LAST UPDATED: 10/01/19
Who We Are
Please read this policy carefully prior to providing us with your personal information because by doing so, you, as a visitor or user of our websites (“You”) will be agreeing to our collection, use, disclosure and retention of the information in the ways and for the purposes described in this policy. You are also agreeing to the collection, use, and storage of your personal information in the United States. If You provide us with personal information about someone other than You, or post any image or text You know or suspect to be under copyright, we will understand You to have that person or entities permission or otherwise possess the right to do so. We reserve the right to take appropriate action, including reporting to applicable authorities, to prevent or manage a breach of this policy or of an individual’s privacy.
After reading this policy if You still can’t find the information You are looking for, You can contact our privacy staff at firstname.lastname@example.org.
The Data We Collect
We collect information from our interactions with You through electronic means that include cookies. The types of personal information we collect depends on your request to us. We collect names, email or postal addresses and/or phone numbers to respond to inquiries and for other reasons at various times. We may collect other types of personal information from time to time where it is required to comply with our legal obligations including keeping our accounts and other business records. You can control most of the personal information You make available to us, with the understanding that we may not be able to respond or complete any particular transaction if You decline to provide us with certain personal information.
Cookies – We collect information indirectly through various types of small text files that are stored on your computer called “cookies”. We use different types of cookies for different purposes including to
- monitor our website traffic
- maintain the integrity of your browsing activities on our websites
- improve your experience by doing away with the need to repetitively enter the same information.
- Although You can use certain features of our websites if You choose to disable cookies on your computer, others require cookies to function securely and correctly.
- If you wish to disable your cookies more information can be found at aboutcookies.org.
Session Cookies – Session cookies last only for the duration of your visit and are deleted when you close your browser. They are essential for secure user navigation through a website while enabling the delivery of basic functionality. Specifically they ensure the security and integrity of your session, preventing fraudulent use and keeping you signed in while you move between pages and service your account.
Persistent Cookies – Persistent cookies last after you have closed your browser, and allow us to remember your actions and website preferences. We use persistent cookies to analyse customer visits to our websites. These cookies help us to understand how customers arrive at and use our website so we can improve the overall experience.
Analytics Cookies – We use analytics cookies to help us make our websites even better for those who visit them regularly. This type of cookie helps us to further understand how individual visitors use our on-line services and allows us to improve the overall service and products offered to you. The information we collect through cookies includes the webpages or parts of our website that You have shown a particular interest in, visited multiple times, and/or spent the most amount of time on, as well as information about certain interactions You have had on those pages. This information may or may not identify You depending on your IP address. As an online company, we collect this information to assess which various features of our websites are of actual use and interest to our customers and what parts of our websites we need to improve. If You have an account with one of our websites and you log into one of our websites that requires an account, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser. When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed. If you edit or publish any content on one of our websites, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Interactive Features, Public Spaces, Comments, Other Websites – Our websites may offer You the option of chatting on-line with one of our staff members, posting information on parts of our websites that are open to the public (a discussion forum, bulletin board or blog), or providing us with comments. Use of any of these features is optional and governed by our website terms and conditions of use posted on our websites. Please review the terms and conditions carefully and use caution and discretion when choosing to make information available on the public parts of our website. Under no circumstances should You provide any personal information, including financial information, when using these features. We cannot control the collection or use of information You choose to make available on the public parts of our websites by individuals outside of LeafWindow. We may provide links to websites not operated by LeafWindow and over which we have no control. You use such links entirely at your own risk: LeafWindow will not be liable in any way for the content, availability, or use of third party websites.
Comments – When visitors leave comments on our websites we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for 1 year.
Media – It is recommended that when you upload images to the website, you avoid uploading images with embedded location data (EXIF GPS) included. This location data from images on the website can be extracted by other visitors to the website.
Embedded content from other websites – Our Website may contain content that is supplied by a third party, and it is possible that the mentioned third parties may collect usage information and your device id when pages from the Website are served to you. In addition, when you are on the Website you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple websites and may be sharing the results of that tracking with us and/or others.
If You choose to click on a link, that link may take you off the Website onto a different website. These other websites may associate their tracking technologies with you, independently collect data about you, including personal information, and may or may not have their own published privacy policies. Third-party applications may also be available via the Website. The owners of these applications may collect personal information and other data from you and may have their own policies and practices. We are not responsible for how third-party providers or their applications collect or use your information and they may be tracking you across multiple websites and may be sharing the results of that tracking with us and/or others. These third-party owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications.
How We Use Your Information
- To improve our websites and your experience using LeafWindow.com.
- To contact you regarding events, information, products or services which may be of interest to you, if you have given us permission to do so or you have previously requested information on events, information, products or services from us and the communication is relevant or related to that prior request and made within any timeframes established by applicable laws.
- To provide you information on events, information, products or services that you request from us.
- To combat Fraud and Abuse Prevention and Credit Risks. We use your personal information to prevent and detect fraud and abuse in order to protect the security of our customers, LeafWindow, and others.
