Effective starting: May 25, 2018
Leesman Ltd (company number 07202869 (“Leesman”, “we”, “us” or “our”) is committed to protecting your privacy and providing you with a safe and secure user experience as our client or on our website.
For the purpose of this policy the controller of personal data is Leesman and our contact details are set out in the Contact section at the end of this Privacy.
Right to Object:
You have a legal right to object at any time to:
· use of your personal information for direct marketing purposes; and
· processing of your personal information which is based on our legitimate interests, unless there are compelling legitimate grounds for our continued processing.
Key Changes– summary box of changes
- More control over your information. We make it easy for you to control the information you provide to us. Our policy explains how you can make choices about your information, and the measures we’ve put in place to keep your information secure.
WHAT THIS POLICY COVERS
Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:
1) What information we collect about you
2) How we use information we collect
3) How we share information we collect
4) How we store and secure information we collect
5) How to access and control your information
6) How we transfer information we collect internationally
7) Other important privacy information
We aim to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 (“GDPR”) and national laws implementing GDPR.
This policy also explains your choices about how we use information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you.
Where we provide the Services under contract with an organisation (for example your employer) that organisation controls the information processed by the Services. For more information, please see the section headed Other Important Privacy Information below.
(1) WHAT INFORMATION WE COLLECT ABOUT YOU
We collect information about you when you provide it to us, and when you use our Services, as further described below:
a) Information you provide to us:
We collect information about you when you input it into the Services or otherwise provide it directly to us.
b) Account and Profile Information:
We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the Services. For example, you provide your contact information and, we keep track of your preferences when you select settings within the Services.
c) Content you provide through our products:
The Services include the Leesman products you use, where we collect and store content that you post, send, receive and share. This content includes any information about you that you may choose to include. Examples of content we collect, and store include: your survey responses (which are only personally identifiable for the period the survey is open and are encrypted), your details if you opt-in for marketing content. We collect content using analytics techniques (Google and cookies) and we collect data about how you interact with our Analytics platform and use features in our Services. See also Cookies and Tracking Technologies below.
d) Content you provide through our websites:
The Services also include our websites owned or operated by us. We collect other content that you submit to these websites, which include social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, activities or events.
e) Information you provide through our support channels:
The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
f) Payment Information:
We currently do not collect payment and billing information on either the survey or analytics platform.
g) Information we collect automatically when you use the Services:
We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.
h) Your use of the Services:
We keep track of certain information about you when you visit and interact with any of our Services.
- All survey response data is anonymised after the survey closes.
i) Device and Connection Information including cookies and Other Tracking:
We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. With our surveys, we use city and country information decoded from your IP address (though not the IP address itself, so it is not possible to identify you from this location information). We use this information in order to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.
(2) HOW WE USE INFORMATION WE COLLECT
How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. We will hold, use and disclose your personal information where it is necessary for the performance of our contract to provide Services to you or for our legitimate business purposes, as set out here:
a) To provide the Services and personalize your experience:
We use information about you to provide the Services to you, including to process surveys, authenticate you when you log in to either the survey or Analytics platform, provide customer support, and operate and maintain the Services.
b) For research and development:
We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful to you. We use anonymised collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services. We automatically analyse and aggregate frequently used search terms to improve the accuracy and relevance of suggested topics that auto-populate when you use the search feature. In some cases, we apply these learnings across our Services to improve and develop similar features or to better integrate the services you use. We also test and analyse certain new features with some users before rolling the feature out to all users.
c) To communicate with you about the Services:
We use your contact information to send transactional communications via email and within the Services; including survey response information, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We also provide tailored communications based on your activity and interactions with us. We also send you communications as you onboard to a particular Service. Some communications are part of the Services and in most cases, you cannot opt out of them. If an opt out is available, you will find that option within the communication itself or in your account settings.
d) To market, promote and drive engagement with the Services:
Where you have given us permission, we use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new product offers, promotions and contests. You can control whether you receive these communications as described below under “Opt-out of communications.”
e) Customer support:
We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyse crash information, and to repair and improve the Services.
f) For safety and security:
We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
g) To protect our legitimate business interests and legal rights:
Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
h) With your consent:
We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the details in the Contact section below.
The Legal Basis for Processing your Personal Information (for EEA users):
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under the GDPR. The legal bases depend on the Services you use and how you use them. Under the GDPR, the main grounds that we rely upon in order to process personal information of clients are the following:
- necessary for entering into, or performing, a contract– we need it to provide you the Services, including to operate the Services, provide customer support and personalised features and to protect the safety and security of the Services;
- necessary for the purposes of legitimate interests– it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
- consent– you give us consent to do so for a specific purpose; or
- necessary for compliance with a legal obligation– we need to process your data to comply with a legal obligation.
Where we are using your information because we or a third party (e.g. our developers) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the services.
(3) HOW WE SHARE INFORMATION WE COLLECT
We make survey tools, and we want them to work well for you. This means sharing your personal information through the Services and with certain third parties. We share the personal information we collect about you in the ways discussed below, but we are not in the business of selling information about you to advertisers or other third parties.
a) Sharing with third parties
We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services.
b) Service Providers:
We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.
c) Leesman Partners:
We work with third parties who provide consulting, sales, and technical services to deliver and implement customer solutions around the Services. We may share your information with these third parties in connection with their services, such as to assist with billing and collections, to provide localized support, and to provide customizations. We may also share information with these third parties where you have agreed to that sharing.
