Privacy Policy

BACKGROUND:

Leadup DXP understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of Leadup DXP website users and partners and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

Leadup DXP is a Luxemburgish corporation with its offices at 80, route de Luxembourg,
L-3360 Leudelange, Luxembourg.

Email address: privacy@leadup-dxp.com

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. That definition englobes personal information as defined by various data protection legislation in Canada (PIPEDA) and the United States.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4.  What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
2. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
8. Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including automated decision-making and/or profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can generally also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau, or a similar service provider.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

5.  What Personal Data Do We Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us:

• Name;
• Date of birth;
• Gender;
• Address;
• Email address;
• Telephone number;
• Business name;
• Job title;
• Profession;
• Payment information;
• Information about your preferences and interests;

6.  How Do We Use Your Personal Data?

In accordance with the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

• Providing and managing your account.
• Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
• Personalizing and tailoring services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by clicking here.
• With your permission and/or where permitted by law, We may also use your personal data for marketing purposes, which may include contacting you by email, telephone or text message and with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity toopt-out.

7.  Information Collected Through Tracking

The information that Leadup DXP collects is used in the aggregate to obtain demographic information about the entire Leadup DXP  audience in order to improve service to its customers and merchants, to perform statistical analysis of the collective characteristics and behavior of its users. From this information, Leadup DXP  can measure overall patron demographics and interests regarding specific areas of the Leadup DXP  domain and to analyze how and where to apply its resources. Leadup DXP also uses the collected aggregate data to inform its sponsors of the number of visitors who have seen and “clicked” on their advertisements.

8.  How Long Will We Keep My Personal Data?

We do not process your personal data for a longer period of time than necessary. If you do not use or purchase service(s) and/or products for twenty-four months, we will stop processing and erase your personal data, unless applicable law authorizes or requires personal data to be kept for a longer period.

9. How and Where Do We Store or Transfer Your Personal Data?

We may store or transfer some or all of your personal data worldwide, including countries that that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Although other countries may not have and may not have data protection laws that are as strong as those that you are used to, we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within Canada, USA and Europe.

When we share your data with external third parties, as detailed below in Part 9, that are based outside of the EEA. The following safeguards are applied to such transfers:

1. We will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection.
2. We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR.
3. Please contact ususing the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we use commercially reasonable precautions, such as security software, physical security features and strict policy guidelines to safeguard the privacy of our users’ personal information; we are also committed to constantly improving our security measures as new technology is made available. We work diligently to protect the safety of customers’ online purchases and merchants’ sensitive information by using authentication technology (certificates) and encryption technology (SSL). Our secure server software encrypts all personal information, including credit card information and/or social security number, which is transmitted over the Internet to and from Leadup DXP website.

10. Do We Share Your Personal Data?

We may sometimes contract with the third parties to supply products or services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

11. How Can I Access My Personal Data?

You have the right to access your personal data, as collected and processed by Leadup DXP, and to request that they be corrected in the event of inaccuracy (if any) or deleted in the event that they are not necessary. You have the right to ask for a restriction of processing or to object to processing as well as the right to data portability. You also have the right to object to the future processing of your personal data for direct marketing purposes at any time, without charge and without justification.

To exercise your rights, all you need to do is to contact us at privacy@leadup-dxp.com

In order to protect your privacy and the security of the data recorded on our website, we may ask you for additional information in order to check your identity before we answer your query.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 20 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex or we have to identify you, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

12.  How Can You Contact Us?

To contact us about anything to do with your personal data and data protection, please use the following details :

Email address: privacy@leadup-dxp.com

13.  Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website.