Last Updated: January 4th, 2022.

Applyplus Ltd t/a theLEAP (“We” or “theLEAP”) are committed to protecting and respecting your privacy.

This privacy statement (together with our terms and conditions and any other policies referred to in it) explains what information we gather about you, what and how we use that information, the lawful basis on which that information is used and who we give that information to. It also sets out your rights and our obligations in relation to your information and who you can contact for more information or queries.

Who this privacy statement applies to and what it covers

This privacy statement sets out how we will collect, handle, store and protect information about you when providing services to you or our clients, or performing any other activities that form part of the operation of our business theLEAP.

This privacy statement also contains information about when we share your personal information with other members of our group and other third parties (for example, third parties carrying out due diligence activities on our behalf).

In this privacy statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.

Children

We understand the importance of protecting children’s privacy. Our website is not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children.

What information we collect

We may collect and process personal data about you because you give it to us, because other people give that data to us (for example, third party service providers that we use to help operate our business) or because it is publicly available.

The personal data that we collect or obtain may include: your name; age; date of birth; gender; e-mail address; home address; country of residence; lifestyle and social circumstances (for example, your pastimes); employment and education details (for example, the organisation you work for, your job title and your education details); your IP address; your browser type and language; your access times; complaint details; details of how you use our products and services; details of how you like to interact with us and other similar information.

We may collect and process personal data about you from other sources as follows:

Employee Data

We collect personal data about our prospective, current and former employees (including contingent workers, providers and interns) as follows: basic identification information, such as your name, title, position, professional history, experience, and contract details.

For current employees, we usually collect in addition to the above:

Use of Personal Data

We will use your personal data to fulfil your requests and we will ask only for data that is adequate, relevant and not excessive for those purposes. Where we send you information for any purpose, it may be sent by e-mail or post. When we ask you for personal data it may include the following purposes:

None of the information that we request from you is mandatory. However, where such information is not provided to us, theLEAP may be unable to identify, protect, or return your money or assets.

The legal grounds we use for processing personal information

We are not allowed to process personal information if we do not have a valid legal ground. Therefore, we will only process your personal information for the purposes outlined above because:

Examples of the ‘legitimate interests’ referred to above are:

To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so because either: (i) we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti money laundering’ obligations (or other legal obligations imposed on us); (ii) the processing is necessary to carry out our obligations under employment, social security or social protection law; (iii) the processing is necessary for the establishment, exercise or defence of legal claims; or (iv) you have made the data manifestly public.

Unsubscribe

We may, from time to time, e-mail or post you information to make you aware of our other similar products and services which may be of interest to you. If you do not wish to receive emails or post from us for these purposes, or if you want to be removed from our electronic mailing list you can either select “unsubscribe” from any of the marketing emails that we send or alternatively .

Anonymous data collected through this website

In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our website. For example, our web server automatically logs which pages of our website our visitors view, their IP addresses and which web browsers our visitors use. This technology does not identify you personally, it simply enables us to compile statistics about our visitors and their use of our website.

Our website contains hyperlinks to other pages on our website. We may use technology to track how often these links are used and which pages on our website our visitors choose to view. Again this technology does not identify you personally – it simply enables us to compile statistics about the use of these hyperlinks.

Links to other websites

This website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. We do not control these websites and are not responsible for their data or privacy practices. We urge you to review any privacy policy posted on any site you visit before using the site or providing any personal data about yourself.

Cookies

In order to collect the anonymous data described in the preceding paragraph, we may use temporary “cookies” and similar technologies (e.g. web beacons, pixels, ad tags and device identifiers) to recognise you and/or your device(s) that remain in the cookies file of your browser for a specific amount of time. For example, we use Google Analytics to help us take and analyse visitor information such as browser usage and new visitor numbers. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited. Please note that the names of cookies, pixels and other technologies may change over time.

Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. We also use your IP address to help diagnose problems with our server and to administer our website. An IP address is a numeric code that identifies your computer on a network, or in this case, the internet. Your IP address is also used to gather broad demographic information. Cookies are useful because they allow a website to recognise a user’s device, preferences and generally help to improve your online experience.

Please also refer to our Cookie Policy.

Social Media

Our website may also contain plugins and other features that integrate third party social media platforms into our website so that we can improve our offer and make it more interesting for you as a user. You will be able to activate them manually. If you do so, the third party companies who operate these platforms may be able to identify you, they may be able to determine how you use this website and they may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plugins and other features, you will be doing so at your own risk as we do not have any influence on the data collected and data processing operation, nor are we aware of the full extent of data collection, the purposes and the storage periods.

Disclosure of your Personal Data

In connection with one or more of the purposes outlined in the “Use of personal data” section above, we may disclose details about you to: our affiliates; third parties that provide services to us and/or our affiliates, such as our lawyers; competent authorities (including courts and supervisory or other authorities); your advisers or where applicable, your employer; credit reference agencies or other organisations that help us make decisions and reduce the incidence of fraud; and other third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in the “Use of personal data” section above.

Where you have chosen to connect your theLEAP account to your Facebook or LinkedIn account we may share, disclose, and transfer personal data to Facebook or LinkedIn, as applicable. This permission will be requested when you connect your accounts. If you have given this permission you may then disable this function at any time by changing your Facebook, LinkedIn or theLEAP account settings (as applicable).

Where appropriate, before disclosing personal data to a third party, we contractually require the third party to take adequate precautions to protect that data and to comply with applicable law.

Where you have consented, we may also share your personal data with other companies within our group of companies who may contact you about their products or services that may interest you.

Please note that some of the recipients of your personal data referenced above may be based in countries outside of the European Union whose laws may not provide the same level of data protection. Those countries currently include India and the United States of America. In such cases, we will ensure that there are adequate safeguards in place to protect your personal data that comply with our legal obligations. To ensure this level of protection for your personal information, we typically use a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission. A copy of these clauses are available by requesting our Supplier Data Protection Addendum from hello@theleap.io

Protection of your personal data

All theLEAP personnel accessing personal information must comply with the internal rules and processes in relation to the processing of personal data to protect them and ensure the confidentiality of such information.

We have also implemented adequate technical and organisational measures to protect personal data against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of the personal information, with particular care for sensitive information.

Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.

How long we keep your information for

We will hold your personal data on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity (which is typically 7 years); (ii) any retention period that is required by law or regulation; or (iii) the end of the period in which litigation or investigations might arise in respect of our activities.

Your rights

You have various rights in relation to your personal data. In particular, you have a right to:

To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us at hello@theleap.io

Right to complain

If you are unhappy with the way we handled your personal information or any privacy query or request you have raised with us you also have a right to complain to a data protection authority in the place where you live or work, or in the place where you think an issue in relation to your data has arisen. A list of national data protection authorities can be found here.

Changes to our privacy statement

We may modify or amend this privacy statement from time to time.

To let you know when we make changes to this privacy statement, we will amend the revision date at the end of this page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.

Contact

If you have any questions, comments or requests regarding this privacy statement contact us.