Last Updated: December 1, 2020
1. The Information We Collect About You
If you are a Lee Equity employee or investor, our policies and practices regarding the collection and processing of your Personal Information are detailed in Lee Equity’s Employee Privacy Notice and Investor Privacy Statement, respectively. For all other individuals, Lee Equity may collect and process the following categories of Personal Information (information that identifies or can be used to identify an individual person, device or household) about you from the sources identified as follows. When we use the term Personal Information, we mean any information that identifies or can be used to identify a specific individual or device.
A. Websites Data. We may collect and process Personal Information about you when you browse or use certain functions on the Site, which may include:
i. Information submitted as part of completing online forms on the Site (including, but not limited to, name, age, date of birth, address, gender, nationality, citizenship and contact information);
ii. Information collected by Cookies (which are small text files containing a string of alphanumeric characters) owned by third parties like Google. When you use the Site, these third parties may send one or more Cookies to your computer or mobile device and collect information about the services that you use and how you use them, which may include device-specific information, your navigation throughout the Site, and other technical and browsing preferences including your location and entry point to the Site. We may use both Session Cookies and Persistent Cookies: a Session Cookie disappears after you close your browser; a Persistent Cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. Persistent Cookies can be removed. Please review your web browser’s “Help” file to learn the proper way to modify your Cookie settings.
iii. Technical information that we may automatically receive and record from your computer, web browser and/or mobile device, including your IP address or other device address or ID, web browser and/or device type, hardware and software settings and configurations, the web pages or sites that you visit just before or just after visiting the Site, the pages you view on the Site, your actions on the Site, and the dates and times that you visit, access, or use the Site. This includes information about how you use and navigate the Site, including which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions with the Site. When you use the Site on a mobile device, we may also collect the physical location of your device by, for example, using satellite, cell phone tower or wireless local area network signals.
B. Identity Verification Information. To help us respond to requests for data access and/or deletion requests as required by applicable laws, as well as create and maintain a trusted environment, we may collect identity verification information from you, such as images of your government issued ID, passport, national ID card, or driver’s license, as permitted by applicable laws, or other authentication information.
C. Communications Data. We may collect Personal Information that you provide when you contact us for any reason, such as to express an interest in obtaining additional information about our services, direct questions or concerns about our services to us, use a “Contact Us” form or similar features, sign up for our emails or attend an event, or download certain content. Such information may include contact information such as name, job title, company name, phone number, and email address.
D. Reputation & Background Check Data. We may collect Personal Information from you and from third parties in connection with performing diligence on job applicants, service providers, and business partners. This data may include contact details, information concerning business practices, creditworthiness, reputation and business history, and job titles or roles.
DO NOT TRACK: Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals.
Please note that if you do not provide certain Personal Information to Lee Equity when requested we may not be able to provide you with access to all areas of the Site and associated services.
2. How We Use Your Information
Your Personal Information may be collected, stored, disclosed and processed by Lee Equity for the following purposes:
1. To operate, maintain, enhance, and provide all of the features of the Site;
2. To personalize the Site, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Site;
3. To understand and analyze the usages trends and preferences of our users, to analyze and report on the Site’s traffic, marketing and usage trends, to improve the Site, and to create new features and functionality;nbsp;
4. For ongoing review and improvement of the information, content and services provided on the Site to ensure it is user friendly;
5. To conduct analysis required to detect malicious data and understand how this may affect your IT system;
6. For in-depth threat analysis, to prevent any potential disruptions such as cyber-attacks, and for statistical monitoring and analysis of current attacks on devices and systems for the on-going adaption of the solutions provided to secure systems and devices against current attacks;
7. To provide you with the products and services for which you subscribe, and to allow you to use and access functionality provided by the Site;
8. To provide you with marketing communications and inform you about news and information relating to our business and services, including new product launches, product updates and general business news (generally, you can opt-out of receiving promotional communications through links provided in the messages or by contacting us directly using the contact information provided below in Section 9);
9. To understand your needs and interests and respond to inquiries, and/or other requests or questions;
10. To detect, investigate and prevent fraud and other crimes or malpractice, and to improve fraud detection and information security;
11. For the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings), and to obtain legal advice or to establish, exercise or defend legal rights;
12. To confirm and verify your identity and to conduct due diligence;
13. For the management and administration of our business, and to comply with our contractual obligations; and
14. For purposes otherwise set out in this Policy.
3. When We Disclose Information
Lee Equity does not sell Personal Information. We do not share Personal Information with other people or nonaffiliated companies except when we have your permission, as required by law, and/or under the following circumstances:
- We work with third party service providers to provide website development, hosting, data storage, maintenance, and other services for us. To the extent it is necessary for these third party service providers to complete their contractual obligations to us, these third parties may have access to or process information about you. Our third party service providers do not have any independent right to use or share such information outside of their relationship with Lee Equity.
