Privacy Policy

Our Privacy Policy outlines what Personal Information we collect, the reasons for collection and the ways in which we use it. It also covers how and when the information may be shared and your rights and choices regarding the information you provide to us.

By using the LEOcrowd platform and the services offered through it, you are acknowledging you have agreed to our Terms and Conditions and that you have read and understood this Privacy Policy and the use of your Personal Information as described in this Privacy Policy.

This Policy applies to all Personal information received by LEOcrowd in any format including electronic, paper or verbal. LEOcrowd will not sell or share this information with third parties in ways different than what is disclosed in this Policy.

Personal information collected by LEOcrowd from Users, Project Creators, Backers, Clients, Business partners and others may be maintained at its corporate offices in England, or at other LEO facilities. LEOcrowd collects Personal information for, among other things, legitimate business reasons such as customer service; meeting governmental reporting and records requirements; maintenance of accurate accounts payable and receivable records; internal marketing research; safety and performance management; financial and sales data; and contact information. All Personal information collected by LEOcrowd will be used for legitimate business purposes consistent with this Policy.

If you have any queries or concerns, please contact us at [email protected].

Who We Are

LEOcrowd.com (together with its parents, subsidiaries, affiliates, agents, representatives, consultants, employees, officers and directors - collectively, "LEOcrowd", "we", "our" or "us") operates globally. In many cases, LEOcrowd operates in jurisdictions considered by the European Union ("EU") to provide adequate levels of protection to the privacy of individual information.

To ensure compliance with the EU Privacy Directive, LEOcrowd's parent company, LEO (Learning Enterprises Organisation Limited), has put in place, Standard Commercial Clauses pursuant to Article 26(2) of the EU Data Protection Directive, which include any non-LEOcrowd entities that process data on its behalf.

LEO's Chief Privacy Officer ("CPO") is responsible for the company's compliance and enforcement of the Policy and all data security issues. The CPO is available to any of its valued employees, customers, vendors, business partners or others who may have questions concerning the Policy or data security practices. Relevant contact information is provided below.

Your personal information may be transferred, stored or processed outside the EEA by staff engaged by LEOcrowd e.g. in the provision of support services etc. By submitting your personal data, you are agreeing to this. LEOcrowd will take all steps reasonably necessary to ensure your data is treated securely and in accordance with this policy.

Changes to the Policy

LEOcrowd reserves the right to modify or amend this Policy at any time consistent with the requirements of any developing international law, principles and practices relating to privacy. If we do, we'll let you know about any material changes made, either by clear notification on the website or by e-mail. If you continue to use LEOcrowd after a change has been made, this indicates your continued acceptance of this Policy.

Information we collect

When you register on our site or use our services, we need to collect and process certain information. The amount of information collected is dependent on the amount of interaction you have with our site and may include:

  • Details you provide if you register as a User/Project Creator on LEOcrowd, subscribe to Newsletters, access content through LEOcrowd or contact us – your first and last name, e-mail, postal address, telephone/mobile number, country of residence, Username and password.

  • Details you provide for Identification purposes (KYC) during the creation of a Project – your legal name, date of birth, postal address, mobile number, digital copies of documents for photo and address verification purposes such as, but not limited to, Passport, Utility Bill, Driving Licence etc.

  • Details you provide when pledging to Projects – your name, credit/debit card details and billing address, e-mail address, Username and password. LEOcrowd does not store your payment information.

  • Details about your activity on and interaction with LEOcrowd including your IP Address, location, type of device/operating system/browser you are using, number of visits you have made to the site and your actions on the site.

  • Information about the ways people visit and interact with our Site, in the form of traffic analytics. You can opt out of being included in Google Analytics IF you do NOT accept our Cookie Policy (see Cookies Section). Analytics is used to improve the user experience by giving LEOcrowd the data required to optimise the website based on the user journey.

  • Any communications you send to us such as, but not limited to, support requests, reporting of a problem/issue, consultation requests or questions or comments

  • Any information submitted via comments or messages to other users.

  • Any other personal information you choose to disclose during your use of LEOCrowd e.g. photo/picture you have uploaded, additional profile information, a link you have shared etc.

You may visit our site anonymously and you may choose not to provide LEOcrowd with your information. However, this will limit your ability to sign-up as a User, create a Project or use many of our services. You may review, update/change or remove your information through your User Profile Dashboard on our website. For more detailed information on the process of becoming a User please refer to our Terms and Conditions.

How we store your information

LEOcrowd use various tools to store your information. Provided below is a list of secure tools that we use to store your information so that you Project creators can create new projects, Project backers can pledge to projects and general users can receive up t date information.

  • LEOcrowd Backend Database

  • Infusion Soft

Using your information

Any of the information we collect from you may be used in the following ways:

  • To communicate with you - The e-mail address you provide may be used to:

    • send you information and updates

    • send you newsletters regarding LEOcrowd and our current activities

    • ask for feedback on LEOcrowd

    • contact you about your access to or use of LEOcrowd

    • send information on related products or services etc.

