We are very pleased about your interest in our website and company, LeadUpp Private Limited. Data protection is of a particularly high priority for the management of LeadUpp.

This Privacy Policy describes how LeadUpp Private Limited (“LeadUpp”, “we”, “our” or “us”) collects, stores, uses and discloses personal data. It also describes your rights with respect to your data. Please read this Privacy Policy carefully and make sure that you fully understand it. You are not legally required to provide us with any of your personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our service providers, please simply do not visit or interact with our website, nor use our Training Program. By using our website or our Training Program, you are expressly consenting to our collection, processing, storing, disclosing, using and handling of your data as set forth in this Policy now, and as amended by us from time to time.

The use of the Internet pages of LeadUpp is possible without any indication of personal data. However, if you want to use specific parts of our Training Program or our website, processing of personal data could become necessary. If processing of personal data is necessary and if there is no legal basis for such processing, we will generally obtain the consent of the data subject.

You may also choose not to provide us with “optional” personal data (i.e. “not required” fields on forms), but please keep in mind that without it we may not be able to provide you with the full range of our website or Training Program or with the best user experience when using our website or Training Program.

When we use the term “personal data” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual. We will not process any special (or sensitive) categories of Personal Data except where we are able to do so under applicable legislation or with your explicit consent.

As the controller in certain cases, LeadUpp has implemented numerous technical and organisational measures to ensure the protection of personal data processed through the website and Training Program. Nevertheless, Internet-based data transmissions may be subject to security vulnerabilities, so that absolute protection cannot be guaranteed.

Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in our End User Licensing Agreement (“Terms / EULA”).

Who do we collect data from?

Business Users/ Institutions: We collect the personal data of the internal focal persons, admins and billing contact of our business customers / Institutions (“Business Customer”), who directly engage with us, for availing our services for their entity/ institute.
Individual Users: personal data of the Individual User where the individual user is directly interacting with the Training Program for himself/ herself.
Visitors / Users of our website: data relating to visitors / users of our website, participants at our events, and any other prospective customer, user or partner (collectively, “Prospects”) who visits or otherwise interacts with our website, digital ads and content, emails, integrations or communications under our control.

Collection of general data and information

We may collect the following categories of personal data, as more elaborately specified further in this Policy:

From Business Customers:

Name, email, country, contractual, billing details, payment information, and any other information submitted by admins, when interacting on behalf of the Business Customer.

From Users accessing our Training Program:

Name, email, country, login credentials, and any other information submitted by such Users when they sign up, log in or use the Training Program.

From all Users/ visitors of our website or Training Program:

The following data may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website or Training Program (so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website or Training Program, (5) the date and time of an access to the website or Training Program, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.

When using these general data and information, LeadUpp does not draw any conclusions about the data subject. Rather, this information is needed (1) to deliver the contents of our website or Training Program correctly, (2) to optimise the contents of our website or Training Program and the advertising for these, (3) to ensure the long-term functionality of our information technology systems and the technology of our website or Training Program, and (4) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. Therefore, LeadUpp analyses anonymously collected data and information on one hand for statistical purposes and on the other hand for the purpose of increasing the data protection and data security of our enterprise, and ultimately to ensure an optimal level of protection for the personal data we process.

We use so-called cookies on our website or Training Program. These are small files that your browser automatically creates and that are stored on your end device (laptop, tablet, smartphone or similar) when you visit our site.

Cookies do not cause any damage to your end device and do not contain any viruses, Trojans or other malware. Information is stored in the cookie that is related to the specific end device used. However, this does not mean that we gain direct knowledge of your identity.

The use of cookies serves on the one hand, to make the use of our website/ Training Program more pleasant for you. We use so-called session cookies to recognise that you have already visited individual pages of our website or Training Program. These are automatically deleted after you leave our site. In addition, we also use temporary cookies for the purpose of user-friendliness, which are stored on your end device for a certain fixed period of time. If you visit our site again to use our services, it is automatically recognised that you have already been with us and which entries and settings you have made so that you do not have to enter them again.

