We act as the controller of Your Personal Data, as we independently decide for what purposes we need them and choose services and tools for their processing.

We minimize the collection of Your Personal Data to the least amount required to use our Services.

Purpose	Legal ground	Your Personal Data
To provide requested services or answer questions	Contract	Name, surname, business e-mail address and Your title. During virtual meetings (if applicable): Your video-image or photo and voice data.
To offer other LeverX service to You based on Services You was previously interested	Legitimate interest to develop our business and satisfy LeverX clients’ needs as we appreciate You	Name, surname, business e-mail address, Company You worked in and Your title, information of the services You were interested.
To manage and optimize Your customer experience by improving our knowledge of our customer	Legitimate interest to improve the quality of our services	Name, surname, business e-mail address, date and time You logged in, time spent on our Website, information system, device, location (such as city and country), features You've been using, advertising that You click on.
To adapt our Website environment to Your / other LeverX clients’ needs	Legitimate interest to improve the quality of our services	Date and time, You logged in, time spent on our Website, information system, device, location (such as city and country), features You've been using, advertising that You click on.
To help spam detection	Legitimate interest to properly defend ourselves, be able to personalise and optimise our offers and Website for their improvement	Date and time, You logged in, time spent on our Website, information system, device, location (such as city and country) features You've been using, advertising that You click on.

The Data concerning You is collected also in order to realize the following functionalities of the Services: Your registration and authentication, communication with You, advertising, infrastructure monitoring.

We collect Your Data when You use the Services.

We get Your Data:

• directly from You;
• from Your browser that automatically transfers some data to us every time You access content on our Website (e.g. the URL of the particular web page You visited or the browser version that you are using to access the Website, date and time, You logged in, time spent on our Website, information system, device, Your location (such as city and country), features You've been using, advertising that You click on).

We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to us, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the Services (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us. The updated list of these parties may be requested from us at any time.

According to our principles of the Data processing all data is:

• Fairly and lawfully processed;
• Processed for a lawful specified purpose;
• Adequate, relevant and not excessive;
• Not kept for longer than necessary;
• Accurate;
• Processed in accordance with the individual’s (data subject’s) rights;
• Secure;
• Not transferred to other countries without adequate protection.

Data Analytics. The following providers collect Data over our Services. You may be able to opt out of Your usage data being tracked. Our providers may change, but we will try to update this list as that happens:

Google Analytics

Google Analytics provides web analytics services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

Microsoft Clarity

Microsoft Clarity provides web analytics services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Microsoft to ensure that they are properly protected.

Facebook Ads Pixel

Facebook Ads Pixel is a advertising tool that uses a short piece of code that is installed on our websites to track visitors. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Facebook to ensure that they are properly protected.

Linkedin Ads

Linkedin Ads is a advertising tool that uses a short piece of code that is installed on ourr websites to track visitors. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Linkedin to ensure that they are properly protected.

MailChimp

Mailchimp is an email service provider, that helps businesses with email and online marketing. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to MailChimp to ensure that they are properly protected.

HubSpot CMS Hub

HubSpot CMS provides web analytics services. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to HubSpot to ensure that they are properly protected.

Google Tag Manager

Google Tag Manager is a web analytics tool. Country: the USA. The relevant privacy policy. Unfortunately, the country of data recipient doesn’t ensure an adequate level of protection of Your Data. Standard Contractual Clauses are used to transfer Your Data to Google to ensure that they are properly protected.

We and our service providers use cookies and other technologies to receive and store certain types of information whenever You interact with our Services through Your computer or mobile device. A cookie is a small file containing a string of characters that is sent to Your computer when You visit a website. When You visit the website again, the cookie allows that site to recognize Your browser. Cookies may store unique identifiers, user preferences and other information. You can reset Your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. Some of our third party may use web beacons – small files used for tracking purposes.

There are four categories of cookies and web beacons used by the websites. Specifically, we use essential, performance, functionality and advertising cookies.

Essential cookies and other tracking technologies are necessary for the operation of the Services. These tracking technologies enable You to move around on the Services and use the Services features. You may not opt-out of these types of cookies because they are required to operate the Services.

