Privacy Policy

2. About the Privacy Policy

This policy describes important details regarding your personal data's relationship with Netlei AB. The policy applies to all services provided by Netlei. The terms that govern your use of the product and service are defined in Netlei's terms of use.

Definitions

The Service – The application where the customer orders and manages their LEI number

The Agreement – The agreement entered into between the company and the customer for the company to provide services to the customer

From time to time, we may develop or offer additional services. If the launch of new or additional services changes how we collect and process your personal data, we will provide you with more information and additional terms or rules. Unless otherwise indicated when we introduce the new or additional services, they are subject to this policy.

The purpose of the policy is to:

• Ensure that you understand what personal data we collect about you, the reasons for collecting and using them, and who we share them with.

• Explain how we use the personal data you share with us to provide you with a good experience when using the service.

• Explain your rights and choices regarding the personal data we collect and process about you, and how we protect your privacy.

We process your data in connection with your use and access to the service. Processing of personal data is required for us to fulfill the agreement with you to provide the service. The legal basis for processing personal data is to fulfill the agreement, and it is necessary for us to process your personal data to fulfill the agreement with you. You are not obliged to provide us with your personal data, but if you choose not to provide your personal data, the consequence is that we cannot enter into an agreement.

3. Your Rights and Preferences

There is a new EU regulation, the General Data Protection Regulation or "GDPR," which grants individuals certain rights concerning their personal data. In accordance with the GDPR, we have implemented transparency and support for users to exercise their rights. Subject to access and except for limitations under applicable law, individuals have the following rights:

• Right to Access – the right to be informed about and request access to the personal data we process about you.

• Right to Rectification – the right to request that we change or update your personal data where they are incorrect or incomplete.

• Right to Erasure – the right to request that we delete your personal data.

• Right to Restriction – the right to request that we temporarily or permanently cease processing all or some of your personal data.

• Right to Object – the right to, at any time, object to our processing of your personal data due to your specific situation, and the right to object to your personal data being processed for direct marketing.

• Right to Data Portability – the right to request a copy of your personal data in electronic format and the right to transfer that personal data for use in another party's services.

• Right Not to be Subject to Automated Decision Making – the right not to be subject to any decisions based solely on automated decision making, including profiling, that would have a legal effect on you or have a similar effect.

If we send you electronic marketing communications in accordance with your consent or as allowed by applicable law, you can revoke your consent or opt-out at any time without any extra cost. The electronic marketing communications you receive from the service (e.g., those sent via email) also include a mechanism to unsubscribe within the message itself. You can learn more about the GDPR rights described above and the controls we offer to all service users regarding these rights. If you have any questions about your privacy, your rights, or how to exercise them, please contact our data protection officer via the attached link: https://leinumbers.com/contact We will respond to your request within a reasonable time after verifying your identity.

4. How We Collect Personal Data

We collect your personal data in the following ways:

• When you register for a user account and use the service – when you register for the service, we collect certain personal data required for you to use the service, such as your name, mailing address, email address, password, and country.

• Through your use of the service – when you use the service, we collect personal data related to your use of the service, such as support, location data, IP address, data from analytics services like Google Analytics, bug reporting, etc.

• Personal data collected to provide additional features/functionality – from time to time, you may explicitly choose to provide us with additional personal data by giving your consent, for us to provide additional features. As described below, we will not collect images and location data without your consent. You can change your mind and withdraw your consent at any time.

• When you use the web-based service – we also use cookies and tracking pixels to collect data about your use of the website for marketing purposes (via email and other digital marketing), such as information about promotions, products, or offers, and for market analysis and to customize the website according to users' needs. The collection of user data and the creation of a user profile are done anonymously using a cookie ID. We create and store user profiles only in an anonymous form and never combine them with your name or any other information, such as your email address, that could reveal your identity.

5. What Personal Data Do We Collect?

Below, we describe the categories of personal data we collect and use about you:

Data for account registration of the service

These are the personal data you have provided or that we have collected to allow you to register for and use the service via the app or web. It includes name, mailing address, email address, password, and country.

Some of the personal data we ask you for are required to create an account. You may also provide us with additional personal data to make your account more tailored to you.

Data about your use of the service

Personal data collected about you when you use the service may include:

• Information about your interactions with the service, such as settings, support, location data, IP address, data from analytics services like Google Analytics, bug reporting. It may also include data about your use of third-party applications and the advertisements you receive.

• User-generated content (as defined in the terms of service) that you send and/or receive via the service and your interactions with customer support.