On the other hand, we use cookies to statistically record the use of our website or Training Program and to optimise and evaluate the same for you. These cookies enable us to automatically recognise that you have already been to our website or Training Program when you visit it again. These cookies are automatically deleted after a defined period of time. Most browsers accept cookies automatically. However, you can configure your browser in such a way that no cookies are stored on your computer, or a message always appears before a new cookie is created. However, the complete deactivation of cookies may mean that you cannot use all the functions of our website or Training Program. The storage period of cookies depends on their purpose and is not the same for all of them. Cookies are used for the aforementioned purposes to protect our legitimate interests.

Cookies requiring consent

Cookies that are neither technical cookies nor functional or performance cookies will only be used with your consent. Functional and performance cookies are so-called "absolutely necessary" cookies, which do not require consent.

We reserve the right to also use information obtained by means of cookies from an analysis of the usage behaviour of visitors to our website or Training Program in order to display specific advertising for certain of our products to you on our own website or Training Program. We believe that this benefits you as a user because we display advertising or content that we believe, based on your browsing behaviour, matches your interests and so you are less likely to be shown random advertising or specific content that may be of less interest to you.

Marketing cookies come from external companies (third party cookies) and are used to collect information across the website or Training Program visited by the user in order to create targeted advertisements for the user. These enable personalised online ads and advanced analysis and evaluation options about the target group and user behaviour.

How can I make choices about cookies and my privacy?

You can manage your cookie settings using the setting options listed below or by configuring your browser settings. Most browsers are pre-set to accept cookies by default. However, you can configure your respective browser so that it only accepts certain cookies or not at all. You can also use your browser settings to delete cookies already stored in your browser or to have the storage period displayed. Furthermore, it is possible to set your browser to notify you before cookies are stored. Since the various browsers can differ in their respective functions, we ask you to use the respective help menu of your browser for the configuration options. Below you will find general instructions on how to manage cookies for the most popular browsers: Google Chrome, Microsoft Internet Explorer and Edge, Mozilla Firefox, Apple Safari, Opera Web. If you would like a comprehensive overview of all third-party accesses to your Internet browser, we recommend that you install specially developed plug-ins for this purpose.

Lifetime of Cookies

Cookies have a lifetime. Some cookies are deleted when you close your browser. Others (for example, those with login details) can remain on your computer for years if you do not delete them. You can delete cookies at any time. Click on one of the links above to go to your browser's user manual. After deleting cookies, you may need to log in again to some websites or specify your preferences.

What cookies does LeadUpp use?

First party and third-party cookies commonly used on the Sites are listed in the table below. We strive to keep this list current and will update it accordingly. In any case, you can always manage all cookies and other tracking technologies used on the sites.

Cookie	Type	Description	Lifespan
vuid	Necessary	Vimeo installs this cookie to collect tracking information by setting a unique ID to embed videos to the website.	2 years
_fbp	Advertisement	This cookie is set by Facebook to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising, after visiting the website.	3 months
fr	Advertisement	Facebook sets this cookie to show relevant advertisements to users by tracking user behaviour across the web, on sites that have Facebook pixel or Facebook social plugin.	3 months
_ga_#	Analytics	This cookie is installed by Google Analytics.	2 years
_ga	Analytics	The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.	2 years
UserMatchHistory	Advertisement	LinkedIn sets this cookie for LinkedIn Ads ID syncing.	1 month
lang	Advertisement	LinkedIn sets this cookie to remember a user's language setting.	session
bcookie	Advertisement	LinkedIn sets this cookie to uniquely identify devices accessing LinkedIn to detect abuse on the platform and diagnostic purposes	1 year
lidc	Advertisement	LinkedIn sets the lidc cookie to facilitate data center selection.	1 day
AnalyticsSyncHistory	Advertisement	LinkedIn sets this cookie to store information about the time a sync took place with the lms_analytics cookie.	1 month
bscookie	Advertisement	LinkedIn sets this cookie to remember that a logged in user is verified by two factor authentication and has previously logged in	1 year
li_sugr	Advertisement	LinkedIn sets this to make a probabilistic match of a user's identity outside the Designated Countries,	90 days
ln_or	Advertisement	LinkedIn sets this to determine if Oribi analytics can be carried out on a specific domain	1 day

E-mail contact

If you contact us via the e-mail address provided, the personal data transmitted with the e-mail will be stored. Insofar as this involves information on communication channels (e.g., e-mail address, telephone number), you also consent to us contacting you via this communication channel, if necessary, in order to answer your request.

