Privacy Policy

Last updated: December 1st 2020

INTRODUCTION

Thank you for choosing to be part of our community at Lead Labs, LLC. (“Company“, “Lead Labs”). We appreciate your trust and we are committed to protecting your privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at team@warmupinbox.com.

We have prepared this Privacy Policy to describe to you what data we collect, why we do so, and what we do with it. It applies to the personal information we collect from users of the WarmUp Inbox (the “Service”). This privacy policy applies to all information collected through our Software, and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Software“). 

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT WILL HELP YOU MAKE INFORMED DECISIONS ABOUT SHARING YOUR PERSONAL INFORMATION WITH US.  

Changes to This Privacy Policy

This Privacy Policy is subject to occasional revision. When changes are made, the Company will make a new copy of the Privacy Policy available on the Software. These changes will be effective immediately for new users of our Service. If you do not wish to permit changes in our use of your personal information, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Continued use of our Software, Application or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

CCPA Disclosure

Under the California Consumer Privacy Act of 2018 (CCPA), Lead Labs must affirmatively inform California consumers of the categories of personal information collected about the consumer, the sources from which that information is collected, the commercial or business purpose for which the personal information is collected, the categories of third parties the information will be shared with, and specific pieces of personal information collected about the consumer.

Lead Labs As a Data Controller and a Data Processor 

Our platform connects directly to an email inbox. We do not scan emails or inboxes for any other purpose but to generate and send emails for registered users. EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as "data controllers") and organizations that process personal data on behalf of other organizations (known as "data processors"). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data. Lead Labs may act as either a data controller or a data processor in respect of your Personal Data, depending on the circumstances.

Information We Collect

Our Software collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, our Software has collected the following categories of personal information from its consumers within the last twelve (12) months:

  1. Category A: Identifiers
    a. Examples: A real name, Internet Protocol address, email address, or other similar identifiers.
    b. Collected: YES

     

  2. Category B: Personal information categories
    c. Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
    d. Collected: YES

     

  3. Category C: Protected classification characteristics under applicable law.
    e. Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
    f. Collected: YES

We obtains the categories of personal information listed above from the following categories of sources:
 

  1. Directly from you. For example, from forms you complete on our Software.
     

  2. Indirectly from you. For example, from observing your actions on our Software or interactions with our advertisers.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following business purposes:

1. To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

2. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

3. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

Data Sharing

We may disclose personally information about you:

A. With our service providers. Companies we contract with who help with parts of our business operations. We require that our service providers only use your PII in connection with the services they perform for us.

B. With your service providers: Companies under contract with, or acting on your behalf, who handle data (such as a customer lists) on your behalf.

C. With our subsidiaries and related companies

D. Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). 

E. In connection with a sale of our business: If a third party acquires some or all of our business or assets, we may disclose your PII in connection with the sale.

F. We also share technical data that we collect about your browsing habits and your device (such as data relating to our cookies, tracking pixels and similar technologies) with other advertising companies in the digital advertising ecosystem. This enables them and us to better target ads to you.

 

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

1. The categories of personal information we collected about you.

2. The categories of sources for the personal information we collected about you.

3. Our business or commercial purpose for collecting or selling that personal information.

4. The categories of third parties with whom we share that personal information.

5. The specific pieces of personal information we collected about you (also called a data portability request).

6. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

7. Sales, identifying the personal information categories that each category of recipient purchased; and

8. Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

 

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act.

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights 

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our Software. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

1. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

2. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

3. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Personal Information Sales Opt-Out and Opt-In Rights 

If you are 18 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 18 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 18 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our Software and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Data Retention 

We retain your Personal Data for as long as necessary to provide you with our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. 

If you have an account with us, we will typically retain your Personal Data for a period of ninety (90) days after you have requested that your account is closed or if it's been inactive for five (5) years.

Data protection law provides you with rights in respect of Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, object to profiling and unsubscribe from marketing communications. 

For the most part, you can exercise these rights by logging in and visiting the My Account page or changing the "cookie settings" in your browser (see our Cookie Policy for more information). There may be circumstances where we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided for in data protection legislation.

Non-Personally Identifiable Information

Non-Personally Identifiable Information is information that does not identify a specific person. This type of information may include things like the Uniform Resource Locator (“URL”) of the website you visited before coming to our Software, the URL of the website you visit after leaving our Software, the type of browser you are using, your Internet Protocol (“IP”) address, or general and/or aggregated location data that does constitute personally identifiable information, and cannot be used as an identifier to discern you as a data subject. 

