privacy

Leif Technologies, Inc.

PRIVACY POLICY

Last Update : March 1, 2020

Introduction

Leif Technologies, Inc. (“Leif”) respects your privacy. This privacy policy describes how Leif collects, uses, shares, and safeguards personal and non-personal data from interactions with our website at https://leif.org or Leif’s proprietary, cloud-based platform for managing income share agreements (ISAs), accessible through our website.

Please read this privacy policy carefully. By interacting with our website or the platform, or by telephone or paper or electronic communications with us, you consent to our privacy practices, as described in this policy. If you have questions or concerns regarding our privacy practices, please contact us using the contact information listed at the bottom of this page.

Information We Collect

Leif collects information based on your consent to the processing of the information for one or more specific purposes and as necessary to perform a contract or contracts, administer an ISA or ISAs, or comply with our legal obligations.

Personal Information

The types of personal information that we collect about you may include, among other things:

  • Identifying information, such as your full name, e-mail address, telephone numbers and account log-in information;
  • Personal Information, such as your full name, Social Security number and financial information;
  • Protected classification information, such as your age or marital status;
  • Commercial information, such as records of personal property;
  • Internet or other electronic network information, such as your interactions with our website, IP address and browsing history;
  • Geolocation information – such as physical location information;
  • Professional employment-related information, such as your current or past job history;
  • Inferences drawn from any of the information identified above.
Non-Personal Data

The types of non-personal information that we collect may include:

  • Site usage, such as traffic, location, and communication data, pages accessed, frequency and duration of access, and browsing history;

  • Computer type, hardware model, the device’s unique identifier, operating system, internet connection, IP address, and browser.

Statistical or aggregated non-personal information does not directly identify you or any specific person. However, we may obtain such information from your personal information. For example, we may aggregate personal information to calculate the number of users residing in a particular postal code.

Leif collects non-personal information to improve the usability of our website and the platform and for other business purposes.

How We Use Your Information

Leif collects information based on your consent to the processing of the information for one or more specific purposes and as minimally necessary to perform a contract or contracts, administer an ISA or ISAs, or comply with our legal obligations.

We collect your personal information: (a) to verify your identity as part of our procedures for the prevention and detection of fraud; (b) to administer an ISA or ISAs; (c) to communicate with you: (d) to provide our products or services to you; (e) to provide you with information that may interest you; (f) to improve the usability of our website and the platform; (g) to tailor content of our products or services; (h) for internal business purposes; (i) or for any reason that you provided the personal information to us.

Personal information remains part of our records until we determine the information is no longer needed, or we are required by law to delete such information. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Data Controller

Leif is a data controller and responsible for your personal information described in this policy.

Sale of Information

We do not sell and will not sell your personal information.

Personal Financial Data

Leif uses Stripe, a third party payment gateway, to process payments made through the platform. Although you use the platform to initiate payments and to manage transactions, Leif does not receive your financial information, such as bank account or credit card details, and Leif has no access to or control over the funds used to make payments. Stripe receives your personal financial information directly and is the data controller responsible for such information. Stripe’s privacy policy governs its privacy practices with respect to such information and is available at https://stripe.com/privacy .

Leif uses Plaid, a third-party service, to connect to user bank accounts. Although you may make payments through the platform, Leif does not receive bank login credentials and has limited, read-only access to a user’s bank account. Plaid receives bank credentials directly, and is the data controller responsible for such information. Plaid’s privacy policy governs its privacy practices with respect to such information and is available at https://plaid.com/legal/ .

Leif uses Payment Rails, a third-party service, to distribute stipends using bank account and routing numbers that you provide. As stated above, Leif does not receive bank login credentials and has limited, read-only access to a user’s bank account. Payment Rails’s privacy policy governs its privacy practices with respect to such information and is available at https://www.paymentrails.com/privacy .

How We Collect Information

We collect most of this personal information directly from you based on your interactions or relationship with our company in order to provide services, including information provided directly through our website or the platform, by telephone, by written correspondence through the mail, email or fax, or by viewing public media/network pages, or other information available online. However, we may also collection information:

  • From publicly accessible sources (e.g., property records or court records);
  • From our service providers (e.g., letter vendor, payment processing vendors, call analytics vendor, and/or electronic signature service provider);
  • Directly from a third party (including financial institutions, employers and tax authorities);
  • Consumer reporting agencies (CRAs)
  • From a third party with your consent (e.g., your authorized representative and/or attorney);
  • Outside companies or organizations that provide data to support activities such as fraud prevention, underwriting and marketing;
  • Through your interaction with our website or the platform, including data passively collected through technology such as “cookies.” This privacy policy covers our use of cookies and does not cover the use of cookies by third parties.