In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the conversation.

The legal basis for the processing of the data is consent if the user has given his consent. The legal basis for the processing of data transmitted in the course of sending an e-mail is our legitimate interest. If the e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is the performance of a pre-contractual or contractual measure.

The processing of the personal data from the e-mail serves us to process the contact. In the case of contacting us by e-mail, we also have the necessary legitimate interest in processing the data.

Contact Form and Free Trial

It is also possible for you to contact us and to get access to our game with a free trial / demo. For this purpose, you will need to provide us with the following via the Contact Form: Name, Company Name, Email address, Country and Telephone number. We store the data you enter to set up a free trial, share a calendar invite for an initial meeting and onboarding and may hold your data in terms of this Policy. This may also include choices made, scores, notes, feedback on demo/ Free Trial.

You have the right to access, correct or delete your registration data at any time, by contacting us via email. The legal basis for the storage is your consent. If the registration aims at the conclusion of a contract, the additional legal basis for the processing is the performance of a pre-contractual or contractual measure. The personal data processed through the Contact Form also serves to prevent misuse of the contact form and to ensure the security of our information technology systems.

Training Program (Access to our game and admin panel)

We process the data of our customers or potential customers in order to enable you to facilitate and use the game or our admin panel. The required information is identified as such in the context of the provision of services and billing as well as contact information. As such this may include name, email, region, department, age, gender, education, country, nickname, choices made, scores, progress, activity, device id, feedback of user of our game.

An administrator account is required to manage the game within your company and the respective users. If you use our admin panel, we transmit the data collected from you and your Users (Name, email id, company name, region, department, age, gender, education, country) to provide you with the functions of the game. This transmission is necessary and to enable you to use the service offered by us on basis of a contractual measure.

Unless otherwise specified the purposes of processing are Contractual performance and service, contact requests and communication, office and organisational procedures, administration, and response to requests, visit action evaluation, interest-based and behavioural marketing. And, the Legal bases are Contractual performance and pre-contractual inquiries, Legal obligation, and our Legitimate interests.

Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as organisation of our operations, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organisation, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the data mentioned in these processing activities.

In this context, we disclose or transfer data to consultants, such as legal advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, based on our business interests, we store information on suppliers, event organisers and other business partners, e.g., for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.

Communications

Services Communications: We may contact you with important information regarding our services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our services/ website /Training Program, billing issues, log-in attempts or password reset notices, etc. Please note that you will not be able to opt-out of receiving certain services communications which are integral to your use (like password resets or billing notices).

Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us, through the website / Training Program, or through our marketing campaigns and/ or newsletter on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify us at any time by sending an email to us, or by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions.

Updating your information

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so within your user or admin account or contact us. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.

Routine deletion and blocking of personal data

We process and store personal data of the data subject only for the period necessary to achieve the purpose of storage and in terms of applicable legislation and statutory retention periods. If the storage purpose ceases to apply or if a storage period prescribed expires, the personal data will be routinely blocked or deleted or anonymised in accordance with the statutory provisions.

Rights of the data subject

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your data. In accordance with applicable law and subject to the terms of this policy, your controls and choices may include:

Right to obtain information about the basis of legal interests, the purpose of the request and use of personal data;
Correcting, updating, and deleting your account with us;
Choosing or changing your choices for subscriptions, newsletters, and alerts;
Right to withdraw consent granted for personal data;
Right to data portability;
Choosing whether to receive from us offers and promotions for our services, or products and services that we think may be of interest to you;
Requesting removal of your personal information from our website or Training Program;
Requesting access to the personal data we hold about you and that we amend or delete it.

