Revised: August 20th, 2020
The purpose of the Site is to allow you to learn about and use the LeadMeNot Application while also informing you of the related data collection and reporting services necessary to create an account and purchase a subscription for use of the Application. This Policy describes how CJ2 Solutions, LLC will handle the information we learn about you through your use of the Site and the Application. If you have questions or wish to contact us about this Policy, you may direct inquiries to:
CJ2 Solutions, LLC 7014 13TH AVENUE, SUITE 202 Brooklyn, NY 11228 Phone: (845) 596-8229
If at some point our information collection or usage practices materially change, we will, without unreasonable delay, post such changes to our website and revise this Policy accordingly. Additionally, we will notify you about the changes we have made and receive your consent before using your personally identifying information in a new way.
WHAT INFORMATION DO WE COLLECT?
We collect different information from you based on your Site/Application usage, and whether you are a visitor to the Site or a subscriber of the Application. We collect personally identifying information (“PII”) when you (i) register and create an account on the Site, (ii) submit questions or information through the Site, or (iii) purchase a subscription. Examples of PII may include your name, username, password, address, telephone number, email address, or credit card information.
If you subscribe to use the Application and install LeadMeNot on any of your devices, the Application will collect additional data that can be viewed on the Site and shared with your accountability partners. Examples of additional data collected through the Application may include the titles of websites visited, email subjects and senders/receivers, application usage logs, file logs, geolocation information, call logs, text logs, application content and data, directory paths, and the dates and times these various events occurred. The additional data collected through the Application will vary depending on the device and operating system in which the Application is being used, as well as your personal account settings. Data collection will continue for as long as LeadMeNot is installed on your device, even if your subscription has lapsed.
Additionally, certain other information will be automatically collected and retained in our logs. This information may include internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamps, geolocation information, and information on what pages Application users visit. We collect and store this information on an individual basis and in aggregate, or combined, form. LeadMeNot may also collect non-PII about users whenever they interact with our service. Non-PII may include:
1. The type of device and technical information about users’ means of connection to our service, including but not limited to the operating system and version, Internet Service Providers (ISPs) used, and other similar information; and
2. The way a user interacts with our service and website, such as through button clicks, time spent using the Application, the percentage of users who purchase subscriptions, etc.
USE AND RETENTION OF NON-PERSONALLY IDENTIFIABLE DATA AS WELL AS PSEUDONYMIZED DATA
We may generate, collect, use, and retain pseudonymized browsing and Application data whenever users interact with our Application. When we generate data collected through the Site and Application, we leverage pseudonymization techniques for the processing of data in such a way that the data can no longer be attributed to a specific data subject without the use of additional information that connects the data to an individual. We may use this data in aggregate for purposes including but not limited to (i) training our artificial intelligence systems in machine learning algorithms, which refines our activity classification system and reports; and (ii) creating and subsequently refining our pattern recognition & prediction models.
The only people we share your personal information with are those whom you designate as your ‘Accountability Partners,’ which you will designate through the Site or Application. Specifically, we only share information with your 'Accountability Partners' to the extent that said information has been identified as a triggering event, where triggering event is defined as an activity that (i) contains words or phrases that may be deemed as objectionable (i.e. contains sexually implicit or explicit content, profanity, obscenities) and/or (ii) containing App names and/or website names defined by the User during onboarding (i.e. "Accessing YouTube app after 7pm every weekday"). We will also share your personal information with trusted third parties (as mentioned in the ‘USE OF THIRD-PARTY SERVICES’ section) who assist us in operating our Site and Application. We may also release your personal information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our safety, property, or rights, or the safety, property, or rights of others. Otherwise, we do not rent, sell, or transfer personal information to any third party.
We retain pseudonymized data for only as long as necessary to fulfill the purposes for which it was collected.
We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information, transaction information, and data stored in relation to our services. Sensitive private data exchange between the service and its users always happens over an encrypted communication channel. Remember that nothing online is 100% secure.
USE OF THIRD-PARTY SERVICES
LeadMeNot uses many third-party services in order to deliver a robust, reliable, and feature-rich service to users and prospective users. A complete account of third-party services used by LeadMeNot is listed below. In accordance with LeadMeNot’s legal, contractual and regulatory obligations such as the European Union (EU) General Data Protection Regulation (GDPR) and Privacy Shield, all third-party services are vetted by LeadMeNot’s Data Protection Officer with the appropriate contractual agreements in place that guarantee the appropriate handling and security of your data. Third-party services and links to the corresponding privacy policies are provided below.
To ask questions or comment about this Statement and privacy practices, or to update, change or remove Personal Data, contact LeadMeNot at firstname.lastname@example.org.