Privacy Policy 

Effective Date: July 10, 2015

This Privacy Policy assumes agreement to our Terms of Service.

Leaderclips Inc. is the owner and operator of www.leaderclips.com (the “Website”) and the Leadersclips/GoMentum mobile applications and/or websites (collectively, “Leaderclips”), which are intended to supply various services as more fully described on the Website (the “Services”) to you, a user of the Services (“you” or “User”)

This Data Security and Privacy Policy (“Privacy Policy”) applies to websites operated in the European Union (“EU”) and constitutes an integral part of our Terms of Services and is subject to the provisions thereof, including with respect to Limitation of Liability and governing law.  We encourage you to read this Privacy Policy before you use our site and to read it again when we notify you of changes to the Privacy Policy that may be made from time to time.

We operate in accordance with applicable data protection legislation and are registered with the Information Commissioner’s Office in the UK.  We recognize the importance of protecting the privacy of individual-specific information (“Personal Information”) collected about our users (referred to as “users,” “you” or “your”). This privacy statement discloses what Personal Information we gather, how we use it, and how you can correct or change it.  It is our intention to give you as much control over your Personal Information as possible to preserve your privacy, while still allowing us to utilize that Personal Information in the course of our business to provide you a valuable service.

Children’s Privacy

We do not collect or maintain information on our website from those we know are under 13, and we do not permit children under 13 years of age to become registered users of our website. No part of our website is structured to attract anyone under 13. By using this website you represent that you are above 13 years of age.

Data Transfers

If you provide Personal Information to us it may be transferred to and processed on computers in the U.S. and other countries.  Do not provide your Personal Information to us through this website if you do not want this information to be transferred outside of your country, or if the laws in your country restrict these types of transfers.  Your provision of Personal Information to us will be handled in accordance with this Privacy Policy.  From time to time, your Personal Information may be transferred to a country different from where you are located.  Your legal rights may be different in these countries, but we will hold your Personal Information in accordance with this Privacy Policy.  You hereby consent to such transfers and processing as described in this Privacy Policy, except in the case of data transfers from the European Economic Area or Switzerland, which our covered under the EU Safe Harbor Framework.  Your provision of Personal Information to us through this website means that you agree to the terms of this Privacy Policy.

What is Covered in This Privacy Policy

This Privacy Policy clearly indicates:

1.  What Personal Information does Leadersclips collect?
2.  How does Leadersclips use Personal Information?
3.  With whom may Leadersclips share Personal Information?
4.  What choices are available to users regarding collection, use and distribution of Personal Information?
5.  What types of security procedures are in place to protect the loss, misuse or alteration of Personal Information under Leadersclips’ control?
6.  How can users correct any inaccuracies in their Personal Information maintained by Leaderclips?

Summary

Leaderclips will not share Personal Information about our customers with anyone other than those within our team that have custodial responsibilities for customer data.  Those within our team that have custodial responsibilities for customer data are limited to only the access that is required for the proper maintenance and care of customer data.

Any intentional misuse of customer data by a team member will result in sanctions, up to and including termination of employment.  Misuse includes sharing data with anyone outside our company, unnecessary or inappropriate access to or replication of data, and inappropriate deletion or manipulation of data.

What Information Do We Collect, and How is it Used?

When visiting the Website and/or using the Services, you may provide us with certain types of information, as described below.  As described in this Privacy Policy, Leadersclips occasionally collects Personal Information from the user.  In each case, you will only be required to provide the Personal Information that we need in order to be able to provide the services you have requested.

You may be entitled under data protection laws to access and review the Personal Information that we hold on you, provided you provide the necessary consent and background information and pay any mandated fee.  All such communications regarding access to your personal data should be addressed to: Leaderclips, Inc., P.O.Box 401, Sherborn, MA 01770 USA. Such enquiries should clearly be marked as data protection queries and as being time sensitive.

Registration (Sign-Up)

In order to use the Services, a user must first complete the registration form.  During registration, a user may be required to give contact information such as first and last name, email address, and a username and password.  We use this information to contact the user about Services for which they have expressed interest.  In order to use the Services, users must provide a username and password.

User Payment Information

When users access the Services, they must provide payment information (such as credit card number and expiration date).  This information is used for one-time and recurring billing purposes according to the type of Services ordered and the terms pertaining thereto, and to fulfill users’ orders.  If we have trouble processing an order, personal information is used to contact the user.  Payment information is stored in encrypted format, as more fully detailed below (see “Security” below) and is used only to send to our credit card processor, for the purposes of collecting payment for Services rendered or to be rendered.  We never make this information visible to anyone other than our credit card processor and never communicate it over a non-encrypted connection.  The full credit card number is never seen by anyone inside our company, once entered and submitted, except by the credit card processor for the purposes of authorizing, clearing and reversing charges to your credit card.

