Privacy Policy

Last Updated: January 2023

EuroLead Sp. z o. o. (“EuroLead”, “we”, “us”, or “our”) operates the business known as EuroLead, which provides services, defined below, which include through the website www.Euro-Lead.com (“Site”). We reserve the right to make changes to this Policy at any given time. If you want to make sure that you are up to date with the latest changes, please be sure to check back periodically.

SECTION 1: About our Services

A About us. EuroLead offers various services and tools designed specifically for recruiters, marketers, and HR specialists who are seeking to make contact with business professionals for employment or marketing purposes, or to obtain industry, market or competitor analysis. EuroLead offers these Services through its Site, or through other tools, to its Users, including access to its contacts search engine tool. The main purpose of this is to provide accurate contact information when Users are seeking to communicate B2B with professionals. Our Prospects Database contains information related to Professional Individuals, and has been curated and indexed from publicly available sources across the internet. Any reference to any of these services of ours, and to our Site, is collectively referred to as our “Services” in this Policy.

B Protection of minors. We do not solicit or target persons under 18 years of age. We do not knowingly collect any information relating to children under the age of 18. If we discover that a child under 18 has provided us with personal information, or we have otherwise came into possession of personal information of a child, we will promptly delete such personal information from our systems.

C Commitment to privacy rights. We take a serious approach to safeguarding privacy rights and respecting them, and in particular we comply as a baseline across our business with the General Data Protection Regulation ((EU) 2016/679, known as GDPR) in recognition of the high standards of rights. Note however that depending on where you live you may not be protected by data privacy laws, or you may have different protection under law. Where we comply with other specific laws, we will state this within this Privacy Policy.

SECTION 2: Who this Policy applies to

This Policy applies to any visitor to our Site, any User of our Services, or any Professional Individuals.

‘User’ means you, if you are a person acting in a business capacity who has created a User Account with us for the purposes of using our Services. This Privacy Policy outlines how we collect, store, process and use personal information of our Users.

‘Professional Individual’ means you, if you are an individual who we have collected information about (including some personal data) from various public sources on the web, in order to index those individuals in our Prospects Database to enable the individual’s publicly available contact information to be made available to our Users. This Privacy Policy outlines how we collect, store, process and use personal data of Professional Individuals.

‘Site Visitor’ means you, if you are not considered a User, but are any other person who is accessing or otherwise making use of our Services, including this Site (including a Professional Individual). If you are a Professional Individual (as defined in this Policy) and you visit our Site for any reason (for example to view any Professional Profile or our contact information page), the provisions throughout this policy related to Site Visitors are deemed to also apply to you in that context.

SECTION 3: Understanding our Professional Profiles

Our Prospects Database contains information about Professional Individuals that has been sourced entirely from publicly available web data. As a part of building this database, we may create Professional Profiles, which is a profile of a Professional Individual visible on our Site, or through our Services. Only Users will have access to all information contained in such Professional Profiles. If you are a Professional Individual and you have become aware (either through ourselves or by some other means) that we hold a Professional Profile of you, you may request to access all the personal data we hold about you, correct it, delete it and opt out of us processing such personal data, and this Privacy Policy explains how to exercise your rights at section 12 and 13. A quick link to opt-out of us processing your information and to delete your Professional Profile is available here.

SECTION 4: Acceptance and Applicable Laws

SECTION 5: Collecting data (for Professional Individuals)

A. How we obtain your data. We may collect personal data about you if you are a Professional Individual from either public sources or third parties, or when you contact us. In either case the career information we obtain about you may include your name, location, work experience, education history (including language skills), phone number, email address, links to your social media profile(s) and any avatar or other such profile or photo.

B. Public information. We may collect personal data about you through publicly available information sources on the web, much like a search engine, we index this information and make it available to our Users through the Prospect Database, and we display parts of this information in Professional Profiles on our Site. Given the vast amount of information indexable from the internet and public sources it may not always be possible to trace the exact source of your information.

C. From third parties. We may collect personal data about you through other Users, Site Visitors or other third parties who may share your personal data with us, or who may use our or third party tools such as browser extensions or plugins to share you personal data with us through the Services.

D. When you contact us. If you contact us in any manner we will keep any information you provide to us including records of correspondence, and you should be aware that we monitor and may record telephone calls and written correspondence for training and security purposes.

E. Visits to our Site or use of Services. If you visit our Site for any reason (see other sections in this Policy related to Site Visitors).

SECTION 6: Collecting data (for Users, Site Visitors and others)

A. How we obtain information about you. We collect information about you if you are a Site Visitor, or User, directly from you, from third parties, and automatically through your use of our Services. We may combine information collected from or about you from these various sources. You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide a product or feature, you may not be able to use that product or feature. The data we collect depends on the context of your interactions with us and our Services, the choices you make, including your privacy choices, and the products and features of our Services that you use or otherwise access.

