02 DEC 2019

Privacy Policy

At Leapfin, we are committed to protecting your data. We also work very hard at being transparent about the information we hold about you and our clients.

Privacy Statement

This Statement explains how your personal information is collected, used, and disclosed by Leap Technologies, Inc., operating as Leapfin, and its subsidiaries and affiliated companies ("Leapfin" or "We"). This privacy statement ("Statement") applies only to your use of the public marketing website, leapfin.com (the "Site") when you are not logged in. This Statement does not apply to websites, applications, or services that display or link to different privacy statements or policies.  By visiting the Site, you are accepting the practices described in this Statement, to the extent permitted by law. 

For purposes of data protection laws, Leapfin, located at 880 Harrison Street, Suite 302, San Francisco, CA 94107, is the data controller of your information collected in connection with this Site and the provision of our services. 

When using this Site or Leapfin’s services, you may share personal information necessary for Leapfin to provide the products you use, operate its business, meet its contractual and legal obligations, protect the security of its systems and customers, or fulfill other legitimate interests.

Information Collected

We collect information about you in various ways when you use our Site. We collect personal information you provide to us. For example, we collect your contact information you provide us on our Site. We may also obtain information about you from other sources such as web analytics and other companies.

When you visit our Site or open one of our emails, some information is automatically collected and stored. For example, when you visit our Site your computer's operating system and device type and other identifiers, Internet Protocol (IP) address, access times, browser type and language, hashed identifiers from email addresses for the purposes of cross-device tracking for targeted advertising, and the website you visited before and after our site may be logged. We also collect information about your usage and activity on our Site.

Cookies
  • We may automatically collect information using "cookies" for targeted advertising and other purposes. Cookies are small data files stored on your hard drive by a website. Among other things, cookies help us improve our Site, related services, and your experience. We use cookies to see which areas and features are popular and to count visits to our Site. You can delete your cookies at any time.
Web Beacons
  • We may collect information using Web beacons. Web beacons are electronic images that may be used on our Site or in our emails. We use Web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon.
Analytics
  • Third parties who provide us with analytics services for the Site may also automatically collect some of the information described above, including, for example, IP address, access times, browser type and language, device type, device identifiers and Wi-Fi information. Please consult the respective privacy policies and statements of these third parties for more information, including how Google Analytics use this data.

Use of Information We Collect

We use personal information collected through our Site for purposes described in this Statement or disclosed to you on our Site. For example, we may use your information to:

  • Operate and improve our internal operations, systems, products, and the Site;
  • Understand you and your preferences to enhance your experience and enjoyment using our Site
  • Respond to your comments and questions and provide customer service
  • Provide and deliver products and services you request
  • Communicate with you about products and services offered by Leapfin and our selected partners
  • Link or combine information about you with other personal information we get from third parties, to help understand your needs and provide you with better and more personalized service
  • Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity
  • Fulfill our contractual and legal obligations

Sharing of Personal Information

We do not share your personal information with third parties other than as follows:

  • With your consent and/or to provide our services
  • With third party vendors, consultants, and other service providers who work for us and need access to your information to do that work, such as those who provide web hosting, maintenance and security services, conduct data analysis and create reports, and provide certain service functionality
  • To (i) comply with laws or to respond to lawful requests and legal process, (ii) to protect the rights and property of Leapfin, our agents, customers, and others including to enforce our agreements, policies, and terms of use or (iii) in an emergency to protect the personal safety of Leapfin, its customers, or any person
  • In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company.

We may also share aggregated or deidentified personal information.

Legal Bases for Collecting Personal Information

We collect and process your personal information on the basis of different legal grounds, depending on the nature of the data provided, including:

  • Performance of a Contract - In order to provide this Site and our services, connection and processing personal information is necessary for the performance of our agreements with you.  
  • Legitimate Interest - We have other needs to collect or process personal information where we have a legitimate interest in providing marketing materials, where you have a reasonable expectation to perform a process or service on your behalf, or to prevent fraud and identity theft.  
  • Legal Obligation - Where we need to retain or provide information based on legal obligations, court orders, tax authority requests, and other obligations.
  • Consent - Leapfin relies upon your consent to collect and process personal information, especially where you rely upon us to provide the services. 

Security of Your Personal Information

Leapfin takes reasonable steps to help protect your personal information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Transfers of Your Personal Information

Personal information we collect may be stored and processed in your region, in the United States or in any other country where we or our affiliates, subsidiaries or service providers maintain facilities. We maintain primary data centers in the United States. We take steps designed to ensure that the data we collect under this Statement is processed according to the provisions of this Statement and applicable law wherever the data is located. When we transfer personal information from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection, we use a variety of legal mechanisms, including contracts, in an effort to help ensure your rights and protections.

