Privacy Policy – LEINPAGE

1. Introduction

This Privacy Policy (the “Policy”) is LEINPAGE’s clear commitment to protecting personal data. LEINPAGE operates multiple digital platforms, including mobile applications, web applications, API services, analytics systems, and technical support programs. When you use our services, you trust us with your information, and we understand that this is a major responsibility. LEINPAGE collects, uses, and shares information according to the principles of transparency, lawfulness, and fairness, with the goal of protecting privacy while ensuring service continuity. This Policy describes in detail the categories of data collected, the purposes of use, retention periods, forms of sharing, available choices, and your rights at each stage. LEINPAGE is committed to complying with applicable data protection laws worldwide, including the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act as amended by the CPRA (CCPA/CPRA), Decree No. 13/2023/ND-CP of the Government of Vietnam on personal data protection, and similar laws in other jurisdictions.

This Policy applies to all services provided directly or indirectly by LEINPAGE. By continuing to access or use the services, you acknowledge that you have read, understood, and accepted the terms of this Policy. If you do not agree with any provision, you should not use the services. This Policy does not apply to services with separate privacy policies that do not incorporate this document, or to the practices of third parties. The term “personal data” in this Policy means any information relating to an identified or identifiable individual, including name, email address, telephone number, physical address, location information, device identifiers, and application data. “Processing” includes any operation such as collection, storage, use, sharing, deletion, or destruction of data.

LEINPAGE acts both as a data controller and, in some contexts, as a data processor on behalf of enterprise customers. In its role as controller, LEINPAGE determines the purposes and means of processing. In its role as processor, LEINPAGE follows contractual instructions from customers. This Policy describes the practices that apply to data under LEINPAGE’s control. If you are an employee or representative of an enterprise customer, you should also review the relevant contractual documentation to understand your specific rights and obligations.

This Policy may be updated from time to time to reflect changes in law, regulation, and operations. We will not reduce your rights without explicit consent. Where material changes occur, we will provide notice through the website, email, or in-application notifications. The latest version takes effect upon publication, and continued use of the services constitutes acceptance of the updated Policy. If you do not agree, you must discontinue use and contact us to exercise your rights. We encourage you to review this Policy regularly to understand how we process personal data.

2. Scope of Application

This Policy applies to all personal data processing activities carried out by LEINPAGE through its websites, mobile applications, desktop software, APIs, developer platforms, social media channels, customer support services, and any online or offline interaction involving the collection of information. This includes data collected when you browse the website, register an account, use products, participate in promotions, contact support, or take part in surveys and events. The Policy applies to all categories of users, including individual customers, enterprise partners, visitors, developers, and any person interacting with the services.

This Policy also covers data collected through different types of devices, including desktop computers, laptops, tablets, smartphones, wearables, Internet of Things devices, or any other access technology. Our platforms may be accessed through browsers, native apps, third-party apps, or embedded integrations. In all such cases, the way LEINPAGE processes data is governed by this Policy. However, third-party websites or services linked from LEINPAGE platforms may have their own privacy policies, and LEINPAGE is not responsible for their practices. You should review those policies before submitting information.

If you access the services through an account provided by an organization or employer, processing may also be governed by contracts between LEINPAGE and that organization. You should review the relevant agreements to understand your rights and obligations. This Policy has a global scope, but some provisions may not apply in certain jurisdictions because of local law. LEINPAGE provides additional jurisdiction-specific provisions for residents of the European Union, the United Kingdom, California, Vietnam, and other regions in the section titled “Supplemental Regional Information.”

LEINPAGE does not knowingly provide services to children below the minimum age required by applicable local law, such as 13 in the United States or 16 in the European Union. If you are below the required age, you should not use the services. If we discover that we collected information from a child without the required parental or guardian consent, we will delete that information. This Policy also does not replace any agreement you may have entered into with LEINPAGE. In case of conflict, the more specific agreement will govern the relevant processing.

