Native Lead Privacy Statement

Your privacy is important to Native Lead Inc. (“Native Lead”, “Company”, “we,” “us,” or “our”). This Privacy Statement applies to our proposed Services as described in our Terms of Use. 

Native Lead respects the right to privacy, protects personal data, and applies appropriate organizational and technical solutions to prevent third parties’ interference with Users’ privacy. By using, installing, downloading, exploiting, and accessing the Services, you accept the practices described in this Privacy Policy to the extent permitted by law. 

Using our Service, you understand and agree to use and share your information, including its publicity on an SNA Web Site, as described in our Terms of Use and herein.

Note that even if removed the information posted on SNA, copies may remain viewable in cached and archived pages or if other users or third parties using the SNA Web Site have copied or saved that information.

In addition, some features of the SNA may be designed to provide others with information about the User’s activity. We encourage you to be mindful of this when considering your use of the Services.

You should not share personal information when using the Services. Given the social nature of some of the Services, that information may be collected, used, or disclosed by others who are part of that social interaction. Note that once you have shared content or made it public, that content may be re-shared by others.

1. Definitions

These will constitute definitions in this Privacy Policy:

• “Affiliate(s)” shall refer to entities controlled by, controlling, or under common control with Lucid Ventures Ltd., including our owners, parent companies, subsidiaries, affiliated companies, officers, directors, suppliers, partners, agents, sponsors, advertisers, and employees, and includes (without limitation) all parties involved in creating, producing, and/or delivering this app and/or its Services.
• “Basic Data” shall refer to information lawfully received by us from our Affiliates that includes information regarding potential Leads.
• “User” shall refer to you and anyone who uses the Site. Use can include but is not limited to reading, browsing, or viewing content, ordering or use of Services, receiving information from us, making a payment, or transferring information.
• “Lead” shall refer to the contact information of a person that we believe matches the description of persons you are interested in acquaintance
• “Lead Report” shall refer to the report sent to you by us, with contact details and URL links to Lead information published on social networks (such as Linkedin, Facebook, or others).
• “Social Network Account” or “SNA” shall refer to the social network account that you authorized and empowered us and gave us your access information to review, read, write, and give orders on behalf of you.
• “Services” shall refer to improving your ability to contact Leads through our use of your SNA and Basic Data.
• “Web Site” – Company’s website URL www.nativelead.com

2. Purpose And Grounds for Processing Your Information
   • The provision by the User of the personal data referred to in this Privacy Policy shall be made with the User’s consent. Refusal to provide such information by the User will result in the refusal to provide certain Services by Company.
   • User must consent to the processing of personal data as of the User registration for the Services.
   • By checking the appropriate box on the Website, the User:
     • Consents to the processing of their data; and
     • Confirms that the User has read and accepted this Privacy Policy.
   • Native Lead processes the personal data to provide the Services. Such processing is, in particular, aimed at fulfilling User’s selected Services, handling complaints, withdrawing from the contract of service, and communicating with Users who have made a complaint or made a declaration of withdrawal from the contract for the provision of Services, as well as ensuring the security of the Services by verifying the identity of the person logging into the User Account.
   • In addition, Native Lead processes the personal data referred to in this Privacy Policy to pursue the legitimate interests of Native Lead, such as:
     • Conducting marketing by Company and Promoters;
     • Promotion of Services of Company;
     • Tailoring the Services to the needs and convenience of Users, including personalizing content on the Services;
     • Statistical measurements and improvement of the Services; and
     • other legitimate interests, whether now existing or hereinafter created.
   • Native Lead processes the personal data of persons who have submitted an inquiry to Native Lead using the contact form, with that person’s consent, to the extent necessary to respond. We may monitor or record your requests and our responses for quality control.
3. Information We Collect
   • Information you provide us directly:
     • Your username, password, name, age, address(es), e-mail address(es), telephone number(s), and payment information.
     • Business, commercial, personal, or other information You share with us. This information may be disclosed orally, by writing, electronically, or already be exposed to us in your SNA account, to which we will have access. 
     • Your Communications with Native Lead. For example, we may send you Service-related e-mails. Note that you may not opt-out of Service-related e-mails.
   • Analytics information and third-party services:
     • We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device when you visit our Website. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
     • We may use other services hosted by third parties to assist in providing our Service and help us understand our Users’ use of our Service. These third-party services may collect information sent by your device when you use the Website, including Internet Protocol (“IP”) address, type of device, operating system version, unique or persistent identifiers associated with your device (such as UDID, MAC address, IFA, or identifiers derived from your device’s technical information), network information, technical characteristics of your device or its software, language settings, and usage information relating to your use of the Website.
   • Cookies and similar technologies:
     • When you visit our Website, we may use Cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use the Service and provide features to you.

