Thank you for using leeloo.ai (the "Website")! In the
course of our dealings with you, we will collect and process personal
data about you and your customers in order to provide you with the
Services you request or access to the Leeloo Software and to
describes in detail how we collect and use your and your customers'
personal data and how you can exercise your rights with this regard.
(or words of similar import) means “LEELOO MARKETING”, LIMITED
LIABILITY COMPANY, having registered address at 01054, 13/2 “B”
Yaroslaviv Val street, Kyiv, Ukraine, that processes your personal
data and interacts with you.
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.
All capitalized terms mentioned hereunder shall have the same meaning
this Website, our Services and Leeloo Software.
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.
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
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.
you have any questions concerning this Policy or our processing of
your personal data, please email us at email@example.com.
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.
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.
note that we will process personal data of your clients only based on
instructions from you as a controller.
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 firstname.lastname@example.org.
Information We Collect About You and How
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.
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
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"),
Process your payment card information when you use a payment card to
purchase a Subscription on our Website. So, we recommend you
service provider. However, they may provide us with certain your
personal data which may include:
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.
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
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);
Please note, that we do not collect or store any personal information
from our Website visitors as part of our remarketing program. Please,
pages for more information. You can control your ads experience
(or opt out of personalized ads altogether) at your Google account.
We only use remarketing to provide you with additional information
and promotions that align with past behavior on our Website.
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
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
if you reside in the European Union ("EU")/ European
Economic Area (“EEA”) or any other jurisdiction that may demand
similar technologies) on our Website, we will provide you with an
opportunity to manage your cookie preferences on the Website. Using
cookies and other similar technologies we may collect from you:
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
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
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
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:
We may also get information by means of:
We never get information which concerns or reveals your:
How Long We Can Keep Your Information
We will keep your information only as long as your account (profile)
is considered to be active and so long as we need to keep it for the
whom we share your data with and who carries out services on our
behalf. If we no longer need to process and keep your data and there
is no requirement for us to keep it in order to comply with our legal
and/or regulatory obligations, we’ll either remove it or
depersonalize it so we can't identify you.
About You We Share with Third Parties. Categories of Recipients
We may disclose your personal data to third parties, including in the
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
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
Your Personal Information Can Be Processed
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
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
The usage of cookies on our Website is aimed at making your user
experience better. Find more information about cookies in our Cookie
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
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’
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.
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;
personal data are no longer necessary in relation to the purposes
for which it was collected and/or processed
withdraw your consent to the processing and there is no other
legitimate reason for processing;
object to the processing and there are no overriding legitimate
grounds for the processing;
object to processing for direct marketing,
personal data have been unlawfully processed, or
personal data have been processed.
may, however, retain some of your personal data for legal compliance
purposes, or where we have a legitimate interest in doing so.
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)
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.
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.
cases, you can make your request by sending us an email
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
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.
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
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
neither party, meaning you and us, shall rely on any written or oral
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.
welcome and should be addressed to email@example.com.
Any questions about the operation of this Policy or any concerns
related the Policy should be firstly referred to us
which has the same legal force as if it were signed in ink.