Effective Date: January 2020
This CCPA Privacy Notice for is specifically for California Residents / Consumers and supplements Leadiro's Privacy Statement. Leadiro has adopted this statement to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and other California privacy laws, and it applies solely to "residents" or “consumers” as either term is defined in the CCPA. Any terms defined in the CCPA have the same meaning when used in this Privacy Notice.
Over the past 12 months Leadiro has processed information containing Personal Data that could reasonably be associated with California residents / consumers across the following categories:
Identifiers & Personal information categories listed in the California Customer Records statute
Personal Information Collected:
- Business Email Address
- Job Title
- Business Phone Numbers (general and direct)
- Business Office Address
- Public Social Link
Categories of Sources from which this Personal Information was Collected:
- Publicly Available Information
- Directly and indirectly: from Leadiro's customers, partners, suppliers and from user activity on Leadiro’s website
We use your information for several purposes, such as:
- Providing our customers with access to a database of accurate Business Data Records designed to enable them to promote their goods and services using direct marketing to the right people (decision makers, influencers, champions etc.) in other businesses;
- Promoting your business so it can be found when searched for;
- Helping us keep you up to date about changes to the platform, its content, our services, changes in policies and other important notifications;
- Enabling you to interact with features or tools on our platform such as our live chat function;
- Providing you with the services we have, including billing for such services, and offering new services;
- Improving your user experience;
- Gathering analytics on usage and other statistics in order to improve features and functionality.
Categories of Third Parties with whom this Personal Information is Shared:
- Leadiro affiliates
- Service Providers
- Leadiro customers
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 prior notice.
Disclosure or Sale of Personal Information and the Right to Opt-Out
We sell personal information collected for our database to our customers. This database may contain information about consumers’ business personas including name, employer, job title, email address, phone number, office address, social media or professional profile link, and work or educational history. This information is sold to Leadiro’s customers for the purpose of business-to-business sales and marketing and recruiting and is provided subject to license agreements that limit its use to those purposes.
A consumer has the right to opt out of the sale of that consumer’s personal information by Leadiro by visiting our Privacy Center and submitting a request to remove the consumer’s profile or delete the consumer’s data. A consumer may also contact us by calling 833-901-0859 or by email to privacy@Leadiro.com. In order to submit a request, a consumer or an authorized agent will be required to demonstrate that such person has control of an email inbox associated with the profile in question. If such person cannot, then we may be contacted regarding other means of verifying such person’s identity or the authorization of a third party to exercise a consumer’s rights on that consumer’s behalf.
In the preceding twelve (12) months, we have sold or disclosed the following categories of personal information for a business purpose:
Category A: Identifiers Category A: California Customer Records personal information categories. Category I: Professional or employment-related information.
For avoidance of doubt, the personal information disclosed and/or sold by Leadiro within the identified categories is limited to business contact information related to a consumer’s profile as an employee of its employer. No sensitive personal information (i.e. Social Security number, passport number, medical or financial information) is collected, shared, disclosed, or sold by Leadiro.
We do not sell the personal information of minors under 16 years of age.
A Consumer’s Other CCPA Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes a consumer’s CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
A consumer has the right to request that we disclose certain information to that consumer about Leadiro’s collection and use of that consumer’s personal information over the past 12 months. Once we receive and confirm a consumer’s verifiable consumer request, we will disclose:
The categories of personal information we collected about that consumer.
The categories of sources for the personal information we collected about that consumer.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about that consumer (also called a data portability request).
Deletion Request Rights
A consumer has the right to request that Leadiro delete any of its personal information that we have collected and retained, subject to certain exceptions. Once we receive and confirm a consumer’s verifiable consumer request, we will delete (and direct our service providers and/or customers to delete) that consumer’s personal information from our records, unless an exception applies.
We may deny a consumer’s deletion request if retaining the information is necessary for us or our service providers or customers to:
1.Complete the transaction for which we collected the personal information, provide a good or service that a consumer requested, take actions reasonably anticipated within the context of our ongoing business relationship with that consumer, or otherwise perform our contract with that consumer.
2.Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3.Debug products to identify and repair errors that impair existing intended functionality.
4.Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5.Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6.Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if a consumer previously provided informed consent.
7.Enable solely internal uses that are reasonably aligned with consumer expectations based on a consumer’s relationship with us.
8.Comply with a legal obligation.
9.Make other internal and lawful uses of that information that are compatible with the context in which a consumer provided it.
Exercising Access, Data Portability, and Deletion Rights
By visiting Managing Your Data you can determine if Leadiro holds your personal business contact data (we do not process personal data such as personal emails, your home address etc.) and you can exercise your right to be removed automatically.
To submit a request to action any rights described above, please submit a verifiable consumer request to us by either:
Contacting us at email@example.com
Calling us at 888-515-5086
Only a consumer or a person registered with the California Secretary of State that a consumer authorizes to act on a consumer’s behalf, may make a verifiable consumer request related to a consumer’s personal information.
A consumer may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows Leadiro to reasonably verify a consumer is the person about whom we collected personal information or an authorized representative.
Describe a consumer’s request with sufficient detail that allows Leadiro to properly understand, evaluate, and respond to it.
We cannot respond to a consumer’s request or provide a consumer with personal information if we cannot verify the consumer’s identity or authority to make the request and confirm the personal information relates to that consumer. Making a verifiable consumer request does not require a consumer to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
Verifiable consumer requests will typically be responded to within 45 days. If we require more time (up to 90 days), we will notify the consumer as to why electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. If we can not comply with a request we will explain the reasons why. For all data portability requests personal information shall be supplied in a usable format to enable a consumer to transfer information from one entity to another entity without impediment.
We do not charge a fee for processing a consumer’s verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will explain why and provide the consumer with a cost estimate before completing their request.
We will not discriminate against a consumer for exercising any CCPA rights.
Changes to Our Privacy Statement
We reserve the right to make changes and update this privacy statement at our discretion and at any time. Please check back regularly to stay updated.
For questions or comments concerning this notice, our Privacy Statement, or your rights regarding the CCPA and how we process your data, please do not hesitate to contact us at:
WeWork Moorgate (UK) 1 Fore Street Avenue London, EC2Y 9DT