Privacy policy

Who are we?  

We are Leadgen Labs s.r.o., company registered in the commercial register maintained by the Municipal Court Prague, Section C 247987, identification number 04458206, with its registered seat at
Příčná 1892/4, 110 00 Praha, Czech republic (hereinafter referred to as the “Provider” or „we“).

Why do we may need to process your personal data? 

We provide our customers (hereinafter referred to as the “Tenant”) a web based application that is used for tracking Tenant’s advertising activities in the area of affiliate marketing business (hereinafter referred to as the “Application”), primarily, but not only, to help market Tenant’s services or products online on third party websites by advertisements (those third parties hereinafter also referred to as the “Users”). To be able to do so we need to process some personal data. Whether, and to what extent, we process personal data may depend on a package of services selected by the Tenant. We process personal data where necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract and to meet legal requirements, above all but not limited to accounting and tax legislation.
For personal data that Tenants submit to or generate in the Application including data about their Users, the Tenant is the controller and the Provider acts as the processor. For service logs, security and billing identifiers needed to operate and protect the Application, the Provider acts as an independent controller.

What does GDPR mean? 

GDPR stands for Regulation EU 2016 slash 679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. GDPR represents the legal framework for the protection of personal data in the European area and directly establishes the rules for the processing of personal data. The Provider is governed by the GDPR rules in its activities and is compliant with the GDPR.

What personal data we may have access to? 

The scope of personal data depends on how the Tenant uses the Application. In general we may process

• settlement and billing data required to administer payments and comply with legal duties
  Where we process Tenant program and payout data we act as a processor for the relevant Tenant. Where we process diagnostic and security data that are necessary to operate the service we act as an independent controller.
• account and relationship data needed to provide access and support
• technical and usage data generated by the Application for operation, security and performance

How do we protect personal data? 

Taking into account the state of the art, the nature, scope, context and purposes of processing personal data as well as other factors, the Provider has implemented appropriate technical and organizational measures in order to ensure the level of security appropriate to relevant identified risks. 

The Provider shall always process personal data only lawfully, fairly and in a transparent manner in relation to the data subject. Personal data are collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. The scope of personal data collected shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

The Provider may use a third party to further process some personal data, especially technical partners. In such a case the Provider will announce relevant information about such a partner on his website www.paldock.com. The Provider shall store any personal data within the Tenant’s region, be it the European Union or the United States.

User onboarding and acceptance

At first registration or first access to the user portal the Provider presents an onboarding flow to users that includes applicable terms and this Privacy Policy or a dedicated privacy notice and records acceptance with timestamp, IP address, user identifier and document version. This acceptance documents delivery of the transparency information required by law. It is not a consent to marketing communications. Any marketing emails require a separate and voluntary opt in.

How long will we have access to personal data?

The Provider processes personal data for the purpose of performance of the contract with the respective Tenant and therefore processes personal data for the duration of the contractual relationship. After its end, the Provider may retain personal data for a limited period where required by law or where necessary to resolve disputes, enforce agreements or comply with other legal obligations. The Provider may also retain limited records necessary to demonstrate compliance and service integrity, including records of notices delivered, acceptances captured and communication preferences, for a reasonable period consistent with statutory limitation periods and the Provider’s retention schedule.

What are your rights regarding your personal data?

We always process personal data in a transparent and correct manner and in accordance with the legal requirements. However, at the same time you have the right to contact us in order to obtain information about your personal data processing or to exercise the rights that are related to personal details. Above all, but not only you have the right to obtain the copy of your personal data processed by the Provider, you have the right to request an update of your personal data if you believe them to be inaccurate, you have a right to request from us the erasure of your personal data if they are no longer required for the purpose for which they were processed. You have a right to data portability. You have a right to object to the processing of your data. 

You have a right to file a complaint with the supervisory authority (Office for Personal Data Protection) should you think that the rules of personal data protection were breached during the processing of your personal data. 

Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Prague 7, www.uoou.cz 

For more information about the Provider’s data protection processes please contact us anytime at dpo@paldock.com.