B. We collect information from you when you sign up to our Services
• We collect information about you directly from you as you input the information to our Services.
• We may collect your personal details including but not limited to your real name, user name, telephone, location, email address, business name and any other information you submit when you create an account or otherwise access our Services and opt to input data.
• If you sign up to receive news or updates from us, we will collect information such as your email address, or your business name and location and other contact information if you provide us with it.

C. We collect data when you communicate with us
• If you contact us in any manner we will keep any information you provide to us including records of correspondence, and you should be aware that we monitor and may record telephone calls and written correspondence for training and security purposes.
• If you provide feedback or testimonials to us, or take part in any customer survey, or participate in events, promotions, product, feature or service launches, or competitions, we will collect any information you provide.

If you’re just browsing our Site, editing or otherwise using your account, making any financial transactions on our Site, or otherwise making any use of our Services we will collect different data as you do it, some of which may be considered personal data:
• Certain features of the Services may allow you to post any text or graphical content, or any other content or information to our Site, (collectively, “User Content”). If you post User Content to our Services (including uploading to our Site), the User Content, as well as other information, such as your name, may be available to other Users and/or Site Visitors, and we cannot prevent such information from being used in a manner that may violate this Privacy Policy, our Terms of Use, the law, or your personal privacy;
• Any information you upload to your account at any time, including the above mentioned User Content and all other personal and non-personal information described above;
• Any information you upload to our Services when submitting any application for any job advertised on our Services which may include your name, email, and CV or LinkedIn or other social profile or online resume;
• Details of any transactions that you carry out, including any information we require to provide the products or services that you sign up or upgrade to, such as financial information that you provide to us or our payment service provider (usually in the form of payment card data) for the purposes of paying for any products, features or services offered by us;
• Data from your other social network accounts if they are linked to our sites (more details below);
• Your location according to the IP address assigned to your computer machine or device by your Internet Service Provider, and mobile location data (more details below);
• Usage data about how you use our site, this is what we consider Anonymous Data, which we collect using Cookies (more details below).

We automatically collect information about you through your use of our Services, including, without limitation:
• Log information which may include your Internet protocol (IP) address, the type of browser you are using, information about the device you are using, domain name, the website that led you to our Services, the website to which you go after leaving our Services, your location, and the dates and times you access our Services.
• Usage information, such as numbers of the scenes viewed by you, the combination of bands selected or used by user, and the types of analytics or algorithms a user applies, search histories or any communication logs if applicable.

Please see our Cookies and Other Tracking Mechanisms section below for more information. We may combine information we collect automatically with information we collect directly from you or from third parties.

We also collect information about you from third parties. For example, if you sign up to, or log into our Services using a third-party platform (e.g., Facebook, Google, or LinkedIn), then we may collect the following information:
• Facebook. If you log into our Services using Facebook, you must enter your Facebook email address and password. We will ask that you grant us permission to access and collect your email address, name, and profile picture. If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public on Facebook.
• Google. If you log into our Services using Google, you must enter your Google email address and password. By logging in through Google, you are granting us access to your email address, name, and profile picture.
• LinkedIn. If you log into our Services using LinkedIn, you must enter your LinkedIn email address and password. By logging in through LinkedIn, you are granting us access to your email address, name, and profile picture.

Please keep in mind that any third-party social networking platform controls the information it collects from you, how it is shared, and what permissions we are able to request. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies (available at Facebook Privacy Policy, Google Privacy Policy, and LinkedIn Privacy Policy, respectively).

SECTION 7: Using data (for Professional Individuals)

We process data, including information about you if you are a Professional Individual in the following ways for legitimate purposes (in addition to any use if you become a Site Visitor or User, see Section 8):
• To index our contacts search engine, the search Professional Profiles and maintain an up to date Prospects Database;
• For research, development and analytical purposes to improve or troubleshoot our Services;
• To respond to any contact you make with us including through any support request or correspondence, feedback, or other communication in any medium;
• To respond to any request made under this Privacy Policy, or any relevant authority regulating data protection matters and to verify your identity if required to do so for purposes of responding to any such request;
• To contact you about your Professional Profile or our Services, which may be by email, at all times in accordance with Data Laws, and with the ability for you to opt out of such communications;
• To maintain the integrity of our Services and detect or prevent any fraudulent or illegal activities, and to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, to respond to a subpoena, warrant, court order, or other legal process or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental or regulatory authority (see how we share information below)

SECTION 8: Using data (for Users, Site Visitors and others)

We use the information we collect about you:
• to provide and maintain our Site and Services and to fulfil your requests for our products, and services on the Site and across our Services;
• to improve our Services;
• to develop new features, programs, products, or services and to offer these to you from us, our affiliates and selected third parties that we believe may be of interest to you;
• to perform technical operations, such as updating our Services and systems;
• to authenticate and/or validate our Users and ensure your qualifications to use our Services;
• for customer service and support purposes.