Performance cookies and other tracking technologies collect information about how You have used the Services. We use performance cookies and other tracking technologies to improve the user experience with our Services.

Functionality cookies and other tracking technologies allow us to remember how You are logged into our Services, when You logged in or out and the actions You have taken while You have been logged into the Services.

Advertising cookies and other tracking technologies are used by our third-party service providers to deliver advertising to You on other third-party websites as well as help measure the effectiveness of our advertising campaigns. We also use these types of cookies to analyze Services’ visits and ad conversions from third-party websites.

The table below lists the types of cookies and third party service providers currently used by us but may not include all cookies or third party service providers. We do not control these third parties' tracking technologies or how they may be used. If You have any questions about an advertisement or other targeted content, You should contact the responsible provider directly. In addition, the below list of cookies and third party service providers is subject to change at any time.

Cookie Type	Tools We Use
Performance	Google Analytics Microsoft Clarity HubSpot Analytics Google Tag Manager
Functionality	HubSpot
Advertising	Google Analytics Microsoft Clarity HubSpot Google Tag Manager Facebook Ads Pixel Linkedin Ads MailChimp

You can learn more about online advertising cookies and Your ability to opt-out of certain online advertising cookies by visiting the following websites: http://www.aboutads.info/choices or http://www.networkadvertising.org/choices. All mobile and web browser settings are slightly different, so to manage cookies, You should refer to the relevant settings within Your device or browser.

For Your mobile device, You can understand which third parties have currently enabled cookies on Your mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative's website at: http://www.networkadvertising.org/mobile-choices from Your mobile device. On Your mobile device You may also select “Limit Ad Tracking” (on iOS devices) or “Opt out of Interest-Based Ads” (on Android).

For detailed information on how to disable and delete cookies in some commonly used web browsers, please visit:

Mozilla Firefox	https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
Microsoft Internet Explorer	https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11
Google Chrome	https://support.google.com/accounts/answer/61416?hl=en
Safari	https://support.apple.com/kb/PH21411?viewlocale=en_US&locale=en_US

Even if You disable cookies and tracking, keep in mind that You may still receive interest-based advertising, including from third parties with whom Your information had been previously disclosed and that You may still receive advertising from third parties, though such advertising may not be based on Your interests and preferences.

All users who are the subject of Personal Data held by us are entitled to:

• ask what information we hold about them and why;

This means that You can ask us what personal data of Yours is processed. You can also ask for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties which have access to information. You have a right to request from us Your personal data in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another controller, if the processing is based on Your consent or on contract and the processing is carried out by automated means;

• ask how to gain access to it;
• be informed how to keep it up to date;
• have inaccurate personal data corrected or removed;

This means You can require all the inaccurate personal data concerning You being corrected. You can also complete the personal data if You feel there is a need to do so;

• prevent us from processing information or request that it is stopped if the processing of such data is likely to cause substantial, unwarranted damage or distress to the individual or anyone else, etc.;

In some cases, prescribed by the applicable laws You can object to processing of Your personal data.

You have a right to object to processing of Your personal data when the processing is related to the performance of our task carried in the public interest or in the exercise of official authority vested in us; or we process Your data to pursue our or third party’s legitimate interests, and You believe that such interests are overridden by Your interests or fundamental rights and freedoms.

If You make a request objecting to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing.

Please note that when processing of Your personal data is carried for direct marketing purposes, You have the right to object at any time to such processing without providing any justification. We will no longer process Your data for such direct marketing purposes. You may refer to relevant sections of this Privacy Policy to learn whether we process Your data for direct marketing purposes;

• require us to ensure that no decision which significantly affects an individual is solely based on an automated process for the purposes of evaluating matters relating to him/her, such as conduct or performance;
• be informed what we are doing to comply with our obligations under the applicable data protection laws.

