At Leads International Corporation, we’re continuously striving to provide you with the best possible experience - and your privacy is important to us.
The recent updates due to the new EU General Data Protection Regulation, effective as of May 25, 2018:
- makes it easier for you to understand which data we collect and how we use it
- gives you increased control over your data
- and provides a detailed explanation of your rights as a user.
1.1 We, the team of Leads International Corporation 3F Dencris Building, Business Center, Barangay Halang, Calamba Laguna, 4027, Philippines, email address: firstname.lastname@example.org (“Email Address”), process your personal data when you use our website (“Website” and, together with, “Products”). The processing of your personal data takes place in compliance with the General Data Protection Regulation (“GDPR”) and the Philippines data protection act, Republic Act No. 10173, (“Data Privacy Act of 2012”) in its current form.
2.1 Controller. The controller of data processing is Leads International Corporation. You can contact us via email under the Email Address.
2.3 Data Protection Officer. Our data protection officer can be contacted under the Email Address. Should you have any questions regarding the processing of your personal data, please do not hesitate to contact him/her.
3.1 In General. Leads International Corporation processes personal data that you as a user of the Products will make available to us, for example by using our Products and that others provide to us (“Data”).
3.2 Data You Provide to Us.
Mandatory Information: You have to provide us with certain information in order to register with us:
- first, middle, and last name;
- tax identification number (TIN);
- upline ID;
- position of the account;
- sponsor ID;
- activation id and code provided by LIC;
Optional Information: Certain information is optional during registration and cannot be added/deleted once encoded:
- secondary sponsor;
We use payment providers (e.g. Paynamics, Paypal, Dragonpay) to process online payments. Although we do not store any card information ourselves, we store a payment ID number that is given out by the respective provider and can be allocated to a person by that payment provider, as well as the history of your transactions.
3.3 Device and Location Information.
When you visit or leave our Products, we receive
- the URL of both the site you came from and the one you go to next, as well as the date, time stamp and time zones;
- IP address, access status/HTTP status code;
- transmitted data volume;
- proxy server, operating system, web browser (including language and version of the browser software) and add-ons;
- the device identifier and features; and/or
- ISP or your mobile carrier; and/or
- GPS information or other phone-related location data (e.g. via WiFi or Bluetooth), after your explicit opt-in.
4.1 Operating the products. We process your Data to be able to provide you with a seamless user experience when using the Products.
Providing Services. To operate the Products and provide the other services, including to:
- authenticate your access to an account;
- track and display your network dashboard;
- enable you to withdraw your earnings;
Customer Support. To investigate, respond to your requests, and resolve complaints and service issues, e.g. to contact you about a question you submitted to our customer service team.
4.2 Business Needs. We process your Data to manage our business needs.
Performance. We process Data to monitor, analyze, and improve the use of our Products, as well as protect the security or integrity of the Products, and their performance and functionality. For example, we analyze user behavior (how frequent do they log in, which function do they usually look, what function slows down during their use) and perform research about the way they use our Products.
Research and Development. We process Data, including public feedback, to conduct research for the further development of our Products, in order to provide you and others with a better, more intuitive and smooth experience.
Marketing General. We process Data to deliver (tailored) marketing materials about Runtastic products and online services to you.
4.3 Compliance and Enforcement.
Compliance. We process your Data to comply with our obligations and in compliance with all applicable laws and regulations.
We share Data with third parties
- if this is necessary, for the Purposes,
- due to a request from a national authority,
- due to a court ruling,
- if required by law,
- if necessary to investigate and defend ourselves against any third-party claims or allegations,
- to exercise or protect the rights and safety of Leads International Corporation, our members, personnel, or
- if you have (explicitly) consented beforehand.
We attempt to notify you about legal demands for your Data when we think it is appropriate, unless prohibited by law or court order, or when the request is an emergency. We may dispute such demands when we believe that the requests are overbroad, vague, or lack proper authority.
Special categories of personal data, such as Upline ID, Sponsor ID, earnings, will never be shared with any third parties.
5.2 Our Services.
Account. Your account is fully visible to your uplines. This means, as soon as you register in the website, people above you will be able to see your account id and every new account that will register under your network.
News Feed. Leads International Corporation has the right to release new articles which is needed to be read before continuing to use your account. This process ensures that the member has successfully read the article.