Storage and Retention of Your Personal Information

We retain your personal information for as long as necessary to provide services requested by you, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly. The criteria used to determine retention include:

How long is the personal information needed to provide applicable services?
  • This includes such things as maintaining and improving the performance of the Site, enabling system security measures, and maintaining appropriate business and financial records.
Do users provide, create, or maintain the data with the expectation we will retain it until they affirmatively remove it?
  • In such cases, we may maintain the data until actively deleted by the user.
Is the personal information of a sensitive type?
  • If so, a shortened retention time may be appropriate.
Are we subject to a legal, contractual, or similar obligation to retain the data?
  • Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data, or data that must be retained for the purposes of litigation.

Your Information Choices And Changes

If you wish to review, correct, delete, or otherwise limit our use of personal information you may have provided to us (for which we reserve the right to charge you a fee, as permitted by applicable law), please contact us at privacy@leapfin.com. In your request, please include your email address, name, physical address, telephone number, and other relevant background.  To protect your privacy and security, we may take steps to verify your identity before granting your request. Note, we may decline requests that are unreasonable, prohibited by law, or are not required to be honored by applicable law.

You may opt out of receiving promotional emails from Leapfin by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. You may also send requests about your contact preferences, changes to your information including requests to opt-out of sharing your personal information with third parties by emailing privacy@leapfin.com.

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site.

Our third-party analytics and advertising partners may provide you with options to opt-out of certain information collection. To opt out of Google Analytics, you can download the Google Analytics Opt-out Browser Add-on.

There are many ways through which web browser signals and other similar mechanisms (for example, "Do Not Track") can indicate your choice to disable tracking, and, while we and others give you choices described in this Statement, we do not currently honor these mechanisms.

Your European Privacy Rights

Resident of the European Economic Area (“EEA”) can exercise certain data subject rights available to them under applicable data protection laws.  Leapfin will comply with requests to exercise these rights in accordance with applicable law. Please note that in some circumstances, we may need to keep processing your information for certain legitimate interests to comply with a legal obligation.  If these rights apply to you, you may request:

  • A copy of certain personal information we hold about you;
  • We prevent the processing of your personal information for direct marketing purposes;
  • We update personal information that is out of date or incorrect; 
  • We delete certain personal information that we hold about you;
  • We restrict the way we process or disclose specific personal information about you; 
  • We transfer your personal information to a third-party; and/or
  • Revoke consent that you previously provided in the collection and use of your personal information.

Our Policy on Gathering Information From And Communicating With Children Online

We recognize the unique privacy concerns regarding children and are committed to protecting children's online privacy. Our services are not geared towards children. Pursuant to the Children’s Online Privacy Protection Act guidelines, we do not intentionally or knowingly collect or maintain personal information online from children under the age of 13. If a parent or guardian is made aware that a child under the age of 13 has provided us with personal information, please contact us by e-mail at privacy@leapfin.com, and we will take commercially reasonable measures to remove the information about the child from our records.

Your California Privacy Rights

If you are a California resident, you have the right to request a notice disclosing the categories of personal information we have collected on you, including the categories of personal information we have collected, the source of that information, our use of that information, and if that information was disclosed to a third party, the categories of third parties to whom such information was disclosed.  You have the right to make a personal information request for the specific information collected on you during the 12 month period preceding the request, the right to have such information deleted, the right to request that the information not be sold to third parties, and the right to not be discriminated against because you have exercised any of these rights. If you are a California resident, to exercise your option, a request can be mailed to privacy@leapfin.com.  In your request, please include your email address, name, physical address, telephone number, and other relevant background.  To protect your privacy and security, we may take steps to verify your identity before granting your request.

Changes To This Statement

Leapfin reserves the right to change, modify, add or delete portions of this Statement from time to time. If we make any changes to this Statement, we will change the "Last Revised" date above, or provide such notice about, or obtain consent to changes, as may be required by applicable law. Your use of this Site and our services constitutes your binding acceptance of such changes. 

Contact Information

If you have any questions about this Statement, or if you wish to lodge a complaint about our privacy practices, please contact us at privacy@leapfin.com or Leapfin, 880 Harrison Street, Suite 302, San Francisco, CA 94107. If you are a California resident, you may have this same information emailed to you by sending a letter to the foregoing address with your email address and a request for information.