We ensure that such third parties agree to comply with similar standards of privacy and confidentiality as those applied by Leesman Ltd. To the extent that any personal information is provided to third parties outside the EEA, or who will access the information from outside the EEA, we will ensure that approved safeguards are in place. We make use of standard contractual data protection clauses, which have been approved by the European Commission, and we rely on the EU-U.S. and Swiss-U.S. Privacy Shield Framework.
d) Social Media Widgets:
The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. Your use of and any information you submit to any of those third-party sites is governed by their privacy policies, not this one.
e) Third-Party Widgets:
f) With your consent:
We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.
g) Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights:
In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect Leesman, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
h) Leesman companies:
We share information we have about you with other Leesman corporate affiliates in order to operate and improve products and services and, as applicable with your permission, to offer other Leesman affiliated services to you. A list of the Leesman Ltd company offices can be accessed here, https://www.leesmanindex.com/contact-us/.
For information on international transfers of your information, please see the section on How We Transfer Information We Collect Internationally below.
i) Business Transfers:
(4) HOW WE STORE AND SECURE INFORMATION WE COLLECT
a) Information storage and security
We use data hosting service providers in Frankfurt and Ireland to host the information we collect, and we use technical measures to secure your data.
b) How long we keep information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
c) Account information:
We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyse personal characteristics about you.
d) Information you share on the Services:
If your account is deactivated or disabled, some of your anonymised information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services. E.g. survey data that contributes to the Leesman benchmarking activities (LMI/L+).
e) Marketing information:
If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your Leesman account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
(5) HOW TO ACCESS AND CONTROL YOUR INFORMATION
You have certain rights available to you when it comes to your information. Below is a summary of those rights, how to exercise them and any limitations.
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion, correction or restriction of your information, or to request your information in a structured, electronic format.
Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
a) Right of Access:
You have the right to access information held about you and you can ask us for a copy of the information at any time. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
b) Deactivate your account:
If you no longer wish to use our Services, you or your administrator may be able to deactivate your Services account. If you can deactivate your own account, that setting is available to you in your account settings. Otherwise, please contact us. If you are an administrator and are unable to deactivate an account through your administrator settings, please contact us. Please be aware that deactivating your account does not delete your information; your information remains visible to other Service users based on your past participation within the Services. For more information on how to delete your information, see below.
c) Delete or Correct your information:
You can delete certain information about you from within the Service by making a request to us. 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.
If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed.
d) Request that we stop using your information:
In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honoured or the dispute is resolved, provided your administrator does not object (where applicable).
e) Opt out of communications:
You may opt out of receiving promotional communications from us by using the unsubscribe link within each email or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings.
f) Turn off Cookie Controls:
g) Send “Do Not Track” Signals:
Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our Services do not currently respond to browser DNT signals. You can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving marketing from us as described above.
h) Data portability:
Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier).
This right exists only in respect of personal information that:
- you have provided to us previously; and
- is processed by us using automated means.
Should you request it, we will endeavour to provide you with an electronic file of your basic account information.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.
You can exercise any of the above rights by contacting us using any of the methods in the Contact section below.
Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
(6) HOW WE TRANSFER INFORMATION WE COLLECT INTERNATIONALLY
a) International transfers of information we collect
We collect information globally and primarily store that information in Frankfurt and Ireland. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.
b) International transfers within the Leesman Companies:
To facilitate our global operations, we transfer information to either Ireland or Frankfurt and allow access to that information from countries in which the Leesman owned or operated companies have operations for the purposes described in this policy. These countries may not have equivalent privacy and data protection laws to the laws of many of the countries where our customers and users are based. When we share information about you within and among Leesman corporate affiliates, we make use of standard contractual data protection clauses, which have been approved by the European Commission, and we rely on the EU-U.S. and Swiss-U.S. Privacy Shield Framework to safeguard the transfer of information we collect from the European Economic Area and Switzerland.
(7) OTHER IMPORTANT PRIVACY INFORMATION
Many of our products are intended for use by organizations. Where the Services are made available to you through an organization (e.g. your employer), that organization is the administrator of the Services and is responsible for the accounts and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.
Administrators are able to:
- require you to reset your account password;
- restrict, suspend or terminate your access to the Services;
- access information in and about your account;
- access or retain information stored as part of your account;
- install or uninstall third-party apps or other integrations
In some cases, administrators can also:
- restrict, suspend or terminate your account access;
- change the email address associated with your account;
- change your information, including profile information;
- restrict your ability to edit, restrict, modify or delete information
Even if the Services are not currently administered to you by an organization, if you use an email address provided by an organization (such as your work email address) to access the Services, then the owner of the domain associated with your email address (e.g. your employer) may assert administrative control over your account and use of the Services at a later date. You will be notified if this happens.
If you do not want an administrator to be able to assert control over your account or use of the Services, use your personal email address to register for or access the Services. If an administrator has not already asserted control over your account or access to the Services, you can update the email address associated with your account through your account settings in your profile. Once an administrator asserts control over your account or use of the Services, you will no longer be able to change the email address associated with your account without administrator approval.
Please contact your organization or refer to your administrator’s organizational policies for more information.
b) Our policy towards children
The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.
d) Internet-based transfers
Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. Unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site via third party networks; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
If you are unhappy about our use of your personal information, you can contact us using the details in the Contact section below. You are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods:
Telephone: 0303 123 11113
Information Commissioner’s Office
If you live or work outside of the UK or you have a complaint concerning our activities outside of the UK, you may prefer to lodge a complaint with a different supervisory authority. A list of relevant authorities in the EEA and the European Free Trade Area can be accessed here.
f) Contact Us
Your information is controlled by Leesman Ltd. If you have any enquires or if you would like to contact us about our processing of your personal information, including exercising your rights as outlined above, please contact your local Leesman office or contact us centrally by any of the methods below.
When you contact us, we will ask you to verify your identity.
Contact name: Data Protection Officer
Telephone: +44 (0) 20 3239 5980
91 Wimpole Street
Our registered office is at:
5 Wormwood Street