We use the information we collect about you:
• to contact you about your account with us (including managing your account and providing you with customer support and product updates);
• to respond to your enquiries;
• to provide you with news and newsletters, special offers, promotions, and other information from ourselves, our affiliates and selected third parties we think may interest you;
• for other informational, marketing, or promotional purposes. Our communications with you may include communications via email;
• to notify you when we make changes to our terms or policies if necessary; and
• to otherwise enforce or exercise any rights in our terms and policies

We use the information we collect about you:
• To analyze how you interact with our Services;
• to monitor and analyze usage and activity trends; and
• for other research, analytical, and statistical purposes.

We use the information we collect about you:
• To protect the safety, rights, property, or security of EuroLead, the Services, any third party, or the general public;
• to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity which we, in our sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, unlawful, or legally actionable activity (or which we are informed about from any other source including law enforcement or third party rights holders);
• to use as evidence in litigation or any other civil dispute, matter or criminal matter; and
• to enforce this Privacy Policy or our Terms of Use or other policies which apply to your use of the Services which you have agreed to comply with as a User or Site Visitor.

We use the information we collect about you to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.

We use aggregate information about Users, Site Visitors and Professional Individuals, and non-personal information that we collect:
• to improve the design, functionality, and content of our Site and Services and to allow us to personalize our Services;
• to provide, maintain, personalize, protect, improve, and develop our products, programs, and services and to operate our business;
• to analyze usage and performance of our Site and Services and for other research, analytical, and statistical purposes; and
• to tailor display advertisements for us and our affiliates, business partners, and selected third parties to offer you products, programs, or services when you use the Services.

SECTION 9: Sharing your data

We may disclose your information (meaning personal information and User Content, and any other information whether personal or not), as described to you in this Policy and any applicable supplemental privacy statements applicable depending on your location and Data Laws.

In addition to the remainder of this section 9, for Professional Individuals, we may share information about you within our Prospects Database and/or Professional Profiles, meaning that the information obtained about you may be shared with Users for the purposes of us delivering the Services to them.

We may disclose your information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Privacy Policy. Within our corporate group business, we may require to share your information to allow us to provide the services to you, if our companies support us in the context of being service providers, which may include, data hosting, server maintenance, customer support, data analytics, marketing, legal and financial services, payment processing and safety and security services.

We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf. For example, we may disclose your information to third-party service providers to process payments on our behalf.

We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer to a buyer or prospective buyer of our business, our professional advisers, such as our lawyers or compliance advisors, or accountants, where it is necessary for them to advise and to any other persons if we are under a duty to disclose or share your information in order to comply with any legal obligation.

We may disclose your information to protect the safety, rights, property, or security of our business, the Services, any third party, our Users, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues, or loss or risk to life or threat of serious harm; to prevent or stop activity which we, in our sole discretion, may consider to be, or to pose a risk of being, an illegal, unlawful, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Privacy Policy or our Terms of Use.

We may be required by law e.g. through potential or actual litigation, court order, public or governmental authorities, or rules and regulations within or out with your country of residence to disclose all or part of your information to third parties. We may also deem it necessary to make such a disclosure in the event of an issue of national security, law enforcement or other such similar situations as we deem necessary including, for example, allegations of alleged infringement of copyright, trade marks or other third parties’ rights by users or any criminal activity, whether formal or informal, from law enforcement or a government official or regulatory body.

We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.

SECTION 10A: Marketing and Communications (to our Users)

We may share your information with our affiliates or third parties to develop and deliver targeted advertising to you of our or third-party products and services, or to help us to prepare marketing reports. We may send you information about our or our affiliates’ products and services, news and offers, and selected third party products and services that we think may be of interest to you. We may do this by contacting you through your email address or mobile phone number that you have provided. Any communication received from us, as consented to by you, will clearly state that it is being sent by us. You have the option to opt-out of our marketing communications at any time (see below).

If you have consented to receive marketing communications from third parties your data may be passed on to such third parties as we enter into data sharing agreements with, from time to time, for marketing and analytical reporting purposes. We cannot be held liable for the content of the third party’s communications or products/services they are promoting. If you have provided this consent, but change your mind, you can opt-out at any time (see below). Please be advised that you will also require to contact the individual third parties who have been marketing to you if you wish to stop receiving their communications directly.

If you, a User, or a person who has previously consented to receive marketing communications, have changed your mind about the marketing consent you have granted to us, you can follow the opt out procedures contained in any marketing email, or you can opt out by emailing us at [email protected]. Please be aware that it may take up to ten (10) business days for us to process opt-out requests.