- In some cases, in order to provide the products and services available through and/or in connection with the Site, we provide information about you to trusted partners who work on behalf of or with us under confidentiality agreements. Our partners do not have any independent right to use or share such information outside of their relationship with Lee Equity.
- We may partner with third parties to manage our advertising on other websites. Our third party partners may use tracking technologies to gather information about your activities on our Site and other websites to provide you with advertising based on your browsing activities and interests.
- We may share information about you in response to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
- We may share information about you if we have a good faith belief that it is necessary to do so in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
- We may transfer or assign information about you if Lee Equity is acquired by or merged with another company, or in the unlikely event of a bankruptcy.
4. Your Rights
Depending on the jurisdiction in which you reside, you may have legal rights in relation to your Personal Information. These rights may include:
- Declining to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Site.
- Requesting and obtaining information regarding how Lee Equity may use your Personal Information.
- In some circumstances, requesting and receiving some Personal Information about you that you have provided to Lee Equity.
- In some circumstances, requesting that Lee Equity correct your Personal Information if it is inaccurate or incomplete.
- In some circumstances, requesting that we erase your Personal Information (but please note that there may be circumstances where we are legally entitled to retain Personal Information regardless of any such request).
- In some circumstances, requesting that we restrict or block our processing of your Personal Information (again, there may be circumstances where we are legally entitled to refuse that request).
- Where applicable, the right to lodge a complaint with the data protection regulator in your jurisdiction if you think that any of your rights have been infringed by Lee Equity.
You can inquire about your rights by contacting us using the details listed below in Section 9.
5. California Privacy Rights
If you are a California resident, you have the right to request certain information from us regarding the manner in which we share with third-parties certain categories of information that identifies you. Lee Equity does not share Personal Information with third parties for those third parties’ own direct marketing purposes.
Effective December 1, 2020, the California Consumer Protection Act (CCPA) provides you with certain rights that are in addition to the rights set out in Section 4 above (if you are a California resident, Personal Information will include the full definition of “Personal Information” under the CCPA).
- The right to request, up to twice in a twelve month period, your Personal Information in a format that is portable and, to the extent technically feasible, in a readily useable format that will allow you to transmit it to another entity.
- The right to request that Lee Equity delete your Personal Information, except in circumstances where Lee Equity is legally entitled to retain Personal Information regardless of any such request.
- The right to opt out of any sale of your Personal Information to any third parties, without experiencing any discrimination, as defined under the law, as a result of your exercise of this right. Note that Lee Equity does not sell Personal Information to third parties.
In addition, Cal. Civ. Code § 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.
If you are a California resident and you wish to exercise any of the rights enumerated in this section, you may contact us at (877) 690-0204 or by e-mail at email@example.com
6. How We Protect Your Information
- Data Security. We use certain physical, managerial, and technical safeguards that are designed to protect the integrity and security of your information. We cannot, however, ensure or warrant the security of any information you transmit to us through the Sites and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Although we may allow you to adjust your privacy settings to limit access to your information, no security measures are perfect or impenetrable. We cannot control the actions of other users or other third parties with whom you may choose to share your information. Therefore, we cannot and do not guarantee that information you post through the Site will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
- Data Retention. We only store your information for as long as may be needed to provide services to you, with the exception of information that we may need to store for a longer period of time to comply with legal or regulatory obligations, resolve disputes, enforce our agreements, or for records management purposes. Lee Equity will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer periods. Even after removal, copies of information that you have posted may remain viewable in cached and archived pages or if other users have copied or stored such information.
- Protecting Children. Our Site and our products and services are intended for use by those over the age of 16. We do not knowingly collect personal information from children under the age of 16. If you are under 16 years of age, then please do not use or access the Sites at any time or in any manner.
7. International Visitors
This Site is controlled and operated by Lee Equity in the United States. If you choose to access the Site from outside the United States, you acknowledge that you will be transferring your information, including Personal Information, outside of those regions to the United States for storage and processing, as necessary to provide to you the products and services available through the Site.
For inquiries about your Personal Information, please contact Lee Equity using the details set out in Section 9, below. While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable laws. Please note that it may take some time to process your request, consistent with applicable law.
8. Other Important Information
- Limitation of Liability. By accessing the Site and/or providing us with Personal Information and other data, you expressly and unconditionally release and hold us harmless from any and all liability for any injuries, loss, or damage of any kind arising from or in connection with the use and/or misuse of such information. In addition, while we take efforts to ensure the proper and appropriate use of data by our service providers that may receive your information from us, we are not responsible for any injuries, loss, or damage of any kind arising from or in connection with the use and/or misuse of your information caused by those service providers.
- Third Party Websites. The Site may provide links to, or features from, other third party websites. If you link to or use such third party sites or features, you do so at your own risk. We do not control and are not responsible for the content or practices of any third party website, application, or other product or service.
9. Our Contact Information