Who Sees Your Personal Information
Third party partners such as marketing firms, distribution partners and select partners. For clarity, by using our Website, You are agreeing that in certain circumstances we may need to disclose your personal information to third parties in order to detect or prevent fraud or other breaches of the law and You hereby agree that this serves as your notice of such disclosure. For users that register on our websites, we store the personal information they provide in their user profile. All users can see and edit their personal information at any time (although some information cannot be changed, e.g. usernames). Our website administrators can also see and edit that information.
How long we retain personal information – We will only retain your personal information for as long as necessary to fulfil our business purposes but not longer than 7 years. As noted earlier, we store personal information in the United States.
How We Secure Your Information – We use commercially reasonable security measures to protect personal information we collect that comply with applicable law, however by no means are totally secure. No data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that You use our Service and provide us with your information at your own risk. At LeafWindow, security is always our highest priority. We do our utmost to make sure all our systems are as secure as possible.
- We follow industry standards on information security management to safeguard sensitive information, such as financial information, intellectual property, employee details and any other personal information entrusted to us.
- Our information security systems apply to people, processes and information technology systems on a risk management basis.
- No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your personal information.
Disclosure Of Your Personal Information
We may have to share your personal information for the purposes set out below. We require third parties to respect the security of your personal information and to treat it in accordance with applicable law.
External Third Parties – We may use third-party vendors to perform certain services on behalf of LeafWindow, such as recruitment services, hosting our website, designing and/or operating website features, tracking website activities and analytics, or performing other administrative services. We may provide these vendors with access to user information, including device identifiers and personal information, to carry out the services they are performing for You or for us. Third-party analytics and other service providers may set and access their own tracking technologies on your device and they may otherwise collect or have access to information, including the potential to have personal information about You. We may share your information with external third parties when we are required to do so by applicable law.
Affiliated Parties – We may share your information with our affiliates.
Legal Process – Subject to applicable law, we may disclose information about You
- If we are required to do so by applicable law or legal process, such as a subpoena
- In response to requests by government entities, such as law enforcement authorities
- When we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss
- In connection with an investigation of suspected or actual unlawful activity
Access and Correction – Under most circumstances you can obtain access to your personal information in our records and information about how we have used and disclosed the information. If You believe there is an error or omission in your personal information, You can ask us to correct it. Requests for access or correction must be made in an email and sent to email@example.com with the subject line of “Subject Access Request”. If we do not feel able to make a correction, we will make a note in the record that the correction was requested but not made. Please note that we are not able to remove information we are required to keep for administrative, legal, or security purposes.
Privacy Staff Contact – You can contact our privacy staff at: firstname.lastname@example.org
Children Accessing Our Websites – Our websites provide no content that is directed towards children and we do not provide services to children, or knowingly collect or solicit personal information from children under 13 years of age.
Your California Privacy Rights – California Civil Code Section 1798.83, also known as California’s “Shine the Light” law, gives California residents the right, once per calendar year, to request disclosure of what kind of personal information has been collected about them and then shared with other third parties for the third party’s direct marketing use, as well as the names and addresses of those third parties with which the information has been shared.
- We do not share information collected by us about You with third parties for those third parties’ direct marketing purposes.
- We do not track our users and visitors over time and across third party websites to provide targeted advertising.
- Consequently, we do not respond to Do Not Track (DNT) signals.
- Other third party websites may keep track of your browsing activities when they provide You with content.
- Any questions can be directed towards email@example.com
EU Privacy Rights – What are your rights and how can you exercise them? – You have specific rights as a ‘data subject’ under Chapter III (Articles 14-25) of Regulation (EU) 2018/1725, in particular the right to access, rectify or erase your personal data and the right to restrict the processing of your personal data. Where applicable, you also have the right to object to the processing or the right to data portability.
You can exercise your rights by contacting the Data Controller, or in case of conflict the Data Protection Officer. If necessary, you can also address the European Data Protection Supervisor (see the Contact information below).
Where you wish to exercise your rights in the context of one or several specific processing operations, please provide their description (i.e. their Record reference as specified under “Where to find more detailed information?” below).
Contact information: The Data Controller – If you would like to exercise your rights under Regulation (EU) 2018/1725, or if you have any comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, please feel free to contact the Data Controller, Directorate-General Communication, unit “Interinstitutional Relations, Corporate Contracts & EDCC”.
The Data Protection Officer (DPO) of the Commission – You may contact the Data Protection Officer with regard to issues related to the processing of your personal data under Regulation (EU) 2018/1725.
The European Data Protection Supervisor (EDPS) – You have the right to have recourse (i.e. you can lodge a complaint) to the European Data Protection Supervisor if you consider that your rights under Regulation (EU) 2018/1725 have been infringed as a result of the processing of your personal data by the Data Controller.
Where to find more detailed information? – The Commission Data Protection Officer (DPO) publishes the register of all processing operations on personal data by the Commission, which have been documented and notified to him. You may access the register via the following link http://ec.europa.eu/dpo-register.
This specific processing operation has been included in the DPO’s public register with the following Record reference: DPR-EC-00080.