Last update: December 02, 2022

This privacy policy has been compiled to better serve the users of our software and services who are concerned with how their personal information is being used online. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle Your Personal Data (hereinafter – the “Personal Data” or “Data”).

This Privacy Policy forms an integral part of the End User License Agreement (EULA) for LeverX mobile application “GoDog” (hereinafter – the “Application”) which is made between the user (hereinafter – the “User” or “You”) and LeverX Poland LLC (hereinafter – “LeverX” or “we”).

By downloading the Application from the Apple AppStore you give us You consent to collect and process Your Personal Data on the terms as specified in this Privacy Policy.

We, LeverX Poland LLC, are the data controller responsible for Your information when You use our Application (hereinafter – Services / Application).

What Data, For What Purposes, Based On What Grounds, We Collect It?

We act as the controller of Your Personal Data, as we independently decide for what purposes we need them and choose services and tools for their processing.

We minimize the collection of Your Personal Data to the least amount required to use our Services.

Legal ground
Your Personal Data
To provide the full functionality of the Application to You
Purpose
Contract
Name, surname, email address, username, avatar, Facebook account details (if you sign in via Your Facebook account), camera permission, push-notification permission, Your social media accounts permission and access to device storage permission, Your dog data (nickname, age, breed, gender, photo).
to contact You with the information regarding our company, applications, services, and courses
Legitimate interest to develop our business and satisfy User’ needs as we appreciate You
Name, surname, e-mail address, information of the services You were interested.
To manage and optimize Your customer experience by improving our knowledge of our customer
Legitimate interest to improve the quality of our services
Name, surname, e-mail address, date and time You logged in, time spent on our Application, information system, device, location (such as city and country), features You've been using, advertising that You click on.
To adapt our Application environment to Your / other User’ needs
Legitimate interest to improve the quality of our services
Date and time, You logged in, time spent on our Application, information system, device, location (such as city and country), features You've been using, advertising that You click on.
To help spam detection
Legitimate interest to properly defend ourselves, be able to personalise and optimise our offers and Application for their improvement
Date and time, You logged in, time spent on our Application, information system, device, location (such as city and country), features You've been using, advertising that You click on.

The Data concerning the User is collected in order to realize the following functionalities of the Application and our services: User registration and authentication, analytics, social features, access to third party accounts, Content commenting, Content performance and features testing, interaction with external social networks and platforms, advertising, device permissions for Personal Data access, infrastructure monitoring, location-based interactions and Managing contacts and sending messages.

You have choices about the data we collect. When You are asked to provide personal data, You may decline. Some of the Data may be collected automatically, for example the Application usage data.  In cases where the Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Application.

You also entitled to have the LeverX erase Your Personal Data, cease further dissemination of the data and potentially have third parties halt processing of the data. The withdrawal of consent do not affect the lawfulness of processing based on consent before its withdrawal. However, if You choose not to provide data that is necessary to provide a service or feature or to withdraw the data that is still relevant to original purposes of processing, You may not be able to use that service or feature.  

The data we collect depends on the context of Your interactions with LeverX, the choices You make, including Your privacy settings, and the service and features You use.

If You are uncertain about which Personal Data is mandatory and whether the Data is collected or not You are welcome to contact LeverX.

You are responsible for any third-party Personal Data obtained, published or shared through the Application and confirm that they have the third party's consent to provide the Data to LeverX.

Do we use 'cookies'?

No. We do not use cookies in our Application.

When do we collect and how we process Your Data?

We collect the Data from You when You install and use the Application.

We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to us, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by LeverX. The updated list of these parties may be requested from us at any time.

According to our principles of the Data processing all data is:

• Fairly and lawfully processed;

• Processed for a lawful specified purpose;

• Adequate, relevant and not excessive;

• Not kept for longer than necessary;

• Accurate;

• Processed in accordance with the individual’s (data subject’s) rights;

• Secure;

• Not transferred to other countries without adequate protection.

What specific permissions do You provide to us?

Facebook permission. The Application ask You for some Facebook permissions allowing it to perform actions with the Your Facebook account and to retrieve information. Upon Your consent the Application will get an access to the User's primary email address.

Approximate location permission (continuous and non-continuous), Precise location permission (non-continuous). Subject to Your consent the Application will access and collect Your device Data including Your location (including precise location) in order to provide location-based services in the Application.

Calendar permission. The Application access the calendar on Your device, including the reading, adding and removing of entries.

Camera permission. The Application may access the camera on Your device and capture images and video from the device.

SMS permission. The Application access features related to the User's messaging including the sending, receiving and reading of SMS.

