PRIVACY POLICY OF LEOPOLY KFT.

2018

This privacy policy (“Policy”) explains how Leopoly Kft. a corporation operating under the laws of Hungary (registered seat: H-4028 Debrecen, Kassai út 26., Hungary, registration number: 09-09-026892, tax number: 25185991-4-09; hereinafter: (“Leopoly”, “Company” “we” or “us”) processes personal data collected from our users (“you” or “user” or “Data Subject”) in connection with the Leopoly services (“Services”) available through our mobile device application (“Application”) and the website located at https://leopoly.com/ (“Website”) or subscribing to our newsletter (“Newsletter”).

The processing and collecting of personal data by Leopoly shall be in harmony with the directly applicable laws of the European Union and the provisions of the Hungarian laws in effect. In case of personal data processing, the Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter: “GDPR”), the Act CXII of 2011 on the Right to Informational Self-determination and Freedom of Information (hereafter: “Freedom of Information Act”), the Act XLVIII of 2008 on the Essential Conditions and Certain Limitations of Business Advertising Activity (hereinafter: “Business Advertising Act”), furthermore the recommendations and the data protection practice of the Hungarian National Authority for Data Protection and Freedom of Information (hereinafter: “NAIH”) and the recommendations of the Article 29 Data Protection Working Party (hereinafter: “WP29”) shall apply.

We will keep confidential the personal data received and take all necessary steps to secure data processing.

1. DEFINITIONS

The following definitions are determined according to the GDPR:

  1. ‘personal data’: shall mean any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
  2. ‘consent’: shall mean any freely given, specific, informed and unambiguous indication of the will of the Data Subject by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
  3. ‘data controller’: shall mean the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
  4. ‘data processing’: shall mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  5. ‘data processor’: shall mean a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
  6. ‘third party’: shall mean a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;
  7. ‘personal data breach’: shall mean a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;
  8. ‘recipient’: shall mean a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with European Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
  9. ‘supervisory authority’: shall mean one or more independent public authorities provided by each Member State which is responsible for monitoring the application of the GDPR in order to protect the fundamental rights and freedoms of natural persons in relation to processing and to facilitate the free flow of personal data within the European Union;
  10. ‘supervisory authority concerned’: shall mean a supervisory authority which is concerned by the processing of personal data because: (i) the controller or processor is established on the territory of the Member State of that supervisory authority; (ii) data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or (iii) a complaint has been lodged with that supervisory authority.

As stated above, Leopoly is the data controller of any data which constitutes personal data and is uploaded and collected when using the Website or the Service or subscribing for the Newsletter.

2. WHAT INFORMATION DOES LEOPOLY COLLECT?

The information we gather from users enables Leopoly to personalize and improve our services and to allow our users to set up accounts on the Website. We collect the following types of information from our users:

  1. Information You Provide to Us on the Website:

    We receive and store any information you enter on our Website or provide to us in any other way using the Services. The types of information collected include, without limitation, email address, user name and password, avatar picture, “about” text, your 3D objects, and description about it.

  2. Information Collected Automatically:

    We receive and store certain types of information whenever you use the Website:

    When you visit our Website, Leopoly automatically receives and records information on our server logs from your browser including your IP address, unique device identifier, browser characteristics, domain and other system settings, search queries, device characteristics, operating system type, language preferences, referring URLs, actions taken on our Website, page requested and parts visited of our Website, dates and times of Website visits, and other information associated with other files stored on your device.

  3. Information Collected Through the Application:

    We receive and store certain types of information whenever you use the Application. The types of information collected include, without limitation the number of saves, the type of models saved, date of registration, date of last use.

  4. Information you choose to display publicly on the network:

    Some users may elect to publicly post personally identifying or sensitive information about themselves in their normal use of the network. This could occur through use of the optional profile fields, in question or answer posts, or when an individual posts a job history on the careers site. Information like that, which is voluntarily posted in publicly visible parts of the network, is considered to be public, even if it would otherwise be considered to be personally identifying or sensitive. As such, it is not subject to the protocols listed below, because we don’t control it; you do. Additionally, voluntarily publicizing such information means that you lose any privacy rights you might normally have with regards to that information. It also increases your chances of receiving unwanted communications, like spam.