• Technical data, which may include web addresses, cookie data, IP address, types of devices you use to access or connect to the service, unique device IDs, device attributes, network connection type (e.g., WiFi, 3G, LTE, Bluetooth), and provider, network and device performance, browser type, language, information enabling digital rights management (DRM), operating system, and service version.

• First and last name

• Address

• Phone number

• E-mail address

• Information about goods/services you have purchased from us

• Historical information about past purchases

• Support information

• Information about how you use the service, including web response time, method of arrival and departure, any download errors that may have occurred, and delivery notifications when we contact you

• Device information, such as the IP address used to connect your computer to the internet, language settings, browser settings, time zone settings, operating system, platform, screen resolution, and delivery notifications when we contact you

• When you contact us via email or the contact form on the website, the data you provide is stored and used to process your request and for any follow-up questions.

Personal data collected through your use of the service

Personal data collected with your permission that allows us to provide you with additional features or functionality.

When using our services, we may need to collect data about you, beyond the data you provide to us. For example, this may include data from collaborators and payment service providers, as well as data on creditworthiness from credit rating agencies, banks, or information companies.

Payment information

We may collect this personal data if you register to use the paid version of the service. The specific personal data collected varies depending on the payment method (e.g., payment by card or invoice) but may include information such as:

• name

• Credit or debit card type, expiration date, and certain digits of your card number

• Address

• Email address

• Phone number

• Information about your transaction history

If you choose to pay by invoice, we provide your personal data to our payment providers to conduct a credit check and send invoices.

Information about contests, surveys, and lotteries

This personal data is used for you to register for and participate in these types of promotions. The specific personal data collected may vary depending on the promotion.

Marketing data

This personal data is used to enable Netlei and our partners/service providers to send marketing communications in the following ways:

• Via e-mail

• Via push notifications

• While you use the service and/or directly from third parties

6. What Do We Use Your Personal Data For?

When you use or interact with the service, we use various techniques to process the personal data we collect about you for various purposes. Below, we describe the reasons for processing your personal data, the legal grounds on which we rely to process your personal data, and the categories of personal data (see section 5 "What Personal Data Do We Collect?") used for each purpose:

Description of Why Netlei Processes Your Personal Data

1. To provide, customize, and improve your experience of the service and other services and products provided by Netlei, for example, by providing customized, personalized, or localized content, recommendations, features, and advertising within or outside the service (including for third-party products and services).

Legal Ground

• Contractual performance

• Legitimate interests

Categories of Personal Data Used by Netlei for This Purpose

• Data for account registration

• Data about service usage

2. To understand how you access and use the service to ensure the technical functionality of the service, develop new products and services, and analyze your usage of the service, including your interactions with applications, advertisements, products, and services made available, linked to, or offered through the service.

Legal Ground

• Contractual performance

• Legitimate interests

Categories of Personal Data Used by Netlei for This Purpose

• Data for account registration

• Data about service usage

3. To communicate with you for purposes related to the service.

Legal Ground

• Contractual performance

• Legitimate interests

Categories of Personal Data Used by Netlei for This Purpose

• Data for account registration

• Data about service usage

4. To handle support matters related to the service/product where we see your name and connected facilities associated with you and the products and services you have purchased.

Legal Ground

• Contractual performance

• Legitimate interests

Categories of Personal Data Used by Netlei for This Purpose

• Data for account registration

• Data about service usage

5. To process your payment and prevent and detect fraud, including payment fraud and illegal use of the service.

Legal Ground

• Contractual performance

• Compliance with legal obligations

• Legitimate interests

Categories of Personal Data Used by Netlei for This Purpose

• Payment information

6. To communicate with you, either directly or through any of our partners, for:

• marketing

• research

• participation in contests, surveys, and lotteries

• advertising purposes

via email, notifications, or other messages, in accordance with any consents you may have provided to us (e.g., via your account settings).

Legal Ground

• Consent

• Legitimate interests

Categories of Personal Data Used by Netlei for This Purpose

• Data about contests, surveys, and lotteries

• Marketing data

• Data about service usage

7. To provide you with information, features, advertising, or other content based on your specific location.

Legal Ground

• Consent

Categories of Personal Data Used by Netlei for This Purpose

• Voluntary mobile data (location data)

7. Sharing of Your Personal Data

In certain cases, we may transfer or share your information with selected third parties. We take all reasonable legal, technical, and organizational measures to ensure that your personal data is handled securely and with an adequate level of protection when transferred or shared with such third parties.

