Last Updated: Jun 30, 2023
Changing Our Notice
We may change this Privacy Notice from time to time. If we make any changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Notice and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). We encourage you to review our Privacy Notice whenever you access the Application to stay informed about our information practices and the ways that you can help protect your privacy. If you no longer agree with this Privacy Notice and do not wish your information to be subject to the Privacy Notice, you will need to stop using the Application. Your use of the Application shall constitute your consent to the present Privacy Notice.
What Information We Collect
We may collect certain user information, including personal data.
Information You Provide To Us. We collect the information you provide directly to us including when you use the Application. This information includes personal data. This personal data will be processed for the purposes described in this Privacy Notice, as it may be amended from time to time. For example, your personal data will be used to create or modify your profile and account, access and use the Application, participate in any interactive features of the Application, submit a contact or consent form, participate in a survey, or request customer support.
The personal data that we may collect directly from you includes your name, username, email address, phone number, information about your Product account preferences, transactional information (including services purchased or subscribed to and amount paid), as well as any contact or other information you choose to provide.
If you are a member of a social media network, like Facebook, you may choose to use your social credentials to create and log into your account. Please review your privacy settings on your social media account, as those settings determine what information may be made available to us when you access the Application.
The personal data provided during payment is collected and processed by our payment processor (in most cases, Stripe). Lekses does not save any personal financial information, including credit card numbers, expiration dates, security codes, or postal codes.
Updating Your Information and Deactivating Your Account. You can update, correct, or modify your account information at any time by logging into your account via the Application and accessing your profile page. If you need help accessing, modifying, or deactivating your account within the Application, please email email@example.com. For users in the European Union (“EU”), please see the section below in this Privacy Notice titled “EU User Rights.”
Information We Collect Automatically When You Use the Application. When you access or use the Application, we may automatically collect information, including personal data, about you, including:
Usage, Log, and Device Information. We collect information from your use of the Application, such as the number of visits, length of time spent using or accessing the Application, IP address (which may allow us to collect general location data), pages clicked on, system activity, hardware settings, device type, operating system, and the date and time of your visit. We collect information on user activity in connection with the Application and may collect information about the features you use, the content you access, and any actions taken in connection with your access and use of the Application.
How We Use Information Collected
We use the information collected through the Application in order to facilitate the provision of the Application and engage with you about our products and offerings. We may use the information that we collect:
- To provide, operate, maintain, and improve the Application;
- To enable you to access and use the Application that you request, including sending you technical notices, updates, alerts, and support and administrative messages;
- To provide and deliver the services and features you request, process and complete transactions, and send you related information, including purchase confirmations and receipts;
- To respond to your comments, questions, and requests, and provide customer service and support;
- To communicate with you about services, features, surveys, newsletters, offers, promotions, events, and provide other news or information about the Application and our select partners;
- To process and deliver survey entries and rewards;
- To review and analyze trends, usage, and activities in connection with the Application and for marketing or advertising purposes;
- To investigate and prevent fraudulent transactions, unauthorized access to the Application, and other illegal activities;
- To personalize and improve the Application, and provide content and/or features that match your interests and preferences or otherwise customize your experience on the Application; and
- For other purposes about which we notify you in advance or for which we receive your consent, as necessary.
Data Retention and Erasure
We retain information for as long as required, allowed or we believe useful within the limits of the following constraints. We will maintain certain data for a period of 7 years from the date of your last log-in or other study activity in order to keep accurate records for tax purposes. After 7 years from your last activity, we will permanently delete all such personally-identifying information. We will keep all other personally identifying information for at least one year after your last login, but in no event longer than seven years. Regardless of the retention period described in this section, we may be required to retain data for longer to comply with legal, regulatory, or audit obligations. Other historical study information may be anonymized and kept at Lekses’s discretion.
If you reside outside the U.S., your information will be transferred to the U.S. and processed and stored there under U.S. privacy standards. By using the Application, you consent to such transfer to, and processing in, the U.S. We are concerned about safeguarding the confidentiality of your information. We provide industry-standard physical, electronic, and procedural safeguards to protect the information we process and maintain. For example, we take reasonable measures to limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
What Information We Share or Disclose to Others
We will not share personal data about you with any third parties except as described in this Privacy Notice, or as defined in an agreement with us in connection with the Application (including a Data Processing Addendum, as applicable). Information that may be shared, pursuant to any applicable agreements, includes:
Third-Party Service Providers. We may share your information with third-party service providers who are working on our behalf and require access to your information to carry out that work, such as to process payment or as it relates to an Application feature. These service providers are authorized to use your personal data only as necessary to provide services to Lekses. As required by the European Union’s General Data Protection Regulation, Lekses enters into Data Processing Addendums with its Third-Party Service Providers that process the personal data of users in the EU.
To opt-out, you can adjust the advertising preferences on your mobile device (for example, in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking). You can also opt-out for companies that participate in the Digital Advertising Alliance’s AppChoices tool by downloading AppChoices https://www.aboutads.info/appchoices and following the instructions in the app. For more information about opting out on mobile devices, please see https://www.networkadvertising.org/mobile-choice.
Compliance with Laws. We may disclose your information to a third party: (a) if we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or government request; (b) to enforce our agreements and policies; (c) to protect the security or integrity of the Application; (d) to protect Lekses, our customers, or the public from harm or illegal activities; (e) to respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person; or (f) as otherwise directed by you.
Business Transfers. We may share or transfer your personal data in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. Your personal data may be part of the transferred assets. Data processing for this purpose is a legitimate business interest. You may be notified thereafter of any such change in ownership or control.
