Last Revised: January 19 2024
1. Your Consent (PLEASE READ CAREFULLY!)
2. Which User Data we may collect? "User Data" consists of the following types of information:
2.1. The first type of information is non-identifiable and anonymous information (“Non-personal Information”). Non-personal Information is any unconcealed information which does not enable identification of an individual User. Non-personal Information is available to us while Users are accessing or using our Site and/or Platform. Non-personal Information which is being gathered may consist of technical information, behavioral information (such as User's experience on the Platform) or aggregated information, and may contain, among other things: technical data, e.g. type of operating system and configuration, device language, screen resolution, screen density, technical features of the User's use of our Platform, software version, hardware type, usage patterns and other statistical data, the time the User spent in our Platform, etc.
2.2. he second type of information is individually identifiable information (“Personal Information”). This information identifies, or may with reasonable effort identify an individual or may be of a private and/or sensitive nature:
- Users and/or visitors of the Site and/or Platform may automatically provide their IP address (or Mac Address, as applicable) and/or advertiser identifier mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below.
- When opening an Account, Users are required to provide the following details: full name, nickname (user name), e-mail address, password and telephone number.
- Alternatively, a User can open an Account and signup to the Platform via existing third party accounts (e.g., Facebook.) used by such User ("Social Network Account"). In the event that a User registers to the Platform through his/her existing Social Network Account, then such Social Network Account provides us with access to certain information about such User as is stored in the User’s Social Network Account, namely, the User's full name, email, country and/or any other information which is detailed and displayed to the User in the notice which appears during the integration process with such Social Network Account. Please read carefully such notice in order to understand what information is made available to us via your Social Network Account. We may collect your login information and other relevant information necessary to enable us to access your Social Network Account in order to collect the abovementioned data contained within your Social Network Account which you provided us access to. We may store the above-mentioned information (or any part of it), in order to achieve the purposes set forth herein. Please remember that the manner in which social networks use, store or disclose your information is governed solely by their policies and we will have no liability or responsibility for the privacy practices or other actions of such social networks. If you do not agree to these practices please do not use the social network integration feature. You hereby agree that such information will be stored even after the linkage to your Social Network Account expires, for any reason.
- Personal Information is collected from the details the Users and visitors of the Site provide in the Contact Form on the Site which includes, inter alia, name, company/organization name, email address and telephone number. You may optionally provide via the Contact Form any text you wish to insert into the “message box”. Our representative may collect additional Personal Information from you. This information may also be collected when contacting via e-mail for support purposes.
- Visitors of our Site may provide us with Personal Information which may be included in the User Generated Content uploaded to the Site and which may be made public.
- In addition, when you subscribe to the Service, you will have the option to use certain Online Payment Processors which will require you to fill out a billing form wherein you will be required to provide to such Online Payment Processors certain Personal Information (such as, a credit card number and other related billing information) (see section 7 below regarding the payment method). We will not store such information on our servers. We only keep token information such Online Payment Processors provide us with, and such information is strictly secured.
For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
3. Which Data Subject(s) Data we may collect
We collect the following Personal Information with respect to Data Subjects:
- Data Subjects automatically provide their IP address (or Mac Address, as applicable) when interacting with the Chatbots mainly for enhancing their experience and for geo-location and security purposes as further detailed below.
- As part of Leo’s interaction with Data Subjects via Leo’s Chatbots, Data Subjects may choose to connect via their Social Network Account. In such event, the Social Network Account provides us with access to certain information about such Data Subject as is stored in his/her Social Network Account, namely, full name, email, country, education, relationship and/or any other information which is detailed and displayed in the notice which appears during the integration process with such Social Network Account. Data Subject must read carefully such notice in order to understand what information is made available to us via the Social Network Account. We may collect login information and other relevant information necessary to enable us to access the Social Network Account in order to collect the abovementioned data contained within the Social Network Account which we were provided access to. We may store the above-mentioned information (or any part of it), in order to achieve the purposes set forth herein. Please remember that the manner in which social networks use, store or disclose information is governed solely by their policies and we will have no liability or responsibility for the privacy practices or other actions of such social networks. If Data Subjects do not agree to these practices they must not use the social network integration feature. Please note that such information will be stored even after the linkage to the Social Network Account expires, for any reason.