3. Information We Collect – Information You Provide

We collect personal data that you voluntarily provide through forms, registration flows, transactions, feedback channels, and other methods of communication. Such data may include, without limitation:

Identification information: full name, alias, email address, telephone number, profile photo, gender, date of birth, national identity card or passport number, tax number, and similar identifiers.
Account information: username, password, security questions, account identifiers, settings, and personal preferences.
Contact information: residential address, business address, postal code, country of residence, and fax number where relevant.
User-generated content: posts, comments, messages, attachments, images, videos, audio, documents, links, source code, and other materials that you upload, generate, or store through the services. Such content may contain your own personal data or the data of others, so you must ensure that you have a lawful basis to share it.
Payment and transaction information: payment card details, payment account information, billing address, purchased products or services, quantity, time, price, shipping method, and related transactional details. Sensitive financial data is generally processed by payment providers, and LEINPAGE receives only the minimum information necessary.
Communications information: email content, call records, chat messages, support requests, survey responses, market research participation, and information provided when you contact customer support, including call recordings where permitted by law.
Optional information: interests, intended use cases, survey feedback, marketing preferences, and information you provide in promotions, contests, events, or feature testing programs.

4. Information We Collect – Information Collected Automatically

When you use the services, we automatically collect certain technical and usage data to operate, secure, and improve the services. The categories of data collected depend on how you interact with the platform and may include:

Device and browser information: device type and version, operating system, settings, mobile carrier name, region code, language, browser type and version, screen resolution, and hardware configuration.
Identifiers and technical parameters: unique device identifiers, advertising identifiers, IP address, cookie identifiers, session IDs, application tokens, and malware or crash information.
System logs and usage data: access time, pages viewed, features used, links clicked, session duration, interactions with content and advertisements, search queries, frequency of use, debugging information, and error reports. This type of information helps us analyze performance and detect problems【455365699422346†L169-L189】.
Interaction data: information about how you interact with emails, events, or customer support, such as email opens or link clicks.
Location information: we use IP addresses to infer approximate location. If you grant permission, we may collect precise location based on GPS, Bluetooth, Wi-Fi, and device sensors in order to provide location-based features and more relevant advertising【455365699422346†L228-L247】. You can enable or disable this through device settings.
Data from third-party sites or apps that use our services: when external websites or apps integrate LEINPAGE technology, such as payment systems, widgets, APIs, advertising tools, or analytics tools, we may receive information about activity, views, interactions, and devices, as described in their policies【455365699422346†L254-L263】.

5. Information We Collect – Information from Third Parties and Public Sources

In addition to information you provide and data collected automatically, LEINPAGE may receive information about you from third parties and publicly available sources to enhance service quality and maintain accurate records. These sources may include:

Linked account providers: when you sign in using or connect your LEINPAGE account to a social or identity provider such as Google or Facebook, we may receive basic profile information, including name, profile photo, friend list, email address, and other information you authorize the provider to share. We use this information to authenticate you and simplify account registration and social discovery functions.
Service providers: LEINPAGE works with payment processors, delivery providers, advertising platforms, analytics vendors, and other service providers. They may provide data relating to payments, conversion events, statistics, or campaign performance to help us measure and optimize services and marketing.
Referrers and other users: if someone invites you to use the services or shares content with you, that person may provide your name, email address, or other contact details. If you participate in a forum, group, or post administered by a third party, we may receive activity data consistent with that third party’s policy.
Public sources and data agencies: we may collect information from public records, government databases, news sources, publicly visible social media, data exchanges, or commercial data repositories for verification, market research, record enhancement, or fraud prevention. For example, we may obtain business profile information from directory partners or demographic trend information from providers to better understand users.
Advertising and analytics partners: advertising partners may provide information about online interests and behavioral trends derived from cookies and device identifiers. Analytics partners may provide product usage statistics and trends to improve features and performance.

