1. General

We are the controller in accordance with current privacy legislations. The Users’ personal data is processed with the purpose of managing and facilitating LEI applications, renewals, transfers and adjacent services.

2. Collection of personal data

We are responsible for the processing of the personal data that the Users contribute to the Service, or for the personal data that we in other ways collect with regards to the Service.

When and how we collect personal data

We collect personal data about Users from Users when they make an application through the Service or otherwise, adding personal data about themselves either personally or by using a third-party source.

We collect data from third parties, such as Facebook, LinkedIn, and through other public sources. This is referred to as "Sourcing" and is manually performed by our employees or automatically in the Service.

The types of personal data collected and processed

The categories of personal data that can be collected through the Service can be used to identify natural persons from names, emails, information from Facebook and LinkedIn accounts, answers to questions asked through the process, titles, and other information that the User or others have provided through the Service. Only data that is relevant for providing the Service is collected and processed.

Purpose and lawfulness of processing

The purpose of collecting and processing personal data is to manage the application, renewal, and transfer of LEI codes. The lawfulness of processing personal data is our legitimate interest in simplifying and facilitating this process.

Personal data that is processed with the purpose of aggregated analysis or market research is always made unidentifiable. Such personal data cannot be used to identify a specific User and is not considered personal data.

The consent of the data subject

The User consents to the processing of their personal data for the purpose of the Controller’s handling of recruiting. The User consents to personal data being collected through the Service when making an application through the Service, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn, and that the Controller may use external sourcing tools to add additional information.

The User also consents to the Controller collecting publicly available information about them and compiling it to provide the Service.

The User consents that the personal data collected as described above will be processed according to the sections on Storage and transfer and How long the personal data will be processed.

The User has the right to withdraw consent at any time by contacting the Controller using the contact details listed under section 9. However, using this right may prevent the User from using the Service.

Storage and transfers

The personal data collected through the Service is stored and processed inside the EU/EEA or such third countries that are considered by the European Commission to have an adequate level of protection. Data may also be processed by suppliers who have entered into binding agreements that comply fully with the lawfulness of third-country transfers, such as Privacy Shield, or other suppliers with adequate safeguards in place to protect the rights of the data subjects whose data is transferred. To obtain documentation regarding such safeguards, contact us using the contact details listed in section 9.

How long the personal data will be processed

If a User does not object in writing to the processing of their personal data, the personal data will be stored and processed as long as deemed necessary for the purposes stated above.

3. Users' rights

Users have the right to request information about the personal data that is processed by us, by notifying us in writing using the contact details below under paragraph 9. Users are entitled to one (1) copy of the processed personal data belonging to them without charge. For any additional copies requested, the Controller reserves the right to charge a reasonable fee based on the administrative costs associated with fulfilling the request.

Users have the right to request the rectification of inaccurate personal data concerning them by submitting a written request via the contact details provided in paragraph 9.

The User has the right to request the deletion or restriction of processing and the right to object to the processing based on legitimate interests under certain circumstances.

The User has the right to withdraw any previously given consent to processing. However, exercising this right may mean that the User can no longer use the Service.

Under certain circumstances, the User also has the right to data portability. This means that the User has the right to receive the personal data and transfer it to another controller, provided that this does not negatively impact the rights and freedoms of others.

The User has the right to lodge a complaint with the supervisory authority concerning the processing of personal data if the User believes that their personal data has been processed in violation of privacy laws.

4. Security

We prioritize personal integrity and work actively to ensure that the personal data of Users is processed with the utmost care. We take all reasonably expected measures to ensure that Users' personal data and the data of others are processed securely and in accordance with this Privacy Policy and the GDPR regulation.

However, transfers of information over the internet and mobile networks can never be completely risk-free, so all transfers are made at the risk of the person transferring the data. It is important that Users also take responsibility for ensuring their data is protected. Users are responsible for keeping their login information secure and confidential.

5. Transfer of personal data to third party

We will not sell or otherwise transfer Users’ personal data to third parties. We may transfer Users’ Personal Data to:

• Our contractors and sub-contractors, acting as our Processors and Sub-Processors in accordance with our instructions, for the provision of the Service;
• Authorities or legal advisors in case criminal or improper behaviour is suspected; and
• Authorities, legal advisors, or other actors, if required by us according to law or authority’s injunction.

We will only transfer Users’ personal data to third parties that we have confidence in. We carefully choose partners to ensure that the User’s personal data is processed in accordance with current privacy legislations.

6. Aggregated data (non-identifiable personal data)

We may share aggregated data to third parties. The aggregated data has in such instances been compiled from information that has been collected through the Service and can, for example, consist of statistics of internet traffic or the geological location for the use of the Service.

The aggregated data does not contain any information that can be used to identify individual persons and is thus not personal data.

7. Cookies

When Users use the Service, information about the usage may be stored as cookies. Cookies are passive text files that are stored in the internet browser on the User’s device, such as computer, mobile phone or tablet, when using the Service. We use cookies to improve the User’s usage of the Service and to gather information about, for example, statistics about the usage of the Service. This is done to secure, maintain and improve the Service.

Users can at any time disable the use of cookies by changing the local settings in their devices. Disabling of cookies can affect the experience of the Service, for example disabling some functions in the Service.

8. Changes

We have the right to, at any time, make changes or additions to the Privacy Policy. The latest version of the Privacy Policy will always be available through the Service. A new version is considered communicated to the Users when the User has either received an email informing the User of the new version (using the e-mail stated by the User in connection to the use of the Service) or when the User is otherwise informed of the new Privacy Policy.

9. Contact

For questions, further information about our handling of personal data or for contact with us in other matters, please use the below stated contact details:

Email: info@leipass.com