a controller. The legitimate interests we rely on for this processing are:
- To provide accurate and reliable reporting to our developers and other partners, to ensure accurate pricing and statistics on performance and to demonstrate the value of our Services; and
- In the interest of developers and other partners to help them better understand their customers and improve their businesses, and evaluate the effectiveness of their online content on and off our Services.
- For providing marketing communications to you. The legitimate interests we rely on for this processing are:
- To promote our Services and issue our direct marketing.
- To research and innovate for social good. The legitimate interest we rely on for this processing is:
- To further the state-of-the-art or academic understanding on important social issues to affect our society and world in a positive way.
- To share information with others including law enforcement and to respond to legal requests. The legitimate interests we rely on for this processing are:
- To prevent and address fraud, unauthorized use of the Services, breaches of our terms and policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or people), our users or others, including as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm.
We will consider several factors when assessing an objection, including: our users' reasonable expectations; the benefits and risks to you, us, other users or third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportional effort. Your objection will be upheld and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons.
If you are under the age of majority in your country and have a limited ability to enter an enforceable contract, we will take particular account of the fact that you are below the age of majority and adjust our assessment of our legitimate interests and the balancing of your interests and rights accordingly. We provide specific protections for people below the age of majority to ensure that they are aware of the risks, consequences, safeguards and rights associated with the processing of their data.
Compliance with a legal obligation
- For processing data when the law requires it, including, for example, if there is a valid legal request for certain data.
Protection of your vital interests or those of another person
- The vital interests that we rely on for this processing include protection of your life or physical integrity or that of others, and we rely on it to combat harmful conduct and promote safety and security, for example, when we are investigating reports of harmful conduct or when someone needs help.
Data retention, account deactivation and deletion
We store data until it is no longer necessary to provide our Services or until your account is deleted – whichever comes first. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. When you delete your account, we delete things that you have posted and you won't be able to recover this information later. Information that others have shared about you isn't part of your account and won't be deleted. If you don't want to delete your account but want to temporarily stop using the Services, you can deactivate your account instead or you can write to us at firstname.lastname@example.org.
How do we respond to legal requests or prevent harm?
We access, preserve and share your information with regulators, law enforcement or others:
- In response to a legal request, if we have a good-faith belief that the law requires us to do so. We can also respond to legal requests when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction and is consistent with internationally recognized standards.
- When we have a good-faith belief that it is necessary to: detect, prevent and address fraud, unauthorized use of the Services, breaches of our TOS or Policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Services), you or others, including as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm.
How do we operate and transfer data as part of our global services?
We share information globally, both internally and externally with our partners and with those you connect and share with around the world in accordance with this Policy. Information controlled by LEEPSE will be transferred or transmitted to, or stored and processed in, the United States or other countries outside where you live for the purposes as described in this Policy. These data transfers are necessary to provide the services set forth in our TOS and Policies, and to globally operate and provide our Services to you. We use standard contractual clauses approved by the European Commission and rely on the European Commission's adequacy decisions about certain countries, as applicable, for data transfers from the EEA to the United States and other countries.
How will we notify you of changes to this policy?
We'll notify you before we make changes to this Policy and give you the opportunity to review the revised Policy before you choose to continue using our Services.
How to contact LEEPSE with questions
If you have questions about this Policy, you can contact us as described below.
As of : 08/16/2019
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