Creation of Anonymous Data

We may create anonymous data records from personal information by excluding information (such as your name) that makes the data personally identifiable to you.  We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our Services and improve Software.  We reserve the right to use anonymous data and aggregated and other de-identified information for any purpose and disclose anonymous data to third parties in our sole discretion.

Third Party Service Providers

We may share your personal information with third party service providers: (1) to provide you with the Services that we offer you through our Software, (2) to enable message transmission, (3) to conduct quality assurance testing or audits, (4) for our own marketing purposes, (5) to facilitate enrollment and creation of accounts, (6) to provide technical support, (7) to facilitate data storage, (8) for billing, (9) to manage sales accounts, and/or (10) to provide other services to our Company. These third party service providers are required to not use your personal information other than to provide the services requested by our Company.

Third Party Links 

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by us (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Other Disclosures

Regardless of any choices you make regarding your personal information (as described below), our Company may disclose your personal information if it believes in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (iii) to protect or defend the rights or property of Company or users of the Application or Services. 

Children

Our Services are not directed to children and we do not intentionally gather personal information from visitors who are under the age of 18.  If a child under 18 submits personal information to Company and we learn that the personal information is the information of a child under 18, we will attempt to delete the information as soon as possible.  If you believe that we might have any personal information from a child under 18, please contact us at team@warmupinbox.com.

Change of Ownership

If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our global privacy standards. Should such an event occur, we will require that the new combined entity follow this privacy notice with respect to your personal information. If we intend to handle your personal information for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your personal information for the new purposes.

Analytics & Marketing

Personal information will not be used for third party marketing purposes with the following exceptions: (1) Third party analytics companies or advertisers on our Software may collect and use information via their own technical tools such as cookies, such as google analytics. This policy does not apply to, and we are not responsible for, cookies used by analytics companies or in third party ads. We encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technologies. And, (2) third parties may track and record user clicking/browsing data as related to retargeting display ads.

User Testimonials and Feedback

We often receive testimonials and comments from users who have had positive experiences with our Services.  We occasionally publish such content.  We may post user feedback on the Company Properties from time to time.  We generally will share your feedback with your first name and last initial only.  If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback.

Security

We use industry standards of security to secure data during transmission and storage. We use the SSL or TSL technology to protect your sensitive information and passwords during transmissions and transactions. We employ random audit to make sure we reduce the risks of fraudulent transaction or transmission as well.

Email Communications

You may indicate a preference to stop receiving further marketing e-mail from us and may “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications.

Social Networking Sites (SNSs)

Some of our Services may enable you to post content to SNSs (e.g., Facebook or Twitter).  If you choose to do this, we will provide information to such SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNSs.  We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.

Users Outside of the United States 

If you are a non-U.S. user of the Services, by using our Services and providing us with data, you acknowledge and agree that your personal information may be processed for the purposes identified in the Privacy Policy.  In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal information may be less protective than the laws in your country.  By providing your data, you consent to such transfer.

International Privacy Laws

If you are visiting the Services from outside the United States, please be aware that you are sending information (including Personal Data) to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your Personal Data will at all times continue to be governed by this Privacy Policy. 

EEA, Switzerland and UK Only 

The GDPR requires us to tell you about the legal ground we're relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out above will typically be because: 

• You provided your consent;
• It is necessary for our contractual relationship;
• The processing is necessary for us to comply with our legal or regulatory obligations; and/or 
• The processing is in our legitimate interest as an event organizing and ticketing platform (for example, to protect the security and integrity of our systems and to provide you with customer service, etc.). 

 

Transfers of Personal Data 

As Lead Labs is a global company, we may need to transfer your Personal Data outside of the country from which it was originally provided. This may be intra-group or to third parties that we work with who may be located in jurisdictions outside the EEA, Switzerland and the UK which have no data protection laws or laws that are less strict compared with those in Europe. 

Whenever we transfer Personal Data outside of the EEA, Switzerland or the UK, we take legally required steps to make sure that appropriate safeguards are in place to protect your Personal Data. 

Contact Us

If you have a question or a complaint about this privacy notice, our global privacy standards, or our information handling practices, you can reach us at: team@warmupinbox.com

Google APIs Use & Access

Warmup Inbox use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.