If you request to opt out of our marketing or communication emails, please be aware that opting out of marketing emails will not impact upon email communications you may continue to receive which are relevant to the administration of your account, or relative to any other Services you have requested to receive from us (unless those have been opted out of also), or which are required in order to communicate with you regarding any support, response, regulatory, legal or other permitted use as described in this Policy.

SECTION 10B: Marketing and Communications (Professional Individuals, not our Users)

We do not market to you in any way unless you have consented to this. If you are receiving any communications from Users or other third parties who have sourced your information from our Services, the sender of that communication is solely responsible for compliance with any applicable laws related to direct marketing, and it is an express condition of our terms of use that any Users do comply with such laws. We have no control over any communications you may receive from Users or third parties. If you wish to opt out of receiving any form of communication from third parties, you should contact that third party directly.

We will only communicate with you if required to by law or regulation or to respond to any communication you instigate. If you want to exercise your right to remove your information from our Prospects Database or any Professional Profile, please complete our Opt Out Form here.

SECTION 11: Retaining and storing your data

We retain the data collected pursuant to this Privacy Policy for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, including Data Laws. Thereafter if the collected data is no longer needed for purposes specified in this Privacy Policy, we delete all aforementioned data in its possession within a reasonable timeframe (typically up to 7 years). Irrespective of the above, we may still retain some of the data to the extent such retention is necessary to enforce our terms or policies, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services and international law enforcement, regulatory requests, or matters of dispute. If your account is ever terminated by us, or you have been identified by us as a potential or otherwise threat to our business, our Services, our Site or our users, your email address will be retained on our internal blacklist for as long as we deem necessary to protect the business and its users. Additionally, if you are a Professional Individual and you request us to delete your information, or remove your Professional Profile, we may require to retain your email address or other such identifiers to minimise the potential for your data to be collected again in future by maintaining our opt out list.

As we transmit data from public sources and make it available on our Services most often in real time, we are not always storing personal data directly. However, whenever we are storing any personal data of any Site Visitor, Professional Individual or User then that data would be stored on our servers in the Netherlands. If you are a resident of the European Economic Area ('EEA') please be informed that we may transfer your data outside of the EEA to countries. By submitting your personal data to us as a resident of EEA, you agree to any such transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and we enter into appropriate agreements with any third parties in compliance with Data Laws for such transfer purposes.

SECTION 12: Understanding your rights

Data Laws give users a number of rights which you are free to exercise at any time regarding any personal data that you have provided to us and we generally apply the rights afforded by the GDPR to all users, even if they are not resident in Europe. We will respond to requests to access or delete your personal data promptly and in any case within any time limits set by applicable Data Laws (if applicable to us in your case). We have summarised the rights here and how you can exercise them to ensure that we are reasonably and fairly processing your personal information in line with your rights, however you should obtain your own legal advice if you wish to rely on any legislative rights not covered here which you believe in good faith we have a duty to respond to. Subject to our own legitimate interests and any regulatory requirements placed upon us we will endeavour to meet requests made in exercising your rights.

If you are a resident of California, USA or Virginia, USA, your attention is drawn to Section 14.

We may require you to provide identification if you are exercising some of these rights, for cases where it is not immediately obvious that you are truly the person to whom the personal information relates, as we need to be certain before making any changes to someone’s personal information that it is your information (or you have that person’s authority to act for them). If identification documents are requested as part of the process, that document will only be collected, stored and processed by us for the sole purpose of confirming your identity in response to your request, and upon completing your request we will delete it.

We may need to communicate with you in response to your request, and we may require to update you on progress/confirm outcomes. We do this by email and when you complete the forms to contact us you will have the ability to consent to us using your email for this purpose. If you contact us by email, we assume that you are consenting to receiving a response from us by instigating the communication. Where any rights exercised by you result in you seeking to object to us processing your personal information or otherwise deleting your personal information, then in order to ensure we do not process any personal information of yours in future, we will retain your email address for the purpose of our opt out list only, and we will delete or anonymise all other information held.

Sometimes we need to keep a record of some data for security purposes (for example to assist law enforcement agencies with any criminal investigations or other regulatory authorities or dispute matters) or for payment processing (to prove to banks that we were authorised to take payments from you if you pay to use the services), even if you have requested removal of your data. Any such data retained will only be used for these limited purposes.

Removing your personal information from our Services will not necessarily mean that the original source of the personal information (other publicly available website materials not owned by us) will be removed, and we are only responsible for removing information within our control or possession, which is particularly important if you are a Professional Individual.

SECTION 13: Exercising your rights

What you can do. You can request a copy of the personal data that we hold about you.

