EU-US Privacy Shield Information

 

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Privacy Policy | Your Privacy Rights

LeadGnome Inc. (“LeadGnome“) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of (a) our website (“Site”), located at LeadGnome.com and (b) our Services, the LeadGnome application (“App”).

  1. User Consent. By submitting Personal Data through our Site or Services, including the LeadGnome App, you agree to the terms of this Privacy Policy, you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy, and you represent and warrant that you have all rights necessary to submit such Personal Data.
  2. A Note about Children. We do not intentionally gather Personal Data from visitors who are under the age of 13.

  3. A Note to Users Outside of the United States. Your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. We adhere to the European Union / United States Privacy Shield Framework, which can be located at https://www.privacyshield.gov/.
  4. Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

    1. Information You Provide to Us.
      1. We may collect Personal Data from you, such as your first and last name, gender, email and mailing addresses, professional title, company name, username and password when you create an account.
      2. When you order Services on our Site, we (or our third party service provider) will collect all information necessary to complete the transaction, including your name, credit card information, billing information and shipping information.
      3. If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
      4. When you participate in one of our surveys, we may collect additional profile information
      5. We may also collect Personal Data, such as at other points in our Site that state that Personal Data is being collected.
    2. Information Collected via Technology.
      1. To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
      2. We also use cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web site. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Persistent Cookies can be removed by following Internet browser help file directions.
      3. We may collect, and we allow third parties to collect, information about how you use and interact with our Site and Services. For example, we use Google Analytics and HubSpot.
    3. Information Collected via the LeadGnome App. When you use the LeadGnome App, the app will collect End User Contact Data from the emails you forward to the App. “End User Contact Data” means information about your contacts that we collect from your forwarded emails and includes first name, last name, email address, company, job title, website URLs, social network handles, instant messenger handles, physical address (but does not include any information that you provide when you register for any of our Site or Services (collectively, “End User Contact Data”).
    4. Information Collected from Third Parties. We may collect the information about you and other individuals (including those in your End User Contact Data) from the following third party sources: (a) third parties who license, sell or otherwise provide data they have collected; or (b) information from publicly available sources, such as via the Internet and social networks, including through public or licensed APIs (“Public Data”). We do not collect data from webpages that have been designated (in a standards-based way) as private.

    5. How We Combine Data. We will not process your End User Contact Data for purposes of cookie tracking, ad exchanges, ad networks, or sending electronic communications (including email). We may, however, combine your End User Contact Data with Public Data to create more complete data records (“Completed Contact Data”). When we do this, we separate data into two different groups: data elements, such as an actual email address, twitter handle, or facebook username, and data associations, which are the links we make between different data elements to assign multiple data elements to the same person. We do not sell your End User Contact Information or disclose your End User Contact Information to any third party; provided, however that we may use your End User Contact Information to make data associations between data elements (provided the data elements constitute Public Data) and disclose these data elements as Completed Contact Data even if the data association was previously undisclosed. For example, if a person has a twitter handle, an email address and a facebook page, all of which constitute Public Data, and you provide End User Contact Data that includes the data association to tie those three elements of Public Data together, we can disclose that connection. Further, nothing shall restrict our right to use, access, process, collect, disclose, share or distribute any Public Data, even if such Public Data is duplicative of your End User Contact Data.
  5. Use of Your Personal Data
    1. End User Contact Data and Completed Contact Data. We use End User Contact Data and Completed Contact Data as described above.
    2. 2. General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:

      1. facilitate the creation of and secure your account on our network;
      2. identify you as a user in our system;
      3. provide improved administration and quality of experience of our Site and Services;
      4. provide the Services you request;
      5. send you a welcome email to verify ownership of the email address provided when your account was created;
      6. send you administrative email notifications, such as security or support and maintenance advisories;
      7. respond to your inquiries related to employment opportunities or other requests; and
      8. send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of LeadGnome.
    3. Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. LeadGnome reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion.
  6. Disclosure of Your Personal Data. We disclose your Personal Data, End User Contact Data and Completed Contact Data as described below and as described elsewhere in this Privacy Policy.
    1. Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site (e.g., credit card processing); to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to LeadGnome. These third party service providers are required not to use your Personal Data other than to provide the services requested by LeadGnome. LeadGnome requires its service providers to whom it discloses Personal Data to contractually agree to provide at least the same level of protection for Personal Data as is described in this Privacy Policy.
    2. Affiliates and Acquisitions. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company, business, or our assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