4. How We Use Your Information
   • We will use your information to:
     • Try to find Leads we think are relevant for you on the SNA.
     • Communicate on your behalf on the SNA with Leads of potential Leads.
     • Log in to your SNA account.
     • Communicate to you via e-mails, telephone, SMS, MMS, or other communication methods.
   • In addition to some of the above specific uses of information, we may use information that we receive to:
     • provide, improve, test, and monitor the effectiveness of our Service;
     • develop and test new services, products, and features;
     • monitor metrics such as total number of visitors, traffic, and demographic patterns;
     • diagnose or fix technology problems;
     • provide you with goods or services;
     • respond to your requests or questions.

5. Sharing of Your Information

We will not share your information with third parties outside Native Lead (or the group of businesses legally part of the same group of companies that Native Lead is part of) without your consent, except as noted in this Privacy Policy.

• Parties with whom we may share your information:

• We may share information about you that already becomes a public domain, such as information that was already published by you on social media platforms and SNA.
• We may share your information (including but not limited to information from Cookies, device identifiers, and usage data) with businesses that are legally part of the same group of companies that Native Lead is part of or that have become part of that group. Affiliates may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates’ services (including providing you with better and more relevant experiences).
• We also may share your information and information from tools like Cookies, log files, and device identifiers with third-party organizations that help us provide the Service to you (“Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
• We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information so that it is no longer associated with you and share that aggregated information.
• If we sell or otherwise transfer part or the whole of Native Lead or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name, e-mail address, and telephone number, content and any other information collected through the Service may be among the items sold or transferred. You will continue to own your content. The buyer or transferee will have to honor our commitments in this Privacy Policy.
• We may access, preserve and share your information in response to a legal request (like a search warrant, court order, or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests in which we have a good faith belief that the response is required by law in that jurisdiction, affects Users in that jurisdiction, and is consistent with internationally recognized standards.
• We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you, and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed, and retained for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

6. How We Store Your Information
   • Your information collected through the Service may be stored and processed in Israel or any other country in which Native Lead, its Affiliates, or Service Providers maintain facilities.
   • Native Lead, its Affiliates, or Service Providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions worldwide. If you are located in the European Union or other regions with laws governing data collection and use that may differ from Israeli law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
   • By registering for and using the Service, you consent to the transfer of information to any other country in which Native Lead, its Affiliates, or Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.
   • We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting access to your account. However, Native Lead cannot ensure the security of any information you transmit to Native Lead or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.
   • Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to e-mails and messages between you and the Native Lead, at all times. We are not responsible for the functionality, privacy, or security measures of any other organization.
7. Your Choices About Your Information
   • You may update us about your information by notifying us via e-mail. Additionally, you may delete or cancel your use of the Services.
   • Unsubscribe from e-mail communications from us by clicking on the “unsubscribe link” provided in such communications. As noted above, you may not opt-out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices).
   • Following termination or deactivation of your use of our Services, Company, its Affiliates, or Processors may retain information (including your account information) for a commercially reasonable time for backup, archival, and/or audit purposes.
8. Other Web Sites and Services

We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. Please remember that when you use a link to go from our Service to another website or service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our Website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third parties that you authorize to access your content. If you use a third-party website or service and allow them to access your content, you do so at your own risk.

9. Data Protection

The collection of Users’ personal data is treated as a database with a high degree of security, stored on a server protected against remote and physical access. Native Lead applies appropriate technical and organizational measures to ensure a degree of security corresponding to the risk of violation of Users’ rights and freedoms. However, no security precautions or systems can be completely secure. Native Lead cannot ensure or warrant the security of any information you transmit to Native Lead, and you do so at your own risk. Native Lead cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. All persons processing personal data in Company have the appropriate authorizations issued by the administrator of personal data.

10. Duration of Personal Data Processing

Native Lead processes the User’s personal data until there is a basis not to do so, which includes:

• If granted User’s consent, when the consent has been revoked, restricted, or other actions have been taken on the part of the User to limit the consent;
• If to perform a contract, for the contract term duration and till the limitations for claims statute expiration.
• If the processing is based on a legitimate interest of the administrator, then until the User objects effectively; and
• If based on tax and accounting purposes, until such time and to the extent per applicable regulations.

11. Cookie Policy

This Cookie Policy applies to your use of the Services and/or the Web Site and any other websites, applications, or services provided by Native Lead that links to this Cookie Policy. Native Lead uses certain technologies to collect information through the Services and/or the Web Site. Native Lead may change this Cookie Policy due to changes or additional requirements of applicable laws.

By using, installing, downloading, exploiting, and/or accessing the Services and/or the Web Site, you accept the information handling practices and storage and access of Cookies as described in this Cookie Policy.

Cookies defined: “Cookies” are small text files stored on your device. They are widely used to make websites and software applications work or work in a better, more efficient way. They can do this because websites and software applications can read and write these files, enabling them to recognize a particular device and remember important information that will make your use of a website or software application more convenient (e.g., by remembering your user preferences).