6. Tracking Technologies – Cookies, Pixels, and Similar Technologies

LEINPAGE and its partners use cookies and other tracking technologies to collect and store information when you visit or interact with the services. These technologies include:

Cookies: small files stored in a browser or on a device to remember choices and recognize devices. We use essential cookies for sign-in and security, functional cookies to retain settings, analytics cookies to measure traffic and behavior, and advertising cookies to deliver relevant promotions.
Pixels and web beacons: small code elements embedded in pages or emails that help determine whether a page or email was viewed or opened, enabling campaign measurement and re-engagement analysis.
Local storage and application caches: storage used by browsers or devices to improve performance and retain temporary information.
Advertising identifiers: device-level advertising identifiers, such as IDFA or AAID, used in mobile environments to support interest-based advertising. You can limit or reset such identifiers through device settings.
Third-party SDKs: software development kits embedded in mobile applications for analytics, advertising, fraud prevention, or functionality. Such SDKs may collect device data, usage data, and identifiers.

7. Purposes of Use

LEINPAGE uses collected personal data for lawful, specific, and transparent purposes, including:

Providing and operating the services: processing registration, authenticating accounts, communicating with users, processing payments, shipping goods where applicable, providing support, delivering content and features, and fulfilling requests and orders.
Maintaining and improving the services: analyzing performance, fixing defects, upgrading products, developing new features, testing functionality, conducting research, and producing internal statistics to optimize user experience.
Personalization: using data to provide recommendations, content, advertisements, and notifications tailored to behavior, interests, location, and interaction history【455365699422346†L269-L284】.
Notifications and communications: sending service updates, security alerts, policy changes, support responses, surveys, feature announcements, promotional information, or other communications by email, push notification, in-app message, SMS, or telephone where permitted and, where required, based on your consent.
Advertising and marketing: displaying advertisements, sponsored materials, and commercial messaging; measuring campaign performance; understanding target audiences; and distributing advertising on LEINPAGE properties and partner platforms.
Security and fraud detection: monitoring suspicious activity, protecting accounts from unauthorized access, preventing spam, phishing, abuse, and policy violations, and protecting LEINPAGE and users from harm【455365699422346†L648-L671】.
Legal compliance and enforcement: responding to legal requirements, tax and accounting obligations, dispute resolution, enforcement of terms, and protection of rights, property, safety, or the public interest.
Research and development: using anonymized or aggregated information to analyze trends, develop machine-learning models, improve system fairness and accuracy, and support product innovation.

8. Legal Bases for Processing

Depending on the context and applicable law, LEINPAGE relies on one or more legal bases to process personal data:

Performance of a contract: processing necessary to provide the services you requested, complete transactions, deliver goods, maintain accounts, or provide warranty and customer support.
Legitimate interests: processing necessary to operate, secure, improve, market, and administer the services, provided those interests are not overridden by your rights and expectations.
Consent: processing based on your clear, informed consent for specific purposes such as direct marketing, processing of sensitive data, collection of precise location, or personalized advertising where required by law. You may withdraw consent at any time.
Compliance with legal obligations: processing required to meet legal duties, such as retaining invoices, complying with tax obligations, responding to regulatory demands, or honoring rights requests under privacy laws.
Protection of vital interests: processing necessary to protect your life, health, safety, or that of another person in urgent circumstances.
Public interest or official authority: processing necessary where LEINPAGE is subject to duties grounded in public interest or official authority under applicable law.

9. Sharing of Information – Partners and Service Providers

LEINPAGE may share personal data with third parties in limited and controlled circumstances, including the following:

Affiliates and subsidiaries: personal data may be shared within the LEINPAGE corporate group for operational support, service delivery, product development, decision-making, and internal administration.
Service providers and contractors: LEINPAGE engages providers for hosting, infrastructure management, payment processing, analytics, marketing support, customer service, identity verification, and related business functions. These providers may only use personal data to provide services on our behalf and subject to strict confidentiality obligations.
Business partners: LEINPAGE may work with advertisers, advertising networks, publishers, social media platforms, app developers, and distribution partners in connection with joint products, campaigns, or distribution arrangements. We share only the information reasonably necessary for the approved purpose.
Analytics and advertising providers: LEINPAGE may share pseudonymized or hashed identifiers and usage information with analytics or advertising partners to measure performance, optimize experiences, or support targeted advertising. We do not sell personal data for monetary payment.
At your direction or with your consent: where you request or authorize sharing, such as linking accounts, posting content publicly, sharing information with employers, or routing technical support through a partner, we will process the request according to your instructions.