    3. Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), LeadGnome may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on LeadGnome; (c) to protect or defend the rights or property of LeadGnome or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or Terms of Use.
    4. Developers. Developers may want access to Personal Data (including End User Contact Data) that we collect from their customers. As a result, we may provide your Personal Data to Developers; however (and in accordance with California’s “Shine the Light” Act codified at Civil Code section 1798.83), we will cease any further disclosure of your Personal Data to Developers for their own direct marketing purposes if you “opt-out” by contacting us as described in Section 13 below. If you wish to discontinue receipt of these emails, please contact the applicable Developer directly to update your preferences. The privacy policies of the Developers may apply to the use and disclosure of your Personal Data that we collect and disclose to such Developers. We contractually require Developers to not, and to require their customers to not, use such data for the purposes of cookie tracking, ad exchanges, ad networks, data brokerages, and sending electronic communications (including email) in violation of applicable law. LeadGnome requires Developers to whom it discloses Personal Data to contractually agree to provide at least the same level of protection for Personal Data as is described in this Policy.

  7. Third Party Websites. When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.
  8. Your Choices Regarding Your Personal Data

    1. Email Choices. We offer you choices regarding the collection, use, and sharing of your Personal Data. If you are a registered user (including a Developer), we will periodically send you free newsletters and emails that promote our Site or Services as well as products or services we think you may be interested in. When you receive such promotional newsletters or communications from us, you may indicate a preference to stop receiving them from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly. Despite your indicated email preferences, we may send you service related communication, including notices of any updates to our Terms of Use or Privacy Policy.
    2. Access, Correction, and Deletion. LeadGnome acknowledges EU individuals right to access their data and allows individuals to view, modify, and set permissions with respect to End User Contact Data that it holds about them. If you choose to connect your LeadGnome account with one of our development partners, you may be giving the partner access to your Personal Data, End User Contact Data or Completed Contact Data. You may receive a copy of your End User Contact Data and make choices about it by emailing LeadGnome support (support@leadgnome.com). If you choose to discontinue sharing your data, any additional data about you that we thereafter collect will be designated as “hide” unless you specify otherwise. If you request that we delete your End User Contact Data, we will not do so because, if we do, another user may later upload your contact information and we will not have a record that you requested that your contact information be deleted. Instead of deleting your contact information, we will retain it and flag it to not be used or shared with third parties.

    3. Additional Choices For California Residents – Your California Privacy Rights (As Provided by California Civil Code section 1798.83). California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses that share customer personal information with third parties for the third parties’ direct marketing purposes to respond to requests from California customers asking about the businesses’ practices related to such information-sharing. Alternately, such businesses may have in place a policy not to disclose a customer’s personal information to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. As described in Section 8.2 above, you can opt-out of our sharing of your personal information with third parties for the third parties’ direct marketing purposes by sending email to support@leadgnome.com. To find out more about your opt-out rights, please contact us at the address listed in Section 13 below. Please note that under California law businesses are only required to respond to a customer making such a request once during any calendar year.

  9. Data Integrity. LeadGnome will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. LeadGnome will take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete, and current. LeadGnome depends on you to update and correct your Personal Data to the extent necessary for the purposes for which it was collected and subsequently authorized by you.
  10. Enforcement. LeadGnome conducts periodic self-assessments to verify that the attestations and assertions it makes about its privacy practices are true and that such privacy practices have been implemented as presented. LeadGnome will take steps to remedy any problems arising out of failure to comply with the Privacy Shield principles.

  11. Disputes.
    1. Generally. LeadGnome takes its users’ privacy concerns seriously. If you believe that LeadGnome has not adhered to this Privacy Policy, please contact LeadGnome as described in Section 13 below. In your email, please describe in as much detail as possible the ways in which you believe that this Privacy Policy has not been complied with. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.
  12. Security of Your Personal Data. LeadGnome is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your account information. Please do not disclose your account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while LeadGnome uses reasonable efforts to protect your Personal Data, LeadGnome cannot guarantee its absolute security.
  13. Contact Information. LeadGnome welcomes your comments or questions regarding this Privacy Policy. Please contact us at this address or email address:

Address: 22 Captain Browns Lane, Acton, MA 01720

Email Address: support@leadgnome.com

  1. Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an email to the last email address you provided to us and/or by prominently posting notice of the changes on our Site. Any changes to this Privacy Policy will be effective upon the earliest of thirty (30) calendar days following our dispatch of an email notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Service. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current email address. In the event that the last email address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Privacy Policy may affect our use of Personal Data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Continued use of our Site or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

 

Addendum: LeadGnome EU Privacy Shield Certification Information

EU-US Privacy Shield Certification

The following information aligns LeadGnome Privacy Statement with the specific points required by the Privacy Shield self-certification process, and ensures LeadGnome’s compliance with the EU-US Privacy Shield Framework.

