My Leadership Foundry –
Mobile Application Privacy Policy

DOWNLOAD THE PRIVACY POLICY PDF
1. INTRODUCTION TO OUR PRIVACY POLICY AND ITS OBJECTIVES

At Leadership Foundry, we want to ensure that we provide you with the best experience possible and that you enjoy our services. To do this, we need to collect and use your personal data. This document (the “​Privacy Policy​”) sets out the essential details relating to your personal data relationship with our company ​B. Mikel Smith & Associa​tes, LLC (“​Leadership Foundry​”, “​we​”, “​us​”, “​our​”) when using the Leadership Foundry Mobile Application (the “​Application​”). The Privacy Policy applies to all of our services provided to you via the Application (the “​Services​”). The aim of the Privacy Policy is to transparently explain to you: (i) what personal data we collect about you, the reasons why we collect the personal data and how we use it, and who we share your personal data with, (ii) the way we use the personal data that you share with us in order to give you the best possible experience when you are using the Services, and (iii) your rights in relation to the personal data we collect and process about you and how we will protect your privacy. Please note that the Services are intended only for users of the age over 18. If you are under this age limit, please do not use the Services and do not provide any personal data to us.

2. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA? HOW CAN YOU CONTACT US?

The entity responsible for the processing of your personal information, which is the so-called “data controller” within the meaning of the EU General Data Protection Regulation (“​GDPR​”), is Leadership Foundry, i.e.:

Name: ​B. Mikel Smith & Associates, LLC

Company Registration Number: ​#014667210

Address: ​525 Meadowland Ct, Roswell, Georgia 30075-2182, United States

E-mail Address: ​brandon@theworksmiths.com

Phone Number: ​1-404-403-6903

Should you ever have questions or concerns about this Privacy Policy or wish to communicate with us regarding related matters, you may reach us by email or post at the above addresses.

3. HOW DO WE COLLECT YOUR PERSONAL DATA AND WHAT PERSONAL DATA DO WE COLLECT?

The table below summarizes the ways in which we collect your personal data via the Application and the categories of this personal data we collect and use:

Ways in which personal data are collected Categories of personal data collected Description of category
  • Personal data collected when you sign up for the Services
  • Account Registration Data
This is the personal data that is provided by you and/or collected by us to enable you to sign up for and use the Services.
This data includes your email address, phone number, full name, the name of the company you work for, and your role in such company.
You also have the option to provide us with certain additional personal data, such as your user picture, in order to personalize your account.
  • Personal data collected through your use of the Services
  • Service Usage Data

This is the personal data that is collected about you while you are using the Services. This data may include:

  • Information about your Services plan type.
  • Information about your interactions with the Services, which include the date and time of any requests you make, content you have accessed (audio files you have listened to, videos you have watched, etc.).
  • Content you post to the Application, such as messages you send or receive via the Application and your interactions with us.
  • Technical Data, which may include your IP address, the types of devices you are using to access or connect to the Services, unique device IDs, device attributes, language, operating system, and the Application version.
  • Personal​ data collected with your permission that enables us to provide you with additional functionalities
  • Payment Data

We may collect such personal data if you purchase any of our paid Services or make other purchases through the Services. The exact personal data collected will depend on the payment method, but may include information such as:

  • Name;
  • Date of birth;
  • Credit or debit card type, expiration date, and certain digits of your card number;
  • Postal code;
  • Mobile phone number;
  • Details of your transaction history.
  • Marketing Data

This personal data is used to enable us to send you marketing communications either:

  • Via email;
  • While using the Services.

Please note that we further use certain information for purposes that include the testing of our IT systems, research, data analysis, marketing, improving the Services, and developing new functionalities within the Services. However, such information gathered and processed by us is always anonymized and cannot be linked to your identity and, as such, do no longer qualify as your personal data.

We may also use UXCam, which is an analytic solution application. UXCam may record the following information about your interactions with the Application: screens visited, interaction patterns (such as screen actions, gestures: taps, scrolls) and device details (type, version, model, operating system). We use the information collected by UXCam to improve our Application. UXCam does not collect personally identifiable information and does not track your browsing habits across applications. For more information, please see UXCam’s ​Privacy Policy​.

4. WHAT DO WE USE YOUR PERSONAL DATA FOR?

When you use or interact with the Services, we use technologies that process the personal data we collect for various reasons. The table below explains the reasons why we process your personal data, the associated legal bases we rely upon to ensure our legal adherence in processing your personal data, and the categories of personal data (identified above in the “How do we collect your personal data and what personal data do we collect?” section above) used for these purposes:

Description of why we process your personal data (the “processing purpose”) Legal basis for the “processing purpose” Categories of personal data used by us for the processing purpose
  • To provide, personalize, and improve your experience with the Services, for example, by providing customized, personalized, or localized content, recommendations and features.
  • Performance of a Contract
    (Article 6 (1) (b) of the GDPR)
  • Legitimate Interest
    (Article 6 (1) (f) of the GDPR)
  • Account Registration Data
  • Service Usage Data
  • To understand how you access and use the Services to ensure the technical functionality of the Services, develop new products and services, and analyze your use of the Services, including your interaction with the Application, advertising products and services that are made available, linked to, or offered through the Services.
  • Performance of a Contract
    (Article 6 (1) (b) of the GDPR)
  • Legitimate Interest
    (Article 6 (1) (f) of the GDPR)
  • Account Registration Data
  • Service Usage Data
  • To communicate with you for Service-related purposes.
  • Performance of a Contract
    (Article 6 (1) (b) of the GDPR)
  • Legitimate Interest
    (Article 6 (1) (f) of the GDPR)
  • Account Registration Data
  • Service Usage Data
  • To process your payments and prevent or detect fraud, including fraudulent payments and fraudulent use of the Services.
  • Performance of a Contract
    (Article 6 (1) (b) of the GDPR)
  • Compliance with Legal Obligations
    (Article 6 (1) (c) of the GDPR)
  • Legitimate Interest
    (Article 6 (1) (f) of the GDPR)
  • Payment Data
  • To communicate with you for marketing or research purposes via email, notifications, or other messages in a manner consistent with the permissions you have given to us.
  • Legitimate Interest
    (Article 6 (1) (f) of the GDPR)
  • Your Consent
    (Article 6 (1) (a) of the GDPR)
  • Marketing Data
5. HOW DO WE SHARE YOUR PERSONAL DATA?

