Last update: September, 2022
Please read this privacy policy (the “Policy”) carefully to understand how Astral Hodling OU registered in Estonia,Lõõtsatn 5, 11415 Tallinn(“Astral”, “Marketplace”, “we”) uses personal information on the Lean Global Marketplace. By accessing or using www.marketplace.leancommunity.org, or any other related sites, applications, services and goods, or any other website operated by Marketplace that links to this policy (each, the “Site”), you acknowledge that you have read and understood this Policy. This Policy may change from time to time; any changes we make to this Policy will be posted on this Site, we will also take any other steps, to the extent required by applicable law, including notifying you about material changes. Changes to this Policy are effective as of the stated “Last Updated” date. We recommend that you check the Policy periodically for any updates or changes.
The short version
Information We Collect – You directly provide us with most of the information we collect: when you register to the Site, use it, complete forms, or register to any of our programs. We also collect information about your communications with Marketplace as well as any of your posts on our blogs or forums and your communication with other users of Marketplace. In addition, we automatically collect information while you access, browse, view or otherwise use the Site and receive information from third party vendors or other available sources.
Our Legal Basis for Using Your Personal Information – Where relevant under applicable laws, all processing of your personal information will be justified by a “lawful ground” for processing as detailed below.
How Do We Use the Information Collected? – We use personal information to provide you with quality service and security, to operate the Site, understand how people use the Site, and to perform our obligations to you; to ensure marketplace integrity and security; to prevent fraud; to contact you and send you direct marketing communications; to promote and advertise the Site, our services and the Marketplace; to comply with lawful requests by public authorities and to comply with applicable laws and regulations.
How Long Do We Keep Personal Information – We will keep personal information only for as long as is required to fulfil the purpose for which it was collected. However, in some cases we will retain personal information for longer periods of time.
Children – This Site is offered and available to users who are at least 18 years of age and of legal age to form a binding contract. Minors under 18 and at least 13 years of age, are only permitted to use the Site through an account owned by a parent or legal guardian with their appropriate permission. Minors under 13 are not permitted to use the Site or the Marketplace services. We do not knowingly collect personal information from children under 13.
Sharing Personal Information with Third Parties – We share personal information with third parties in order to operate the Site, provide our services to you, fulfil obligations imposed on us by applicable laws and regulations, and prevent fraud, infringements and illegal activities.
Where We Store Personal Information – Some of the personal information you provide to us will be stored or processed on our behalf by third party suppliers and data processors and may be located in other jurisdictions, such as Poland or Estonia.
Cookies – We use cookies and similar technologies (such as web beacons,hotjar, pixels, tags, and scripts) to improve and personalize your experience, provide our services, analyze website performance and for marketing purposes.
Do Not Track (DNT) – Our Site does not respond to Do Not Track (DNT) signals.
External Links – the Site contains links to third party sites and if you link to a third party site from the Site, any data you provide to that site and any use of that data by the third party are not under the control of Marketplace and are not subject to this Policy.
Security – We implement technical and organizational measures to maintain the security of the Site and your personal information and in preventing unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures.
Rights of EU, EEA and UK Users – Where we process personal data related to EU, EEA and UK user, further terms apply to our processing in relation to your rights as a data subject under EU data protection laws, as detailed below.
Specific Provisions for California Residents – If you are a California resident, you are entitled to specific privacy rights as detailed below.
Updating Personal Information – We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. In the event that you believe your information is in any way incorrect or inaccurate, please let us know immediately.
Contact Us – You can exercise your rights over your personal information, by contacting us at contact@leancommunity.org.
Information We Collect
Information You Provide.
When you register to the Site, use it, complete forms, participate in skills tests or surveys, or use the Site as collaborator, and/or register to our affiliate or influencer or similar program, we ask you to provide certain personal information, including a valid email address, or Google account login details and username. We will also ask you to provide or otherwise collect additional information, such as, your name, profile details, physical address or billing information, telephone number or other contact details, transactional information, payment information (for example, in certain cases we process your payment method and credit card number), taxpayer information and forms, details about other social networks linked accounts, details about your listed offers, purchases, education, profession and expertise, information and files uploaded by you to the Site, and additional authentication information (such as copies of your government issued ID, passport, or driving license.
Information We Collect Automatically.
We collect information while you access, browse, view or otherwise use the Site. In other words, when you access the Site we collect personal information on your usage of the Site, including transactions and communications with other users through the Site, your searches, the pages you visited, as well as other actions on Site. We also, collect, use and process the information relating to such usage, including geo-location information, IP address, device and connection information, browser information and web-log information, and the URLs of the web pages you’ve viewed or engaged with before or after using the Site. We also collect and process information relating to the use of cookies and similar technologies, as detailed below. We use that information to provide you our services, enhance user experience, personalize your browsing experience as well as monitor the Site for preventing fraud and inappropriate content or behavior.