    • reply to any correspondence you send to us

    • and for any other reasonable purposes related to your registration or LEOcrowd.

    Please note: If at any time you would like to unsubscribe from receiving future e-mails, we include detailed unsubscribe instructions at the bottom of each e-mail and you can also change your Privacy options under your User Profile Dashboard on our website.

  • To ensure account security and protect LEOcrowd's services - We collect KYC information, (reserving the right to send this data to a third-party provider to verify your personal details) to prevent fraud and abuse and to ensure those that register meet the requirements as set out in our Terms and Conditions. We may also use your personal information to investigate a complaint made by a User, a breach of LEOcrowd's Terms and Conditions or to detect criminal activity, fraud, misuse or damage to LEOcrowd or its Services, to enable us to prosecute those responsible.

  • To process transactions - By pledging/backing a Project, you are agreeing that your details may be used for the fulfilment of Rewards, as per our Terms and Conditions, and the agreement between the Backer and the Project Creator. LEOcrowd also uses information you have provided to complete Pledge transactions and deliver the service requested.

  • To personalise your experience and improve customer service - By using information you have supplied to us we can respond more effectively to Customer Service Requests and support needs, and tailor your use of the website to be more User specific.

  • To improve our website - By receiving feedback, by tracking and analysing your use of our Services and by using the information you provide, to interact with you regarding our website, LEOcrowd can make significant improvements to the User Experience.

Protecting your information

The privacy principles in this Policy are based on the Privacy Shield Privacy Principles (see: https://www.privacyshield.gov/welcome), and include:

Your Right to be Informed:

LEOcrowd will inform you about:

  • the types of personal data it processes;

  • the reasons why it processes your personal data;

  • if it intends to transfer your personal data on to another company and the reasons why;

  • your right to ask LEOcrowd to access your personal data;

  • your right to choose whether you allow LEOcrowd to use your personal data in a "materially different" way or to disclose it to another company (also known as the right to "opt-out"). When the data is sensitive, (that is, data that reveals, for example, your ethnic origin or the state of your health) LEOcrowd will inform you about the fact that it may only use or disclose such data if you allow this (also known as the right to "opt-in");

  • how to contact LEOcrowd if you have a complaint about the use of your personal data;

  • the independent dispute resolution body where you can bring your case;

  • LEOcrowd will provide you with a link to its privacy policy.

Limitations on the use of your data for different purposes

LEOcrowd will only use your personal data for the purpose for which it was originally collected, or for which you have subsequently authorised. If LEOcrowd wants to use your data for a different purpose, this will depend on how much the original purpose diverges from the new purpose:

  • LEOcrowd will not use your data for a purpose that is incompatible with the original purpose;

  • If the new purpose is different but related to the original one (i.e. "materially different"), LEOcrowd may only use your data if you do not object or, in the case of sensitive data, if you consent.

  • If the new purpose is different from the original one but still close enough that it would not be considered as materially different, such use is permissible.

You also have a right to choose whether you allow LEOcrowd to pass on your personal data to another company. While you do not have such a choice when your data will be sent to another company (also known as an "agent") for processing on behalf, in the name and under the instructions of LEOcrowd, LEOcrowd will have to sign a contract with the agent that obliges the latter to provide the same data protection safeguards as contained in the Privacy Shield framework.

Data minimisation and obligation to keep your data only for the time needed

LEOcrowd may only receive and process personal data to the extent they are relevant for the purpose of processing, and it has to ensure that the data used is accurate, reliable, complete and up-to-date. It is only allowed to keep your personal data for as long as necessary for the purpose of processing. It may keep your data for longer periods only if it needs them for certain specified purposes such as archiving in the public interest, journalism, literature and art, scientific or historical research, or for statistical analysis. If your data continues to be processed for these purposes, LEOcrowd will comply with the Privacy Principles.

Obligation to secure your data

LEOcrowd will ensure that your personal data are kept in a safe environment and secured against loss, misuse, unauthorised access, disclosure, alteration or destruction, taking due account of the nature of the data and the risks involved in the processing.

Obligation to protect your data if transferred to another company

As noted above, under certain conditions and considering the purpose for which it received your personal data, LEOcrowd may transfer them to another company. This can happen for instance when LEOcrowd shares your data (with a company that itself decides how to use the data, a so-called "controller") without you objecting to that or concludes a service contract with a (sub-) processor (a so-called "agent"). Irrespective of its location, within or outside the U.S., the company that receives the data must ensure the same level of protection of your personal data as guaranteed under the Privacy Shield framework. This requires a contract between LEOcrowd and the third-party setting out the conditions under which the third-party can use your personal data and its responsibilities to protect your data. This contract will have to require the third-party to inform LEOcrowd of situations where it cannot continue to meet its obligations, in which case it must stop using the data.

