Leap Data Protection Policy

Leap Platforms (DIFC) Ltd and/or its affiliates and subsidiaries (collectively "Leap", "we" or "us") values your security and privacy. Leap is subject to the Data Protection Law, DIFC Law No. 5 of 2020 (the "DP Law"), and may for certain types of personal data processing, be subject to laws from other jurisdictions.

As such, it is the policy of Leap to respect the privacy of our website services users. In accordance with the DP Law and as applicable in our Terms of Use and User Agreements, Leap collects information about you when you use or access our websites or you avail of our other web-based products, information or services (collectively, the "Website Services") as well as through other interactions and communications you may have with us.

This online data protection policy (the "Policy") sets out the basis on which any information, including any personal data, we collect from you, or you provide to us, will be processed by Leap. Each time you access or use the Website Services or provide us with information, by doing so you acknowledge the practices described in this Policy. For use of specific services (such as creating a User profile on our website) you may be asked to opt-in to our use of the information that you submit there. Your rights described herein apply in these instances as well.

1. Scope and Application

This Policy applies to persons anywhere in the world who access or use Leap's Website Services ("Users").

2. Collection of information

Information you give us

This is personal data you give us by providing information or filling in forms via our Website Services, or by corresponding with us (for example, by telephone, e-mail or any other digital or electronic form). It includes for example information you provide when you register to use Leap Marketplace and/or Leap Community or when you report a problem with any of our Website Services. If you contact us, we will keep at least an electronic record of such correspondence, including personal information shared at that time, in order to reply or process it as per your request. The personal information you give us may include your name, address, e-mail address and phone number, certain device information, username, password, residential building, work address, photograph, and other registration information you choose to provide ("Personal Information" or "Personal Data").

The Website Services collect and process Personal Data for specific, lawful purposes only, or for the performance of tasks carried out in your interests or the interests of Leap.

The Website Services are not targeted, intended, or expected to be of use to children. Apart from providing information for specific services or purposes, as directed by Leap processes, User-provided contributions of content or contact information regarding or about children are expressly prohibited.

Information we collect about you and your device

Each time you use our Website Services we may and often will automatically collect the following information:

- Personally identifiable information including details required for accessing Website Services, such as name, email address, profile information, user name, password, or cookies, based on your preferences and settings;

- Technical information, including the type of mobile device you use, a unique device identifier (for example, mobile network information, your mobile operating system, the type of mobile browser you use, device token, device type, time zone setting ("Device Information");

- Details of your use of our Website Services including, but not limited to traffic data, weblogs and other communication data, and the resources that you access ("Log Information");

- Location information if the Website Services uses GPS technology to determine your current location. If you wish to use this particular feature, you may be asked to opt-in to your data being used for this purpose.

If you do not wish to share certain data with us or do not want us to use / share it for certain purposes (to the extent possible, in accordance with applicable laws and information in this notice), you can alter your preferences at any time. Where applicable, please check with your device provider's instructions for further information about how to do this.

Other Information We May Collect Through Your Use of the Website Services or the App

When you use any Website Services, we may collect Personal Data including demographic information, for example information that you submit, or that is necessary to collect, which may include, but is not limited to, post code, age/birth date, current residence, hometown, gender, username, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, device location, IP address, SMS data, transaction information, business activities and services / distribution locations, browsing history information, searching history information, and registration history information ("Demographic Information").

3. Use of Personal Data

We may use Personal Data that you provide to us or we collect from you to:

- Provide, maintain, and improve our Website Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information about them), develop new features that will enhance your user experience and our efficiency, provide customer support to Users, authenticate users, and send administrative messages, whether information-only or required by applicable law;

- Provide the Website Services functionality that you lawfully and validly request access to, whether temporarily or for the life of any relevant Terms or User Agreement agreed between you and Leap;

- Perform internal regulatory, administrative and operational requirements, including, for example, to prevent fraud or abuse of our Website Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; to ensure you and Leap are complying with internal or external legal requirements, including those that necessitate use of digital systems; and to monitor and analyze usage and activity trends;

- Send you communications we think will be of interest to you based on your preferences and previous interactions with us, including information about products, services, promotions, news, and events, where permissible under DIFC Laws and according to any other applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards;

- Notify you about changes to this Policy, or our Website Services;

- Allow you to participate in any interactive features of our Website Services;

- Keep our Website Services safe and secure; or

- Personalize and improve the Website Services, including to provide or recommend features, content, social connections, referrals, and advertisements, in accordance with your preferences, to the extent permissible by law.