How We Use Cookies

A cookie is a small text file that is stored on a user’s computer or other device for record-keeping purposes. Cookies help website providers understand how users use a website, remember a user’s login details, and store website preferences. Our Sites use cookies and other technologies to function effectively. These technologies record information about your use of our website, including:

  • Browser and device data , such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting;

  • Usage data , such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.

You can remove cookies by following the directions provided by your browser. If you remove cookies, you can access our website or the platform, but your ability to use some of the features may be limited. In addition, we may use other technologies to identify you, store your preferences, prevent fraud, improve site or platform security, or assess the performance of our website or platform.

How We Share Information

Except as provided below, Leif does not share or disclose any personally identifiable information to any company or marketing group external to Leif. Leif may share personal information it collects with its employees who need to know that information to provide services to you. However, Leif may, share aggregate information with other persons or entities for purposes determined by Leif to be appropriate under the law, without restriction. For example, Leif may share your personal information with third parties to the extent it is reasonably necessary to manage or service your account, process payment, fulfill a transaction, provide customer service, or as otherwise authorized by law. In addition, we may disclose personal information that we collect:

  • to fulfill the purpose for which you provide it;
  • to our subsidiaries and affiliates;
  • to contractors, service providers, and other third parties who support our business and are contractually bound to maintain the confidentiality of the personal data and to use it solely for the purpose for which it was disclosed;
  • to administer an ISA or ISAs;
  • to third parties to market their products or services to you if you have consented to or have not opted out of such disclosures;
  • with your consent;
  • to comply with our obligations or enforce our legal rights;
  • to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our users is among the assets transferred;
  • to a third party pursuant to a subpoena, court order, or other form of legal process or in response to a request by or on behalf of any local, state, federal, or other government agency, department, or body, whether or not pursuant to a subpoena, court order, or other form of legal process, or in connection with litigation brought against, or on behalf of, Leif, where appropriate or as otherwise required by law;
  • if we reasonably believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company, our users, or others; or
  • for any other purpose disclosed by us when you provide the information to us.

Security of Your Personal Information

We take all reasonable steps to protect your personal information from unauthorized access, modification or disclosure, including misuse, interference, and loss. Leif has implemented physical, technical and administrative security safeguards to protect against the unauthorized release of or access to personal information. We employ internal and external system safeguards designed to protect confidentiality and security of personal information. Leif and its third party providers secure such information in accordance with industry standards.

We cannot guarantee the security of online transactions and communications sent electronically, as no electronic transmission or storage can be 100% secure. Our users provide information to us at their own risk. E-mail posted or sent to Leif may not be secure against interception by unauthorized individuals. To protect against interception by unauthorized individuals, or because we cannot verify your identity, we may be unable to respond to e-mail requests concerning your account unless you have requested or authorized us to do so.

The confidentiality of any communication or material transmitted to or from Leif via the website, via e-mail or SMS cannot be, and is not, guaranteed. You acknowledge that the technical processing and transmission of the website’s content may be transferred unencrypted and involve: (a) transmissions over various networks; and (b) changes to confirm and adapt to technical requirements of connecting networks or devices. Accordingly, Leif is not responsible for the security of information transmitted or received via the Internet or personal communication devices (such as a smart phone).

We are not responsible for the privacy or security practices of any third party, including our users, payment processors and any third parties to whom we disclose personal information. The collection, use, storage, and disclosure of your personal information by such third parties is subject to their own privacy and security policies.

We may make links available to you to access websites, products, or services that are not under our control, solely for your convenience. The owners or operators of such websites, products, or services maintain their own policies regarding privacy and terms of use, and they are solely responsible for content. We disclaim any responsibility for linked websites, products, or services that are not under our control.

We will collect the IP Address of all visitors to the Leif website for internal security and other proprietary purposes. We will do so even if you have included a Do Not Track request as there is no current industry standard for recognizing Do Not Track browser signals. We do not release this data outside of our corporate team nor utilize the data other than for internal purposes.

