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We, at Leadgen Network Organization, are committed to protecting the privacy rights of our users. Therefore, we designed and maintained on an ongoing basis, a privacy compliance framework under which our users will be able to get information and exercise their rights with respect to their information and privacy.
Information We Collect and How We Use It: When you use Our Services, we collect certain information about your use, interaction with content, the site from which you arrived and to which you are heading, and some additional technical information about the device and system from which you are consuming the services. Upon your choice to use a “click to call” service we may offer, the phone number from which you made the call may be collected for a limited time of up to 3 months.
The information is used to operate our Site and App, provide you with Our Services, improve them over time, monitor analytics and statistics, and enable us to sync and resolve payment issues with our business partners (including clients, vendors, and affiliates).
We will not share your information unless we are required to by law, or as required to provide you with Our Services.
- Our Legal Bases of Processing
- Information We Process
- Consent, Choice, and Modifications
- Purposes for the collection of information
- Sharing Your Information with Third Parties
- Links to and Interaction with Third Party Properties
- Choices and Opt-Out
- Your Rights
- Information Security
- Children’s Privacy
- Non-US Users
- Contact Us
2. Our Legal Bases of Processing.
We process and use Personal Information in accordance with data protection laws. Our legal ground for processing your Personal Information will typically be one or more of the following:
2.2. Legitimate Interests. We may use some of your Personal Information where we have legitimate business grounds to do so. We use this Personal Information to operate, improve and promote Our Services (for example, when we customize your experience of Our Services or for analytics purposes) and to protect our business (for example, to prevent fraud or ensuring the Our Services’ security).
2.3. Legal Obligations. In some cases, our use of your personal information will be necessary to comply with regulatory obligations or legal requirements (for example, addressing complaints from users or authorities);
2.4. Consent. In certain cases. We will ask for your consent to process and use your Personal Information in order to provide additional services (for example, when you subscribe to our newsletters, create your user profile, provide us Personal Information to get tailored offers or add a review on a service or product). When we rely on consent as our legal basis of processing You may ask to withdraw your consent by clicking here. Once we have verified your request, we will contact you.
3. Information We Process.
When you visit or use Our Services we may collect certain information about your visit and usage of Our Services, in one or more of the following ways:
3.1.4. User Profile and User Reviews. We may offer you the option to give a review of one of our Partners or to create a user profile for some of Our Services which entails providing us with additional information about you that will assist us in providing you with a customized experience.
3.2. Information We Collect from You. We collect information about your use of Our Services and your interaction with Our Services, as follows, and in the following ways:
3.2.1. Device Information: For delivering and compatibility purposes, so as for language, geographic location and time zone, we collect device information such as: device type and version, operating system type, language and version, and information that can be extracted out of a user agent, such as browser type and version, screen resolution.
3.2.2. Interactions and Usage: In order to provide Our Services, operate the Site and App, and keep improving them, so as to be able to sync with our Partners and affiliates, we collect information about your interaction and use of Our Services, such as: URLs from which you were directed to the Site or App and to which you are referred from the Site or App, internal URL’s of the Site or App in which you visited and your actions with respect to Our Services (such as view or click), date/time stamp of Site or App use, the timing for clicks and page-views.
3.2.3. Log Files: We collect information through server log files, but also by deploying tracking technologies within Our Services, such as pixel tags. We do this to analyze trends, track user’s engagement, and interaction with Our Services. The type of information collected may include internet protocol (IP) addresses that your Internet service provider allocated to your device. We collect IP for a limited time and for specific purposes. First is to better understand your geographic location (country, region, and language) and therefore be able to provide Our Services in your own language and relevant to your place of origin. Second, we use automated tools to analyze IP addresses and flag those that are fraudulent.