Personal Data We May Share

Recipient Categories

Service Providers and Others

Reasons for Sharing

• We use technical service providers who apply the technical infrastructure needed to provide the service, especially hosting, storage, management, and maintenance providers for the service's content and the information we process.

• We use technical service providers that assist us in communicating as described in section 6 "What Do We Use Your Personal Data For" in this policy.

• We employ marketing and advertising partners to show you more personalized content or to help us understand your use of the service to provide you with a better service.

• We may also share personal data with certain marketing and advertising partners to send marketing communications about the service and/or Netlei's products.

Recipient Categories

Police and Data Protection Authorities

Reasons for Sharing

We share your personal data when we believe in good faith that it is necessary for us to do so to fulfill a legal obligation under applicable law or respond to a valid legal process, such as a search warrant, a court order, or a subpoena.

We also share your personal data when we believe in good faith that it is necessary for our legitimate interests or those of third parties, such as national security, law enforcement, legal disputes, criminal investigations, protecting someone's safety, or preventing death or imminent bodily harm, provided that we believe such interests outweigh your interests or fundamental rights and freedoms requiring the protection of your personal data.

Recipient Categories

In Case of Asset Transfer

Reasons for Sharing

In the event Netlei sells or buys any business or assets, we may disclose your personal data to a prospective seller or buyer of such business or assets.

8. Data Storage and Deletion

We retain your personal data only as long as necessary to provide you with the service and for legitimate and essential purposes, such as maintaining the service, making data-driven decisions on new features and solutions, fulfilling our legal obligations, and resolving disputes. We retain your personal data for as long as you use the service.

Upon your request, we will delete or anonymize your personal data so that it no longer identifies you, unless we are legally entitled or obligated to maintain certain personal data, including in the following situations:

• If there is an outstanding issue associated with your account, such as outstanding payments on your account or unresolved claims or disputes, we will store necessary personal data until the issue is resolved.

• If we must retain the personal data for our legal, tax, auditing, and accounting obligations, we will store necessary personal data for the period stipulated in applicable law.

• If it is necessary for our legitimate business interests, such as preventing fraud or maintaining the security of our users.

9. Transfer to Other Countries

Personal data collected within the EU and Switzerland may be transferred to and processed by a third party in a country outside the EU and Switzerland. In such cases, Netlei ensures that the transfer of your personal data is carried out in accordance with applicable privacy laws, especially by establishing appropriate contractual, technical, and organizational measures, such as the standard contractual clauses approved by the European Commission.

10. Links

We may display third-party ads and other content that links to third-party websites. We cannot control or be held responsible for the privacy practices of third parties or their content. If you click on a third-party ad or link, you understand that you are leaving the service, and any personal data you provide is not covered by this policy. Please review the third party's privacy policies to understand how they collect and process your personal data.

11. Protecting Your Personal Data

We strive to protect the personal data of our users. We implement appropriate technical and organizational measures to safeguard the security of your personal data, but please note that no system is ever completely secure. We have implemented various policies to protect against unauthorized access and unnecessary storage of personal data in our systems.

Your password secures your user account, so we recommend using a unique and strong password, limiting access to your computer and browser, and logging out when you have finished using the service.

12. Children

The service is not intended for children under 13 years of age. In some countries, stricter age limits may apply under local laws. More information can be found in our Terms of Service.

We do not knowingly collect personal data from children under 13 years of age or below the applicable age limit ("age limit"). If you are below the age limit, you should not use the service or provide any personal data to us.

If you are the parent or guardian of a child below the age limit and become aware that your child has provided personal data to the service, you can contact us via email to exercise your applicable rights, as described in the "Your Rights and Preferences" section 3 of this policy.

If we become aware that we have collected personal data about a child under 13 years of age, we will take reasonable steps to delete the personal data. This may include deleting the child's account.

13. Changes to the Privacy Policy

We may occasionally make changes to the policy.

When we make material changes to this policy, we will provide you with clear notice under the circumstances, such as by displaying a prominent notice in the service or by sending an email. We may notify you in advance.

Therefore, make sure to read all such notices carefully.

14. How to Contact Us

Thank you for reading our privacy policy.

If you have any questions about this policy, you can contact us via email at: support@leinumbers.com

Netlei AB is the data controller for the personal data processed under this policy. The supervisory authority is the Swedish Data Protection Authority (Datainspektionen), whose mission is to oversee compliance with data protection regulations by those processing personal data. If you believe that Netlei AB is processing your personal data in violation of data protection regulations, you have the right to lodge a complaint with the Swedish Data Protection Authority.

We hope you will be satisfied with using the service!