Categories of personal data
Leapter Company may process your following categories of personal data:
- Identification data: first name/names, surname, position (including information on any political position/s), business name, IP address.
- Contact information: registered address, telephone number, e-mail address, correspondence address.
- Data related to your habits and preferences: data that relate to your interest in and use of our products and services in relation to financial and transactional data.
- Data from your interactions with us: data collected through our websites, apps, and social media pages, meetings, calls, chats, emails, and interviews (“Personal Data”).
Purposes and legal grounds for personal data processing
Personal data may be processed by Leapter Company for the following purposes:
- For the execution of contracts;
- For the communication and implementation of measures taken before the conclusion of the contract;
- To record transactions arising from the contracts and inquiries;
- To analyse customer preferences for the purpose of establishing marketing activities, in which you may be interested, and for conducting marketing activities regarding services provided by Leapter Company, especially for advertising products or services that match your needs;
- To accept, review and respond to your complaints regarding Leapter Company’s activities;
- To perform the obligations imposed on the controller by the provisions of the generally applicable law;
- To share your personal data within Leapter Company for internal administrative purposes in accordance with the principle of necessary knowledge, which will allow us to respond appropriately to your requirements and avoid unnecessary administrative duplications.
Your Personal Data will be processed on the basis of Article 6, para. 1, item a), item b), item c) and/or f) GDPR. For their legitimate interests within the meaning of Article 6, para. 1, item f) GDPR, we consider direct marketing and the necessary sharing of Personal Data within the Leapter Company group. We will not process Personal Data for other purposes that are inconsistent with the objectives described above, unless the processing is required by law, or unless Leapter Company is authorised by you to process it.
Sharing personal data
Leapter Company may provide Personal Data to the following third parties for the purposes specified in this document and below:
- (a)Entities and authorities, to which we are obliged or authorised to provide Personal Data in order to pursue the objectives specified above and for fulfilling the obligations imposed by law;
- (b) Companies or persons with whom Leapter Company has concluded cooperation agreements on entrusting the performance of certain activities for Leapter Company (“Data Processor”), including entities with which Leapter Company has contracted for the destruction of data. Such entities will be obliged by the agreements they have concluded with Leapter Company to apply the appropriate security, as well as technical and organisational measures to protect the Personal Data and to process it exclusively in accordance with the instructions provided by Leapter Company;
- (c) Leapter Company’s subsidiaries and affiliates.
Provision of personal data to third countries
Personal Data will not be provided to any third country outside the European Economic Area (“EEA“).
Period of personal data storage
Personal Data will be stored by Leapter Company and/or the Processors for the period for which this is necessary for the purposes referred to in clause 3 of this documentation, for the purposes required in accordance with the provisions of the generally applicable law and for the purpose of defending Leapter Company’s rights. The Personal Data storage period for specific purposes is listed below:
- When fulfilling contracts, the storage period will be 10 years from the termination of the contract.
- In the case of the communication and implementation of measures taken before the conclusion of the contract, the storage period will be completed by concluding the contract or, if the contract is not finally concluded, two years from the end of the communication or measures.
- For the registration of transactions arising from contracts and inquiries, the deposit period will be 10 years from the conclusion of the contract, or from the execution of the inquiry.
- For marketing activities in connection with the services provided by Leapter Company, especially for the offer of products or services that meet your needs, the storage period will be three years from the termination of the legal relationship, on the basis of which we perform the marketing activities.
- For the receipt and review of your complaints regarding Leapter Company’s activities and response to them, the storage period will be 10 years from the receipt of the complaint.
- In fulfilling the obligations imposed on data controllers by generally applicable legislation, the storage period will be in accordance with that legislation.
- When sharing your Personal Data within Leapter Company for internal administrative purposes in accordance with the principle of necessary knowledge, which will allow us to respond appropriately to your requirements and avoid unnecessary overlapping activities, the storage period will depend on the primary purpose for which the personal data is processed.
Rights of data subjects
Depending on the objective and the grounds on which we process your data, you may be entitled to the following rights regarding Personal Data protection:
- (a) Right to access your Personal Data: the data subject is authorised to obtain confirmation from Leapter Company as to whether that person’s personal data is being processed and, if so, they are authorised to obtain access to it. Leapter Company will provide you with a copy of the Personal Data that is being processed, at your request. Leapter Company may collect a charge, of a reasonable amount, arising from the administrative costs for all further copies you request.
- (b) Right to rectify your Personal Data: you are entitled to correct the Personal Data that applies to you and that is incorrect. Subject to the objectives of the processing, you are 3/3 entitled to request that incomplete Personal Data is supplemented, including by presenting an additional declaration.
- (c) Right to erasure your Personal Data (“right to be forgotten”): you are entitled to demand the deletion of your Personal Data if the circumstances provided for by law take place and Leapter Company is required to delete such Personal Data without delay.
- (d) Right to restrict the processing of your Personal Data: in such a case, Leapter Company will, at your request, specify that Data and it may only be processed for specified purposes.
- (e) Right to data portability: under certain circumstances, you are entitled to receive your Personal Data in a structured, commonly-used machine-readable format, which has been provided to Leapter Company and you are entitled to send this Personal Data to another entity without obstruction by Leapter Company.
- (f) Right to object to the further processing of your Personal Data: in certain circumstances, you are entitled to file an objection to the processing of your Personal Data for reasons related to your particular situation and Leapter Company may be required to stop processing such Personal Data.
- (g) The right to file a complaint with the appropriate supervisory authority, if the data processing breaches the provisions of the GDPR.
- (h) The right to withdraw consent: if certain processing is based on your consent, you havethe right to withdraw that consent at any time, in the same way as it was given or via the email address of our data protection officer, referred to in point 10 of this documentation.
Sources of Personal Data
Your Personal Data may come from: i) you or your statutory representative or principal (in the case of a power of attorney that has been provided to us); ii) an entrepreneur, with respect to which you are the representative or beneficial owner; iii) a party to an agreement concluded with Leapter Company; and/or iv) from generally accessible sources; in particular, from various databases and registers.
Requirement to Provide Data
At Leapter Company, we need your Personal Data to provide you with services or to comply with Leapter Company regarding the obligations referred to in point 3 of this documentation.
Miscellaneous Provisions
We would like to inform you that Leapter Company may periodically update this documentation in accordance with the applicable law (e.g., if we implement new systems or processes, which are related to the use of Personal Data) and, in such a case, we will inform you accordingly of the changes that have been made. Should you have any questions regarding Personal Data or exercising your rights to privacy, please contact our data protection officer, via this e-mail address: info@leapter.com