Additionally, in order to improve your online experience at Marketplace, we have implemented impression reporting. While you view our ads, we gather user Global Unique Identifier, HTTP request data like, user agent, IP, host, URL, country/continent from which request made, browser info, device/operating system/operating system version.
Information We Receive from Third Parties.
We receive information from third party vendors and/or other commercially available sources, such as:
- Third party vendors who provide us data to supplement the information we collect about you, in accordance with applicable laws. For example, we receive fraud warnings from service providers for our fraud prevention and risk assessment efforts. We also receive information from enrichment service providers to enhance and personalize your experience as well as from advertising and marketing partners in order to manage and measure our campaigns.
- If you link, connect, or login to your account with a third-party service (e.g. Google, Facebook, LinkedIn), we receive certain information, such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
- If you choose to invite contacts from your G-suite directory, we will have the ability to view details of contacts, subject to your G-suite permission. We will use this data to allow you to invite your contacts to your Marketplace account. We will also use aggregated anonymized information for our internal purposes.
- If you integrate into your account information from third parties or otherwise integrate your account with third party systems, tools or products, we will receive certain information about you according to your permissions at such third parties.
- We also receive certain information about you, if you are invited to Marketplace by another user (for example, as part of our collaboration tools and referral program), in such case we will receive limited information, such as your email address or other contact information, and we will use it for the same purpose it was provided and in accordance with the terms of this Privacy Policy.
We combine your personal information with information we collect automatically or obtain from other companies and use it for the purposes detailed in this Policy.
Our Legal Basis for Using Your Personal Information
Where relevant under applicable laws, all processing of your personal information will be justified by a “lawful ground” for processing. In the majority of cases, processing will be justified on the basis that:
- you have provided your consent for us to use your personal information for a specific purpose;
- our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with services which you have purchased);
- the processing is necessary to comply with a relevant legal obligation or regulatory obligation that we have (e.g. fraud prevention); or
- the processing is necessary to support our legitimate interests as a business (e.g. to improve our services to you), subject to your interests and fundamental rights and provided it is conducted at all times in a way that is proportionate.
How Do We Use The Information Collected?
We will use your personal information for the following purposes:
- to provide you with quality service and security, to operate the Site, to perform our obligations to you and to develop and improve our service. For example, we use personal information to verify your identity. We also use this information to establish and set up your account, verify or re-issue a password, log your activity, enable your communications with other members, provide customer support and contact you from time to time. The information helps us to develop and improve our services, to understand and analyse our performance as well as your preferences and performance and to customize and personalize our service and enhance your experience.
- to ensure marketplace integrity, prevent fraud and maintain a safe and secure marketplace and services. For example, we use personal information to monitor, track and prevent fraudulent activities and other inappropriate activities, monitor content integrity, conduct security investigations and risk assessments, verify or authenticate information provided by you, enforce our Terms of Service and comply with applicable laws.
- to contact you, as requested by you or as otherwise approved by you or permitted according to this Policy.
- to promote and advertise the Site, our services and the Marketplace. For example, we use the information collected from you for the purpose of sending direct marketing messages (as detailed below), to show you information that may be of interest to you, to organize and facilitate referral programs, contests or other promotional activities or events.
- to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.
We will ask for your consent before using information for a purpose other than those set out in this Policy.
Direct marketing:
- We use your personal information to send you direct marketing communications about our products, services or promotions from Marketplace that may be of interest to you or our related services. This may be via email, post, SMS, telephone or targeted online advertisements.
- We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications which we believe may be of interest or relevance to you, based on the information we have about you.
Updating Personal Information
We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. In the event that you believe your information is in any way incorrect or inaccurate, please let us know immediately. We will make sure we investigate the matter and correct any inaccuracies as quickly as possible where necessary or give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we will ask you to verify your identity before we can act on your request. If for any reason you have a problem with deleting your personal information, please contact us at contact@leancommunity.org and we will make reasonable efforts to delete any such information pursuant to any applicable privacy laws.
You can review and change your personal information by logging into the Site and visiting your account profile page.
If you delete your user-generated content, as defined in the Terms of Service, from the Site, copies of youruser-generated content may remain viewable in cached and archived pages, or might have been copied or stored by other Site users.
Contact Us
To exercise any of your rights in connection with your personal information, we kindly ask that you to contact us at contact@leancommunity.org.
If you have any questions (or comments) concerning this Policy, please email our team at contact@leancommunity.org, and we will make an effort to reply within a reasonable timeframe.