How to make the request. Generally, to obtain a copy of your data, simply email [email protected] stating that you wish to request a copy of all personal data that we have about you, and you must include your name, email address and any relevant information to help us locate your information for example the URL Professional Profile if applicable.

The process. Upon receipt of your request and following verification of your identity if required by us to process your request, we will endeavour to provide the information that we are permitted to share (which may be redacted if it includes personal data or another person) to you within 14 to 30 days (or sooner if required by Data Laws). If you seek to make multiple requests within a short time period, we reserve the right to charge a nominal fee to cover the cost of our response to multiple access requests.

What you can do. We want to make sure our records are up to date and accurate, and in some countries Data Laws require us to allow you to correct or amend your personal data.

How to make the request. To request a correction or amendment to your personal data, simply email [email protected] stating that you wish to request a copy of all personal data that we have about you, and you must include your name, email address and any relevant information to help us locate your information for example the URL Professional Profile if applicable.

The process. Upon receipt of your request and following verification of your identity if required by us to process your request, we will review the changes you wish to make, and within a reasonable and practical time period (or earlier if required by Data Laws) our customer support team will ensure that your personal information held is corrected/updated/amended in line with your request, and they may inform you of this upon completion.

It’s ok to change your mind about what personal data you are allowing us to use and keep and what you don’t want us to use or keep. We have to advise you however, that opting out of some personal data processing/storage may result in a loss of functionality of the Services and a reduced user experience.

What you can do. You can tell us at any time that you want us to stop processing your personal information, if (i) you are a Professional Individual and we are processing your personal information under a lawful basis within our Prospects Database/Professional Profiles and you do not wish for that to happen, or (ii) you are a User or Site Visitor, or any other person, who has previously consented to data processing but has now changed your mind and want to revoke any prior consent.

How to make the request
• If you are a Professional Individual, please complete our form here.
• If you are a User, or any other person who is not a Professional Individual, please email [email protected].com with your name, email and any information about how your personal data is being processed by us and details of your request to object to the processing of that information.

The process. Upon receiving a notice from you via the form submission you make (or by email if applicable), we will promptly stop processing your personal information (subject to retention explained in Section 12) and (i) if you are a Professional Individual we will remove you from our Prospects Database and any Professional Profile, or (ii) if you are a User, we will take steps to close your account as we will be unable to administer your account and provide the Services to you if we are unable to process your personal data necessary for the account operation. In order to ensure we do not process any personal information of yours in future, we will retain your email address for the purpose of our opt out list only, and we will delete or anonymise all other information held.

What you can do
• If you are a User you can request that we remove and delete your personal information (which will mean your account will be closed).
• If you are a Professional Individual, you can request that we remove and delete your personal information, meaning that it will be removed from our Prospects Database/Professional Profiles.
• We treat any request to destroy personal information as being a request to fully delete all such personal information, unless you tell us otherwise, we will assume that you wish to be removed entirely, subject to data retention explained in Section 12.

How to make the request
• If you are a Professional Individual, please complete this opt out form.
• If you are a User, or any other person who is not a Professional Individual, please email [email protected] with your name, email and any information about how your personal data is being processed by us and details of your request to object to the processing of that information.

The process. Upon receiving a notice from you via the form submission you make, further to any verification we may need to make, we will take all reasonable and practical steps to remove your personal information from our Services, and in the case of Users, we will close your account.

(i) Right to be “be forgotten”. This right is for the erasure of your personal data, and is for residents of the UK and EU only. Please follow the process outlined at Section 13D (above). If you have any problems, please contact [email protected]

(ii) Right to data portability. This right allows you to receive personal information in a structured, commonly used, and machine-readable format and is for residents of the UK and EU only. Please email [email protected] with your name, email and any relevant additional information to enable us to process your request.

SECTION 14: Notice to residents of California, USA and Virginia, USA

A. If you are a User, or Professional Individual, that is resident in California, USA or Virginia, USA, we have prepared this Notice to comply with the US Data Laws.

B. Personal Information collected. In addition to the information provided in this Privacy Policy at Sections 5 and 6, this Section 14 further details important information related to categories of personal information collected, what personal information is collected, and the sources of that personal information.

C. Categories of personal Information Collected. We collect identifiers (‘Identifier Data’), internet or other electronic network activity information (‘E-Data’), geolocation data (‘Location Data’) and Employment-related information (‘Employment Data’). Please note that under Virginia state laws, personal data does not include information which is publicly available. We do not collect sensitive personal information as defined by US Data Laws. In addition to any information stated in Sections 5 and 6 of this Privacy Policy, we can provide the following details:

• Identifier Data may include full names, email addresses, phone numbers, IP addresses, device identifiers, social media profiles, business emails, job titles and company or employer information, business mailing addresses.
• E-Data may include data related to how you interact with our Site or Services (as defined in our Privacy Policy) over the internet and across your devices.
• Geolocation Data may be physical location data derived from IP addresses or business location addresses.
• Employment Data may include business email addresses, telephone numbers, physical business addresses or mailing addresses, employment status, employment history, job titles and employer names or business names.