If you wish to exercise your privacy rights under applicable law (including the EU or UK GDPR or the California Consumer Privacy Act (CCPA)), please contact us by email.

If you are a GDPR protected individual/ entity, you have the following rights:

a) Right to confirmation

Every data subject has the right to obtain confirmation from us as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may, at any time, contact LeadUpp.

b) Right of access

Any person concerned by the processing of personal data has the right to obtain at any time from LeadUpp, free of charge, information about the personal data stored about him or her and a copy of that information. In addition, the European Directive and Regulation Body has granted the data subject access to the following information:

the purposes of the processing,
the categories of personal data processed,
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organisations,
if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration,
the existence of the right to obtain the rectification or erasure of personal data concerning him or her, or the restriction of processing by LeadUpp, or the right to object to such processing,
the existence of a right of appeal to a supervisory authority,
if the personal data are not collected from the data subject: Any available information on the origin of the data.

Furthermore, the data subject shall have the right to obtain information as to whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards in relation to the transfer.

If a data subject wishes to exercise this right of access, he or she may contact LeadUpp at any time.

c) Right of rectification

Any person affected by the processing of personal data has the right to request the immediate rectification of any inaccurate personal data concerning him or her. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.

If a data subject wishes to exercise this right of rectification, he or she may, at any time, contact LeadUpp.

d) Right to erasure (right to be forgotten)

Any person concerned by the processing of personal data has the right to obtain from us the erasure without delay of personal data concerning him or her, where one of the following grounds applies and insofar as the processing is not necessary.

the personal data were collected or otherwise processed for such purposes for which they are no longer necessary.
the data subject revokes the consent on which the processing was based pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9(2)(a) GDPR and there is no other legal basis for the processing.
the data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
the personal data have been processed unlawfully.
the erasure of the personal data is necessary for compliance with a legal obligation to which we are subject to.
the personal data have been collected in relation to information society services offered pursuant to Art. 8(1) GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to arrange for the deletion of personal data stored by LeadUpp, he or she may, at any time, contact LeadUpp. LeadUpp will arrange for the deletion request to be complied with immediately.

If the personal data has been made public by LeadUpp and our company is responsible pursuant to Art. 17 Para. 1 GDPR to erase personal data, LeadUpp shall implement reasonable measures, including technical measures, taking into account the available technology and the cost of implementation, in order to inform other data controllers which, process the published personal data that the data subject has requested from those other data controllers to erase all links to or copies or replications of the personal data, unless the processing is necessary. LeadUpp will arrange the necessary in individual cases.

e) Right to restriction of processing

Any person affected by the processing of personal data has the right to request us to restrict processing if one of the following conditions is met:

The accuracy of the personal data is contested by the data subject for a period enabling us to verify the accuracy of the personal data.
The processing is unlawful, the data subject objects to the erasure of the personal data and requests instead the restriction of the use of the personal data.
We no longer need the personal data for the purposes of the processing, but the data subject needs it for the assertion, exercise or defence of legal claims.
The data subject has objected to the processing pursuant to Article 21(1) of the GDPR, and it is not yet clear whether the legitimate grounds override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of personal data stored by LeadUpp, he or she may, at any time, contact LeadUpp. LeadUpp will arrange the restriction of the processing.

f) Right to data portability

Every person affected by the processing of personal data has the right to receive the personal data concerning him or her which has been provided by the data subject to a controller in a structured, commonly used and machine-readable format. The data subject shall also have the right to transmit such data to another controller without hindrance from us to whom the personal data have been provided, provided that the processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Article 9(2)(a) of the GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in LeadUpp.

Furthermore, when exercising the right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to obtain the direct transfer of personal data from one controller to another controller where technically feasible and provided that this does not adversely affect the rights and freedoms of other persons.

In order to assert the right to data portability, the data subject may at any time contact LeadUpp.

g) Right of objection

Any person affected by the processing of personal data has the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her which is carried out on the basis of Art. 6 para. 1 lit. e and f GDPR.

LeadUpp shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the assertion, exercise or defence of legal claims.