3.2.4. Cookies and Similar Technologies. Our Services may use “cookies” and other anonymous web tracking technologies (such as “web beacons” and “pixel tags”) implemented by us or by third-party service providers. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that website to recognize your browser. Cookies may store your online preferences and other information about the interaction you make on Our Services. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent to your browser. However, some features or services, included in the Site and App, may not function properly without cookies, and some features may become unavailable for you in such a case. A pixel tag is a type of technology placed on a website for the purpose of tracking activity on websites, or when emails are opened or accessed (if applicable), and is often used in combination with cookies.
3.3. Information we receive from Third Parties. Like many Internet-based services, Our Services are operated and provided in collaboration, sync, and interaction with third parties, including Partners, affiliates, and other third parties. In order to enable and facilitate such sync, we may receive information from third parties, such as an internal user identifier that our system generates for each user (not a unique identifier), and the summary of action taken by you (click, purchase, view, form submission or a phone call). In some of Our Services, you will be able – upon your choice – to consume Our Services on a click-by-call basis. In which case, a third-party vendor/s facilitate the call transmission, tracking, and feedback for success. In such cases, the phone number from which you called may be provided to us (with no other information about you attached), for a limited time and for purposes of resolving referrals and successful calls with our Partners. Except for this purpose, we do not make any other use of such information, unless you will give us your explicit consent.
4. Consent, Choice, and Modifications.
Some of Our Services will require you to submit specific Personal Information. In such a case you can choose whether you want to use such Services or not. Be aware that even if you provided us with your Personal Information, you have the full right to withdraw such consent at any time (please refer to section 8 below to get further details about opting out and withdrawing consent).
5. The Way We Use Personal Information.
To generally provide you with Our Services and constantly improve them. We will use your Information to: (a) administer and make available Our Services to you; (b) further develop and generally improve Our Services; (c) counting and tracking purposes of referrals and ads; (d) validation of users as human and anti-fraud monitoring (e) respond to your inquiries and other communications with you; (f) identify or authenticate your access and use of Our Services.
6. Sharing Your Information with Third Parties.
We do not share Personal Information about you with third parties, except for the following circumstances:
6.3. Other Third Parties. We may send or otherwise share your Information to/with various third parties that help us with our business operations (for example, customer service operators and email or phone administration providers), that help us understand how our users use Our Services, operate them and to improve them. These third parties may have their own privacy policies that they adhere to, and we require them to make it available whenever their services are provided. We recommend you revisit such privacy policies when those third parties render their services directly to you. Also, these third parties may be based (and their servers may be located) anywhere in the world.
We use ActiveProspect’s TrustedForm Script and Jornaya script to independently document users’ consent to be contacted. These tools are embedded on certain pages on our website and collect the following information when you interact with the page(s) where the script is present: page URL, mouse movements and clicks, contact information inputted by the user, a snapshot of the page, including IP address of the user’s computer, time on the page, date and time that the tools script were loaded, as well as the date and time of the various user interactions with the page, and HTTP headers from the user’s browser. For more information about ActiveProspect’s data use and collection policies and practices and Jornaya data use and collection policies, please review:
6.6. Merger, Sale or Bankruptcy. In the event that LNO or one of our affiliated entities is acquired by or merged with, a third party entity, or otherwise sells all or part of our/its assets, we may (and hereby reserve the right to) transfer or assign the Personal Information and other information we have collected or received. In such a case, we will require the acquiring entity to post its data practices and provide you with any of your rights as per the jurisdiction of your residency.
We may also share some non-Personal Information with the following type of third parties and under the following circumstances:
7. Links to and Interaction with Third-Party Properties.
8. Choices and Opt-Out.
8.1. Cookies and Tracking Technologies. you may set your browser to refuse and/or block any cookies from the Site, App, or third party services (for more details please refer to Section 2.1.1 hereof).
8.2. When applicable, review and update or request to remove your Personal Information from our servers (for more details please refer to Section 2).