User Profile

We store Personal Information that we collect, and log files to create a profile of our users.  User profiles help tailor visits to our Website and to direct pertinent, Team Leader approved marketing promotions.

Cookies

When you visit the Website, we send one or more cookies to your computer or other device.  We use cookies to improve the quality of our Services, including for storing user preferences, improving search results and ad selection, and tracking user trends, such as how people search.  Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent.  However, some Leadersclips features and services may not function properly if your cookies are disabled.

This Privacy Policy covers the use of cookies by Leadersclips only and does not cover the use of cookies by any third parties.  Some of our business partners, such as Google Analytics and any third parties serving advertisements to our website, may use cookies on our Website in the future, and such cookies may collect anonymous traffic data.  However, we will have no access to or control over these cookies.

We use persistent cookies on our website which are cookies that stay in your web browser between visits. We use these to capture information about our visitors that helps us to improve the performance of our website and create a better experience.

Cookie Information

1. mtm_parse_sess_production

Purpose: Authentication

More info: Authentication cookie to identify the logged in user

2. mtm.sess2

Purpose: User Tracking

More info:  Additional information about the logged in user

3.  Persistent Cookie

Purpose: Google Analytics

More info:  These cookies are ‘analytical’ cookies.  They allow us to recognize and count the number of visitors and to see how visitors move around the site when they are using it.  These cookies help us to improve the way the website works, for example, by making sure users are finding what they need easily.

Most browsers are set up to accept cookies. If you want to change your cookie preferences, you can make these through your browser settings or refuse the cookies when you enter the website. Please remember that our cookies are often used to give you certain functionality and without them you may not be able to use some of our website e.g., save properties from our listings.

You can also remove cookies that have already been set in your browser via your browser settings. If you are having trouble doing this or would like more information, the website http://www.allaboutcookies.org/ has information on how to do this across a range of browsers. The Microsoft cookies guide is also a great source of information about what cookies do http://www.microsoft.com/info/cookies.mspx. If you have any questions about how we cookies please get in touch with us.

Log Files

Like most standard website servers, we use log files.  This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use.  Session IDs, IP addresses, etc. are not linked to Personal Information in our database, except as entered by the user during registration.  Session IDs and IP addresses entered during registration time by the user are tied to Personal Information to enable the provision of our Services.

Operational Procedures

Our operational procedures to provide data security and privacy including the following:

  • Limiting the number of people within our firm and business partner relationships that have access to detailed information about our customers and members.  Those that are granted access to perform their work responsibilities are trained on and agree to this policy.
  • We review our business partners, such as developers, data and application hosting providers, credit card processors, email vendors, and application distributors and their data security and policies to ensure that they that align with our positions on data security and privacy.
  • Internal procedures and practices are followed to protect our customer’s data, such as data encryption, complex password definition (with frequent revision and controlled access), and in some cases dual authentication requirements prior to data access.
  • Written agreements (physical or electronic signature) will be secured from customers and sponsor companies before information about that customer is shared within our system.  For example, prior to publishing information about a company within a team’s Fast Start (or other) customized information (videos, documents, product information), the Leaderclips team will obtain formal approval to publish Personal Information from designated Team Leaders.
  • We reserve the right to market directly to members of our user community that are associated directly with the default Leaderclips team and not one of our client companies.

User Communications

When you send email or other communications to Leadersclips, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.  When you send and receive SMS messages to or from one of our services that provides SMS functionality, we may collect and maintain information associated with those messages, such as the phone number, the wireless carrier associated with the phone number, the content of the message, and the date and time of the transaction.  We may use your email address to communicate with you about our services.

Surveys

From time-to-time our Website may request information from users via surveys.  Participation in these surveys is completely voluntary and the user therefore has a choice whether or not to disclose this information.  The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip/postal code).  Survey information will be used for purposes of monitoring or improving the use and satisfaction of the Website and/or the Services.

Supplementation of Information

In order for the Website to properly function, it is necessary for us to supplement Personal Information we collect with information from certain third party sources, including Google Analytics and our credit card processor.  We use https://stripe.com/ to process our users’ credit card transactions.  We may also use other third parties for credit card transactions.

Additional Information Use

In addition to the above, we may use Personal Information we collect from you and your computer to:

  • Provide, maintain, protect, and improve our Services (including advertising services) and develop new services; and
  • Protect the rights or property of Leadersclips or our users.

Leadersclips processes personal information on our servers in the United States of America and in other countries.  In some cases, we process personal information outside your own country.