Subject to the personal data protection regulations applicable to You, You may request us to erase Your Personal Data without undue delay. The request shall be made on the legal grounds provided in the information protection regulations applicable to You, which include among other:

• the personal information is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• You withdraw Your consent on which the processing is based according to the provisions of the applicable to You information protection regulations and where there is no other legal ground for the processing;
• You object to the processing pursuant to the applicable information protection regulations and there are no overriding legitimate grounds for the processing, or the information subject objects to the processing;
• the personal information has been unlawfully processed;
• the personal information has to be erased for compliance with a legal obligation in the USA, European Union or the law to which we are subject.

You may also ask us to receive Your Data and have it transferred to another Data controller. In this case You have the right to receive Your Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

If You cannot access certain information and personal data collected by LeverX, You can always contact LeverX by using our contact form. We will respond to requests to access or delete Your personal data within 30 days.

Any requests to exercise Your rights can be directed to us through the contact details provided below.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or You provide as described in this Privacy Policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• For any other purpose disclosed by us when You provide the information.
• With Your consent.

We may also disclose Your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our clients, our customers, or others.

The security of Your Personal Data is important to us. We follow generally accepted standards to protect the Personal Data submitted to us, both during transmission and after it is received. We process Your Data using computers and/or other IT enabled tools. We take technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. We also guide and train our personnel to process Your data securely according to our internal data protection policies. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures. We may suspend Your use of all or part of the services without notice if we suspect or detect any breach of security. If You believe that Your account or information is no longer secure, please notify us immediately at compliance@leverx.com.

We retain Personal Data according to the type of information in question and the purpose for which it is used. We delete Personal Data within a reasonable period after we no longer need to use it for the purpose for which it was collected. We may archive Personal Data (for example, by storing it in inactive files) for a certain period prior to its final deletion, as part of our ordinary business continuity procedures or as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types, actual retention periods can vary significantly. The criteria used to determine the retention periods include, for instance:

• The period of data processing needed to provide Services. This includes such things as maintaining and improving Services, keeping our systems secure, and maintaining appropriate business and financial records. This is the general rule that establishes the baseline for most data retention periods.
• The data subject's consent for a longer retention period. If so, we will retain data in accordance with the consent.
• We are subject to a legal, contractual, or similar obligation to retain the data. Mandatory data retention laws can be applied in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

This section applies only to California consumers. It describes how we collect, use, and share California consumers' Personal Data in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act (“CCPA”) requires businesses to disclose whether they sell Personal Data. We are a business, and do not sell Personal Data. We may share Personal Data with third parties if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Data.

If You are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply You with the information You need in an alternative format that You can access.

For purposes of this section “Personal Data” has the meaning of “Personal Information” given in the California Consumer Privacy Act (“CCPA”).

We collect the following statutory categories of Personal Data:

Identifiers, such as name, business e-mail address, during virtual meetings with You – Your video-image or photo and your voice. We collect this information directly from You or from third party sources.

Internet or network information, such as browsing and search history. We (or our Service Providers) collect this information directly from Your device.

Geolocation data, such as IP address (if applicable). We (or our Service Providers) collect this information from Your device.

Other personal information, in instances when You interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys; or in providing the Services.

The business and commercial purposes for which we collect this information are described in Section “What Data, For What Purposes, Based On What Grounds, We Collect It?” of this Privacy Policy. The categories of third parties to whom we 'disclose' this information for a business purpose are described in Section Do we provide / disclose Your Data to the third parties?” of this Privacy Policy.

You have certain rights regarding the Personal Data we collect or maintain about You. Please note these rights are not absolute, and there may be cases when we decline Your request as permitted by law.

The right of access means that You have the right to request that we disclose what Personal Data we have collected, used and disclosed about You in the past 12 months.

The right of deletion means that You have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.

The right to non-discrimination means that You will not receive any discriminatory treatment when You exercise one of Your privacy rights.

You can exercise Your rights Yourself or You can alternatively designate an authorized agent to exercise these rights on Your behalf. Please note that to protect Your Personal Data, we will verify Your identity by a method appropriate to the type of request You are making. We may also request that Your authorized agent have written permission from You to make requests on Your behalf, and we may also need to verify Your authorized agent's identity to protect Your Personal Data. Please see our contact information below.

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users' Personal Data, we will notify You by email and through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for You, and for periodically visiting our Website and this Privacy Policy to check for any changes.