10. Sharing of Information – Legal Requests and Corporate Events

In certain circumstances, LEINPAGE may disclose personal data in order to comply with law or because of corporate structural events:

Compliance with law and legal process: LEINPAGE may disclose information to comply with legal obligations, subpoenas, court orders, lawful requests from regulators or law enforcement, or other mandatory requirements. We will review such requests carefully and disclose only the minimum information reasonably necessary.
Protection of rights and safety: LEINPAGE may use or share personal data where reasonably necessary to protect the rights, property, or safety of LEINPAGE, users, employees, or the public; to investigate fraud, abuse, terms violations, or security threats; or to prevent harm.
Professional advisers: LEINPAGE may share information with attorneys, auditors, insurers, and other professional advisers where necessary to obtain advice, manage risk, or protect legal interests. These parties remain subject to confidentiality obligations.
Corporate transactions: if LEINPAGE is involved in a merger, acquisition, restructuring, asset sale, financing, assignment, or transfer of all or part of its business, personal data may be transferred as part of that transaction. In such a case, we will require the recipient to respect this Policy or provide notice of any material change.
Mandatory reporting and statistics: in some industries, LEINPAGE may be required to provide aggregated or de-identified reporting to regulators, tax authorities, or other governmental bodies.

11. International Data Transfers and Storage

LEINPAGE operates servers, databases, and service infrastructure in multiple countries to maintain performance, redundancy, and service availability. Personal data may be stored in your country of residence or transferred to another jurisdiction where LEINPAGE or its providers maintain infrastructure. Such jurisdictions may have data protection laws that differ from those in your location. Regardless of location, LEINPAGE applies protective measures designed to safeguard personal data consistently.

Where data is transferred outside the European Economic Area or other jurisdictions with transfer restrictions, LEINPAGE uses recognized legal transfer mechanisms, which may include Standard Contractual Clauses issued by the European Commission, adequacy decisions, recognized data transfer frameworks such as the Data Privacy Framework, or your explicit consent where appropriate. We also require recipients to provide appropriate security and confidentiality protections.

Data is stored in secure facilities with physical access controls, monitoring, and infrastructure designed to reduce the risk of disaster, outage, or cyberattack. LEINPAGE uses technical measures such as encryption in transit and, where applicable, at rest, firewalls, network segmentation, and key management controls. Access is restricted to personnel and contractors with a legitimate business need, subject to confidentiality obligations.

During cross-border transfers, LEINPAGE requires service providers to sign data processing agreements and comply with privacy and security obligations under applicable law. Backup copies may be maintained across multiple jurisdictions for business continuity and disaster recovery. Data is retained only for as long as necessary for the original purpose and legal compliance, and is later deleted or anonymized.

International transfers may also be subject to local legal requirements. For example, Vietnam’s Decree 13/2023/ND-CP may impose conditions on outbound transfer of personal data. LEINPAGE complies with such requirements and provides notices to competent authorities where required.

12. Data Security and Safeguards

LEINPAGE implements technical, organizational, and administrative measures to protect personal data against unauthorized access, loss, misuse, alteration, or destruction. We build products with strong security features designed to protect information on an ongoing basis【455365699422346†L648-L671】. Core measures include:

Encryption: LEINPAGE uses industry-standard encryption protocols, such as TLS, to protect data in transit and uses encryption to protect certain categories of data in storage where appropriate.
Access controls: access to systems and personal data is granted only to employees, contractors, and agents with a business need and subject to security training, multi-factor authentication, logging, and oversight.
Policies and internal processes: LEINPAGE maintains formal security policies, periodic employee training, internal review processes for data collection and processing, and internal audits to support compliance.
Monitoring and detection: LEINPAGE deploys systems to detect and block security threats, malicious software, and abnormal behavior. Where risks are identified, incident response procedures are used to contain impact, remediate harm, and provide required notice.
Third-party review: LEINPAGE assesses the security posture of vendors before engagement and imposes contractual requirements regarding security, confidentiality, incident reporting, and remediation.