Generally, we do not share your personal data with third parties. However, we may do so if you choose to make use of a specific Services feature for which the sharing of particular personal data is required for the proper use of the given Services feature, or you grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Services. In addition, we may share certain personal data with these categories of recipients for the reasons outlined below:

Categories of Recipients Reason for sharing
  • Service​ Providers and Others

We use technical service providers who may operate aspects of the technical infrastructure that we use in order to provide the Services, in particular, providers that host, store, maintain, and manage the Application and the data we process.
We might also use technical service providers to help us communicate with you. And, we might use advertising and marketing partners to provide you with more tailored content and better service. Finally, we might share personal data with certain marketing and advertising partners to send you promotional communications about the Services.

  • Law​ Enforcement and Public Authorities

We will share your personal data when we, in good faith, believe it is necessary for us to do so in order to comply with legal obligations under applicable law, or respond to valid legal processes.


We will also share your personal data where we, in good faith, believe that it is necessary for the purposes of our own or a third party’s legitimate interest relating to law enforcement, litigation and/or criminal investigation, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

To ensure that you receive the greatest privacy guarantees and data protection assurances we can provide, we carefully review all third parties with which we cooperate. Our third-party service providers do not have any right to use the information we share with them beyond what is necessary for them to assist us.

Storage and international data transfers

Our Services are hosted and your personal data is stored in the United States.

We might also subcontract certain processing to, or share your personal data with, third parties located in countries other than your home country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country of residence. In such instances, we shall ensure that the transfer of your personal data is carried out in accordance with all applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place.

6. DATA STORAGE AND ITS DURATION, DELETION OF THE DATA

Your privacy and the security of your personal data are very important to us. For this purpose, we implement appropriate technical and organizational measures to help protect the security of your personal data. We have implemented various policies, including access and retention policies, to guard against unauthorized access and unnecessary retention of personal data in our systems. We have taken necessary precautions to also ensure that data deletion is conducted securely.

We only store your personal data for as long a time as is necessary to provide you with the Services and for legitimate and essential business purposes, such as maintaining the performance of the Services, making data-driven business decisions about new features in our Services, complying with our legal obligations, and protecting our legal interests.

Once you delete your Account, or if you so request, we will delete or anonymize your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including in situations such as the following:

  • To the extent that we are required to do so by law (e.g. for our legal, tax, audit, and accounting obligations);
  • If ​we​ believe that the data may be relevant to any ongoing or prospective legal proceedings or dispute;
  • In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
  • Where necessary for our legitimate business interests, such as maintaining the security of our system.
7. YOUR RIGHTS RELATING TO YOUR PERSONAL DATA

We inform you that, as a national of the European Union or a European Economic Area member state, you have, as available and except as limited under applicable law, the following rights under the GDPR in relation to your personal data:

  • Access to your personal data
    The right to be informed of and request access to the personal data we process about you.
  • Update your personal data
    The right to request that we amend or update your personal data where it is inaccurate or incomplete
  • Erase your personal data
    The right to request that we delete your personal data.
  • Restrict the use of your personal data
    The right to request that we temporarily or permanently stop processing all or some of your personal data.
  • Object to the use of your personal data
    The right to object to our processing of your personal data when we no longer have a legitimate or legal need to do so. When we process your data for the safeguarding of legitimate interests, you may object to this processing on grounds relating to your particular situation. In such case, we will no longer process your personal data, unless we can demonstrate compelling legitimate grounds for this processing that must override your interests, rights and freedoms or be for the establishment, exercise or defense of legal claims.
  • Object to direct marketing
    The right to object to your personal data being processed for direct marketing purposes.
    If we send you electronic marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time, withdraw such consent or declare your objection. Any electronic marketing messages you receive from us will include an opt-out mechanism within the message itself, e.g. an ‘unsubscribe’ link in the email you receive from us.
  • Object to automated decision-making
    The right not to be subject to a decision based solely on automated decision-making, including profiling, whereby such decision would have a legal effect on you or produce a similarly significant effect. Please note, we do not employ automated individual decision-making within the meaning of Article 22 of the GDPR.
  • Port your personal data
    The right to request a copy of your personal data in a machine-readable format and the right to transmit such personal data for use in another party’s service.
    In order to exercise your rights, you are welcome to contact us in one of the ways described in the “Who is responsible for the processing of your personal data? How can you contact us?” section above. We will respond to your request within a reasonable period of time upon our verification of your identity. If you are unsatisfied with the way in which we are using your personal data, you may also contact your local responsible Data Protection Authority to register a complaint.
8. CHANGES

We are committed to keeping you informed about how your personal data is being handled. If we make any material changes to this Privacy Policy, we will notify you as appropriate under the circumstances, e.g. by sending you an email or by displaying a notice within the Application.

9. EFFECTIVENESS

This Privacy Policy is effective as of August 1st, 2019.