PRIVACY POLICY

Introduction


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 administer our relationship with you. This Privacy Policy ("Policy") describes in detail how we collect and use your and your customers' personal data and how you can exercise your rights with this regard.


In this Privacy Policy, references to “we”,” us” or “our” (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 as set forth in the Terms of Use, unless otherwise stated.


This Privacy Policy shall be applied to you during the whole use of this Website, our Services and Leeloo Software.


General Provisions


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 love@leeloo.ai.


Your Customers


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.


Children


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 love@leeloo.ai.


What Information We Collect About You and How


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.


  1. Personal data we may collect from you for the performance of a contract with you may include:


  1. Contact details: such as your name, your email address, your telephone number associated with your profile.

  2. Profile information: such as your contact details (as above) and other any information you share when purchasing a Subscription on our Website.

  3. 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"),

  4. Process your payment card information when you use a payment card to purchase a Subscription on our Website. So, we recommend you carefully review privacy policy of corresponding payment 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.


  1. We also have a legitimate interest for processing of certain your personal data which may include:


  1. 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).


  1. Personal data which we collect when, and for the purposes of communicating with you for the purposes related to our Services:



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.


  1. 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).


  1. 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:



Please note, that we do not collect or store any personal information from our Website visitors as part of our remarketing program. Please, read Google’s Privacy Policy and Analytics Help 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.


  1. With your prior opt-in consent we may process the following information for the following purposes:


  1. 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.


  1. if you reside in the European Union ("EU")/ European Economic Area (“EEA”) or any other jurisdiction that may demand from us to obtain your prior consent to use cookies (and/or other 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:



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.



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 purposes described in this Privacy Policy. This also includes anyone 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.


Information About You We Share with Third Parties. Categories of Recipients


We may disclose your personal data to third parties, including in the following circumstances:



Where 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 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.

Cookies


The usage of cookies on our Website is aimed at making your user experience better. Find more information about cookies in our Cookie Policy.


Your Privacy Rights


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:




We may, however, retain some of your personal data for legal compliance purposes, or where we have a legitimate interest in doing so.



In all cases, you can make your request by sending us an email at love@leeloo.ai.


Your Consent


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 love@leeloo.ai.


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 love@leeloo.ai or through the unsubscribe link at the bottom of our marketing emails.


Complaints


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:


Ukraine

Representative of the Authorized Person for the Protection of Personal Data

Secretariat of the Ukrainian Parliament Commissioner for Human Rights

Email: hotline@ombudsman.gov.ua

Final provisions


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.


This Privacy Policy creates a full understanding between us and you. Unless information is expressly set out in this Privacy Policy, neither party, meaning you and us, shall rely on any written or oral information.


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.


Contacting Us


Questions, comments and requests regarding this Privacy Policy are welcome and should be addressed to love@leeloo.ai.


Any questions about the operation of this Policy or any concerns related the Policy should be firstly referred to us at love@leeloo.ai.


This Privacy Policy agreement is concluded in the electronic form, which has the same legal force as if it were signed in ink.