Privacy Notice

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 privacy@leadsv.com.

2. Our Privacy Statement

2.1 Application
This Privacy Policy clearly explains how Lead SV handles and collects information that could be used to identify a person ("Personal Data") that is collected through use of Services.

"Non-Personal Data" as used in this Privacy Policy is therefore any information that does not relate to a person and/or cannot be used to identify a person. When you interact with the Services, we may collect Non-Personal Data. The limitations and requirements in this Privacy Policy on our collection, use, disclosure, transfer and storage/retention of Personal Data do not apply to Non-Personal Data.

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 automatically collect: We also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which you access the Services ("Automatic Data"). Automatic Data, includes without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address) characteristics about your access device and/or browser, statistics on your activities on the Services, information about how you came to the Services and data collected through Cookies, Pixel Tags, Local Shared Objects, Web Storage and other similar technologies. You can find out more information about how we use Cookies and other similar tracking technologies in our Cookie Statement.

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

We collect and use the Personal Data we collect in a manner that is consistent with this Privacy Policy. We may use the Personal Data as follows:

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
If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is collected or we will obtain your consent subsequent to such collection but prior to such use. 

4.6 Aggregated Personal Data
In an ongoing effort to understand and serve our Users better, we often conduct research on our customer demographics, interests and behavior based on Personal Data and other information that we have collected. This research is typically conducted on an aggregate basis only that does not identify you. Once Personal Data is in an aggregated form, for purposes of this Privacy Policy, it becomes Non-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
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of Lead SV (or its assets) will continue to have the right to use your Personal Data and other information in accordance with the terms of this Privacy Policy.

5.3 Parent Companies, Subsidiaries and Affiliates
We may also share your Personal Data with our parent companies, subsidiaries and/or affiliates for purposes consistent with this Privacy Policy. Our parent companies, subsidiaries and affiliates will be bound to maintain that Personal Data in accordance with this Privacy Policy. 

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
You can connect your Lead SV information to your accounts on third party services like Facebook, in which case we may collect, use, disclose, transfer and store/retain information relating to your account with such third party services in accordance with this Privacy Policy and the policies set forth by those third party services.

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

We may store Personal Data itself or such information may be stored by third parties to whom we have transferred it in accordance with this Privacy Policy. We take what we believe to be reasonable steps to protect the Personal Data collected via the Services from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration and destruction. However, no network, server, database or Internet or e-mail transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us electronically. Please keep this in mind when disclosing any 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. 

Please refer to our Cookie Statement for more information about our use of cookies and other similar tracking 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.

A specific note about Google Tag Manager ("GTM"): GTM is a utility built by Google in order to efficiently load JavaScript on the page. We additionally use the GTM service in order to obtain user consent for cookie usage when applicable. Blocking GTM will automatically opt you out of all Personal Data, but will also reduce your ability to use certain functionality of the service such those which require Personal Data as stated above.

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.

(d) Retention
It may take up to forty-eight (48) hours for us to process an unsubscribe request. Even after you opt out of all electronic communications, we will retain your Personal Data in accordance with this Privacy Policy, however, we will no longer use it to contact you.

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. Exclusions

11.1 Personal Data Provided to Others
This Privacy Policy does not apply to any Personal Data that you provide to another User or visitor through the Services or through any other means, including through comments or discussion on any public areas of the Services. 

11.2 Third Party Links
This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by us (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies. 

12. Children - Children's Online Privacy Protection Act

We do not knowingly collect Personal Data from children under the age of thirteen (13). If you are under the age of thirteen (13), please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to us through the Services, please contact us and we will endeavor to delete that information from our databases.

13. International Privacy Laws

If you are visiting the Services from outside the United States, please be aware that you are sending information (including Personal Data) to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your Personal Data will at all times continue to be governed by this Privacy Policy.

14. Changes To This Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right, in our sole discretion, to update or modify this Privacy Policy at any time (collectively, "Modifications"). Modifications to this Privacy Policy will be posted to the Site with a change to the "Updated" date at the top of this Privacy Policy. In certain circumstances Lead SV may, but need not, provide you with additional notice of such Modifications, such as via email or with in-Service notifications. Modifications will be effective thirty (30) days following the "Updated" date or such other date as communicated in any other notice to you.

Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was updated on the date indicated above. Your continued use of the Services following the effectiveness of any Modifications to this Privacy Policy constitutes acceptance of those Modifications. If any Modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing and otherwise using the Services.

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 privacy@leadsv.com. 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.

Your rights
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.