4. Processing, Storage and Transfer of Personal Data

We will take all steps reasonably necessary to ensure your data is processed fairly and lawfully, in accordance with the DP Law, other applicable laws and this Policy. By submitting your Personal Data (including Log, Device and / or Demographic Information), we expect you to understand that such transfer, storing or processing is necessary for performance of tasks carried out by Leap (or its subsidiaries or affiliates) in the interests of Leap or in order for Leap to perform its general administrative and regulatory functions in a proportionate, lawful manner, including but not limited to responding to enquiries you raise via the Website Services and maintaining contacts for future informational or promotional activities. Unless otherwise notified, Leap does not ordinarily rely solely on automated decision making when processing your Personal Data.

In order to conduct our operations or fulfil regulatory obligations, we must transfer the Personal Data described in this Policy to and from, and process and store it in, the United Arab Emirates and (where applicable or required) with processors in other countries, some of which may have less protective privacy laws than those where you reside.

Where applicable to transfers undertaken in accordance with this Policy and relevant Terms of Use, transfers of Personal Data from within the DIFC to an data importer outside of the DIFC must comply with the approved standard contractual clauses described in Regulations 5 of the DIFC Data Protection Regulations and available at this link, which set out safeguards for such transfers.

In all such cases, and generally for any processing operations, we take appropriate technical and security measures to protect your Personal Data and other information in accordance with this Policy. Please see section 7 below for further details.

To preserve the integrity of our databases, to carry out on-going Website Services , for research, analytics and statistics purposes and to ensure compliance with applicable laws and regulations, we retain Personal Data submitted by Users for a reasonable length of time unless otherwise prescribed by applicable law.

Leap is not responsible for the accuracy of the information you provide, and will modify or update your Personal Data in our databases when you provide updated information or ad hoc upon your request, as further outlined below.

We will erase or put beyond active use your Personal Data upon request, unless we are required to retain it in accordance with DIFC or other applicable laws or to perform agreed services, in which case we align with applicable principles such as purpose specification and data minimization.

If it is not disproportionate or prejudicial, and required beyond this policy's notices, we'll contact you to let you know we are processing your personal information.

By accessing or using the Website Services to which this Policy applies, we can reasonably expect that you understand that all information submitted by you through the Website Services or otherwise to Leap may be used by Leap to support these processing operations, in accordance with applicable laws and its policies.

5. Sharing of Personal Data

We may share Personal Data which we collect about you as described in this Policy or as described at the time of collection or sharing, including as follows:

Through Our Website Services

We may share Personal Data which we collect about you as described in this Policy or as described at the time of collection or sharing, including as follows:

- With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us; or

- With third parties with whom you choose to let us share your Personal Data, for example other apps or websites that integrate with our API or Website Services, or those with an API or Service with which we integrate.

Other Types of Data Sharing

We may share your Personal Data:

- With Leap subsidiaries and affiliated entities, to the extent permissible by law;

- With vendors, consultants, marketing and advertising partners, and other service providers who need access to such Personal Data to carry out work on our behalf or to perform a contract or other agreement we enter into with them or with you;

- If we otherwise notify you and you provide your affirmative opt-in to share your data, where needed;

- In response to a request for information by a competent authority or government entities if we determine that such disclosure is in accordance with, or is otherwise required by any applicable law, regulation, or legal process;

- With law enforcement officials, government entities or authorities, or other third parties as required by applicable law;

- With third parties in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company; or

- With third parties in an aggregated and/or anonymized or pseudonymized form that cannot reasonably be used to identify you

Government Data Sharing

In some circumstances we are legally obliged to share information with public authorities or law enforcement. For example, we may be required to provide information related to a court order or where we must cooperate with other supervisory authorities in handling complaints or investigations. We might also share information with other regulatory bodies in order to further their, or our, objectives. In any scenario, we'll satisfy ourselves that we have a lawful basis on which to share the information, document our decision making, and satisfy ourselves we have a legal basis on which to share the information.

6. Your Rights and Choices

Marketing and Preferences

Leap supports Users' legal rights to opt-in or subsequently opt-out of receiving communications from us and our partners. You have the option to ask us not to process your Personal Data for marketing purposes and to remove it from our database, to not receive future communications or to no longer receive our Website Services.

You may change your preferences at any time.

Please note that we may continue to send you transactional or service-related e-mails despite your desire to not receive promotional or marketing e-mail messages. Additionally, please note that if you elect to opt-out of or unsubscribe from receiving promotional or other similar e-mails or messaging from one of our Website Services, you may continue to receive promotional emails from our other websites, providers, or other, non-affiliated marketers whose services you may have accessed via the Website Services.

Finally, while we may remove your individual contact information from our professional contacts database, please be aware that if such information is in a different, third party's marketing directory through your request or election, you will need to request removal with such third party directly.