9. Your Rights.
As an EU based user, you may:
Access the Personal Information that we keep about you. We will need to ask you to provide us certain credentials to make sure that you are who you claim you are. If you find that the Personal Information is not accurate, complete, or updated, then please provide us the necessary information to correct it.
Contact us if you want to withdraw your consent to the processing of your Personal Information. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
Object to the processing of your Personal Information for direct marketing purposes, in case your Personal Information used for such a purpose.
Have a right to lodge a complaint with a data protection supervisory authority.
9.2. Canada. If you are a resident of Canada, you are permitted to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, where applicable. To make such a request, please click here.
Request to Know/Access. You have the right to know what information we have collected, used, disclosed, or in the preceding twelve (12) months. Please read Section 3.1 (Information you provide to us), Section 3.2 (Information we collect), and Section 3.3 (Information we receive from third parties) to exercise this right. We will also disclose to you the specific pieces of personal information that we collected about you if we receive your request for such information and verify your identity.
Request to Deletion. You have the right to request that we delete from our databases any of your personal information that we collect and retain, subject to certain exceptions (such as detecting security incidents, debugging, comply with legal obligations, etc.). We will delete your personal information from our records once we verify your identity and unless an exception applies.
No Discrimination. We will not discriminate against you for exercising your above rights, by: (A) denying you goods or services; (B) charging you different rates for goods or services; (C) providing you with a different level or quality of goods or services; or (D) suggesting that you will receive a different price, rate, level, or quality of goods or services. We may have a different rate or provide a different level or quality of service if the difference is reasonably related to the value provided to you by your personal information we collect.
Handling Privacy Requests. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If the exercise of your right requires more time (up to 45 additional days), we will inform you of the reason and extension period in writing. We may deny your request if we couldn’t verify your request or if we must retain your personal information for certain activities (such as detecting security incidents, debugging, comply with legal obligations, etc.).
Our California Do Not Track Notice. Some web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is an HTTP header field indicating your preference for tracking your activities on Our Service or through cross-site user tracking. We do not currently respond to DNT signals. We may allow third parties, such as companies that provide us with analytics tools, to collect Personal Information about an individual consumer’s online activities over time and across different web sites and services when a user uses Our Services
10. Information Security.
We and respective third-party services/affiliate entities implement data security systems and procedures to secure the information transmitted, processed, and stored on the Site or App, our computer servers, and systems. For example, the Site and App are encrypted by using SSL and so as with any other information at transport, we periodically review our information and data collection practices to ensure constant monitoring, we use third-party processing and serving services that implement various information security standards and certifications (at rest and transmission), and we monitor and filter access to data when it comes to personnel in our organization. Such systems and procedures reduce the risk of security breaches, but they do not provide absolute security, as there is no such thing when it comes to the world-wide network. Therefore, we cannot guarantee that Our Services and our servers are immune to unauthorized access to the information stored therein and to other information security risks.
11. Children’s Privacy.
Our Services are not designed to attract children under the age of 16. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 16. If we learn that we have collected Personal Information from a child under 16, we will use commercially reasonable efforts to delete that information as quickly as possible. If you believe that we might have any such information, please click here.
12. Non-US Users.
We may transfer your Information (including Personal Information) outside the country in which it is collected or in which you reside (e.g., to the United States), including to a country that may not offer the same level of protection for Personal Information as the country in which you reside. However, in which case we make sure to place all contractual safeguards to ensure your Information is processed in a way that offers an adequate level of protection when it is shared between or among our third-party vendors.
Protecting your privacy online is an evolving practice, and we use our best efforts to evolve Our Services in a manner that meets these requirements and best practices as per all jurisdictions in which Our Services are available.
14. Contact Us.
14.1. General Data Protection Regulation (GDPR) – European Representative. Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Leadgen Network Organization, Inc has appointed the European Data Protection Office (EDPO) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by:
Sending an email to email@example.com
Using EDPO’s online request form at https://www.edpo.brussels/contact
Writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium