General Statement

We collect personally identifiable information to provide you with products and services made available through our website, including, but not limited to, provision of the service, communicating with you and managing your registered user account. leanGears collects your personal data such as Name, Email address and your Organization name when you register for using our products. We use this information to fulfil your requests for products and our services to you. We contact you for license expirations, to answer general product queries and to improve our services toward you in the process.

1. Privacy policy overview

This section explains how we may have process your information. Leangears LLC, registered in Delaware, US is the organization that owns the products and services found under https://leangears.com . This is the privacy policy for leanGears and its products. This privacy policy applies to all information collected to you by leanGears LLC, regardless of how it is collected and stored. It includes the type of information collected when you interact with our services, how can it be processed, how can you control the disclosure of your information and how your information is protected. leanGears LLC is the data controller of this information as mentioned in GDPR (EU General Data Protection Policy) and we decide how and why the information you provide to us is processed. This policy explains how we use this information in providing quality services. This policy may be amended or updated from time to time to reflect changes on how we process the information provided and based on changes in law. Read the policy carefully and from time to time to review any changes that we make.

2. Categories of Information

We may process your personal details (Name), contact details (email address), purchase details (payments, product license information), information about your interactions with us and any views, opinions and feedback you provide to us. Personal information referred in this document means information about an individual or from which any individual is directly or indirectly identifiable. Process, Processing, Processed means anything that is done with any Personal Information, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation use, disclosure by transmission, making it available, alignment, restriction, destruction or deletion. All this activity takes place in US and India. As mentioned in the previous section, leanGears LLC is a company registered in Delaware, USA. However, the server that runs leanGears are with Amazon Web Services (AWS) and are in US and India. Even if you reside outside US and India, your personal information will still be transferred to the servers that reside in US. The information stored in US and India will comply with the privacy standards of both these countries. leanGears will transfer your personal data on demand to other countries where it does business. We may process the below personal information about you:

• Personal details, including but not limited to: Your name, your login credentials (username/password) and your Organization name.
• Contact details limited to email address.
• Consent records and conversations including but not limited to: records of any consents you may have given with date and time, means of consent and any conversation through email and other means.
• Purchase and payment details, including but not limited to: Subscription plan and Email.
• Views and opinions, including but not limited to: any views and opinions that you or others choose to send us, or publicly post about us on social media platforms or inside the product.

Under certain circumstances and depending on applicable laws, some of this other information may constitute personal information. Personal Information together with Other Information in hereafter referred to as User Information.

3. Sensitive Personal Information

We do not collect or otherwise process your sensitive personal information. Where we need to process your sensitive personal information for legitimate purpose, we do so in accordance with applicable law. The services are not intended for use by children. We do not collect or otherwise process personal information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may deemed to be sensitive under GDPR in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Information under GDPR or any other regulation, we would rely on one of the following legal bases:

• Compliance with applicable law: We may process your Sensitive Personal Information where the processing is required or permitted by applicable law;
• Detection and prevention of crime: We may process your Sensitive Personal Information where the processing is necessary for the detection or prevention of crime (including the prevention of fraud);
• Establishment, excise or defence of legal rights: We may process your Sensitive Personal Information where the processing is necessary for the establishment, exercise or defence of legal rights;
• Consent: We may process your Sensitive Personal Information where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Information. You must be at least sixteen years of age, or the age of majority in the jurisdiction where you reside if that age is greater than 16, to use the product and services. If a parent or guardian becomes aware that his or her child have provided us with personally identifiable information without their consent, he or she should contact us at gearmeup@leanGears.com. We do not knowingly collect personally identifiable information from children under 16. If we become aware that a child under 16 has provided us with personally identifiable information, we will delete such information from our database. leanGears reserves the right to refuse service to anyone at any time without for any reason.

4. How we collect information

We may collect or obtain user information from you: directly from you (such us when you contact us); in the course of our relationship with you (for example, if you make a purchase, free or otherwise); when you make your Personal Information public (for example, if you make public posts about us on social media); when you use our products; visit our services; when you register to any of our products. We may also receive User Information about you from third parties (such as from our social network, partners and resellers). We may also create User Information about you, such as records of your interaction with us. leanGears is not responsible for Personal Information you volunteer about yourself in public areas of the services, such as Social Media forums. This policy does not cover the practices of third parties who may provide information about you to leanGears. Collection of User Information: We may collect User Information about you from the following sources:

• Data you provide: We may obtain your Personal Information when you provided it to us across our Services (for example, where you sign up for emails, newsletters; create a profile or account on any part of the services; participate in surveys; contact us via email, telephone or by other means; or purchase subscriptions, etc.).
• Business Relationship Data: We may collect or obtain your Personal Information in the ordinary course of our relationship with you (for example, if you make a purchase from us).
• Data you make public: We may collect or obtain your personal information that you clearly choose to make public, including via social media (for example, we may collect information from your social media profile(s), if you make public post about us).
• Service data: We may collect or obtain your Personal Information when you visit, download, use or register to use any part of our service.
• Content and advertising information: if you choose to interact with any third-party content or advertising on the channels, we may receive User Information about you from the relevant third party.
• Third Party information: We may collect or obtain your Personal Information from service providers and third parties who provide it to us and combine such information with information we have collected about you. This may include channels such as social network sites or services (Facebook, Twitter, LinkedIn etc.)

Please note that leanGears is not responsible for the information you volunteer about yourself in the discussions in certain public areas of the services or information that you choose to make public in your member profile or other areas of the services that allow users to upload or post content. You can change your publicly available information at any time via your profile page. This privacy policy does not cover the practices of third parties, including those that may disclose information to leanGears. We are not responsible for the accuracy of any information provided by third parties or third-party policies or practices. We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal administrative purpose and analysis. We may also combine data you have provided to us with data obtained from third parties such as social networks.

5.Purpose of processing Information

We may process User Information for the following purposes:

• Providing the service to you
• Communicating with you
• Advertising to you on the channels
• Analysing usage reports
• Purchase activity across product lines
• Marketing our services to prospects
• Managing our IT Systems
• Financial Management
• Conducting Surveys
• Ensuring Security of our systems
• Conducting investigations wherever necessary
• Compliance with law The purpose which we may process User Information, subject to applicable law, include:
• leanGears services:
  1. Offering Promotions and giveaways
  2. processing of your payments for purchases and subscriptions
  3. Management of your account
  4. Offering promotions and marketing information
  5. customer support and relationship management.
• Improving the services: Operating and managing the services for you; providing personalized contents; communicating and interacting via services; identifying issues, planning improvements; creating new services; and notifying the changes in services.
• Surveys: engaging with you for obtaining your views, opinions and feedback on our services.
• Communications: communicating with you via any means (emails, calls or social media) regarding information which you may be interested, ensuring that such communications are provided in compliance with applicable laws; maintaining and updating your contact information wherever appropriate; and obtaining your prior-consent where required.
• Advertising: Providing advertising based on your interests and interactions with the services and channels, including user information to serve you advertisement of the channels, both within the service and on channels.
• Audience Engagement: identification and development of audience engagement, advertisement and promotional strategies on various platforms and channels, both within service and on channels.
• User engagement and purchases: tracking purchase of traffic and activity across the service and on Channels and provision on analytics.
• Fraud Prevention: Our service may use third party fraud prevention software designed to prevent your credit card and other Personal Information from being used in a fraudulent purchase through the service. Such software may work by analysing your Behavior anddetecting patterns that indicate fraud and may also involve a third party tracking your activity over time and over a network of sites.
• IT Administration: Administration of leanGears’s IT systems; network and device administration; network and device security; implementing data security and information system policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity and compliance with legal requirements.
• Security: electronic security measures to help mitigate the risk and provide the ability to identify and rectify a security incident.
• Financial Management: General business and financial management purposes, including: economic, financial and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate audit; and compliance with legal requirements.
• Investigations: Detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
• Legal proceedings: establishing, exercising and defending legal rights.
• Legal compliance: Subject to applicable law, we reserve the right to release information concerning any user of Services when we have grounds to believe that user in violation of our Terms and Conditions or other published guidelines or has engaged in any illegal activity, and to release information in response to court and governmental orders, other requests from government entities, civil subpoenas, discovery requests and otherwise as required by law or regulatory obligations. We may also release information about users when we believe in good faith that such release is in the interest of protecting rights, property, safety or security of leanGears, any of our users or the public, or to respond to an emergency.

6. Direct Marketing

We may process your User Information to contact you via email or other methods of communication to provide you with information regarding the services that may be of interest to you. We may send information regarding the services, upcoming promotions and or other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law. You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any such emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for.