  5. Children merit specific protection:

    We do not collect any personally identifiable information from children under the age of 16. If you believe that a child has provided us with personally identifiable information without the consent of his or her parent or guardian, please contact us at hello@leopoly.com. If we become aware that a child under age 16 has provided us with personally identifiable information, we’ll delete it.

3. What About Cookies?

We collect mainly anonymous data from the Website, such as searches. The anonymized data can include user session data such as IP address, web browser type, the time spent on the page by the user, and user-clicked buttons. Leopoly processes anonymous data in order to improve the page, to bring it to perfection. During this procedure Leopoly can incorporate “cookies”, which collect the visitor’s first level domain name, the date and the exact time of access. The “cookie” alone can’t be used to reveal the identity of the visitor. The “cookie” is a file, which is sent to the browser of the visitor and stored on the hard drive of the visitor. Cookies don’t damage the computer of the visitor. The browser can be set to indicate when a cookie is received, so the visitor can decide to accept the so-called cookie or not. We do not collect or manage any information that would allow the identification of the visitor.

4. How Does Leopoly Use My Information?

We may use your information, including your personal information - based on diverse purposes as well as the legal basis of the processing - as follows:

  1. We process the following personal data for the purpose and on the legal basis of the performance of the contract, product and service fulfillment:

    • User name
    • Email address
    • Password

    The above information you provide is used for purposes such as responding to your requests for certain products and services, customizing the content you see, communicating with you about specials, sales offers, and new features, and responding to problems with our services. It is also used to manage payments, issuing the invoice or requests for information, or to otherwise serve you, provide any requested services and administer sweepstakes and contests.

  2. We process the following personal information based on your consent (as the legal basis of this processing) for marketing purposes, to deliver coupons, mobile coupons, newsletters, receipt messages, e-mails, and mobile messages. We also send marketing communications and other information regarding services and promotions based on your consent and administer promotions:

    • Email address
    • Avatar picture
    • "About” text

    You shall always have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on your consent before your withdrawal.

    We may post user testimonials on the Website to reflect the experiences and honest opinion of the users regarding the Application. These testimonials contain the name and the profile picture of the reviewers, which is considered personal data. We may only post the testimonials after the prior consent of the users. The users shall have the right to update or delete their testimonials by an email sent to the following address of the customer service: hello@leopoly.com.

  3. We process personal data for the purpose and on the legal basis of compliance with legal obligations to prevent fraudulent transactions, monitor against theft and otherwise protect our customers and our business. We also process personal data for the purpose and on the legal basis of legal compliance and to assist law enforcement and respond to subpoenas.

  4. We process the following personal data for the purpose and on the legal basis of the legitimate interests of Leopoly, to improve the effectiveness/ of the Website, mobile experience, and marketing efforts, to conduct research and analysis, including focus groups and surveys and to perform other business activities as needed, or as described elsewhere in this Policy.

    Personal data collected when you visit our Website:

    • IP address
    • Unique device identifier
    • Browser characteristics
    • Domain and other system settings
    • Device characteristics
    • Operating system type
    • Language preferences
    • Referring URLs
    • Actions taken on our Website,
    • Page requested, and parts visited of our Website,
    • Dates and times of Website visits,
    • Number of saves
    • The type of models saved
    • Date of registration

    For collecting the above-mentioned data and making statistics and analysis we may use the following software and programs:

    NameRegistered seatCountry
    Google Analytics (Google LLC.) 1600 Amphitheatre Parkway Mountain View, CA 94043 United States
    Facebook pixel, Instagram (Facebook Inc.) 1601 Willow Road Menlo Park, CA 94025 United States
    Mailchimp 675 Ponce de Leon Ave NE
    Suite 5000
    Atlanta, GA 30308 USA    		 United States
    LinkedIn 1000 W. Maude Avenue
    Sunnyvale, CA 94085
    USA    		 United States
    Salesforce The Landmark @ One Market
    Suite 300
    San Francisco, CA 94105    		 United States
    Crazy Egg, Inc. 16220 East Ridgeview Lane, La Mirada, CA 90638, United States United States

    Personal data collected when you use the Application:

    • Actions taken in our Application,
    • Dates and times of Application visits,
    • Number of saves
    • The type of models saved
    • Date of registration,

    Leopoly uses both the above listed personal data and the derived aggregated data for statistical purposes as well.