Device permission. It enables access to the unique identifier of Your device where the Application is installed. The Application would also collect the Application usage data from Your device.

Messaging permission. The Application contains chat functionality which enables Users to communicate to each other. This permission grant us the right to access such chats for storage of the users messages only.

Social media accounts permission. Used for accessing the User's social media account profiles, such as Facebook and Twitter.

Storage permission. Used for accessing shared external storage, including the reading and adding of any items.

Which Technologies We Use To Collect Your Data?

Data Analytics. The following providers collect Data over our Services. You may be able to opt out of Your usage data being tracked. Our providers may change, but we will try to update this list as that happens:

Mixpanel

Mixpanel provides analytics services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

Amplitude

Amplitude provides analytics services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

Firebase

Firebase provides hosting services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

Apple Store Connect

Apple Store Connect provides analytics services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

Apphud

Apphud provides service for integrations with external services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

AppsFlyer

AppsFlyer provides analytics services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

Facebook SDK

Facebook SDK provides analytics services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

What Rights Do You Have As A Data Subject?

All users who are the subject of Personal Data held by us are entitled to:

• ask what information we hold about them and why;

This means that You can ask us what personal data of Yours is processed. You can also ask for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties which have access to information. You have a right to request from us Your personal data in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another controller, if the processing is based on Your consent or on contract and the processing is carried out by automated means;

ask how to gain access to it;

• be informed how to keep it up to date;

• have inaccurate personal data corrected or removed;

This means You can require all the inaccurate personal data concerning You being corrected. You can also complete the personal data if You feel there is a need to do so;

prevent us from processing information or request that it is stopped if the processing of such data is likely to cause substantial, unwarranted damage or distress to the individual or anyone else, etc.;

In some cases, prescribed by the applicable laws You can object to processing of Your personal data.

You have a right to object to processing of Your personal data when the processing is related to the performance of our task carried in the public interest or in the exercise of official authority vested in us; or we process Your data to pursue our or third party’s legitimate interests, and You believe that such interests are overridden by Your interests or fundamental rights and freedoms. 

If You make a request objecting to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing. 

Please note that when processing of Your personal data is carried for direct marketing purposes, You have the right to object at any time to such processing without providing any justification. We will no longer process Your data for such direct marketing purposes. You may refer to relevant sections of this Privacy Policy to learn whether we process Your data for direct marketing purposes;

require us to ensure that no decision which significantly affects an individual is solely based on an automated process for the purposes of evaluating matters relating to him/her, such as conduct or performance;

• be informed what we are doing to comply with our obligations under the applicable data protection laws.

Subject to the personal data protection regulations applicable to You, You may request us to erase Your Personal Data without undue delay. The request shall be made on the legal grounds provided in the information protection regulations applicable to You, which include among other:

• the personal information is no longer necessary in relation to the purposes for which they were collected or otherwise processed;

• You withdraw Your consent on which the processing is based according to the provisions of the applicable to You information protection regulations and where there is no other legal ground for the processing;

• You object to the processing pursuant to the applicable information protection regulations and there are no overriding legitimate grounds for the processing, or the information subject objects to the processing;

• the personal information has been unlawfully processed;

• the personal information has to be erased for compliance with a legal obligation in the USA, European Union or the law to which we are subject.

You may also ask us to receive Your Data and have it transferred to another Data controller. In this case You have the right to receive Your Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

If You cannot access certain information and personal data collected by LeverX, You can always contact LeverX by using our contact form. We will respond to requests to access or delete Your personal data within 30 days.

How To Exercise Your Rights As To Your Personal Data?

Any requests to exercise Your rights can be directed to us through the contact details provided below. 

Do we provide Personal Data to the third parties?

We do not sell, trade, or otherwise transfer to outside parties Personal Data unless otherwise is provided in this Privacy Policy. This does not include hosting partners and other parties who assist us in operating our Application, website, conducting our business, or serving our Users, so long as those parties agree to keep this information confidential. We may also release information when its release is appropriate to comply with the law, enforce our Application policies, or protect ours or others' rights, property, or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

We may disclose personal information that we collect or You provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • For any other purpose disclosed by us when You provide the information.
  • With Your consent.

We may also disclose Your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our clients, our customers, or others.

How do we protect Your information?

Your Personal Data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. We use different organizational and technological measures to protect Your personal information including data encryption in transfer and on the servers. All sensitive information You supply to us is encrypted.

All LeverX members, all our staff and third parties whenever we hire them to provide support services, are required to observe our privacy standards and to allow us to audit them for compliance.