• Use of Cookies. Native Lead uses Cookies stored on the User’s Device for the following purposes:
• Types of Cookies. Native Lead uses the following types of Cookies to:
  • To make it easier for the User to use the Services and/or Web Site;
  • To ensure the User’s subsequent association with the device when reconnecting to the Services and/or Web Site;
  • To create statistics that assist Company in understanding how Users use the Services and/or Web Site and to improve the structure and content;
  • To adapt the content of the Services and/or Web Site to the User’s specific preferences and to optimize the use of the Services and/or Web Site to the User’s individual needs; and
  • Other for other legitimate business purposes.
• Collection and Storage of Cookies.
  • Native Lead may store information about HTTP queries directed by Users to the Web Site’s server.
  • The browsed resources are identified by URL addresses and relate to the following information:
    • The public IP address of the terminal equipment from which the query came;
    • The User’s station name, which identification is carried out by HTTP protocol;
    • The User’s name is provided in the authorization process;
    • Time of the inquiry;
    • The first line of the HTTP request;
    • The HTTP response code;
    • The amount of data sent by the server;
    • The URL of the page previously visited by the User provided that an external link made the transition to the Web Site;
    • Information about the User’s browser; and
    • Errors information that occurred while executing HTTP transactions.
  • Through its Web Site, Native Lead may automatically collect any information contained in Cookies. The information collected in this way is used, for example, to:
    • Manage the Web Site;
    • Identify possible security risks;
    • Research User traffic on the Web Site for statistical purposes, including by using Google Analytics and Get Response tools, to the extent that mailing campaigns are additionally carried out; and
    • other legitimate business purposes.
  • The information obtained from Cookies is in no way combined with the User’s personal data and is not used to determine the User’s identity.
    • The scope of information automatically obtained from Cookies by Native Lead depends on the User’s web browser settings. The User should check the browser settings of their device to find out what information is automatically provided by the browser or to change those settings. It is recommended to read the “Help” content of the web browser.
    • A web browser, software for browsing websites, i.e., a web browser, usually allows Cookies to be stored on your device by default. Users can change the settings. The web browser allows you to delete Cookies, and it is also possible to block Cookies automatically. It is recommended to read the “Help” content of the web browser.
    • If the User does not wish to receive Cookies, he/she may change browser settings. However, disabling Cookies necessary for authentication, security, or maintenance processes may make it difficult for and, in extreme cases, prevent the User from logging into the system or using the services offered by Company.
    • When using the Services and/or the Web Site, Cookies may also be placed on the device to enable the use of the functionalities of the Web Site, which are integrated with services offered by other providers, in particular, Facebook, Instagram, LinkedIn, Google, PayPal, or another third-party application. Each provider sets out the rules for the use of Cookies in its privacy policy, which is not affected by Native Lead. For security reasons, Company recommends that each User read the privacy policy and the use of Cookies before using the resources offered by other websites or services.

12. Children’s Privacy

Native Lead does not knowingly collect or solicit any information from anyone under the age of 13 or anyone under 18 who has not received permission from a parent or legal guardian to use the Service. Native Lead does not knowingly allow such persons to register for the Service. The Service is not directed at children under the age of 13 or children under the age of 18 who have not received permission from a parent or legal guardian to use the Service. In the event that we learn that we have collected personal information from a child under the age of 13, or a child under the age of 18 who has not received permission from a parent or legal guardian to use the Service, we will delete that information as quickly as possible. If you are a parent or legal guardian and think either that your child under 13 has given us information or that your child under 18 has used the Service and given us information without your permission, please get in touch with us at______________.

13. Company’s Data Officers
    • The Personal Data Administrator, determining the purposes and methods of processing the User’s personal data on the Platform, is: _____________
    • In Company, the position of the Data Protection Officer has been appointed to ensure easy contact between the User and Company for all matters related to the processing of the User’s personal data, including the exercise of their rights related to the processing of their personal data on the Platform.

The Data Protection Officer is: _______________

14. Your Rights About Your Data

In connection with the processing of the User’s personal data, the User has the following rights:

• The right to access to his/her personal data, including obtaining a copy of it;
• The right to request rectification of his/her personal data;
• The right to the erasure of his/her data;
• The right to complain with the supervisory authority for the protection of personal data;
• The right to restrict the processing of his/her personal data;
• The right to object to:
  • Processing of his/her personal data;
  • Direct marketing, including profiling; and
  • Processing of his/her personal data in the administrator’s legitimate interest.
• If personal data is processed based on the User’s consent, the User has the right to withdraw consent. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
• If personal data is processed based on the User’s consent or for the performance of the contract, the User has the right to transfer personal data.
• To exercise the rights referred to in this section ‎14, the User should contact Company via the application form located on the Site under “Contact us.”

15. Changes to Our Privacy Policy

Native Lead may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of Native Lead or the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.

16. How to Contact Us

If you have any questions about this Privacy Policy or the Service, please contact us at: office@nativelead.io