This policy was updated May 3, 2018.
1. Who We Are
1.1 Lead SV
Welcome to Lead SV! We are a consultancy on a mission to help people grow in the workplace. Through our platform and services, we create custom learning & development experiences for companies.
These offerings are available (a) online through various Lead SV properties including without limitation, Lead SV, the Lead SV List, and the lead.sv short link service ("Sites"); (b) off platform, including without limitation, sponsorship or distribution services; and (c) through webpages, application programming interfaces, and subdomains ("Applications"). For brevity, these are collectively referred to as "Services".
1.2 Who's Who
To reduce confusion, this policy uses the term "Business" to refer to Lead SV, LLC a California Limited Liability Corporation with its place of business as PO Box 549 Redwood City, CA 94064, Reg. No. 201727210005 and may also use the terms "us" and "we" for clarity. This policy also uses the term "Users" to refer to all visitors or consumers of Services and may also use the terms "you" and "your" for clarity.
If you have any questions or concerns at any time, please do not hesitate to contact us at the address above or by contacting us at email@example.com.
2. Our Privacy Statement
3. Personal Data That We Collect
When you use or interact with us through the Services, we may collect Personal Data.
Information you provide to us: For all Users we collect Personal Data when you voluntarily provide such information to the Services, such as when you register for a mailing list, contact us with inquiries, respond to one of our surveys, or request access to materials via email. The Personal Data we may collect includes without limitation your name, address, email address and other information that enables Users to be personally identified.
Information we obtain from other sources: We may also collect or receive Personal Data from third party sources, such as social media or other third party integrations, your credit card issuing bank, our payment processing partners or other third parties.
When you submit Personal Data to us, we may associate other Non-Personal Data (including Non-Personal Data we collect from third parties) with your Personal Data. At such instance, we will treat any such combined data as your Personal Data until such time as it can no longer be associated with you or used to identify you.
4. How We Use Your Personal Data
4.1 Specific Reason
If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.
4.2 Access and Use
If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyze your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity or qualifications to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services and to assess your ongoing qualification to use such Services.
4.3 Internal Business Purposes
We may use your Personal Data for internal business purposes, including without limitation, to help us improve the content and functionality of the Services, to better understand our Users, to improve the Services, to manage your account and provide you with customer service, and to generally manage the Services and our business.
4.4 Lead SV Marketing Communications
Where it is in accordance with your marketing preferences, we may use your Personal Data to contact you in the future for our marketing and advertising purposes, including without limitation, to inform you about services or events we believe might be of interest to you, to develop promotional or marketing materials and provide those materials to you, and to display content and advertising on or off the Services that we believe might be of interest to you. See "Opt Out from Electronic Communications" below on how to opt out of Lead SV Marketing Communications.
4.5 Other Purposes
4.6 Aggregated Personal Data
5. How We Disclose And Transfer Your Personal Data
5.1 No Sale
We are not in the business of selling your Personal Data. We consider this information to be a vital part of our relationship with you. Therefore, we will not sell your Personal Data to third parties, including third party advertisers. There are, however, certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties without further notice to you, as set forth below.
5.2 Business Transfers
5.3 Parent Companies, Subsidiaries and Affiliates
5.4 Agents, Consultants and Service Providers
We may share your Personal Data with our contractors and service providers who process Personal Data on behalf of Lead SV to perform certain business-related functions. These companies include our marketing agencies, database service providers, backup and disaster recovery service providers, email service providers and others. When we engage another company to perform such functions, we may provide them with information, including Personal Data, in connection with their performance of such functions.
5.5 Facebook and Other Third Party Connections
5.6 Legal Requirements
We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Services or the public, or (e) protect against legal liability.
6. How We Store Your Personal Data
7. How You Can Access, Update, Correct or Delete Your Personal Data
You can request access to some of your Personal Data being stored by us. You can also ask us to correct, update or delete any inaccurate Personal Data that we process about them.
Users may exercise these rights by contacting us directly by email or at the address specified below.
If a User initiates a valid data deletion request, Lead SV is authorized to delete or anonymize Personal Data of the requesting User from the Services.
We will consider and respond to all requests in accordance with applicable law.