If LeadUpp processes personal data for the purpose of direct marketing, the data subject shall have the right to object at any time to processing of personal data processed for such marketing. If the data subject objects to LeadUpp to the processing for direct marketing purposes, LeadUpp will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her which is carried out by LeadUpp for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

In order to exercise the right to object, the data subject may directly contact LeadUpp. The data subject is also free, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise his or her right to object by means of automated procedures using technical specifications.

h) Right to withdraw consent under data protection law

Any person affected by the processing of personal data has the right to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, he or she may, at any time, contact LeadUpp.

California Requirements: This Privacy Policy describes the categories of personal data we may collect and the sources of such information, and our retention and deletion practices. We also included information about how we may process your information, which includes “business purposes” under the California Consumer Privacy Act (CCPA). We do not sell your personal information for the intentions and purposes of CCPA. We may disclose personal data to third parties or allow them to collect personal data from our services as described hereinabove, if those third parties are authorized third party services providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data.

If you have any questions or would like to exercise your rights under the CCPA, you can contact us by email.

Please note that when you ask us to exercise any of your rights under this Privacy Policy or applicable law, we may instruct you on how to fulfill your request independently; refer you to your admin; or require additional information and documents, including certain personal data and credentials in order to process your request in a proper manner (e.g. in order to authenticate and validate your identity so that we know which data in our systems relates to you, and where necessary, to better understand the nature and scope of your request). Such additional information will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request, and of how each request was handled), in accordance with this Privacy Policy. We may redact from the data which we make available to you, any personal or confidential data related to others.

Data Controller/ Processor

Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller”, who determines the purposes and means of processing; and the “data processor”, who processes such data on behalf of the data controller. Below we explain how these roles apply to our services, to the extent that such laws and regulations apply.

LeadUpp is the “data controller” of its prospects, Users and Business Customers personal data, as detailed in sections above. Accordingly, we assume the responsibilities of a data controller (solely to the extent applicable under law), as set forth in this Privacy Policy.

LeadUpp is the “data processor” of personal data contained in the data provided by the Business Customer. We process such data on behalf of our Business Customer (who is the “data controller” of such data) and in accordance with its reasonable instructions, subject to this Policy (to the extent applicable) and other commercial agreements with such Business Customer. Our Business Customers are solely responsible for determining whether and how they wish to use our services, and for ensuring that all individuals using the services on the Business Customer’s behalf or at their request, as well as all individuals whose personal data may be included in data provided by the Business Customer processed by us, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, use or other processing of data through us are fully met by the Business Customer.

Name and address of the data controller/ processor

LeadUpp Private Limited

No. 8, S No. 80/2, Pl No. 10,

Baner Road, Aundh, Pune 411007

E-mail: hola@leadupp.co

Website: https://leadupp.co/

Legal basis of processing

We use personal data for the following purposes, and in accordance with the legal bases as provided hereinbelow:

Enable us to provide the services and the Training Program;
Ensure that our website or Training Program is presented in an effective manner for you and for your device;
Provide you with marketing information about us and our services, including personalised marketing;
Notify you about changes to our Training Program;
Carry out our obligations arising out of our contracts with you or your institution;
Implement precontractual measures
Keep the Training Program and the website secure;
Improve user experience on our Training Program;
Enable us to be legally compliant;
Defend our servers against malicious attacks;
Communicate with you.

We process your personal data for these purposes based on our legitimate interests or a third party’s legitimate interest, as the case may be, to ensure we provide our Training Program in an effective, safe and efficient manner.

Where we process your personal data for administering your account, or to the extent necessary to allow you to access our Training Program, we do so for the purposes of our contract with you or the relevant Business Customer.

We do not undertake automated individual decision, including profiling, which produces legal effects concerning the Data Subject or significantly affects the Data Subject. However, in certain cases where such automated individual decision is undertaken, the same is necessary for the purposes of performance of our contractual obligations with the Business Customer and for the provision of our services. By using our Training Program, the Data Subject expressly consents to the same.

