Privacy Notice
Last updated: August 2024
INTRODUCTION
Leaf.fm Ltd (“Leaf”, “us”, “we”, or “our”) operates https://www.leafgrow.io, https://www.leafsignal.com and https://www.leafanswers.com websites and the Leaf Answers and Leaf Signal applications (the “Services”).
Leaf is committed to protecting your privacy. This privacy notice will inform you as to how we look after your personal data when you visit our website, our Answers platform (app.leafgrow.ai) or engage with us as a client, prospective client, or supplier.
Leaf is the data controller for the processing that we undertake that is outlined in this privacy notice. As the data controller, we are responsible for deciding how we hold and use the personal data we collect.
We are registered with the Information Commissioner’s Office (ICO) with registration number ZB502234. If you have any questions about how we process your personal data or this privacy notice, would like to exercise your data protection rights, or submit a compliant about how we have handled your personal data, you can contact us using the details below:
Leaf.fm Ltd
2nd Floor 14 Blandford Square
14 Blandford Square
Newcastle Upon Tyne
NE1 4JA
or via email at hello@leafgrow.io
Throughout this Privacy Policy we refer to Data Protection Laws, which means the UK’s Data Protection Act 2018, United Kingdom General Data Protection Regulation (UK GDPR) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR) and any legislation implemented in connection with the aforementioned legislation. Where we process the personal data of people in the European Union, it also includes the EU General Data Protection Regulation (EU GDPR). Similarly, to the extent that we process the personal data of individuals located in other countries, we will comply with the relevant data protection legislation as applicable.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We only collect personal data that we know we will use and in accordance with the Data Protection Laws.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Identity Data includes first name, last name, username or similar identifiers.
· Contact Data includes work address, email address and telephone numbers.
· Transaction Data includes details about payments to and from you and other details of products and Services you have purchased from us, as well as records of conversations and agreements related to our provision of Services to you.
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties.
· Technical data includes device information, IP address and browser tracking.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
You are under no statutory or contractual requirement or obligation to provide us with your personal data; however, we require at least the information above in order for us to deal with you as a prospect, client, or supplier in an efficient and effective manner.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
· Direct interactions. You may give us your personal information by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you enquire about our products or Services, give us feedback or contact us for any other purpose.
· We may also received your personal data from third parties such as someone else within your organisation or from another of our clients where you have asked to be referred.
· We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Log Data”). This Log Data may include information such as your computers Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics. When you access the Service by or through a mobile device, this Log Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use and other statistics.
BEAHVIOURAL MARKETING
Leaf uses remarketing Services to advertise on third party web sites to you after you visited our Service. We, and our third party vendors, use cookies to inform, optimize and serve ads based on your past visits to our Service.
Google AdWords remarketing Service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
X
X remarketing Service is provided by X Corp.
You can opt-out from X’s interest-based ads by following their instructions: https://help.x.com/en/safety-and-security/privacy-controls-for-tailored-ads
You can learn more about the privacy practices and policies of X by visiting their Privacy Policy page: X Privacy Policy
Facebook
Facebook remarketing Service is provided by Meta Platforms Inc.
You can learn more about interest-based advertising from Facebook and opt out from interest-based ads by visiting this page: Ad preferences | Facebook
Facebook adheres the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
LinkedIn remarketing Service is provided by LinkedIn Corporation. You can find out more about how this works by visiting LinkedIn’s Privacy Policy: LinkedIn Privacy Policy
In addition, to manage your preferences on LinkedIn with regard to interest-based advertising, click here: Manage your advertising preferences | LinkedIn Help
PURPOSES FOR PROCESSING AND LEGAL BASIS
We will only use your personal data when the law allows us to. In line with our legal obligations under the Data Protection Laws, we always identify a lawful basis for processing.
The legal basis we mainly rely on for processing personal data is legitimate interests, provided that your interests and fundamental rights do not override our interests. The purposes for which we rely on this lawful basis are:
· To contact you, following your enquiry or to reply to any questions;
· To send B2B marketing communications to you;
· To deal with any customer service enquiries, reply to any suggestions, issues or complaints you have contracted us about;
· To deal with your organisation as a prospect, including drawing up a proposal and contract and communicating with you for this purpose;
· To fulfil the contract we have with your organisation to provide you with the agreed Services;
· To process any payment made by your organisation for the Services provided;
· To request your feedback in order to improve our Services;
· To power our security measures for this website and the Leaf Grow platform so you can safely access them;
· To deal with your organisation as a supplier, where applicable.
In a small number of circumstances, we will seek your consent to process your personal data:
· To use marketing and analytics cookies on our website and Leaf Grow platform;
· To share your contact details with any third party partners for the purpose of marketing.
For more information on the essential and non-essential cookies that we use on the website, please visit our consent management platform by clicking “Cookie Settings” on our cookie banner.[PS1]
COOKIES
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computers hard drive.
We use “cookies” to collect information. For cookies that are not essential for the running of our website, we will ask your consent before using them. However, if you do not consent to additional cookies, you may not be able to use some portions of our Service.
DISCLOSURES OF YOUR PERSONAL DATA
Leaf may transfer your personal data for the above purposes to other recipients and categories of recipients listed below:
· Data processors – we engage with certain third parties to provide elements of services for us. We have Data Processing Agreements in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do it. They will not share your personal data with any organisations apart from us or other sub-processors who must comply with our Data Processing Agreement. They will hold your personal data securely and retain it for the period we instruct. These data processors include Google (for use of Google Workspace and G-Mail), Xero (for accounting), and HubSpot (CRM).
Where we share your personal data with organisations located in countries that are not covered by an adequacy decision, we rely on standard contractual clauses, with the UK Addendum where required, as our mechanism to safeguard the transfer.
In addition, in the event that we choose to sell, transfer or merge parts of our business or our assets with a third party, your personal data will be shared. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We also may share your personal data with other third parties in the following circumstances:
· Where we are required to do so by law (such as for tax purposes);
· If we need to share personal data in order to establish, exercise or defend our legal rights (such as for the prevention of fraud, and reducing credit risk).
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
Your personal data will be retained in accordance with our retention policy which categorises all of the information held by Leaf and specifies the appropriate retention period for each category of data. Those periods are based on the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and Leaf’s business purposes.
For information related to you and your organisation’s contract with us as a client or supplier, we generally keep information for 7 years from the end of our relationship with you. If there is a dispute or a legal action, we may need to keep this personal data longer.
YOUR LEGAL RIGHTS
Under data protection legislation, you have the following rights:
· to ask us for access to information about you that we hold
· to have your personal data rectified, if it is inaccurate or incomplete
· to request the deletion or removal of personal data where there is no compelling reason for its continued processing
· to restrict our processing of your personal data (i.e. permitting its storage but no further processing)
· to object to direct marketing (including profiling) and processing for the purposes of scientific/historical research and statistics
· not to be subject to decisions based purely on automated processing where it produces a legal or similarly significant effect on you
You can exercise any of the above rights by contacting us using the contact information outlined above.
Where we rely on consent to process your personal data, you have the right to withdraw your consent at any time. You can do this by navigating to our consent management platform on our website.
Any requests received by Leaf will be considered under applicable Data Protection Laws.
If you have a concern about the way we are collecting or using your personal data, we ask that you raise your concern with us in the first instance. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner’s Office at www.ico.org.uk or your local data protection authority.