8. How Long We Retain Your Personal Data
We may retain your Personal Data as long as you are an identified User of the Services. You may request that your information be deleted by contacting us. However, we may retain Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
9. Cookies, Pixels Tags, Local Shared Objects, Web Storage And Similar Technologies.
10. Your Choices
You have several choices available when it comes to your Personal Data:
10.1 Limit the Personal Data You Provide
You can browse the Services without providing any Personal Data (other than Automatic Data to the extent it is considered Personal Data under applicable laws) or with limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionality of the Services. For instance, in order to register for the Lead SV newsletter, your email address is required to be provided to the Services.
10.2 Opt Out from Electronic Communications
(a) Lead SV Marketing Communications
Where it is in accordance with your marketing preferences, Lead SV may send you electronic communications marketing or advertising the Services themselves or events on the Services. You can also "opt out" of receiving these electronic communications by clicking on the "Unsubscribe" link at the bottom of any such electronic communication.
(b) Social Notifications
If you connect your Facebook account or sign up for other social media integrations whose product features include social notifications (i.e., updates on what your friends are doing on the Services), you will receive these social notifications. You can manage these social notifications by toggling your social settings to private or disconnecting such integration.
(c) Transactional or Responsive Communications
Certain electronic communications from Lead SV are responsive to your requests. For instance, if you request materials over email, we will send a link to these tools and resources to the email address provided. As a further example, if you email us, we will return your email. Notwithstanding any unsubscribe election that you have made, you will still receive these transactional or responsive emails. You can stop receiving these types of emails only by contacting us. By electing to stop receiving all electronic communications from us or through our system you will no longer receive any information that is exclusively transmitted over email.
10.3 Do Not Track
We currently do not participate in any "Do Not Track" frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your Personal Data.
11.1 Personal Data Provided to Others
11.2 Third Party Links
12. Children - Children's Online Privacy Protection Act
13. International Privacy Laws
14. Changes To This Policy
15. Dispute Resolution
If you have a complaint about Lead SV's privacy practices you should write to us at:
Lead SV, LLC, Attn: Privacy Officer, PO Box 549 Redwood City, CA 94062, USA, or by email at firstname.lastname@example.org. We will take reasonable steps to work with you to attempt to resolve your complaint.
16. EEA, SWITZERLAND AND UK ONLY
The EU General Data Protection Regulation (GDPR)
In May 2018, a new data privacy law known as the EU General Data Protection Regulation (or the "GDPR") becomes effective. The GDPR requires Lead SV to provide Users with more information about the processing of their Personal Data.
Here is what you need to know:
Legal grounds for processing your Personal Data
The GDPR requires us to tell you about the legal ground we're relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out in Section 4 above will typically be because:
- you provided your consent;
- it is necessary for our contractual relationship;
- the processing is necessary for us to comply with our legal or regulatory obligations; and/or
- the processing is in our legitimate interest as a consultancy offering learning & development training and resources, (for example, to protect the security and integrity of our systems and to provide you with customer service, etc.).
Transfers of Personal Data
As Lead SV is a global company, we may need to transfer your Personal Data outside of the country from which it was originally provided. This may be intra-group or to third parties that we work with who may be located in jurisdictions outside the EEA, Switzerland and the UK which have no data protection laws or laws that are less strict compared with those in Europe.
Whenever we transfer Personal Data outside of the EEA, Switzerland or the UK, we take legally required steps to make sure that appropriate safeguards are in place to protect your Personal Data. Lead SV does not certify via Privacy Shield, but you may contact us as set forth in Section 15 for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.
Personal Data retention
We retain your Personal Data for as long as necessary to provide you with our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.
Data protection law provides you with rights in respect of Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, object to profiling and unsubscribe from marketing communications.
If you wish to exercise these rights, please contact us using the contact information set out in Section 15 above. Please note that requests to exercise data protection rights will be assessed by us on a case-by-case basis. There may be circumstances where we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided for in data protection legislation.
If you have a complaint about how we handle your Personal Data, please get in touch with us as set forth in Section 15 to explain. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.
Lead SV as a data controller
EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as "data controllers") and organizations that process personal data on behalf of other organizations (known as "data processors"). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.
Lead SV acts as a data controller. For example, if you register for a newsletter, contact us via a form, or request a download of an asset, Lead SV will be a data controller in regards to the Personal Data that you provide. We will also be a data controller of the Personal Data that we have obtained about the use of Applications or Services. We use this to conduct research and analysis to help better understand and serve Users of the Services as well as to improve our platform.