- We may collect additional Personal Information with respect to Data Subjects which are your existing customers, such as details derives from your CRM systems with respect to their insurance policies.
4. How does Leo Collect the above mentioned information?
4.1. With respect to Users:
- We collect information through your entry and use of the Platform. In other words, when you are using the Platform we are aware of it and may gather, collect and store the information relating to such usage.
- We collect information which you may, at your discretion, provide us voluntarily. For example, we collect Personal Information when you decide to provide us when opening an Account and/or when contacting us via the support e-mail or Contact Form. We may also collect Personal Information when you register and open an Account through your Social Network Account. When registering through your Social Network Account, you agree to grant us access to Personal Information stored in your Social Network Account, as detailed above. Please note that when you will use the Chatbots, we will retain chat history with the Chatbots, for the purposes detailed below.
4.2. With respect to Data Subjects:
- We collect information which Data Subject, at his/her discretion, provides us voluntarily. For example, we collect Personal Information when a Data Subject interacts with the Chatbots via his/her Social Network Account (which may be collected via the SDK). When connecting to the Chatbots via Social Network Account, the Data Subject grants us access to Personal Information stored in his/her Social Network Account, as detailed above.
- We collect information about Data Subjects from your CRM systems, which are held by third party service providers, and any other information you provided us with in any other means.
We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.
5. What are the Purposes of the Collection of the above mentioned information?
5. 1. With respect to Users:
We will collect Personal Information in order to:
- Enable the overall operation of the Service
- Personalize user experience on the Service
- Verify the User's identity when he/she signs in to the Service, as well as verifying User's identity for the purpose of dealing with inappropriate interactions of User and/or fraudulent use of our Service.
- Be able to contact Users for the purpose of providing them with technical assistance and support.
- Determine general geo-location information (i.e., country) from which the User's computer is connected to the Internet in order for us to know the general location of our Site and Platform Users as well as in order to safeguard our Site and/or Service.
- Allow us to contact Users with proposals and tailored information regarding our products, events, offers, services, features, enhancements, special offers, upgrade opportunities, and events of interest etc. (including by way of newsletter).
- Enable payment through third party Online Payment Processors. Please note that we do not collect and store credit card or other financial information. In addition, we will collect Non-personal Information in order to (i) enhance the User's experience while using the Platform and/or the Site; (ii) learn about the preferences of Users and general trends on and uses of the Services; and (iii) use it for statistical, analytical and research purposes and for customization, developing and improvement of our Services.
5.2. With respect to Data Subjects:
We will collect Personal Information in order to:
- Enable the overall operation of the Service, including for the purpose of engaging and contacting with Data Subjects on your behalf, via Massages.
- Verify Data Subject's identity
- Personalize user experience relating to the Service
- Be able to contact Data Subjects for the purpose of providing them with technical assistance and support.
- Determine general geo-location information (i.e., country) from which the Data Subject's computer is connected to the Internet in order for us to know the general location of such users as well as in order to safeguard our Site and/or Service.
- Allow us to contact Data Subjects with proposals and tailored information regarding new User products, events, offers, services, features, enhancements, special offers, upgrade opportunities, and events of interest etc, all on behalf of our Users.
Please note that the Services may include the sending of notifications, messages, emails and alerts via various means of communication to Data Subjects and to Users. You hereby agree that we may use details including Personal Information of Data Subjects, provided to us by such Data Subject or by you (including, without limitation, e-mail address and phone number) for the purpose of providing Data Subjects commercial and/or non-commercial communications related to your services. Data Subjects may withdraw their consent by sending a written notice to [Liri – please add e-mail address] or alternatively follow the instructions for removal from the mailing list which are available in the message transmitted to Data Subjects.
You hereby grant us a limited, non-exclusive and non-assignable license to use, store, upload, and copy Data Subjects' Data solely for the purpose of providing you the Services and as further permitted hereunder. This may include updating, revising and deleting Personal Information or any other information applicable to Data Subjects' Data relating to their insurance policies, in accordance with the Data subject request, all on your behalf.