D. Retaining your data. US Data Laws require us to share information with you about our data retention periods, ensuring that we are minimizing the amount of time we are holding your personal information and limiting this to as long as is necessary. We fully describe our data retention policy at Section 11 of this Privacy Policy.

E. Sources of the personal information collected. In addition to anything else stated within this Policy, the sources of personal information collected are:

• Identifier Data may be sourced from directly or indirectly from (i) publicly available information or (ii) your activity on our Site, or (iii) other Users or our customers (former, current or potential) or (iv) third party data suppliers or (v) third party data sales providers.
• E-Data may be sourced directly and indirectly from (i) your activity on our Site, or (ii) interactions or communications from our Users or our customers (former, current or potential)
• Geolocation Data may be sourced from directly or indirectly from (i) publicly available information or (ii) your activity on our Site, or (iii) other Users or our customers (former, current or potential) or (iv) third party data suppliers or (v) third party data sales providers.
• Employment Data may be sourced from directly or indirectly from (i) publicly available information or (ii) your activity on our Site, or (iii) other Users or our customers (former, current or potential) or (iv) third party data suppliers or (v) third party data sales providers.

F. Purpose of collection of personal information. Sections 7 and 8 of our Privacy Policy set out the purposes of collection and we will not collect personal information for any purpose other than any purpose disclosed to you within this Privacy Statement or our Privacy Policy.

G. Sharing your personal information. How we share your personal information is set out in Sections 9 and 10 of this Policy. As stated throughout this Policy, the personal information of Professional Individuals may be included in Professional Profiles, or our Prospects Database, which we allow our Users to access if they have agreed to our strict Terms of Use and this data may include the various information described at part D of this Section 14. For purposes of US Data Laws we do sell your personal information. Virginia state law provides exceptions for sharing personal information meaning that, if you opt-out of data sharing, we do not need to honour that opt out, if we require to disclose your information in the following permitted ways (i) to a third party acting as a data processor for us e.g. payment processing provider, (ii) to a third party for purposes of providing a product or service that you have requested we/they provide to you, (iii) to our affiliate companies, (iv) if the information is information you have intentionally made available to the general public via a mass media channel and did not restrict such information to a specific audience e.g. information which is publicly available through such platforms, and (v) as part of a merger, acquisition or such similar corporate transaction.

H. Automated decision making/profiling/targeted advertising. We do not use automated decision making or profiling or targeted advertising.

I. Your rights depending on whether you live in California, USA or Virginia, USA:
• You have the right to obtain from us access to the information we hold on you, obtain a copy of it in machine readable format, or ask us to correct your data; and you are entitled to know if we have shared that information with any third parties. If you would like to request this information, please submit your request by emailing [email protected] or writing to us (see the end of this Policy for our full contact details).
• You have the right to ask us to delete all the personal information we hold on you. If you would like to request the deletion of your information, please submit your request by emailing [email protected] or writing to us (see the end of this Policy for our full contact details).
• It is important to protect you that we ensure the person making the request to access or delete your personal information is really you and we will contact you to let you know what else we need from you before we send you a copy of your personal information, which currently involves providing us with photographic identification (which is used for the purpose of verifying your identity and is not otherwise used or stored by us). You are entitled to receive a response from us within 45 days to any request for access to or deletion of your personal information. Any disclosures made by us will only cover a period of 12 months prior to the date of the request and you may only make a request for access to, or for data portability, twice within any 12 month period – any additional requests will be at our discretion to process.
• Please note that Your Right to Access and Right to Deletion are not absolute and are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us if you are a User, or the security of the our systems of networks. Further, we may be entitled to retain certain information in order for us to provide Services contemplated at the time your information was collected and which can be reasonably anticipated, to assess and detect and prevent any security incidents or malicious, fraudulent or otherwise illegal or unlawful activity, to comply with any additional laws, for scientific or analytical research if so permitted, to comply with obligation placed upon us by any court, government or regulatory authority, to assist law enforcement, or to make any other internal uses of the information what remain compatible with the purposes for which it was initially collected.
• You have the right to understand how we share or sell your personal information (as described in this Privacy Policy), and importantly you have the right to opt out of having your Personal Information sold as defined in the CCPA. To opt out of any data selling please visit our dedicated ‘Do Not Sell My Personal Information page which provides details of how you can easily opt out of any future sales of your information, if applicable.
• You have the right to appoint an authorized agent to submit a request to opt-out of the sale of personal information on your behalf if you provide the authorized agent written permission to do so. If you use an authorized agent to submit a request, he or she must provide their name, email address, phone number, and written permission from you that includes your contact information. We will contact you using the information provided and verify your identity directly with us. We cannot respond to your request to provide additional disclosures or delete any personal information if we cannot verify your identity and the authorized agent’s authority to make the request on your behalf. Written permission is not required if the agent provides proof of power of attorney.
• You have the right to not be discriminated against by us for exercising your rights, and we do not discriminate against any person, although you understand that it may not be possible for us to provide the Services if we don’t have access to certain information that is required to ensure the Services can be properly provided to you.
• Appealing a decision we’ve made (Vriginia residents only). You may have the right to appeal our refusal of any data request your make, through an appeal process. To appeal our refusal to provide the information (if this ever occurs), please write to us at [email protected] We are legally obligated to respond within 60 days to you. If we do not accept your appeal you will then be entitled to escalate the matter by the submitting a complaint to the Virginia Attorney General’s office by mailing [email protected] or writing to 202 North Ninth Street. Richmond, VA 23219. We cannot guarantee these details are accurate and if you require to contact the AG Office, please double check all contact information.