Where Personal Data is stores and processed

Personal data collected by LeverX may be stored and processed in Your region or in any other country where LeverX or its affiliates, subsidiaries or service providers maintain facilities. Typically, the primary storage location is in the Google servers according to the Google data storage policies, with a backup to the data centers as specified by Google. The storage provider is chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located.

When we transfer Personal Data from the locations as specified above to other countries, we use a variety of legal mechanisms, including contracts, to help ensure Your rights and protections travel with Your data.

How Long Do We Keep Personal Data?

LeverX retains personal data for as long as necessary to provide the services, 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 products, actual retention periods can vary significantly. The criteria used to determine the retention periods include, for instance:

  • The period of data processing needed to provide the services. This includes such things as maintaining and improving the performance of those services, keeping our systems secure, and maintaining appropriate business and financial records. This is the general rule that establishes the baseline for most data retention periods.
  • The data subject's consent for a longer retention period. If so, we will retain data in accordance with the consent.
  • LeverX is subject to a legal, contractual, or similar obligation to retain the data. Mandatory data retention laws can be applied in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users' Personal Data, we will notify You by email and through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for You, and for periodically visiting our Website and this Privacy Policy to check for any changes.

How Can You Contact Us And/Or Complaint?

All questions and complaints regarding this Privacy Policy, processing Your Personal Data may be lodged using the contact details below.

LeverX Poland LLC

Address: Wołodyjowskiego 67A, 02-724 Warsaw, Poland.

Email compliance@leverx.com

Unless otherwise stated, LeverX Poland LLC is a data controller for personal data we collect through the Services subject to this statement.  

What specific permissions do You provide to us?

Facebook permission. The Application ask You for some Facebook permissions allowing it to perform actions with the Your Facebook account and to retrieve information. Upon Your consent the Application will get an access to the User's primary email address.

Approximate location permission (continuous and non-continuous), Precise location permission (non-continuous). Subject to Your consent the Application will access and collect Your device Data including Your location (including precise location) in order to provide location-based services in the Application.

Calendar permission. The Application access the calendar on Your device, including the reading, adding and removing of entries.

Camera permission. The Application may access the camera on Your device and capture images and video from the device.

SMS permission. The Application access features related to the User's messaging including the sending, receiving and reading of SMS.

Device permission. It enables access to the unique identifier of Your device where the Application is installed. The Application would also collect the Application usage data from Your device.

Messaging permission. The Application contains chat functionality which enables Users to communicate to each other. This permission grant us the right to access such chats for storage of the users messages only.

Social media accounts permission. Used for accessing the User's social media account profiles, such as Facebook and Twitter.

Storage permission. Used for accessing shared external storage, including the reading and adding of any items.

Which Technologies We Use To Collect Your Data?

Data Analytics. The following providers collect Data over our Services. You may be able to opt out of Your usage data being tracked. Our providers may change, but we will try to update this list as that happens:

Mixpanel

Mixpanel provides analytics services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

Amplitude

Amplitude provides analytics services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

Firebase

Firebase provides hosting services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

Apple Store Connect

Apple Store Connect provides analytics services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

Apphud

Apphud provides service for integrations with external services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

AppsFlyer

AppsFlyer provides analytics services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

Facebook SDK

Facebook SDK provides analytics services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

Do We Use “Cookies”?

We and our service providers use cookies and other technologies to receive and store certain types of information whenever You interact with our Services through Your computer or mobile device. 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 site to recognize Your browser. Cookies may store unique identifiers, user preferences and other information. You can reset Your browser to refuse all cookies or to indicate when a cookie is being sent.

However, some website features or services may not function properly without cookies. Some of our third party may use web beacons – small files used for tracking purposes.

There are four categories of cookies and web beacons used by the websites. Specifically, we use essential, performance, functionality and advertising cookies.

Essential cookies and other tracking technologies are necessary for the operation of the Services. These tracking technologies enable You to move around on the Services and use the Services features. You may not opt-out of these types of cookies because they are required to operate the Services.

Performance cookies and other tracking technologies collect information about how You have used the Services. We use performance cookies and other tracking technologies to improve the user experience with our Services. 

Functionality cookies and other tracking technologies allow us to remember how You are logged into our Services, when You logged in or out and the actions You have taken while You have been logged into the Services.

Advertising cookies and other tracking technologies are used by our third-party service providers to deliver advertising to You on other third-party websites as well as help measure the effectiveness of our advertising campaigns. We also use these types of cookies to analyze Services’ visits and ad conversions from third-party websites. 

