EFFECTIVE DATE: September 26, 2016
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
The TRUSTe certification covers our collection, use and disclosure of information we collect through our website and our service accessible behind the login. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged Lean Brokers.
US–Swiss Safe Harbor
Lean Brokers complies with the U.S. Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from Switzerland. Lean Brokers has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Lean Brokers’ certification, please visit http://www.export.gov/safeharbor/.
EU-U.S. Privacy Shield
Lean Brokers LLC participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Lean Brokers LLC is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield.
Lean Brokers LLC is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequent transfers to a third party acting as an agent on its behalf. Lean Brokers LLC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Lean Brokers LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Lean Brokers LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
1.2. NOTICE CONCERNING CHILDREN. PLEASE NOTE: We are a general audience site, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a Site user is under age 13, we will promptly delete any personal information in that user’s account.
2. INFORMATION COLLECTION PRACTICES
2.1. INFORMATION RELATED TO DATA COLLECTED FOR OUR CUSTOMERS. Lean Brokers LLC collects information under the direction of its Customers and has no direct relationship with the individuals whose personal data it processes. If you are a client of one of our Customers and would no longer like to be contacted by one of our Customers that use our service, please contact the Customer that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Customers.
2.2. ACCESS AND RETENTION OF DATA CONTROLLED BY OUR CUSTOMERS. Lean Brokers LLC has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Lean Brokers LLC’s Customer (the data controller). If the Customer requests Lean Brokers LLC to remove the data, we will respond to their request within 30 days. We will retain personal data we process on behalf of our Customers for as long as needed to provide services to our Customer. Lean Brokers LLC will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
2.3. WHAT BASIC INFORMATION DOES THE COMPANY COLLECT AND USE?
a) LOGIN DATA COLLECTED. We collect information regarding your use of the Lean Brokers Site and Services, your login time and duration and your last known login date and time. We may also track and analyze non-identifying and aggregate usage and volume statistical information from you and provide such information to third parties.
b) CONTACT INFORMATION. In operating the Site and Services, Company may include registration, subscription accounts, online surveys, and other online forms that ask users to provide their names, e-mail addresses, U.S. postal address and other contact information. In registering for the use of Services on this Site, you will provide information such as your name, username, password, email address, postal address and other contact information or other information requested at the time of registration. You acknowledge this information is personal to you and, you by creating a Lean Brokers account, allow Lean Brokers and others to identify you.
c) PERSONAL INFORMATION COLLECTED. In order for you to access certain premium services and to purchase a subscription to our premium Services that we offer via the Site, we require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information includes the following categories of information: (1) Contact Data (such as your name, mailing address, and e-mail address); (2) Financial Data (such as your account or credit card number); and (3) Demographic Data (such as your zip code, age, and income). We use this information to contact you about the services on our site in which you have expressed interest. You must provide contact information (such as name, email). We use this information to fill your order for a subscription to Lean Brokers products. If we have trouble processing an order, we will use this information to contact you. When you subscribe to one of Lean Brokers products you will receive a welcome email. As part of registering for the Service, you may receive email newsletters from us. We do not collect personal information about you except when you specifically provide this information on a voluntary basis. If you communicate with us by e-mail, complete online forms, surveys or contest entries, any information provided in such communication may be collected as Personal Information.
d) THIRD PARTY APPLICATIONS OR SERVICES. Lean Brokers provides Services that allow you to manage your accounts and applications with Third Party Services including Gmail, Twitter, FaceBook, LinkedIn, HubSpot Integration, Mail Chimp Integration and others (collectively “Third Party Services”). By voluntarily electing to link your Lean Brokers Service(s) with Third Party Services, you will share with Lean Brokers and Lean Brokers will store your Third Party Services’ access data including any usernames and passwords used in accessing those Third Party Services. The Lean Brokers Services and Third Party Services accessed through the Lean Brokers Services are used primarily for managing your social media accounts and sharing and distributing your information publicly to the world. Any information shared through use of the Lean Brokers Site or Lean Brokers Services or Third Party Services accessed through Lean Brokers Services will be shared with and stored by Lean Brokers. This information includes any information shared through Third Party Services accessed through Lean Brokers Services, including, but not limited to messages sent via Third Party Services, Third Party Applications Username or IDs, posts, location tags, photos, biographical information, etc. We may track and analyze non-identifying and aggregate usage and volume statistical information from you and provide such information to third parties. You may also provide personal information about other people, such as their name, date of birth, employment and gender. This information is only used for the sole purpose of completing your request or for whatever reason it may have been provided
e) GEOGRAPHICAL INFORMATION. Lean Brokers may access your geographic location data at the time that you login to Lean Brokers Services. We may also track and analyze non-identifying and aggregate usage and volume statistical information from you and provide such information to third parties.
f) MOBILE ANALYTICS. We use mobile analytics software to allow us to better understand the functionality of our mobile software and applications on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
2.4. WHAT ADDITIONAL INFORMATION DOES COMPANY COLLECT AND USE?
a) LOG FILES. As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.
c) LOCAL STORAGE OBJECTS (FLASH/HTML5). We and third parties use Local Storage Objects (LSOs) such as HTML5 and Flash to store content information and preferences. We and third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML and Flash to collect, store and analyze information. Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs please click here.
