LEADSPACE® PRIVACY POLICY

Leadspace Inc. and Leadspace Ltd. (“We”, “Our”, “Us”) respect your privacy. This privacy policy describes the ways we collect and process your personal information, as a user of Our service (the “Service”) and the rights and options available to you with respect to the handling of such information.

AnchorTHE IDENTIFIABLE INFORMATION THAT WE COLLECT

We collect and store your contact details that you provided to activate the Leadspace Service account, and your name (only), if you use your Leadspace account for accessing third party data providers. We also collect traffic data that is regularly generated with users’ online activities such as IP addresses, session durations, and viewed pages (“Personal Information”).

When We collect your Personal Information, We will give you timely and appropriate notice describing what personal information We are collecting, how We will use it, and the identity of third parties with whom We may share it. We will provide you with the choice and means for limiting the use and disclosure of Personal Information. Notice will be provided in clear and conspicuous language when you are first asked to provide Personal Information to Leadspace, or as soon as practicable thereafter.

AnchorAnchorWHAT DO WE DO WITH IDENTIFIABLE INFORMATION?

We will use your Personal information to operate and enable the Service; to improve and customize your experience with the Service; to send you Service-related updates, notices and announcements; to enforce the Leadspace Software Service Agreement that your employer executed; to take any action in any case of dispute, or legal proceeding; to prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Service; and to comply with any requests and orders of law enforcement agencies and authorities.

AnchorSHARING IDENTIFIABLE INFORMATION WITH OTHERS

We do not sell, rent, lease or other provide your Leadspace account details, and your activities with the Service and the Leadspace website to third parties. We may only share such information with third party providers strictly to operate the Service. We may share such information with Our affiliates such as subsidiaries, and parent companies, with the express provision that their use of your Personal Information will comply with the provisions of this policy.

We may also receive your Business-related Personal Information from third parties and share that information with service providers, customers and other third parties as part of our Service, for marketing purposes, or if otherwise necessary to fulfill the purposes for collecting the information. Any such third party will commit to protect your privacy as required under applicable law.

Disclosure to Competent Authorities – We may disclose Personal Information with or without notice (a) if required by a subpoena or other judicial or administrative order; (b) where required by law; or (c) at our sole discretion, where we deem it necessary to protect the safety of any individual, the general public, or to prevent violations of the rights of Leadspace or any third party.

Additionally, a merger, acquisition or any other structural change may require us to transfer Personal Information to another entity, as part of the structural change, provided that the receiving entity will comply with this policy.

We may be liable for onward transfers to third parties in violation of the Privacy Shield Principles. For further information, please find below the EU-US Privacy Shield chapter of this policy.

AnchorAnchorAGGREGATED AND ANALYTICAL INFORMATION

We may use anonymous, statistical and aggregated data that is derived from your Personal Information, but does not identify you, for Our own purposes.

We use the standard analytics tools of Google Analytics and we may use additional or other analytics tools, from time to time. The privacy practices of these tools are subject to their own privacy policies. See Google Analytics Privacy Policy at: http://www.google.com/analytics/learn/privacy.html.

We use anonymous, statistical or aggregated information and may share it with our partners for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you. We will share your identifiable information only subject to the terms of this policy, or subject to your prior consent.

We will share your identifiable information only subject to the terms of this policy, or subject to your prior consent.

AnchorCHOICE

We will give you choices about the ways we use and share your Personal Information, and We will respect the choices you make. We will offer you the opportunity to choose whether your Personal Information is (a) to be disclosed to a third party; or (b) to be used for a purpose other than the purpose for which it was originally collected.

At any time you can stop using the Leadspace website.

Termination of your Leadspace Service account is subject to the terms of your subscription agreement with Us.

At any time, you may opt-out of Our mailing list, or request that your Personal Information will not be shared with Our affiliates, or with Our third-party providers, by contacting Us. It may take up to Ten (10) business days for your opt-out request to take effect. Please note that certain opt-out requests may require Us to terminate your account, for example, if transferring your personal details to a third-party provider is essential to provide the Service.

You can exercise your choice by contacting us at: info@leadspace.com.

We request and collect minimal personal details that we need for the purposes described in this policy. At any time, you may opt to terminate your use of the Service. Thereafter, we will stop collecting any personal information from you. However, We may store and continue using or making available certain personal information that is related to you. For further information, please read the Data Retention section in this policy.

Some web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is a HTTP header field indicating your preference for tracking your activities on the Service or through cross-site user tracking. Our Service does not respond to DNT signals.

AnchorYOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident who provides personal information in obtaining products or services for personal, family or household use, California Civil Code Section 1798.83 (“Shine the Light” Law) permits you to request in writing and obtain from us, once per calendar year, information about the customer information we shared, if any, with other third parties for their own direct marketing purposes.

If applicable, this information would include a list of the categories of customer information and the names and addresses of those businesses with which we shared customer information during the preceding calendar year (such as requests made in 2018 will receive information regarding 2017 sharing activities).

To make such a request, please contact us at: info@leadspace.com and write “Request for California Privacy Information” for the subject of your message. We will send you a reply e–mail within 30 days containing the requested information once we confirm your request.

Not all information sharing is covered by the “Shine the Light” requirements, and only that information which is covered will be included in our response.

AnchorACCESSING YOUR PERSONAL INFORMATION

If you find that your Personal Information is not accurate, complete or up-to-date, please provide us the necessary information to correct it.