  5. Cookies: Leopoly may use automatically collected information and cookies information to: (a) remember your information so that you will not have to re-enter it during your visit or the next time you visit the Website; (b) provide custom, personalized advertisements, content, and information; (c) monitor the effectiveness of our marketing campaigns; and (d) monitor aggregate usage metrics such as total number of visitors and pages viewed.

  6. Data integrity and purpose limitation: Leopoly will only collect and retain personal data which is relevant to the purposes for which the data is collected, and we will not use it in a way that is incompatible with such purposes unless such use has been subsequently authorized by you. We will take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete and current. We may occasionally contact you to determine that your data is still accurate and current.

5. How Long We Retain Your Personal Data?

We will retain your personal data for so long as it is needed to fulfill the purposes outlined in this Policy or until you withdraw your consent, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no longer or no legal basis to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. Rights of the Data Subjects

  1. Right to be informed, Right of access and to rectification: You have the right to obtain confirmation of whether or not we are processing personal data relating to you, have communicated to you such data so that you could verify its accuracy and the lawfulness of the processing and have the data corrected, amended or deleted where it is inaccurate or processed in violation of the GDPR.

  2. Right of Erasure: In certain circumstances, you may have a broader right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

  3. Right to Object to Processing: You may have the right to request us to stop processing your personal information and/or to stop sending you marketing communications.

  4. Right to Restrict Processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is inaccurate or unlawfully held).

  5. Right to Data Portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance.

7. Will Leopoly share any of the information it receives?

  1. Leopoly shall not ensure access for a third party to personal data provided by you without your preliminary consent, except the cases, when Leopoly’s data transfer is necessary for the performance of the contract, or for the purposes of the legitimate interests pursued by Leopoly, or prescribed by law.

  2. We share certain personal information with third party vendors in a third country who supply software applications, web hosting and other technologies for the Website. We will only provide these third parties with access to information that is reasonably necessary to perform their work or comply with the law. Those third parties will never use such information for any other purpose except to provide services in connection with the Website. We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. We may also request data process service for processing the personal data in a third country.

    During the service of data process the data processor shall abide under the present Policy, the relevant legislations in force, and the provisions of the existing contracts.

    We use the data process service of the following companies:

    Name Registered seat Country Activity (data processing service)
    Mailchimp 675 Ponce de Leon Ave NE
    Suite 5000
    Atlanta, GA 30308 USA    		 United States Marketing automation platform, that helps us to keep connection with our customers and audience.

  3. Transfer of Personal Data collected from individuals located within the EU:

    We only transfer personal data collected from individuals located within the EU to a third-party having a registered seat outside the EU or the United States of America acting as a data processor without appropriate safeguards when it is necessary for the performance of the contract. Leopoly will make every effort to ensure that the personal data transferred is safe and secure and that the personal data is processed in a manner consistent with the GDPR.

    Based on the adequacy decision by the Commission of the European Union regarding third countries like United States (Privacy Shield) ensures an adequate level of data protection. Due to the fact that our service provider Mailchimp has his registered seat in the USA and complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework, the transfer of your personal data to the mentioned service provider can take place.

8. Right to remedy

  1. You may exercise your rights by email sent to hello@leopoly.com or by a declaration addressed to us, sent by post to our registered seat.

  2. If you don’t agree with our decision, you have the right to an effective judicial remedy or to lodge a complaint to the NAIH (registered seat: H-1125 Budapest, Szilágyi Erzsébet fasor 22/C., Hungary, website: http://www.naih.hu), or to any other competent supervisory authority of the European Union Member State.

9. Amending the Policy

We reserve the right to change the Policy, or to modify it according to the changes in the applicable laws of the European Union law or the Hungarian law.

The present Policy shall enter into force on 25th May, 2018

10 Questions

If you have any questions concerning this Policy or the Services, please contact us at hello@leopoly.com. You can also contact us at our contact office at H-4028 Debrecen, Kassai út 26., Hungary.

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