Welcome to the Leo Shine website. This Online Privacy Policy (“Policy”) applies to information or data (“Information”) about you that Leo Shine LLC (“our”, “we”, or “us”) may obtain about visitors to www.leoshine.com (the “Site”) and individuals (our “Clients”) who use the Leo Shine platform (the “Service”). With respect to data about Site visitors and Clients, this Policy describes how we may collect, use, and share Information we obtain about them through the Site, the choices Site visitors and Clients have regarding our use of the Information; how we safeguard the Information we collect; and how to contact us regarding our privacy practices. Any updates or modifications to this Policy will be posted to our Site on this page. By using or accessing the Site, you signify that you have read, understand and agree to be bound by this Policy. Our Site is operated in the United States but it can be accessed worldwide due to the nature of the Internet. Residents of the European Economic Area (“EEA”), which includes the member states of the European Union, should consult the sections of the Policy relating to the “European General Data Protection Regulation (GDPR)”. California residents should consult the section titled “California Consumer Privacy Act (CCPA)” for rights that apply to them. Information We Collect We may collect and process the following Information when you visit the Site. • Personal Data. You may provide us with your contact details, such as name, job title, employer, mailing address, phone number, email address, or other similar Information, which we may use to directly identify and respond to you or for administrative purposes. • Device Information. Leo Shine may obtain Information about the computer or device you are using when you access the Site, including the type of device, its operating system, device settings, unique device identifiers, and crash data. • Log Data. As with most websites, our servers automatically collect Information when you access or use our Site and record that data in log files. This log data may include your computer’s Internet Protocol (IP) address, the address of the web page visited before or after using the Site, browser type and settings, the date and time the Site was used, Information about browser configuration and plugins, language preferences, and cookie data. • Authentication Data. To verify the identity of registered users on the Site we may collect a user name, password, password hint(s), and other similar authentication Information. • Other Information You Provide. This includes emails and other communications that you send us or otherwise contribute, such as customer support inquiries. Please be aware that Information you post on public parts of our Site may be visible to anyone. We collect Personal Data only when you provide it to us but we may collect other types of Information whenever you use our Site through automated means. We may introduce new features, which may involve new or different Personal Data processing activities. If we make a material change to how we process your personal data, we will notify you by email and may also update this Policy. How We Use Your Information We may use the Information we collect about you for various purposes, including to: • Respond to emails, inquiries, comments, questions, or other requests for support; • Transact with you and provide various Services to you; • Communicate with you regarding the Site and our Services; • Monitor and analyze trends, usage, and activities of visitors and Clients; • Enhance the viability and effectiveness of the Services; • Guard against potential fraud and combat the use of fraudulent email addresses; • Publicize certain statistical information about the behavior of visitors to the Site; • Improve the Site, our marketing, and other products or Services we may offer; • Contact you regarding your use of the Site or, in our discretion, changes to our policies; • Provide users with customized services; • Verify and/or authenticate a registered user’s identity; • Comply with applicable laws, regulations, or legal process as well as industry standards and our company policies; • Prevent, investigate, identify, or take any other action with regard to any suspected or actual fraudulent or illegal activity or any activity that violates our Terms of Use; or • For any other purpose, with your consent. When you submit Personal Data through the Site, whether by directly providing it to us upon request or voluntarily disclosing it through comments, you are giving consent to the collection, use, sharing and disclosure of your Personal Data as set forth in this Privacy Policy. We also process Information in other ways for which we provide specific notice at the time of collection and obtain your consent to the extent required by applicable law. Automated Data Collection / Cookies In addition to Information you submit to us, we may collect certain Information using automated tools and tracking technologies. This includes: • Cookies. Cookies are text files placed in your computer's browser to store your preferences. We use cookies or other tracking technologies to understand Site and Internet usage and to improve or customize the Platform and the content, offerings, or advertisements you see on the Site. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. However, not accepting cookies may make certain features of the Site unavailable to you. • Web Beacons. We may also use "web beacons" or clear GIFs, or similar technologies, which are small pieces of code placed on a web page or in an email, to monitor the behavior and collect data about the visitors viewing a web page or email. Web beacons may also be used to provide Information on the effectiveness of our email campaigns. We may also use third-party web analytics services, such as Google Analytics, to help us understand and analyse how visitors use the Site. Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, our Site is not designed to respond to “Do Not Track” signals received from browsers. By visiting the Site, whether as a registered user or otherwise, you acknowledge, and agree that you are giving us your consent to track your activities and your use of the Site through the technologies described above, as well as similar technologies developed in the future and that we may use such tracking technologies in the emails we send to you. Please note that no such tracking technologies will collect any Personal Data from you unless you choose to submit it to us. Sharing of Information In no event will we disclose, rent, sell or share any of your Personal Data to third parties for direct marketing purposes. We only share your Information with third parties for the purposes described below. We may disclose personal Information to our employees, agents, vendors, consultants, contractors, and other service providers and affiliated organizations that need the Information to carry out work on our behalf. For example, we use a third-party payment processor that is governed by its own privacy policy to handle payments for our Services. These