Our Use Of Aggregated And Anonymized Information

We may share anonymized usage data which does not identify you specifically with third parties. We may combine your data with those of other users of our website/ Training Program and share this information in aggregated and anonymized form with third parties to help us improve the design and delivery of our Training Program, increasing the effectiveness for all users.

Duration for which the personal data are stored

The criterion for the duration of the storage of personal data is the respective statutory retention period. After the expiry of the period, the corresponding data is routinely blocked or deleted or anonymised, provided that it is no longer required for the fulfilment of the contract or the initiation of the contract.

When and with whom do we disclose your Personal Data?

We may share your information with organisations that help us provide the services described in this policy and who may process such data on our behalf and in accordance with this policy, to support our services.

Typically, and unless otherwise stated in this policy, data may be shared on the basis of our contractual and pre-contractual obligations. Equally, if you have consented to it, or where we have a legal obligation to do so or on the basis of our legitimate interests (e.g., when using agents, hosting providers, technical service providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to perform our contractual obligations, administrative tasks and duties efficiently and effectively).

If we commission third parties to process data, it shall be on the basis of a "processing agreement".

In relation to metadata obtained about you, we may share a cookie identifier and IP data with analytic service providers to assist us in the improvement and optimisation of our website or Training Program which is subject to our Cookies Policy as defined above.

We may also disclose information in other circumstances such as when you agree to it or if the law, a Court order, a legal obligation or regulatory authority ask us to. If the purpose is the prevention of fraud or crime or if it is necessary to protect and defend our right, property or personal safety of our staff, the website / Training Program and its users.

Integration Of Services and Contents of Third Parties

We use within our website and/ or Training Program, on the basis of our legitimate interests, content or services offered by third-party providers in order to integrate their content and services.

This always requires that the third-party providers of this content are aware of your IP address, since the content or service could not send to your browser without the IP address. The IP address is thus required for the display of this content, and we endeavour to use providers that only use your IP address for the delivery of the content or services. However, Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our website and/ or Training Program, as well as be linked to such information from other sources. These technologies are subject to the Privacy Policies of such third party providers. We encourage you to carefully read the terms and privacy policies of such third party providers. We have no liability or responsibility for the content, activities of such third party providers.

Children Data

Our website and Training Program is not intended for children, and we do not knowingly collect data relating to children. If you become aware that your Child has provided us with Personal Data, without parental consent, please contact us and we will take the necessary steps to remove that information from our server.

Data security and International transfers

The security, integrity, and confidentiality of your information are extremely important to us. LeadUpp takes appropriate technical and administrative security measures to protect your personal data from loss and misuse.

Our main operations are based in India and your personal information is generally processed, stored and used in global data centres of HostGator and Digital Ocean both in the USA, as well as Google Firebase in case of a free trial. We take steps to ensure there is an appropriate level of security, so your personal information is protected in the same way as if it was being used within the EU and the EEA. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.

In the event that the security of information and/or personal data is breached as a result of a security failure, we will immediately, and not later than any period specified under any applicable law, notify the Users whose personal information security is breached.

Where we have given you a username, password and/or security information which enables you to access the Training Program, you are responsible for keeping these access credentials confidential. You must not share these details with anyone, or store them in a way that may allow a third party to access them.

Where we need to transfer your data outside the EU and the EEA, we will use one of the following safeguards:

The use of approved standard contractual clauses in contracts for the transfer of personal data to third countries.
Transfers to a non-EEA country with privacy laws that give the same protection as the EEA.

Google Firebase

We use the Firebase service in our Free Trial, a service provided by Google LLC ("Google"), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

The Firebase is a web hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on the location from which our website/ Training Program is accessed. Firebase is a fast, fully managed, serverless, cloud native NoSQL database that simplifies the storage, synchronization and retrieval of data for mobile, web and IoT applications worldwide.

The Firebase is used by us to store data of users (name, email address, number, organization name, country, date and time of access, choices made, notes, scores and feedback etc.). Google processes the data on our behalf in order to transmit data stored to your terminal device. Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

By integrating Firebase, we pursue the purpose of being able to offer you a better service within the scope of our website and Training Program. The legal basis for the processing of personal data described here is our legitimate interest. The use of Google Firebase gives us the opportunity to provide you with better use and information through our website/ Training Program.