Access to and Correction of Your Personal Information

You have the right to access information held about you. Your right of access can be exercised for any reason, at any time, in accordance with DIFC and other applicable laws.

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

You may also request that we restrict the processing of, erase, transfer the information you gave us from one organisation to another, or otherwise process your Personal Data in line with the relevant articles providing for such rights set out in the DP Law or other applicable laws.

Any access request generally comes at no cost to you and we must respond within one month unless provided otherwise by the DP Law or other applicable laws. We may, where permissible, impose a reasonable fee to meet any extraordinary administrative costs in providing you with details of the information we hold about you.

When you contact us about a potential Personal Data error or query, we will endeavour to confirm or verify the information in question, then correct verified inaccuracies and respond to the original inquiry. We will endeavour to send a correction notice to businesses or others whom we know to have received the inaccurate data, where required and / or appropriate. However, some third parties and third party sites may continue to process inaccurate data about you until their databases and display of data are refreshed in accordance with their update schedules, or until you contact them personally to ensure the correction is made in their own files.

As set out in Article 39 on the DP Law, we may not discriminate against you for exercising your rights by denying services or changing prices or quality of service, unless reasonable to do so in general, as objectively determined, and applicable to all individuals offered or receiving such benefits.

7. Security Precautions

Leap makes every effort to ensure that your Personal Data is secure on its system. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, Leap cannot warrant or guarantee the security of any Personal Data you transmit to us, and you do so at your own risk.

Leap has established policies and procedures for securely managing information and protecting Personal Data against unauthorized access. We continually assess our data privacy, information management and security practices. We do this in the following ways:

- Establishing policies and procedures for securely managing information;

- Limiting employee access to viewing only necessary information in order to perform his or her duties;

- Protecting against unauthorized access to Personal Data by using data encryption, authentication and virus detection technology, as required;

- Requiring service providers with whom we do business to comply with relevant data privacy legal and regulatory requirements;

- Monitoring our websites through recognized online privacy and security organizations;

- Engaging in regular third party audits of our policies and practices; and

Conducting background checks on employees and providing training to our employees.

If you have any further questions about our security and processing activities, please refer to our Terms of Use. To the extent permitted by applicable law, Leap expressly disclaims any liability that may arise should any other third parties obtain the Personal Data you submit through fraud or otherwise where it is no fault of the Leap.

8. Cookies

A cookie is a small text file that is unique to the web browser on your computer or mobile device, which is used to retain user preferences, and enhance browsing experience ("Cookie"). Leap uses Cookies to track overall site usage and enables us to provide a better user experience. We do not use Cookies to "see" other data on your computer or determine your email address.

The primary types of cookies we drop and the information collected using them include (but are not limited to):

Essential / Necessary

Axeptio - is a consent management platform that allows businesses and organizations to easily obtain, manage, and document user consent for data processing and other purposes.

Site Analytics

Mixpanel – is a product analytics solution, that helps teams analyze how and why people engage, convert, and retain—in real-time, across devices—to improve their user experience.

Most browsers acceptand maintain Cookies by default. The DIFC Data Protection Law requires that DIFC entities set the collection method to the bare minimum, necessary cookies in order to operate the relevant website or app. Check the 'Help' or 'Settings' menu of your browser to learn how to change your Cookie preferences. You can choose to alter Cookies settings related to the use of our Website Services, but this may limit your ability to access certain areas of the Website.

Alternatively you may wish to visit an independent source of information, www.aboutcookies.org, which contains comprehensive information on how to alter settings or delete Cookies from your computer as well as more general information about Cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual or network operator for advice.

9. External Links

The Website may contain links to other websites on the Internet that are owned and operated by third parties (the "External Sites"). These links are provided solely as a convenience to you and not as an endorsement by Leap of the contents of or reliability on such External Sites. You acknowledge that Leap is not responsible for the availability of, or the information and content of any External Site. You should contact the site administrator or webmaster for those External Sites if you have any concerns regarding such links or the content located on such external Sites.

If you decide to access linked third party websites, you do so at your own risk. Leap does not accept liability, and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the content of another website to which you may link from the Website Services.

10. Changes to this Policy

We may change this Policy from time to time and without notice. If we make significant changes in the way we treat your Personal Data, or to the Policy, we will endeavor to provide you notice through the Website Services or by some other means, such as email. Your continued use of the Website Services after such notice constitutes your understanding of the changes. We encourage you to periodically review this Policy for the latest information on our privacy practices. We provide links to it through:

- The Website Services

- Referencing it in our Terms of Use

- Incorporating it into our contracts, agreements, and other documents as necessary or appropriate

Contact Us

If you have any questions or complaints related to how Leap processes your personal data, please contact support@leapbydifc.com or call on +971 4 362 2222.