The table below lists the types of cookies and third party service providers currently used by us but may not include all cookies or third party service providers. We do not control these third parties' tracking technologies or how they may be used. If You have any questions about an advertisement or other targeted content, You should contact the responsible provider directly. In addition, the below list of cookies and third party service providers is subject to change at any time. 

You can learn more about online advertising cookies and Your ability to opt-out of certain online advertising cookies by visiting the following websites: http://www.aboutads.info/choices or http://www.networkadvertising.org/choices. All mobile and web browser settings are slightly different, so to manage cookies, You should refer to the relevant settings within Your device or browser.

For Your mobile device, You can understand which third parties have currently enabled cookies on Your mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative's website at: http://www.networkadvertising.org/mobile-choices from Your mobile device. On Your mobile device You may also select “Limit Ad Tracking” (on iOS devices) or “Opt out of Interest-Based Ads” (on Android).

For detailed information on how to disable and delete cookies in some commonly used web browsers, please visit:

Mozilla Firefox – https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored

Microsoft Internet Explorer – https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11

Google Chrome – https://support.google.com/accounts/answer/61416?hl=en

Safari – https://support.apple.com/kb/PH21411?viewlocale=en_US&locale=en_US

Even if You disable cookies and tracking, keep in mind that You may still receive interest-based advertising, including from third parties with whom Your information had been previously disclosed and that You may still receive advertising from third parties, though such advertising may not be based on Your interests and preferences. 

What Rights Do You Have As A Data Subject?

All users who are the subject of Personal Data held by us are entitled to:

• ask what information we hold about them and why;

This means that You can ask us what personal data of Yours is processed. You can also ask for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties which have access to information. You have a right to request from us Your personal data in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another controller, if the processing is based on Your consent or on contract and the processing is carried out by automated means;

ask how to gain access to it;

• be informed how to keep it up to date;

• have inaccurate personal data corrected or removed;

This means You can require all the inaccurate personal data concerning You being corrected. You can also complete the personal data if You feel there is a need to do so;

prevent us from processing information or request that it is stopped if the processing of such data is likely to cause substantial, unwarranted damage or distress to the individual or anyone else, etc.;

In some cases, prescribed by the applicable laws You can object to processing of Your personal data.

You have a right to object to processing of Your personal data when the processing is related to the performance of our task carried in the public interest or in the exercise of official authority vested in us; or we process Your data to pursue our or third party’s legitimate interests, and You believe that such interests are overridden by Your interests or fundamental rights and freedoms. 

If You make a request objecting to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing. 

Please note that when processing of Your personal data is carried for direct marketing purposes, You have the right to object at any time to such processing without providing any justification. We will no longer process Your data for such direct marketing purposes. You may refer to relevant sections of this Privacy Policy to learn whether we process Your data for direct marketing purposes;

require us to ensure that no decision which significantly affects an individual is solely based on an automated process for the purposes of evaluating matters relating to him/her, such as conduct or performance;

• be informed what we are doing to comply with our obligations under the applicable data protection laws.

Subject to the personal data protection regulations applicable to You, You may request us to erase Your Personal Data without undue delay. The request shall be made on the legal grounds provided in the information protection regulations applicable to You, which include among other:

• the personal information is no longer necessary in relation to the purposes for which they were collected or otherwise processed;

• You withdraw Your consent on which the processing is based according to the provisions of the applicable to You information protection regulations and where there is no other legal ground for the processing;

• You object to the processing pursuant to the applicable information protection regulations and there are no overriding legitimate grounds for the processing, or the information subject objects to the processing;

• the personal information has been unlawfully processed;

• the personal information has to be erased for compliance with a legal obligation in the USA, European Union or the law to which we are subject.

You may also ask us to receive Your Data and have it transferred to another Data controller. In this case You have the right to receive Your Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

If You cannot access certain information and personal data collected by LeverX, You can always contact LeverX by using our contact form. We will respond to requests to access or delete Your personal data within 30 days.

How To Exercise Your Rights As To Your Personal Data?

Any requests to exercise Your rights can be directed to us through the contact details provided below. 

Do we provide / disclose Your Data to the third parties?

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or You provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • For any other purpose disclosed by us when You provide the information.
  • With Your consent.

We may also disclose Your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our clients, our customers, or others.

When processing Your order, we need to share the information you provided when placing the order with the payment service provider responsible for the processing of Your payment, in order to fulfil your order.

Your Personal Data will only be shared to the extent required to process your payment.

The legal basis for the processing and transfer of Personal Data in such a case is Art. 6 (1) (b) GDPR, as the processing and transfer of this data serve the purpose of fulfilling contractual relationships.