Your right to access and correct your data

You have the right to ask LEOcrowd to give you access to your personal data. This means that you have a right to have your data communicated to you but also to get information about the purpose for which the data are processed, the categories of personal data concerned and the recipients to whom the data are disclosed. You can then request the company to correct, change or delete them if they are not accurate, outdated or have been processed in violation of the Privacy Shield rules. LEOcrowd also has to confirm whether or not it holds or processes your personal data. You are normally not obliged to give any reasons as to why you would like to access your data; however, LEOcrowd may ask you to do so if your request is too broad or vague. LEOcrowd has to respond to your access request within a reasonable time frame. LEOcrowd may sometimes be able to limit your access rights, but only in specific situations such as when providing access would undermine confidentiality, breach professional privilege or conflict with legal obligations.

Sharing your information

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information and will not distribute your personal information to outside parties without your consent. However, we may disclose information about you in the following ways:

  • Once you create an account with LEOcrowd and post a Project or any content, anyone using the LEOcrowd site will be able to view basic information about you such as, but not limited to, your Username, any information you choose to add to your profile (picture/short bio) etc. You can change or delete any of this information at anytime by accessing it through your User Profile Dashboard. However, you should be aware that if you have embedded such information within the main Project Page of your Project, you will not be able to change or alter this information once the Project has been submitted/approved or gone ‘live', without contacting the LEOcrowd team at [email protected]

  • We may share your information with certain trusted third-party services and those who assist us in operating our website but the conditions for doing so are laid out in the previous section 'Protecting your Information (Obligation to protect your data if transferred to another company)'.

  • To enable LEOcrowd's employees and agents to administer any accounts or services provided to you through the site, your information will be shared with them.

  • We also reserve the right to release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or other's rights, property or safety. However, non-personally identifiable user information may be provided to other parties for marketing, advertising or other uses.

  • When a User backs a project and the project is funded successfully, then some of the Backers information must be shared with the Project Creator to assist him/her in the fulfilment of Rewards including, but not limited to, the Backers e-mail address, postal address etc. Project Creators should not ask for any information that isn't necessary for the provision of the reward and Project Creators never receive Backers' credit card details or payment information. More detailed information in outlined in our Terms and Conditions. Project Creators may also receive analytical information on their project from time to time.

There are some types of data that will not be publicly displayed or revealed to other Users. This includes:

  • Password details

  • Any payment information you provide

  • Phone/Mobile Number

  • Date of Birth

  • Verification Documents

  • Any additional private profile information

  • Any correspondence you send to us regarding for example, support questions or reporting a problem.

How we find our audience

LEOcrowd use marketing out reach so that we can get in front of new audiences and promote values content/offers to existing users. We use a variety of companies that allow for advertising to placed on their website. All of our marketing outreach is in alignment with the Companies own rules.

Provided below is a list of companies that we use for marketing:

  • Facebook Advertising

  • Instagram Advertising

  • Twitter Advertising

  • Google Adwords

  • Youtube Advertising

  • OutBrain (article submission)

  • PR (outreach channels)

Cookies

Cookies are small data files that a site or its service provider sends to your browser from a web server, which are then stored on your device's hard drive. Cookies allow us to recognise your device but not the specific person using it.

We use them to optimise our websites performance, to improve the user's experience and to share relevant content with the users on third-party networks, so that they can receive more valuable content and insights into the Crowdfunding industry and our services (references in our Terms and Conditions and this Policy to ‘cookies' also include other means of automatically accessing or storing information on your device).

Your browser may give you the ability to control and decide whether you accept cookies and many sites offer you the option to allow cookies to run on your device. However, if you choose to turn off or not accept cookies, you should be aware that this can limit the functionality of some areas of the LEOcrowd website and may not offer you the optimal user experience that the cookies will help you experience.

By agreeing to our Terms and Conditions and by continued use of our site, you are providing your consent for us to use cookies in the ways described in this Policy.

Children

LEOcrowd's website is not directed toward children, and people under the age of 18 (or those not old enough to form a binding contract where they live) cannot become a registered user of the site. LEOcrowd does not knowingly collect any personal data from children under the age of 18 Nevertheless, LEOcrowd and its parent company, LEO (Learning Enterprise Organisation Limited), are committed to complying with applicable laws and requirements, such as the United States' Children's Online Privacy Protection Act ("COPPA").

Removal/Correction of Personal Information/Disputes

Any questions or concerns regarding the use or disclosure of Personal information should be directed to the LEO's Chief Privacy Officer at the address given below, as the parent company of LEOcrowd. LEO (Learning Enterprises Organisation Limited) will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal information in accordance with the principles contained in this Policy.

LEOcrowd Users also have the option to request that LEOcrowd no longer use information previously provided, correct information previously provided or remove information previously provided to LEOcrowd.


By mail:

FOR THE ATTENTION OF: Chief Privacy Officer

LEO Global Office

Battle Barns Preston Crowmarsh

Wallingford

Oxfordshire

OX10 6SL

England


By email:

[email protected]

Any enquiries should include the individual's name, address and other relevant contact information such as phone/mobile number or e-mail address.

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