If you suspect any misuse or loss of, or unauthorized access to personal information, please let us know immediately by contacting us using the contact information provided at the bottom of this page.

Your Choices

Leif offers you certain choices in connection with the personal data it collects from you, including:

Your Account: Leif strives to ensure that any personal information that we collect, use, disclose, or store is accurate and complete. Our users are responsible for providing us with accurate, up-to-date information. You may review, update and correct your contact information, including your telephone number and email address, after logging in to the website. Leif is not responsible for any information provided to us that is inaccurate, incomplete, or outdated.

You have the choice to request access to, correction of, deletion of, or an explanation concerning our use or disclosure of your personal information. You also have the choice to withdraw your consent for the use or disclosure of your personal information. However, we are not required to comply with your request if one of several exceptions apply, including circumstances where is necessary for us or our service provider to maintain your personal information in order to complete the transaction with you; internal use that is reasonably aligned with your expectations; compliance with a legal obligation; or other use your personal data internally that is compatible with the context in which you provided it.

Your Choice to Decline Cookies: You may adjust your browser settings to decline cookies if you do not want to accept cookies. However, declining cookies may affect proper operation of the Leif website.

If you have questions or concerns regarding your rights, please contact us using the contact information provided in this policy.

Retention of Personal Information

Leif will retain your personal information until we determine the information is no longer needed or as otherwise required by law. Thereafter, we will take reasonable steps to destroy or permanently anonymize such information in accordance with applicable law.

California Residents - Your Legal Rights under the California Consumer Privacy Act

In addition to your rights under this policy, this notice explains certain rights California residents have under the California Consumer Privacy Act (“CCPA”).

As described in this policy, we may have collected the categories of personal information from you within the last 12 months. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:

  • The right to access personal information – You have the right to request access to your personal information that we collected about you in the previous 12 months, subject to certain exceptions. Please note that if your access request requires the disclosure of personal information of another individual, we won’t be able to comply with all of your access request. Similarly, if responding to your access request would cause us to violate any law, rule, regulation, or law enforcement request, Leif would not be able to fulfil your request.

  • The right to delete personal information –You have the right to request that we delete your personal information. However, we are not required to comply with your request if one of several exceptions apply, including circumstances where is necessary for us or our service providers to maintain your personal information in order to complete the transaction with you; internal use that is reasonably aligned with your expectations; compliance with a legal obligation; or other use your personal data internally that is compatible with the context in which you provided it.

  • The right to non-discrimination - We will not discriminate against you if you exercise any of these rights.

  • The right to an authorized agent – You can designate an authorized agent to make any of these requests by providing your express written authorization. We must be able to verify your identity and the authorization must include the authorized agent’s name, address, telephone number, and email address (for providing the personal information collected or to respond to a request for deletion). We may require you to directly confirm that you provided the authorized agent with permission to submit the request.

  • If you wish to exercise any of these rights, please contact Leif using the contact information set forth in this policy.

If you choose to contact Leif by [email/phone/in writing], you will need to provide us with:

  • Enough information to identify you [e.g., your full name, address and customer or contract ID number];

  • Proof of your identity and address (e.g., a copy of your driving license and a recent utility or credit card bill); and

  • Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. Leif is not responsible for the security or confidentiality of any information once it has been provided to you.

Canada Anti-Spam Law

We comply with the Canada Anti-Spam Law. Individuals who provide us with a Canadian mailing address will not receive unauthorized Commercial Electronic Messages (as defined by the Canada Anti-Spam Law), unless the individual has opted in to receive such messages.

Children’s Privacy

We have not designed our website and the platform for use by children under age 13. Leif does not knowingly collect information from children under the age of 13.

Links to Other Websites

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information, which you provide while visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Changes to the Privacy Policy

Leif reserves the right to change this policy without prior notice at any time and for any reason. You can determine whether we have changed our privacy practices by referring to the effective date at the bottom of this page. Any changes to the policy will become effective upon our posting of the revised policy on our website. Your continuing interaction with our website or with the platform constitutes your consent to the revised policy. We encourage you to review our website from time to time for changes to our privacy policy.

Contacting Us

Questions, comments, and complaints about Leif’s data practices can be submitted:

  • By email at support@leif.org ;
  • By telephone at 646-760-3318; or
  • By mail at 416 W. 13th Street, Suite 206, New York, NY 10014.