LeadGnome complies 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. LeadGnome has certified that it adheres 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 the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

In compliance with the EU-US Privacy Shield Principles, LeadGnome commits 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 the dedicated LeadGnome compliance team at:

support@leadgnome.com

LeadGnome has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus.

If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

LeadGnome is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Organization Information:

  • LeadGnome Inc. (a Delaware Company)
  • 22 Captain Browns Lane, Acton, MA 01720

Organization Contact: Valid individual within LeadGnome handling of complaints, access requests, and any other issues concerning LeadGnome’s compliance with the EU-US Privacy Shield Framework.

  • Bruce Greer
  • VP Engineering
  • support@leadgnome.com

Organization Corporate Officer: Certifying LeadGnome compliance with the Privacy Shield Framework:

By submitting this self-certification, the below listed corporate officer attests that he/she is authorized to submit the self-certification on behalf of your organization and all entities or subsidiaries indicated below.

  • Matthew Benati
  • Chief Executive Officer
  • support@leadgnome.com

Types of information covered by LeadGnome Privacy Policy:

Note differences in this policy regarding the term “human resources data”. Human Resources Data refers to personal data about employees, past or present, collected in the context of the employment relationship. Information other than Human Resources data includes the following: customer, client, visitor, and clinical trial data.

  • LeadGnome’s Privacy Policy covers: Personal data other than human resources data

Purposes for which LeadGnome collects and processes personal data in reliance on the Privacy Shield:

  1. General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
    1. facilitate the creation of and secure your account on our network;
    2. identify you as a user in our system;
    3. provide improved administration and quality of experience of our Site and Services;
    4. provide the Services you request;
    5. send you a welcome email to verify ownership of the email address provided when your account was created;
    6. send you administrative email notifications, such as security or support and maintenance advisories;
    7. respond to your inquiries related to employment opportunities or other requests; and
    8. send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of LeadGnome.
  2. Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. LeadGnome reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion.
  3. Disclosure of Your Personal Data. We disclose your Personal Data, End User Contact Data and Completed Contact Data as described below and as described elsewhere in this Privacy Policy. We will provide an individual opt-out choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your personal information, you may submit a written request to support@leadgnome.com.

  1. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, LeadGnome is potentially liable.
    1. Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site (e.g., credit card processing); to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to LeadGnome. These third party service providers are required not to use your Personal Data other than to provide the services requested by LeadGnome. LeadGnome requires its service providers to whom it discloses Personal Data to contractually agree to provide at least the same level of protection for Personal Data as is described in this Policy.
    2. Affiliates and Acquisitions. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy and contractually agree to provide the same level of Personal Data as described in this Policy. If another company acquires our company, business, or our assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

    3. Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), LeadGnome may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on LeadGnome; (c) to protect or defend the rights or property of LeadGnome or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or Terms of Use. LeadGnome may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
    4. Developers may want access to Personal Data (including End User Contact Data) that we collect from their customers. As a result, we may provide your Personal Data to Developers; however (and in accordance with California’s “Shine the Light” Act codified at Civil Code section 1798.83), we will cease any further disclosure of your Personal Data to Developers for their own direct marketing purposes if you “opt-out” by contacting us as described in Section 13 below. If you wish to discontinue receipt of these emails, please contact the applicable Developer directly to update your preferences. The privacy policies of the Developers may apply to the use and disclosure of your Personal Data that we collect and disclose to such Developers. We contractually require Developers to not, and to require their customers to not, use such data for the purposes of cookie tracking, ad exchanges, ad networks, data brokerages, and sending electronic communications (including email) in violation of applicable law. LeadGnome requires Developers to whom it discloses Personal Data to contractually agree to provide at least the same level of protection for Personal Data as is described in this Policy.

User’s RIGHT to access their data:

LeadGnome takes privacy, trust and the management of personal information very seriously. You can manage your publically available contact information by sending a request to support@leadgnome.com. Through this mechanism a user can:

  • Control and promote your single online identity
  • Control the information that others see about you
  • Correct data that is no longer valid
  • Opt out completely and remove the public information that we have for your contact record

Location of LeadGnome’s privacy policy applicable to personal data covered under LeadGnome’s self-certification:

Federal Trade Commission will serve as the statutory body and has jurisdiction to investigate claims against LeadGnome regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy.

Additional Information

  • LeadGnome’s annual revenue as of October 14, 2016 is less than $1 Million
  • LeadGnome’s industry sector is “Technology”
  • LeadGnome currently employs less than 100 people