At any time, you can contact us at: info@leadspace.com and request to access the personally identifiable information that we keep about you. We will ask you to provide Us certain credentials to make sure that you are who you claim to be and to the extent required under applicable law, will make good-faith efforts to locate the personally identifiable information that you request to access.

If you are eligible for the right of access under applicable law, you can obtain confirmation from Us of whether We are processing personally identifiable information about you, and receive a copy of that data, so that you could –

verify its accuracy and the lawfulness of its processing;

request the correction, amendment or deletion of your Personal Information if it is inaccurate or if you believe that the processing of your Personal Information is in violation of applicable law or the Privacy Shield Principles (please see the EU-US Privacy Shield section in this policy for further information).

We will use judgement and due care to redact from the data which we will make available to you, personally identifiable information related to others.

AnchorDATA RETENTION

We retain your Personal Information for as long as necessary to fulfill the purposes of using the information under this policy or as permitted by law.

We will keep aggregated non-identifiable information without limitation, and to the extent reasonable We will delete or de-identify potentially identifiable information, when we no longer need to process the information.

AnchorTRANSFER OF DATA OUTSIDE YOUR TERRITORY

We may store and process information in various sites throughout the globe, including in sites operated and maintained by cloud-based service providers in the US. If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you provide Us your express and unambiguous consent to such transfer. You can contact our privacy team at: info@leadspace.com for further information about data transfer.

AnchorEU-US PRIVACY SHIELD

We comply with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.

We have certified that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.

If there is any conflict between this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles will govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov. The Federal Trade Commission (FTC) has jurisdiction over our compliance with the EU-US Privacy Shield Framework.

AnchorCOOKIES

Cookies are small files that a web server sends to a user’s device, when the user browses online.

Your device removes session cookies when you close your browser session. Persistent cookies last for longer periods. You can view the expiry date of each cookie, through your browser settings.

We use both types. We use persistent cookies to remember your log-in details and make it easier for you to log-in the next time you access the Service. We use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Service’s features and tools, and to improve the user’s experience with Our Service.

Every browser allows you to manage your cookies preferences. You can block or remove certain cookies, or all of them through your browser settings. Please bear in mind that blocking or removing cookies will influence your user experience with Our Service. For example, disabling or blocking Our cookies will require you to re-enter your log-in details, or even prevent you from using features of the Service.

We also use clear gifs which are tiny graphics with a unique identifier (but do not retain any personally identifiable information), which are used to count user or visitor visits/clicks to web pages while using the Service.

You can find more information about cookies and other online tracking technologies through the US Federal Trade Commission and the EU Commission websites at: https://www.consumer.ftc.gov/articles/0042-online-tracking, or http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm.

If you wish to learn more about the types of cookies that We and our service providers use, and the ways these cookies are used, please contact us at: info@leadspace.com. By visiting our site, third parties (such as Marketo, Google, Intercom and Bombora) may place cookies and other trackers on users’ browsers for analytics, marketing automation, customer relations management, and targeted advertising purposes. These third parties may collect different type of data (such as, IP addresses, cookie identifiers, website activity). Here you can find instructions on how you can opt out of receiving targeted advertising. Every browser allows you to manage your cookies preferences. Please bear in mind that disabling cookies may complicate or even prevent you from using the Service.

AnchorINFORMATION SECURITY

We maintain the confidentiality of your Personal Information and We take reasonable steps to ensure that the Information is accurate, complete, current and reliable for its intended use. We take reasonable measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have put in place appropriate physical, electronic and organizational procedures to safeguard and secure your Personal Information from loss, misuse, unauthorized access or disclosure, alternation or destruction.

These measures provide sound industry standard security. However, although We make efforts to protect your privacy, We cannot guarantee that the Service will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

AnchorDISPUTE RESOLUTION

We do periodical assessments of our data processing and privacy practices, to make sure that We comply with this policy, to update the policy when needed, and to verify that the policy is displayed properly and accessible. If you have any concerns about the way We process your personal information, you are welcome to contact our privacy team at: info@leadspace.com, or write to us at:

Leadspace, Inc.

445 Bush Street, Suite 900

San Francisco, California 94108

1-855-532-3772

We will look into your query and make good-faith efforts to resolve any existing or potential dispute with you.

In compliance with the EU-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information.  European Union individuals with inquiries or complaints regarding this privacy policy should first contact our privacy team. Our privacy team’s contact details are indicated above.

We have further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to the EU Data Protection Authorities. Please contact the EU Data Protection Authorities for more information and to file a complaint, at no charge. You may find the relevant contact details at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Additionally, if you are an EU data subject, you may invoke binding arbitration in certain cases, as further described in Annex I of the EU-U.S. Privacy Shield Agreement. For further information, please visit the Privacy Shield web site at: www.privacyshield.gov, or contact our privacy team.

AnchorCHANGES TO THIS PRIVACY POLICY

From time to time, we may update this policy. If the updates have minor if any consequences, they will take effect 7 days after we post a notice on the Service’s website. Substantial changes will be effective 30 days after Our notice was initially posted.

Until the new policy takes effect, you can choose not to accept it and terminate your use of the Service. Continuing to use the Service after the new policy takes effect means that you agree to the new policy. Note that if We need to adapt the policy to legal requirements, the new policy will become effective immediately or as required.

AnchorAnchorCONTACT US

Please contact our privacy team at: info@leadspace.com for further information.

Last updated: February 3, 2019.

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