As part of the processing, Google is entitled to use subcontractors. A list of these subcontractors can be found at https://privacy.google.com/businesses/subprocessors/.

For further information on data handling in connection with Google Analytics, please refer to Google's privacy policy:

https://support.google.com/analytics/answer/6004245?hl=en

https://firebase.google.com/support/privacy

Information on Google's privacy settings can be found at https://privacy.google.com/take-control.html?categories_activeEl=sign-in.

Google Analytics

We use Google Analytics, a service provided by Google Inc. This means that the data collected can in principle be transmitted to a Google server in the USA, whereby the IP addresses are anonymised by means of IP anonymisation so that an allocation is not possible. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can object to the collection and processing of this data by Google Analytics by setting an opt-out cookie that prevents the future collection of your data when you visit this website: http://tools.google.com/dlpage/gaoptout?hl=en.

Facebook Remarketing

Within our website, so-called "Facebook pixels" of the social network Facebook, which is operated by Meta Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are a resident of the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"), are used. With the help of the Facebook pixel, it is possible for Facebook to determine the visitors to our website/ Training Program as a target group for the display of advertisements, so-called "Facebook ads". Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our website or Training Program. This means that with the help of the Facebook pixel we want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook pixel, we can also track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad.

The Facebook pixel is directly integrated by Facebook when our website / Training Program are accessed and can save a so-called cookie, i.e., a small file, on your device. If you subsequently log in to Facebook or visit Facebook while logged in, your visit to our website will be noted in your profile. The data collected about you is anonymous for us, so it does not allow us to draw any conclusions about the identity of the user. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible. The processing of the data by Facebook takes place within the framework of Facebook's data usage policy. Accordingly, you can find more information on how the remarketing pixel works and generally on the display of Facebook ads, in Facebook's data usage policy: https://www.facebook.com/policy.php

You can object to the collection by the Facebook pixel and use of your data for the display of Facebook ads. To do so, you can visit the page set up by Facebook and follow the instructions there on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads or declare the objection via the US page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform-independent, i.e., they are applied to all devices, such as desktop computers or mobile devices.

Google Maps

We use the Google Maps service in our admin panel and game. If you are logged in to Google, your data will be directly assigned to your account. If you do not want your data to be associated with your Google profile, you must log out before. Google stores your data as usage profiles and uses them for the purposes of advertising, market research and/or designing its own services in line with requirements. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our services. You have the right to object to the creation of these user profiles, and you must contact Google to exercise this right.

Our website uses functions of the network LinkedIn. The service provider for these functions is the LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. For more information, please see LinkedIn’s privacy policy at: www.linkedin.com/legal/privacy-policy.

Vimeo

Our website uses embedded videos of the video portal Vimeo. The provider is Vimeo Inc, 555 West 18th Street, New York, New York 10011, USA. For more information, please see Vimeo’s privacy policy at: https://vimeo.com/privacy.

MailChimp

We use MailChimp (Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA) for sending Promotional Communications. With the help of MailChimp, we can analyse our newsletter campaigns. When you open an email sent with MailChimp, a file contained in the email (so-called web-beacon) connects to MailChimp's servers in the USA. This makes it possible to determine whether a newsletter message has been opened and which links, if any, have been clicked on. In addition, technical information is recorded (e.g., time of retrieval, IP address, browser type and operating system). This information cannot be assigned to the respective newsletter recipient. It is used exclusively for the statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients. For more details, please refer to the privacy policy of MailChimp at: https://mailchimp.com/legal/terms/.

Changes

This policy and our commitment to protecting the privacy of your personal data can result in changes to this policy. Please regularly review this policy to keep up to date with any changes. Your continued use of the website/ Training Program after the changes have been implemented will constitute your acceptance of the changes.

Queries and Complaints

Any comments or queries on this policy should be directed to us at hola@leadupp.co. If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us.