3. USE AND SHARING OF INFORMATION
3.1. WHAT DOES COMPANY DO WITH COLLECTED INFORMATION?
a) PERSONAL & CONTACT INFORMATION. We use Contact Data to send you information about our company or our products or services, or promotional material from some of our Partners, or to contact you when necessary. We may use your personal information to verify your identity, to check your qualifications, or to follow up with transactions initiated on the Site. We may also use your contact information to send follow-up information regarding Lean Brokers’ services, contact you regarding other services Lean Brokers offers, inform you of the availability of a newsletter or hotline information available on our site, any changes to the Site, or to send you additional information about Lean Brokers. We use your personal information to contact you about the services on our site in which you have expressed interest. We use this information to fill your order for a subscription to Lean Brokers products. If we have trouble processing an order, we will use this information to contact you. When you subscribe to one of Lean Brokers products you will receive a welcome email. As part of registering for the Service, you may receive email newsletters from us. We do not collect personal information about you except when you specifically provide this information on a voluntary basis. If you communicate with us by e-mail, complete online forms, surveys or contest entries, any information provided in such communication may be collected as Personal Information. If you do not want to receive promotional material or newsletters from us please follow the unsubscribe mechanism available in those messages or contact us at firstname.lastname@example.org.
c) COMMUNICATION FROM THE SITE. We communicate with our customers using information provided to us in various ways, which include but are not limited to:
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
Based upon the personal information you provide us, we will send you a welcoming email to verify your username and password. We will also communicate with you in response to your support inquiries, to provide some of the services you request. We will communicate with you by email.
If you wish to subscribe to our newsletters, we will use your name and email address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe in each newsletter. Please see the ‘unsubscribe’ feature at the bottom of each newsletter or contact us at email@example.com. The customer’s email list is stored on our system, but is not used by Lean Brokers in any other way other than to occasionally remind invited users to join the account that the account owner has registered for.
Surveys or Contests
From time-to-time we may provide you the opportunity to participate in contests or surveys on our site. If you participate, we will request certain personal information from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information and demographic information (such as zip code). We use this information to notify contest winners and to monitor site traffic or personalize the site.
We post testimonials from time to time. We always receive permission to post prior to posting. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
You can import contacts from your Outlook or other email account address book to invite them to become members of our site. We collect the username and password for the email account you wish to import your contacts from and will only use it for that purpose.
Public Member Directory
We will list you in our publicly accessible member directory. If you wish to request removal of your information from our directory, you can contact us at email@example.com.
The profile you create on our site will publicly accessible unless otherwise indicated. You may change the privacy settings of your profile through your account portal. To remove unauthorized profiles, please send an email to firstname.lastname@example.org
You can log in to our site using sign-in services such as Gmail, Facebook or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your networks.
e) LEGAL DISCLOSURE. In certain situations, Lean Brokers LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, to any other third party with your prior consent to do so. If Lean Brokers is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
f) ACCESS TO INFORMATION. Upon request Lean Brokers LLC will provide you with information about whether we hold, share, or process on behalf of a third party, any of your personal information. To request this information please contact us at email@example.com. If your personal information changes, or if you no longer desire our service, you may correct, update, delete it by making the change on the Account section page or by emailing our Customer Care at firstname.lastname@example.org or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request to access within 30 days.
g) DATA RETENTION. We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact our Customer Care at email@example.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
h) PUBLIC FORUMS. Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
i) SUPPLEMENTATION OF INFORMATION. In order to provide to enhance our services to you, we may on occasion supplement the personal information you submitted to us with information from third party sources. To enrich our Profiles of individual customers, we tie this information to the personal information they have provided to us.
4. CONFIDENTIALITY AND SECURITY.
4.1. SECURITY. The security of your personal information is important to us. When you enter sensitive information such as log in credentials, Geo-location Data or a credit card number on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at email@example.com.
6. LOST OR STOLEN INFORMATION. You must promptly notify us if your credit card, user name, or password is lost, stolen, or used without permission. In such an event, we will remove that credit card number, user name, or password from your account and update our records accordingly.
8. CONTACT INFORMATION AND POLICY UPDATES
8.1. CONTACTING US. If you have any questions about this Policy, our practices related to this Site, or if you would like to have us remove your information from our database please feel free to contact us at the following: Lean Brokers LLC 2043 Colorado Avenue, Suite B Santa Monica, CA 90404 firstname.lastname@example.org