What Information Do We Disclose?

Aggregate Information (non-personally identifying)

We share aggregated demographic and security vulnerability information with our users, partners and advertisers.  This is not linked to any Personal Information.

Information Sharing and Disclosure

We do not commercialize or share any Personal Information with 3rd parties, unless:

  • Such information is shared and/or commercialized following receipt of a specific request and/or permission from users;
  • Such information is shared with affiliated companies and/or potential investors (in any form of business transaction, including purchase or merger) pursuant to an agreement which contains reasonable confidentiality arrangements;
  • Such information is shared with contractors who work with us (in order to facilitate our business) pursuant to an agreement which contains reasonably confidentiality arrangements;
  • Such information is shared in order to comply with or in accordance with any applicable law and/or court orders and/or in order to prevent suspected illegal acts, frauds, situations involving potential threats to the safety of any person, or as otherwise required by law;
  • Such information is shared in order to help Leadersclips defend against claims and/or establish or exercise any legal right that Leadersclips may have;
  • Such information is shared in order to help Leadersclips prevent violations of Leadersclips’s Terms of Use and this Privacy Policy or to otherwise protect the rights, property, or safety of Leadersclips, or others, including exchanging information with third parties for fraud protection and credit risk reduction.

By using this website and providing your personal details to it, you consent to these transfers.

Business Transitions
In the event that Leadersclips goes through a business transition, such as a merger, being acquired by another company, or selling all or part of its assets, users’ Personal Information will, in most instances, be part of the assets transferred.  By using this website and providing your personal details to it, you consent to this transfer.

Services Announcements

It is often necessary to send out a strictly Services-related announcement.  For instance, if our Services are temporarily suspended for maintenance we might send users an email.  Generally, users may not opt-out of these communications, though they can deactivate their account.  However, these communications are not promotional in nature.

Customer Services Communications

We communicate with users on a regular basis via email to provide requested Services, offers, or information.  In regards to issues relating to their account, we reply via email or phone.

Links

The Website contains links to other sites.  Please be aware that we are not responsible for the privacy practices of such other sites.  We encourage our users to be aware when they leave our Website and to read the privacy statements of each and every Web site that collects Personal Information.

This Privacy Policy applies to Leadersclips services only.  We do not exercise control over the sites displayed as search results, sites that include Leadersclips applications, products or services, or links from within our various Services.  These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you.

Security

Leadersclips takes reasonable measures in order to safeguard users’ Personal Information.

Payment information (such as credit card number and/or national identification number) and information about the security vulnerability of users’ website is protected, by using Secure Sockets Layer (SSL) software, which encrypts the aforementioned information when viewed online.

While on a secured page, such as our order form, the lock icon on the bottom of Web browsers such as Firefox and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just surfing.

In addition, we limit access to Personal Information to employees who we believe reasonably need to receive such information to provide our Services or in order to do their jobs and take other precautions we deem reasonable to protect the security of users’ Personal Information.

However, users should be aware that we cannot fully guarantee the security of their Personal Information.  As in many computer systems, internet applications and software programs, unauthorized use, failure of hardware or software, etc.  may be injuriousness to the confidentiality of users’ Personal Information.

If users have any questions about security, please contact us at contact@leaderclips.com.

Correcting/Updating/Deleting/Deactivating Personal Information

If a user’s Personal Information changes, or if a user no longer desires our Services, we provide a way to correct, update or delete/deactivate users’ Personal Information.  This can usually be done at the Registered User account settings page or by emailing our Customer Support through contact@leaderclips.com.

When a request for user deletion is received, we will make all reasonable efforts to purge said data from our systems.  However, due to the nature of our service, some information may not be fully removed due to backups or archived copies; however, such information will only be used for the purpose of performing a contract that the user has entered into with us.

Notification of Changes

If we decide to change our privacy policy, we will post those changes to this privacy statement and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.  We will use information in accordance with the privacy policy under which Personal Information was collected.

Dispute Resolution 

Any questions or concerns regarding the use or disclosure of personal information should be directed to the Better Business Bureau at the address given below:

Council of Better Business Bureaus, Inc.

BBB EU Safe Harbor

3033 Wilson Boulevard, Suite 600

Arlington, VA 22201 U.S.A.

http://www.bbb.org/council/eusafeharbor/bbb-eu-safe-harbor-dispute-resolution-program/

Leaderclips will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Leaderclips and the complainant, Leaderclips has agreed to participate in the dispute resolution procedures of the Better Business Bureau pursuant to the Safe Harbor Principles.

Contact Information

If users have any questions or suggestions regarding our privacy policy including privacy, information use, collection, or security please contact us at contact@leaderclips.com.