SECTION 15: Cookies and tracking

A. About Cookies. We, or our service providers, may collect information about your computer or mobile device by using Cookies. Cookies are small text files that are placed on your computer by websites that you visit and provide statistical data to us, that does not identify you personally but tell us a lot about your browsing habits to tailor your user experience to suit your needs. We use cookies to enhance our security, help us gather information during subscription and understand our web traffic trends and to share your non- personal information with carefully selected third parties for marketing purposes. When you visit the publicly available sections of the Services, a session ID cookie is placed on your computer that only lasts while you’re visiting. We also place persistent cookies (also known as local storage devices) on user computers, so that we remember them to make your login in process faster and easier.

B. Why we use cookies. Using cookies on our Services enables us to:

• estimate our audience size and usage pattern;
• store information about your preferences, and so allow us to customise the Services according to your individual interests;
• speed up your user experience on Site;
• recognise you when you return to any Site or Services;
• provide anonymised statistical information: Non-personal data may be gathered on our behalf using cookies, log file data, and code that is embedded on our websites by specific third party partners to help these selected third parties to deliver relevant advertisements to you;
• help improve the services we provide to you.

C. Your cookie choice. You have the right to choose whether or not to accept cookies and we explain how you can exercise this right below. However, please note that if you choose to refuse cookies you may not be able to use the full functionality of our Site and the websites of other companies. You can amend your cookie settings by following you device instructions and preference settings, or your browser settings. Further information about cookies, including how to see what cookies have been set on your device/browser and how to manage and delete them, visit www.aboutcookies.org and www.youronlinechoices.eu.

D. Detailed cookie usage. We may use the following cookies with the functions and purposes explained here:

• Analytics and research. We may use the information collected by Google Analytics to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. You can opt-out of Google Analytics here https://tools.google.com/dlpage/gaoptout. We or our service providers use these tools to help us understand use of, and to improve, our Services, performance, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services;
• Authentication. These cookies help us to identify our members so that when you’re logged in, you can enjoy all of the features without having to continually log in – our website “remembers” you and allows you full access without the need to keep entering your log in details.
• Security and Site integrity. We may use cookies and other devices, such as CAPTCHAs, to help keep the Site and our users safe and secure by protecting the Site from fraud and spam attacks to keep your data safe.
• Site features and Services. These cookies and local storage devices provide the functionality that our users enjoy, such as uploading of photographs, chats, instant messaging, your account settings etc. We also use cookies to help provide experiences, such as links to other social media sites. In some cases, the site feature you choose may allow a third party to place cookies or local storage devices on your computer. The third party who places cookies on your device is responsible for how they process their data you should always read their privacy policies including Twitter and Facebook whose own privacy policies apply.
• Performance. We need to use certain cookies and local storage devices to ensure our users have the best possible experience, such assisting with your navigation of our site, ensuring pages load up quickly and respond faster to your requests for our Services.

E. Do not track. Our Services do not currently respond to any web or mobile Do Not Track signals.

SECTION 16: Safeguarding and security

A. What we are doing. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site/Services and any transmission is at your own risk. We take reasonable administrative, physical, and electronic measures designed to safeguard and protect your information from unauthorized access or disclosure. This includes using secure software and storing your information in encrypted form behind a firewall designed to block access from outside our network. Although we use commercially reasonable efforts to safeguard the privacy of your information, transmissions on the Internet cannot be made absolutely secure. Where any information is required to be disclosed to third party service providers to ensure the provision of Services to you, all such third parties are subject to strict agreements to ensure the continued safeguarding of your data as much as possible. We assume no responsibility or liability for disclosure of any of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our reasonable control.