Aggregated and/or Anonymized Data. We may also share aggregated and/or anonymized information that does not directly identify you individually with third parties. For example, in an ongoing effort to better understand and serve the users of the Application, we may conduct research on customer demographics, interests, and behavior based on the personal information, interviews, and other data provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregated data with our agents and business partners. This aggregated information does not identify you personally. We may also disclose aggregated user statistics in order to describe the Application to current and prospective business partners, and to other third parties for other lawful purposes.
Links To Third-Party Websites
We may place links to third-party websites on the Application. When you click on a link from our Application to a third-party website, your activity and use are governed by that website’s policies; not by those of Lekses. We encourage you to review their privacy and user policies.
How We Store Information
By using and accessing the Application, you understand and agree to the storage of information and any other personal data on Lekses’s server and cloud-based solutions located in the United States, or as defined in an agreement with us (including a Data Processing Addendum, as applicable).
How We Secure Information
We have adopted reasonable physical, technical and organizational safeguards against accidental, unauthorized, or unlawful destruction, loss, alteration, disclosure, access, use, or processing of information we collect.
You may access your account information and our Application only through the use of an individual user ID and password. To protect the confidentiality of personal data and information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been compromised in any way. Please note that we will never ask you to disclose your password to us.
Unfortunately, the transmission of information via the Internet and apps is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us. Any transmission of personal information is at your own risk. We are not responsible for any circumvention of any privacy settings or security measures.
If you have any questions about the security of your personal data, you can contact us at firstname.lastname@example.org.
Our Global Data Privacy and Protection Practices
Lekses uses Standard Contractual Clauses as the basis for Lekses’s approach to cross-border transfers. These Standard Contractual Clauses provide appropriate safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals and the exercise of the corresponding rights.
EU User Rights
For all requests surrounding your personal data or questions about your rights per this Privacy Notice, please contact us at email@example.com, and we will respond promptly.
Right to Access, Rectification, or Erasure. You have the right to access, update, correct, or delete your personal data. You also have the right to rectify any inaccuracies in your personal data.
Right to Restrict Data Processing. You have the right to restrict the processing of your personal data upon request if it is (a) inaccurate or unlawful, (b) under contest, or (c) no longer being processed for the original purpose. Lekses may continue to process the data if it is necessary to resolve legal claims, for the protection of the rights of another person, or for reasons of important public interest. If Lekses objects to the restriction of data processing, we will notify you promptly after receiving your request.
Right to Data Portability. You have the right to request and obtain the personal data that you provided to us or that we collected through your consent or contractual agreements. We will provide your information in a commonly used, machine-readable format promptly, but no longer than 90 days from the initial request depending on the complexity and volume of requests. If circumstances arise where we are unable to complete your request, we will promptly provide a relevant explanation, as well as inform you of additional steps that you may take.
Retaining Your Personal Information and Data. We will retain your personal data to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your personal information for as long as your account is active or as needed to provide you with the Application, but no longer than the period necessary to fulfill the purposes outlined in this Privacy Notice.
Receiving Promotional and Other Communications. We will obtain your consent before sending you promotional, newsletter, or Application information emails that we feel may interest you. We may obtain consent from you through a website contact or consent form or by email. You may opt-out by either checking the relevant box on the communication consent form, by following the opt-out instructions provided in our emails to you, or by emailing us with your specific request. If you opt-out, we may still send you non-promotional communications, such as security alerts and notices related to your access to or use of the Application or those about your account or our ongoing business relations.
Withdrawing Your Consent. You may withdraw any consent you previously provided to us for the processing of your personal data. As required by applicable law, we will apply your preferences going forward, within a reasonable amount of time. Even where you withdraw your consent, we may still process your personal data for limited purposes, for example, to give effect to your request or to safeguard our business. In some circumstances, withdrawing your consent to our use or disclosure of your personal information will mean that you cannot use our Application.
Lodging a Complaint with a Supervisory Authority. You have the right to submit a complaint to an EU supervisory authority if you believe that your personal data has been processed in a manner that is not compliant with the GDPR. You also have the right to submit a complaint to an EU supervisory authority if Lekses is unable to comply with your right of data portability or does not respond to your request within a timely manner.
If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of personal information we have shared with third parties, for the third parties’ direct marketing purposes, during the preceding calendar year. To request a notice, please submit your request to firstname.lastname@example.org, with “California Shine the Light Inquiry” in the subject line. You may also opt out of our sharing of your personal data we have shared with third parties, for the third parties’ direct marketing purposes by emailing us at email@example.com.
Our Policy Toward Children
In compliance with COPPA, the Children’s Online Privacy Protection Act at https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule, and the Federal Trade Commission’s Children’s Online Privacy Protection Act at https://www.ftc.gov/system/files/2012-31341.pdf the Application is not directed to children under the age of 13 and does not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information, please contact us at firstname.lastname@example.org. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information.
If you are a California resident under the age of 18 and a registered user of our the Application, you may request that we remove content and information that you post on the Application. To obtain removal of such content or information, please send an email with a detailed description of the specific content or information you would like removed to email@example.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted, since the content and information may remain in our databases, may remain visible in a manner that does not identify you, or may have been re-posted by another user. There may be other circumstances in which applicable laws do not require or allow removal even if requested.
Data Protection Officer
Lekses will appoint a Data Protection Officer if and when required by GDPR Article 37 and by the Data Protection Laws. The Privacy team, including any appointed Data Protection Officer, may be reached at firstname.lastname@example.org or via the contact information provided below.
If you have any questions about this Privacy Notice, please contact email@example.com.
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