13. Data Retention and Deletion

LEINPAGE retains personal data for as long as reasonably necessary to fulfill the purposes described in this Policy or to comply with legal, accounting, tax, audit, and reporting obligations. Retention periods vary based on the type of data and the processing context:

Account data and profile records: retained until you request deletion or the account is terminated. You may delete data by closing the account or removing individual records. Certain information, such as billing and transaction records, may be retained longer where required by law or for dispute resolution.
User-generated content: you may delete content at any time, but backup or synchronized copies may remain for a limited period before final deletion. Content shared with other users or published publicly may be retained to preserve service integrity.
Analytics and log data: usage data, system logs, and technical records are generally retained for shorter periods for security and analytics purposes, then aggregated or anonymized. Some information may be retained longer for research or statistical purposes after de-identification.
Legal obligations and disputes: LEINPAGE may retain information where required by law, such as invoice retention under tax rules, or where necessary to resolve disputes, enforce agreements, or establish, exercise, or defend legal claims.

14. User Rights (GDPR and CCPA)

As a data subject, you may have rights under privacy laws including the GDPR and the CCPA/CPRA. These rights are intended to give you greater control over personal data:

Right to be informed: you have the right to know what data is collected, the purposes of use, the legal bases relied upon, and the categories of recipients. This Policy is intended to provide that information and LEINPAGE will provide additional notice where required.
Right of access: you may request a copy of the personal data LEINPAGE holds about you, together with information about how it is used. The first copy will generally be provided free of charge, subject to applicable law.
Right to rectification: you may request correction of inaccurate or incomplete personal data【803158853081582†L251-L266】.
Right to erasure: also known as the “right to be forgotten,” you may request deletion of personal data where it is no longer necessary, where consent is withdrawn, or where another lawful basis for erasure applies, subject to legal exceptions【551981313083513†L187-L193】.
Right to restrict processing: you may request that LEINPAGE temporarily suspend processing in certain situations, such as where data accuracy is contested or an objection is pending.
Right to data portability: you may request personal data you provided to LEINPAGE in a structured, commonly used, machine-readable format and request transfer to another controller where legally applicable.
Right to object: you may object to processing based on legitimate interests or direct marketing. LEINPAGE will stop such processing unless it has compelling legitimate grounds or another lawful basis to continue.
Rights regarding automated decision-making and profiling: you may request human review where a decision based solely on automated processing has a legal or similarly significant effect on you.
Right to withdraw consent: where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

15. Privacy Choices and Controls

LEINPAGE provides tools and settings to help you control personal data and privacy preferences:

Account settings: you may access your profile to review and update personal information, change passwords, enable two-factor authentication, and manage login methods. You may add or remove contact information, update addresses, and change language preferences.
Content and data management: you may delete posts, attachments, comments, or other content at any time. LEINPAGE may also provide tools that allow you to export copies of your data. Some data may take time to be fully deleted because of backup systems.
Marketing preferences: you may opt in to or opt out of marketing emails, messages, or notifications. Each marketing email includes an unsubscribe mechanism. Service and security notices may still be sent when necessary.
Cookie and advertising controls: you may adjust browser settings to block or delete cookies, reject some forms of tracking, limit advertising tracking on mobile devices, or reset advertising identifiers. LEINPAGE may also provide in-product settings for advertising and analytics preferences.
Rights requests: you may use our forms or contact channels to request access, correction, deletion, or portability. LEINPAGE may verify identity before acting on a request.
In-app privacy settings: certain services may provide dashboards allowing you to control usage data, disable location collection, disable search history, turn off personalization, or configure profile visibility to other users.