Please note that one of the Service's features includes the option to share Chatbots with friends and/or family of Data Subject. It is the Data Subject's responsibility to make sure he/she received their consent for such sharing.
You hereby represent and warrant that you will use the Services in compliance with any applicable laws, including without limitation any applicable privacy protection laws, including any applicable laws, regulations, orders, decrees and policies relating to the collection, use or dissemination of information about Users and Data Subjects (among others, you are responsible for obtaining, before you use the Service, all Data Subject consents required by applicable law for our collection and use of the Data Subjects' Data (including but not limited to any Personal Information) for the purposes set forth herein, and you further acknowledge that, as applicable, the database of the Data Subjects' Data of your services has been duly registered in the applicable governmental authorities).
For avoidance of doubt, Leo has the unrestricted right to use Non-personal Information, aggregate information, and/or de-identified Personal Information, for any purpose, including for any commercial purpose, and to transfer and disclose Non-personal Information, aggregate information, and/or de-identified Personal Information to third parties at its own discretion. Leo is and shall be the sole owner of Non-personal Information, aggregate information and/or de-identified Personal Information derived from your Account and/or use of the Services.
6. Sharing Information with Third Parties
For avoidance of doubt, Leo may, at its own discretion, use Non-personal Information and transfer and disclose it to any third parties.
8. Deletion or Modification of Personal Information
Data Subjects may request us, via the Chatbots (as part of our Services), the modification of Personal Information collected with respect to such Data Subject. Notwithstanding, you are responsible to handle all other modification and deletion requests made by the Data Subjects. If you are unable to handle any request and only we possess the ability or power to solve such request, please forward that request to us and provide us with the necessary instructions and we will make reasonable efforts to solve the issue pursuant to any applicable privacy laws.
If for any reason you wish to delete, update or modify your Personal Information included in your Account you may do so by clicking the "Settings" option available through the Platform. You control access to your Account and you have full administrative control over the data, including to view or modify it. Alternatively, you can send us an email to: [Liri – please add email address] and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws.
Note that unless you instruct us otherwise we may retain and use your Personal Information after termination of your Account, for as long as reasonably required for the purposes of which such Personal Information was collected, including without limitation, for future analytics and analysis, in order to comply with our legal or business requirements or obligations, to resolve disputes, to enforce our TOS and/or to enable the User to reinstate his/her Account, all as permitted under any applicable privacy laws. Further, we will retain Data Subjects' Data all for the purpose of providing our Services to you, and retain such information for as long as reasonably required for the purposes of which such Personal Information was collected, as permitted under any applicable privacy laws.
Aggregate and/or anonymous information derived from your Account and/or use of the Service may remain on Leo servers indefinitely.
We take reasonable measures to maintain the security and integrity of our Service, User Data and/or Data Subjects' Data that we collect and prevent unauthorized access to them or use thereof through generally accepted industry standard technologies and internal procedures. The User and Data Subjects information is hosted on the Amazon AWS Cloud servers which provide advanced strict security standards (both physical and logical).Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.
The Site and/or Service are intended for Users over the age of eighteen (18). Therefore, Leo does not intend and does not knowingly collect Personal Information from minors under the age of eighteen (18) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Service. If we learn that we collected Personal Information from minors under the age of eighteen (18) we will delete that information as quickly as possible. Please contact Leo at firstname.lastname@example.org if you have reasons to suspect that Leo collected Personal Information from minors under the age of eighteen (18) and we will delete that information as quickly as possible.
11. Direct Marketing
You hereby agree that we may use your contact details (including, without limitation, e-mail address and phone number) for the purpose of informing you of products, services and other updates and new features which may be of interest to you, as well as for sending you newsletters and other materials to the e-mail address you provided in the registration process. You may withdraw your consent via sending a written notice to Leo by e-mail to the following e-mail address: [Liri – Please add e-mail address] or alternatively follow the instructions for removing yourself from the mailing list which are available in the message transmitted to you.
12. Third Party Service Providers
13. International Data Transfer
We transfer information collected about Users and Data Subjects, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.
14. Cookies and Other Tracking Technologies
15. Social Features