third parties can use the Information to which they have access to fulfil the purposes for which we shared the information. We may also share your Information: • If we are required to do so by the law, regulations or legal process; • To respond to requests by government agencies; • When we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual illegal activity; • To enforce our policies, or to protect legal rights, property, or safety; • In connection with a corporate transaction, such as joint venture, partnership, merger, or in the unlikely event of bankruptcy. Notwithstanding any of the above, we will not share Personal Data if the applicable privacy and data protection law prohibit such sharing, including, without limitation, the General Data Protection Regulation (“GDPR”) and the California Consumer Protection Act (“CCPA”). Information Security We maintain appropriate administrative, technical, and physical safeguards designed to help protect Information collected or received through the Site. Although we strive to safeguard Information, transmission via the Internet or any wireless network is not completely secure and we cannot guarantee the security of your Information collected through the Site. As a result, you provide Personal Data to us at your own risk. You hereby acknowledge that we are not responsible for any intercepted Information sent via the Internet, and you hereby release us from any claims arising out of or related to the use of intercepted Information in any unauthorized manner. Data Retention We will store your Personal Data for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the Information was collected, or as may be permitted under applicable law. Unless otherwise required by applicable law, at the end of the retention period we will remove Personal Data from our systems and records or take appropriate steps to properly anonymize it. Links to Other Websites Websites that are operated by entities not affiliated with Leo Shine may have their own privacy policies or notices, which we strongly suggest you review. We are not responsible for the content or privacy practices of any linked websites over which we exercise no control. Children’s Privacy This Site is not intended for, nor targeted to, children less than 13 years of age, and we do not knowingly or intentionally collect Information from children under 13. If you are under 13, please do not send any personal Information about yourself to us. If we learn that we have received Information directly from a child who is under the age of 13, we will delete the Information in accordance with applicable law. Your Choices You have several choices available when it comes to Information about you: • Limit the Information that you provide: If you have an account with us, you can choose not to provide the optional account Information. You may edit, alter, or delete Information that you provided to us when you registered for an account or that you uploaded when using the Service by logging into your account. • Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. Please note that even if you opt out of receiving promotional communications, we may continue to send you non-promotional emails. • Set your browser to reject cookies: You can opt out of the collection and use of certain Information, which we collect by automated means by changing the settings in the device you use to access the Site. However, without cookies, you may not be able to use all of the features of the Site. • Opt out of our internal analytics program: You can do this through your user settings. By opting out, you will stop sharing Information with our analytics tool about events or actions that happen after the opt-out. • Close your account: You can close your account if you no longer want to use our Services. Please keep in mind that we may continue to retain your Information after closing your account, as described in “Data Retention” above. Your Rights If you are located in certain parts of the world, including California and countries that fall under the scope of the GDPR, you may have certain rights regarding your Information, like the right to request access to or deletion of your data. If you are visiting the Site from outside the United States, please be aware that Information we collect will be transferred to and stored on our servers in the United States. By using the Site, you acknowledge and consent to the transfer and processing of your Personal Data in the United States as described in this Policy. GDPR Under the GDPR, we are considered a “controller” and a “co-processor” of the Personal Data of EEA Residents. If you are located in a country that falls under the scope of the GDPR, you have certain rights with respect to your Personal Data, subject to any exemptions provided by the law, including the rights to: • Request access to your Personal Data; • Request correction or deletion of your Personal Data; • Object to our use and processing of your Personal Data; • Request that we limit our use and processing of your Personal Data; and • Request portability of your Personal Data. You can submit these requests by email but applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. You also have the right to make a complaint to a government supervisory authority. CCPA The CCPA permits users in California to request certain details about how their “Personal Information” (as defined by California Civil Code Section 1798.83) is shared with third parties for direct marketing purposes. If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law. The categories of Personal Information we collect are generally described above but differ for individual consumers depending on the Services used by such consumers. Under CCPA, qualifying California consumers may have the following rights: • Request to know the categories of Personal Information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the Personal Information came, the categories of third parties we share it with, and the specific pieces of Information we collect about you; • Request deletion of Personal Information we collect or maintain; and • Opt out of any sale of Personal Information; When you contact us about one of your rights under this section, we will need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to request on your behalf by giving us written authorization. Changes We reserve the right to change this Policy at any time at our sole discretion. In the event we make changes to this Policy, such policy will be re-posted in the "Privacy Policy" section of our Site with the effective date at the top of this Policy. Therefore, we encourage you to review this Policy from time to time so that you are aware of any changes made to this Policy. In any event, your continued use of the Site after any update to this Policy will constitute your acceptance of the change(s), and if you do not accept any changes, you may choose not to use the Site or opt out by sending us an appropriate notice. Contact Us If you have any questions or comments about this Policy, please contact us at newyork@leoshine.com