16. Location Data, Children’s Data, and Sensitive Data

Location data: if you grant permission, LEINPAGE may collect precise location data from your device to support functions such as navigation, local content, nearby recommendations, or location-based advertising. Location may be determined using GPS, Wi-Fi, Bluetooth, device sensors, or IP address. You may disable such access through device or application settings, although some features may then not function correctly.

Sensitive data: LEINPAGE collects sensitive categories of personal data, such as health information, biometric data, financial information, government identifiers, religious belief information, or data concerning sexual orientation, only where necessary and on the basis of explicit consent or another valid legal basis. Sensitive data is used only for the stated purpose and is protected with heightened safeguards, restricted access, and limited retention.

Children’s data: LEINPAGE’s services are not directed to children below the minimum age under applicable law, commonly 13 or 16 depending on jurisdiction. LEINPAGE does not knowingly collect personal data from children. If you are below the required minimum age, you should not use the services or submit personal data. Parents or guardians may contact us if they believe a child submitted information without authorization, and LEINPAGE will delete the relevant data. Where a service is specifically designed for younger users, LEINPAGE will require parental consent, collect the minimum data necessary, and provide additional management controls.

LEINPAGE complies with child privacy rules such as the U.S. Children’s Online Privacy Protection Act (COPPA) and similar laws elsewhere. We do not use sensitive data or children’s data for marketing or advertising purposes.

17. Third-Party Links and Services

LEINPAGE services may contain links to websites, applications, or services operated by third parties, as well as integrations such as social logins, plugins, widgets, or APIs. Accessing or using third-party services is optional, and your use of them is governed by their own terms and privacy policies. LEINPAGE does not control and is not responsible for the content, privacy practices, or conduct of third parties. You should review the relevant third-party policies before providing information.

When you use a third-party sign-in method, such as Google or Facebook, the provider may send LEINPAGE basic information about you and may authenticate your identity on our behalf. Social platforms or other apps may also collect data about your interactions with our content or advertising and share statistical information with LEINPAGE. While LEINPAGE processes the information it receives under this Policy, it is not responsible for the independent data practices of those third parties.

LEINPAGE services may also contain components supplied by third parties, such as maps, video players, payment modules, chat functions, or software libraries. These providers may collect usage or device data when you interact with those components. You should remain cautious when disclosing information to any outside party and make sure you understand how that party uses data.

If you share content to external services or link your activity with outside platforms, the information will be processed under the policy of the receiving party. LEINPAGE does not control the actions of other users or third parties and is not responsible where you voluntarily make information public. Use privacy settings carefully and share only what you are prepared to disclose.

18. Supplemental Regional and Country-Specific Information

LEINPAGE provides additional provisions to meet legal requirements in specific jurisdictions:

European Union / EEA / United Kingdom: LEINPAGE complies with the GDPR and related national laws. Personal data is processed only on a recognized lawful basis. You may lodge a complaint with your local supervisory authority if you believe your data has been processed unlawfully. LEINPAGE may appoint an EU/UK representative and a Data Protection Officer where required.
California, United States: under the CCPA/CPRA, LEINPAGE must provide notice of the categories of personal information collected, the purposes of use, the sources of collection, and the categories of recipients; and must provide rights to know, delete, opt out of sale or sharing, correct, limit the use of sensitive personal information, and avoid discrimination. LEINPAGE provides channels dedicated to California rights requests. LEINPAGE does not sell personal information for money, but where advertising-related sharing is deemed “sharing” under California law, California residents may opt out. LEINPAGE also follows the Delete Act and implementing regulations where applicable, including mechanisms related to deletion requests involving data brokers【551981313083513†L245-L268】.
Vietnam: LEINPAGE complies with Decree 13/2023/ND-CP on personal data protection. We collect and process personal data after notice and consent except where law permits otherwise; we do not process data beyond the notified scope; we ensure local storage or satisfy lawful conditions for outbound transfer; we meet reporting obligations to the Personal Data Protection authority where required; and we respond to data subject requests within legally required timelines. Data subjects may request access, correction, withdrawal of consent, restriction, objection, and compensation where their rights are infringed.
Other regions: LEINPAGE also seeks to comply with laws such as Brazil’s LGPD, Canada’s PIPEDA, Singapore’s PDPA, Thailand’s PDPA, South Africa’s POPIA, and similar legal frameworks. Additional notices and rights may be provided where required by applicable law.