B. What you should do to protect yourself. You should take steps to protect against unauthorized access to your device and your User account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

C. Third party links. Our Services may contain links to third-party websites and applications. Any access to and use of such linked websites and applications is not governed by this Privacy Policy but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third-party websites or applications and you should use caution and closely review any privacy policies applicable to any third-party websites or applications that may be linked to through our Site or Services. We may use Google Apps service to service our application inbox offline and to compose and send mail communications electronically through the customer mailbox feature of our Services, and the privacy policy of Google Apps Services will apply in such cases, available here https://policies.google.com/privacy

SECTION 17: Important legal matters

A. LIMITATION OF LIABILITY. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES, SO THE FOLLOWING LIMITATION AND EXCLUSIONS MAY NOT APPLY TO YOU AS A PERSON, A SITE VISITOR, A PROFESSIONAL INDIVIDUAL OR A USER OF OUR SERVICES. TO THE FULLEST EXTENT ALLOWED BY APPLICABLE LAW, UNDER NO CIRCUMSTANCES AND UNDER NO LEGAL THEORY (INCLUDING, WITHOUT LIMITATION, TORT, CONTRACT, STRICT LIABILITY, OR OTHERWISE) SHALL EuroLead Sp. z o. o. (OR ITS LICENSOR(S) OR SUPPLIER(S)) BE LIABLE TO YOU OR TO ANY OTHER PERSON FOR (A) ANY INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES OF ANY KIND, INCLUDING DAMAGES FOR LOST PROFITS, LOSS OF GOODWILL, WORK STOPPAGE, ACCURACY OF RESULTS, OR COMPUTER FAILURE OR MALFUNCTION, OR (B) ANY AMOUNT, IN THE AGGREGATE, IN EXCESS OF THE GREATER OF (I) $100 OR (II) FOR USERS, THE AMOUNTS PAID BY YOU TO EuroLead Sp. z o. o. IN CONNECTION WITH THE SERVICES IN THE THREE (3) MONTH PERIOD PRECEDING THIS APPLICABLE CLAIM, OR (C) ANY MATTER BEYOND OUR REASONABLE CONTROL.

B. GOVERNING LAW AND JURISDICTION. This Privacy Policy will be governed by the laws of England and Wales. Foreign laws do not apply. Any disputes relating to this Privacy Policy or any supplemental Privacy Statement, or the Services to which they relate, will be heard exclusively in the courts located in England, UK.

C. LANGUAGE. All of our terms of use and Privacy Policy / Privacy Statements are written in the English language and any proceedings relating to these documents and any related dispute shall be conducted in English. If we make these documents available in any other language, the terms in the English language version shall prevail.

SECTION 18: Our company information

SECTION 19: Important Representative Contact Information

(a) Contacting our Data Protection Officer
Should you have any reason to contact our Data Protection Officer, they can be contacted by writing to the above address, marked for their attention, or by emailing [email protected].
Any communications to the DPO which do not relate to data protection and privacy matters will not be responded to.

(b) GDPR Art. 27 Representative
In accordance with GDPR, as we are established in Europe, we are not required to designate an EU Representative and all enquiries may be made to the Data Protection & Information Officer.

(c) UK Applied GDPR Art.27 Representative
In compliance with the UK Data Protection Act 2018, we are required to designate a UK Representative and we have appointed a third party representative for this service which is Elpha Fox Privacy, and you may contact them by mailing your request to Euro-Lead.com, c/o Elpha Fox Privacy, 7 Bell Yard, London, WC2A 2JR.

(d) Swiss Federal Act on Data Protection (FADP) Representative
Residents of Switzerland may be entitled to exercise your rights under the Swiss Federal Act on Data Protection (FADP). These are broadly the same rights as listed throughout this Privacy Policy, although your supervisory authority is the Federal Data Protection and Information Commissioner (FDPIC). We have appointed DataRep as our Data Protection Representative in Switzerland so that you can contact them directly regarding rights or questions you have relating to the Swiss FADP. If you want to raise a question to us or exercise your rights under the Swiss FADP, you may do so by: (i) Sending an email to DataRep at [email protected] or (ii) Mailing your inquiry to: DataRep, Leutschenbachstrasse 95, ZURICH, 8050, Switzerland. Please ensure your request is addressed to DataRep, and any cover letter quotes EuroLead as the reference. Any mail addressed directly to EuroLead, sent to this Swiss address, will not be received. For information on how our Swiss representative handles your information, please visit www.datarep.uk/privacy-policy.

SECTION 20: Concerns

We hope that we will be able to directly resolve any complaint that you may have, however, if you are not happy with how we handle any complaint, depending on your place of residence, you may be able to raise a complaint at any time to your country’s national data protection authority