Service provider responsible for the processing of Your payment is Stripe Inc., 354 Oyster Point Blvd South San Francisco, CA 94080 United States, (hereinafter referred to as „Stripe“).

All payments are processed in accordance with Stripe’s privacy policy. Stripe’s privacy policy can be found at https://stripe.com/privacy.

In no case, and in no phase of the payment are we able to access or save any information or data about the transaction or the credit card used for the payment.

How Do We Protect Your Personal Data?

The security of Your Personal Data is important to us. We follow generally accepted standards to protect the Personal Data submitted to us, both during transmission and after it is received. We process Your Data using computers and/or other IT enabled tools. We take technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. We also guide and train our personnel to process Your data securely according to our internal data protection policies. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures. We may suspend Your use of all or part of the services without notice if we suspect or detect any breach of security. If You believe that Your account or information is no longer secure, please notify us immediately at compliance@leverx.com

How Long Do We Keep Personal Data?

We retain Personal Data according to the type of information in question and the purpose for which it is used. We delete Personal Data within a reasonable period after we no longer need to use it for the purpose for which it was collected. We may archive Personal Data (for example, by storing it in inactive files) for a certain period prior to its final deletion, as part of our ordinary business continuity procedures or as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types, actual retention periods can vary significantly. The criteria used to determine the retention periods include, for instance:

• The period of data processing needed to provide Services. This includes such things as maintaining and improving Services, keeping our systems secure, and maintaining appropriate business and financial records. This is the general rule that establishes the baseline for most data retention periods.

• The data subject's consent for a longer retention period. If so, we will retain data in accordance with the consent.

• We are subject to a legal, contractual, or similar obligation to retain the data. Mandatory data retention laws can be applied in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

California Privacy Rights

This section applies only to California consumers. It describes how we collect, use, and share California consumers' Personal Data in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act (“CCPA”) requires businesses to disclose whether they sell Personal Data. We are a business, and do not sell Personal Data. We may share Personal Data with third parties if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Data.

If You are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply You with the information You need in an alternative format that You can access.

For purposes of this section “Personal Data” has the meaning of “Personal Information” given in the California Consumer Privacy Act (“CCPA”).

How We Collect, Use, and Share Your Personal Data?

We collect the following statutory categories of Personal Data:

Identifiers, such as name, business e-mail address, during virtual meetings with You – Your video-image or photo and your voice. We collect this information directly from You or from third party sources.

Internet or network information, such as browsing and search history. We (or our Service Providers) collect this information directly from Your device.

Geolocation data, such as IP address (if applicable). We (or our Service Providers) collect this information from Your device.

Other personal information, in instances when You interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys; or in providing the Services.

The business and commercial purposes for which we collect this information are described in Section “What Data, For What Purposes, Based On What Grounds, We Collect It?” of this Privacy Policy. The categories of third parties to whom we "disclose" this information for a business purpose are described in Section Do we provide / disclose Your Data to the third parties?” of this Privacy Policy.

Your California Rights

You have certain rights regarding the Personal Data we collect or maintain about You. Please note these rights are not absolute, and there may be cases when we decline Your request as permitted by law.

The right of access means that You have the right to request that we disclose what Personal Data we have collected, used and disclosed about You in the past 12 months.

The right of deletion means that You have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.

The right to non-discrimination means that You will not receive any discriminatory treatment when You exercise one of Your privacy rights.

How to Exercise Your California Rights

You can exercise Your rights Yourself or You can alternatively designate an authorized agent to exercise these rights on Your behalf. Please note that to protect Your Personal Data, we will verify Your identity by a method appropriate to the type of request You are making. We may also request that Your authorized agent have written permission from You to make requests on Your behalf, and we may also need to verify Your authorized agent's identity to protect Your Personal Data. Please see our contact information below.

Changes to Our Privacy Policy

From time to time, we may update this Privacy Policy. In the event we materially change this Privacy Policy, the revised Privacy Policy will promptly be posted to the Application and our websites, if applicable. You agree to accept posting of a revised Privacy Policy electronically on our website as actual notice to You. Any dispute over our Privacy Policy is subject to this notice, our EULA. We encourage You to periodically check back and review this policy so that You will always know what information we collect, how we use it, and to whom we disclose it. If You have any questions that this statement does not address, please contact us via our contact form.

How can You contact us and/or complaint?

All questions and complaints regarding this privacy policy, processing Your Personal Data may be lodged using the contact details below.

LeverX Poland LLC

Address: Wołodyjowskiego 67A, 02-724 Warsaw, Poland

Email compliance@leverx.com

Unless otherwise stated, LeverX Poland LLC is a data controller for personal data we collect through the services subject to this statement.