19. Policy Changes, Contact, and Complaints

LEINPAGE may revise this Privacy Policy to reflect changes in law, technology, or business operations. When we update the Policy, we will publish the new version on the website and specify its effective date. If the changes materially affect your rights, we will provide more prominent notice, such as email notice or in-app notice. LEINPAGE will not reduce the rights described in this Policy without your consent. You should review the Policy periodically to remain informed of current practices.

If you have questions, concerns, complaints, or wish to exercise your rights under this Policy, you may contact LEINPAGE through the following channels: (i) Email: [email protected]; (ii) Post: Data Protection Department, LEINPAGE Company, address …; or (iii) the online support portal on the website or within the application. Please provide enough detail for us to verify and process the request. LEINPAGE will respond within the timeframe required by applicable law and will make reasonable efforts to resolve concerns promptly.

You may also have the right to submit a complaint to a competent data protection authority or other authority with jurisdiction in your country of residence. LEINPAGE will cooperate with regulators and authorities to resolve complaints and follow lawful guidance. If a dispute cannot be resolved informally, you may use the legal remedies available under applicable law.

When responding to requests, LEINPAGE may need to verify your identity in order to protect personal data against unauthorized access. We may request additional information to confirm identity or clarify the scope of your request. LEINPAGE may deny a request where there is no legal basis, where the request is manifestly unfounded or excessive, or where compliance would adversely affect the rights and freedoms of others. In such cases, we will explain the reason and, where appropriate, identify available alternatives.

20. Terms and Definitions

This Policy uses the following terms with the meanings set out below:

Rights of access, erasure, portability, objection, and restriction: rights granted to data subjects under the GDPR and similar laws, enabling individuals to manage how their data is processed.

Personal data: any information relating to an identified or identifiable individual, including name, address, email address, telephone number, device identifiers, IP address, location data, account records, preferences, and any other information linked to a person.
Sensitive data: a category of personal data that may include health information, financial information, government-issued identifiers, biometric data, race or ethnicity, religious or political beliefs, sexual orientation, and children’s data. Sensitive data requires heightened protection and, in many cases, explicit consent.
Processing: any operation or set of operations performed on personal data, whether automated or not, including collection, recording, organization, structuring, storage, alteration, retrieval, consultation, use, disclosure, dissemination, restriction, erasure, or destruction.
Data controller: a person or organization that determines the purposes and means of processing personal data. LEINPAGE generally acts as the controller for data it collects directly.
Data processor: a person or organization that processes personal data on behalf of a controller and according to its instructions. LEINPAGE may act as a processor when providing services to enterprise customers.
Cookie: a small text file stored on your device to remember information when you visit a website. Cookies may be session-based or persistent.
Pixel / web beacon: a small code element placed in a page or email to detect viewing activity and collect associated log information.
Device identifier: a string of numbers or characters used to uniquely recognize a device, such as Apple IDFA or Android AAID.
Anonymization: the process of removing or altering personal data so that a specific individual can no longer be identified. Properly anonymized data is no longer personal data.
Sale of data: under some laws such as the CCPA, a transfer or disclosure of personal information to a third party in exchange for money or other valuable consideration. LEINPAGE does not sell personal data for monetary consideration.
Sharing of data: making data available to a third party for a specific purpose, with or without payment. LEINPAGE shares data according to the principle of necessity and in compliance with applicable law.