5.3 Service Providers and Other Third Party Services.
Service Providers. We share your information with others, who help us provide and improve our Products (e.g. maintenance, analysis, audit, payments, and fraud detection, marketing and development). Service providers will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. We use processors such as Google, Amazon Web Services, Digital Ocean, etc.
6.1 Storage Period. We store your Data as long as you are a registered user of the Products. Beyond that, we only store Data, if it is legally necessary (because of warranty, limitation or retention periods) or otherwise required.
6.2 Account Suspension, Freeze, or Deletion. If you violate anything from our Terms and Conditions or Code of Ethics, Leads International Corporation has all the right to suspend or freeze your account depending on the violation. Furthermore, for repeat offenders, account deletion can be enforced. For a deleted account, all Data we have about you will be deleted, with the following exceptions:
- Any Data required for Leads International Corporation’s performance of contractual obligations or compliance with statutory retention obligations shall not be deleted but minimized to the necessary extent.
A deletion request does not affect Data, if the storage is legally necessary, for example for accounting purposes.
7.1 Exercise your Rights. To exercise your rights defined in section 7.2 to 7.8, please send a request via email to the Email Address or via mail to our postal address.
7.2 Revocation of Consent. You can revoke your consent - in those cases where consent for processing is necessary - for future data processing at any time. However, this does not affect the lawfulness of Data processing based on the consent before the revocation. In certain cases, we may continue to process your information after you have withdrawn consent, if we have another legal basis to do so or if your withdrawal of consent was limited to certain processing activities.
7.3 Right of Access. You have the right to obtain (i) confirmation as to whether or not your Data is being processed by us and, if so, (ii) more specific information on the Data. The more specific information concerns, among other things, processing purposes, categories of Data, potential recipients, or the duration of storage.
7.4 Right to Rectification. You have the right to obtain the rectification of inaccurate Data concerning you from us. In case the Data processed by us is not correct, we will rectify these without undue delay and inform you of this rectification. Please note that (i) you can rectify much of your information in the settings and (ii) it is not technically possible for us to rectify all kinds of data in our Product.
7.5 Right to Erasure. You have the right to delete Data we store about you. Should you decide to do so, please go to your account settings on the Website and delete your account there. If you are unable to do this, please contact us via the Email Address. As a safety measure, we will send you an email in order for you to confirm this deletion. We will delete your Data after this confirmation. Please note that your phone may still have Data stored on it after deletion of your account.
7.6 Right to Restriction of Processing. You have the right to obtain a restriction of processing of your Data from us in the following cases:
- you make an inquiry pursuant para. 7.4, if you so request;
- you are of the opinion that the processing of your Data is unlawful, but are opposed to an erasure of data;
- you still require the Data for the establishment, exercise or defense of legal claims; or
- you have objected to the processing pursuant para. 7.8
7.7 Right to Data Portability. You have the right to (i) receive a copy of your Data in a structured, commonly used and machine-readable format and (ii) transmit those Data to another controller without hindrance from us. You can print screen a copy of your Data in your account on the Website.
7.8 Right to Object. You have the right to object at any time to the processing of Data for which our legitimate interests are the legal basis, including profiling based on those provisions. You also have the right to object to the processing of Data for direct marketing purposes.
7.9 Right to File a Complaint. You have the right to file a complaint with your local supervisory authority if you think that the processing of Data infringes the applicable law.
8.1 Legal Bases. Data protection laws regulate that we are only allowed to collect and process your Data if we have lawful bases for processing. The lawfulness of processing of Data stems from:
- your (explicit) consent in cases where you have given (explicit) consent to the processing;
- the necessity for the performance of your user contract
- legitimate interests pursued by Leads International Corporation or a third party.
Our legitimate interest includes protecting you, Leads International Corporation, or others from security threats or fraud, complying with all applicable laws, managing and improving our business (e.g. customer service, reporting) including possible corporate transactions, enabling users to view their account dashboard with productive experience.
8.2 Security Measures. We are committed to protecting your Data and implement appropriate technical and organizational security measures to protect it against any unauthorized or unlawful processing and against any accidental loss, destruction, or damage. Those security measures are constantly revised to comply with the latest technological developments.
9.2 Material Changes. If we make material changes to it, we will provide notice directly in our Products (through News), or by other means (via Email), to offer you the opportunity to review the changes before they become effective. Material changes could, for example, include further tracking, profiling, and analytics services. Should your consent be necessary, we will ask for it before the changes become effective. If you object to any changes, you may need to close your account as it might not function properly.