LAST UPDATED: June 17, 2019
- Information Collection
- General Use. We collect, process, and retain information from you and any devices (including mobile devices) you may use when you: register for an account with us; update or add information to your account; participate in community discussions, chats, or dispute resolution; engage or communicate with us, other users or third parties in connection with the Services; post or complete referrals and relationship management transactions using the Services; or otherwise access, use or download any part or whole of the Services. Such information includes without limitation:
- identifying information such as your name, address, telephone number and email address;
- information or content you provide in the course of using the Services, such as identifying information relating to any third party you are referring to another user of the Services;
- geographic or location information, which data may be precise or imprecise;
- content of your communications via the Services;
- financial information (such as credit card or bank account numbers) in connection with the Services;
- information relating to the performance of the Services you experience; and
- information you provide via web form, community discussion, chats and dispute resolution.
- Automatic Collection. By using the Services, we may automatically collect information about how you use the Services, the areas of the Services that you visit, as well as information about your computer or mobile device, such as your Internet protocol (IP) address, device ID, physical location, browser and operating system type, resolution of your screen, language settings in your browser, referring URLs, and other technical information. This information is necessary for providing personalized and location-based content and services as well as for analyzing web traffic, troubleshooting problems, preventing fraud, and improving the Services.
- Third Party Data. We may obtain data from third parties. We protect data obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of the data and applicable laws. These third-party data sources vary over time, but may include without limitation: data brokers from which we purchase demographic data to supplement the data we collect; social networks when you grant permission to us to access your data on one or more networks, service providers that help us determine a location based on your IP address in order to customize certain products to your location, and partners with which we offer co-branded services or engage in joint marketing activities.
- Feedback. Any suggestions or comments for improving or modifying the Services that are included in your communications with us (“Feedback”) will be deemed to be non-confidential and non-proprietary to you, and you agree that: (a) Lead Bank is therefore not subject to any confidentiality obligations with respect to the Feedback; (b) the Feedback is not confidential or proprietary information of any third party and you have all of the necessary rights to disclose the Feedback to us; (c) Lead Bank may irrevocably freely use, reproduce, publicize the Feedback; and (d) you are not, nor is any other party, entitled to receive any compensation or reimbursement of any kind from us in relation to the Feedback.
- Information Use
You hereby consent to our using any of the information we collect on you (the “Information”), which includes without limitation your Personal Information:
- to deliver our Services to you;
- to improve our Services in order to better serve you;
- to provide you with a personalized experience when using our Services;
- to provide targeted advertising to you;
- to appropriately respond to your communications and provide you with customer service;
- to contact you about feature updates and informational and service-related communications;
- for internal statistical, marketing or operational purposes, including without limitation generating sales reports and measuring and understanding demographic, user interest, purchasing and other trends among our customers; and
- Information Disclosure
- Other Users. When interacting with another user, the other user may request and we may provide him/her with your Personal Information as necessary for the ordinary use of the Services, such as your name, account ID, email address or contact details. The other user receiving your Personal Information is not allowed to use such information for purposes unrelated to the transactions or services engaged, such as to contact you for marketing purposes, unless you have express consented to it. Contacting users with unwanted or threatening messages is a violation of our Agreement. Other users may be provided Personal Information about you that is necessary to facilitate the ordinary use of the Services.
- International Transfer and Storage. Your Information may cross international borders in order to facilitate the Services. In some cases, your Personal Information may be disclosed, processed, and stored outside Canada, and therefore may be available to government authorities under lawful orders and laws applicable there.
- Information Security
We protect your Personal Information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, and information access authorization controls. If you believe your account has been abused, please contact us. Lead Bank follows generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
- Third Party Policies
We cannot guarantee the privacy or security of your Personal Information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of each such third-party before any such engagement or disclosure. This is true even where the third parties to whom you disclose Personal Information are other users of our Services.
The Services may contain links to third party websites or applications that are not owned, maintained or operated by Lead Bank. Any such links are provided solely as a convenience to you and not as an endorsement by Lead Bank. Lead Bank is not responsible for the content of such linked third-party websites or applications and does not make any representations, warranties or guarantees regarding the content or the privacy practices of such third parties. For certainty, Lead Bank disclaims any liability associated with your access to, use of, download of, or reliance on, such third-party websites or applications and their content. If you decide to access, use or download any such third-party website, application or content, you do so at your sole risk.
If you do not wish to accept cookies, you have the option of blocking or disabling cookies. Your computer provides you with the ability to clear all cookies that have been stored onto your hard drive, should you wish to do so. However, please be aware that you may be unable to access certain parts of the Services if you block or disable our cookies.
- Marketing & Advertising
The Services are not intended for, nor does Lead Bank knowingly collect information from, children under the age of fourteen (14). If we learn that we have collected Personal Information from a child under fourteen (14), we will take steps to delete the information as soon as possible. If you are aware of a user under the age of fourteen (14) using the Services, please contact us immediately.
- Withdrawal of Consent & Changes to Personal Information
Lead Bank takes reasonable steps to help ensure that the Personal Information we collect from you is accurate, complete and current. You may request access to your Personal Information and request that erroneous or inaccurate Personal Information be updated.
- Data Retention
Lead Bank retains Personal Information for as long as necessary to provide the Services and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly.
After it is no longer necessary for us to retain your Personal Information, we dispose of it in a secure manner according to our data retention and deletion policies. We are not responsible for any liability or loss you experience as a result of our disposal of Personal Information.
- Contact Us
If you have any questions about Lead Bank’s privacy and data management policies, contact our Privacy Officer at firstname.lastname@example.org.