7. Cookies and related technologies

We may Process your User Information by placing or reading Cookies and similar technologies on the Services. Certain technologies enable us to assign a unique identifier to you and relate information about your use of the Services to Other Information about you. We and our partners also use these technologies to analyse trends; administer the Services; collect and store information such as user settings and anonymous browser identifiers; supplement to our server logs and other methods of traffic and response measurement; gather demographic information about our user base; and to improve our understanding of traffic on the Services. Certain third parties may collect information about you for online behavioral advertising purposes for you to receive relevant interest-based advertising on the Services and on other websites, platforms and media channels. We may use Online Data as well as other User Information to send you online behavioral ads we believe are more relevant to your interests. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on the Services. We and our partners (including but not limited to e-commerce partners, affiliates, and analytics providers) also may use technologies such as pixel tags, IP addresses, and Local Storage such as HTML5 to analyse trends; administer the Services; collect and store information such as user settings and anonymous browser identifiers; supplement our server logs and other methods of traffic and response measurement; track users’ location and movements around the Services; gather demographic information about our user base; and to improve our understanding of traffic on the Services and visitor behaviour. We may receive reports based on the use of these technologies by these third-party companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing Local Storage. These third parties may use Online Data as well as another User Information to send you OBA. For example, if you read an article about a subject on the Services, the third party may use cookies to later serve you an advertisement for a product or service related to the viewed article. These third-party vendors may connect information about pages you visit on the Services with information about pages you visit on other Channels and show you advertising based on this combined information. These advertisements may appear when you are visiting a different section of the Services or on another Channel. The specific providers we use for OBA are subject to change. Currently, we do NOT use any such services. If we do, we will list them here or somewhere relevant on our Site.

8. Lawful processing of Personal Information

We may process your User information, where: you have given your consent; the Processing is necessary for a contract between you and us; the Processing is required by applicable law; the Processing is necessary to protect the vital interests of any individual; or where we have a legitimate interest in the Processing. In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

• Consent: We may Process your User Information where we have obtained your prior, express consent to the Processing;
• Contractual necessity: We may Process your User Information where the Processing is necessary in connection with any contract that you may enter with us;
• Compliance with applicable law: We may Process your User Information where the Processing is required by applicable law;
• Vital interests: We may Process your User Information where the Processing is necessary to protect the vital interests of any individual; or
• Legitimate interests: We may Process your User Information where we have a legitimate interest in carrying out the Processing for managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedom.

9.Information disclosed to Third Parties

We may disclose your User Information to: legal and regulatory authorities; our external advisors; parties who Process User Information on our behalf; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third-party providers of advertising, plugins or content used on the Services. We may disclose your User Information to other entities within the Company group, for legitimate business purposes, in accordance with applicable law. In addition, we may disclose your User information to:

• Legal and regulatory authorities, upon request, or for the purposes of any actual or suspected breach of applicable law or regulation;
• Outside personal advisors (such as accountants, auditors or lawyers), subject to binding contractual obligations of confidentiality;
• Third party processors (such as analytic providers, data processors, etc,) located anywhere in the world, subject to the requirements mentioned in this policy;
• Any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;
• Any relevant party for prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against the prevention of threats to public security;
• Any relevant third party acquire(s), if we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
• Any sponsors of promotional giveaways. The registration data for such event is to be used by us as part of User Information, and may be shared with the sponsor and others, subject to this policy and Sponsor’s privacy policy. We may also share your information with third party vendors involved in the administration of such events. For promotional giveaways, please read the terms and conditions carefully before you submit your information;
• To third parties whose practices are not covered by this Privacy Policy.

Certain functionalities on the service may permit interactions that you initiate between the Service and certain third-party services. Examples include "liking" or "sharing" content over social media platforms through our Service. If you use third party features, both leanGears and the third party may have access to certain information about you and your use of our Service and the third-party service. For example, if you post information on a third-party service that references our services (such as Hashtag), your post may be used on or in connection with our Service or that third-party service. We are not responsible for the practices employed by websites linked to or from the Service, nor the information or content contained therein, or any information third parties obtain through your use of Third Party features. Please remember that when you use a link to go from the service to another website, our privacy policy is no longer in effect. Your browsing and interaction on any other website, is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding. With respect to surveys, should leanGears choose to undertake them, if responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise, we will disclose only aggregate information regarding its user’s responses in surveys to the other participants in the survey. Where survey allows users to write comments, and where leanGears advises users of the possibility of such disclosure at the time they take the survey, leanGears reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.

Some of our advertisers may use third party advertising service companies to serve advertisements, for OBA or otherwise, and perform related services when you interact with the Channels. Often, these third-party advertising companies employ cookies and other technologies to measure the effectiveness of website, app and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Services. We may also engage third party providers to assist with the segmentation of this data. We may engage third party providers to assist with the collection, storage and segmentation of Online Data. Such providers are required to maintain the confidentiality of this information. These third-party providers may collect User Information from our Services for their own purposes, such as to monitor fraud around the web. If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to:

1. only Process the User Information in accordance with our prior written instructions; and
2. use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law. The Services contain links to other sites or partners whose information practices may be different from ours. You should consult the privacy policy of these third parties to learn how your privacy is protected.

10. International Transfers of Information

We may transfer your Personal Information to recipients in other countries. Because of the international nature of our business, we may need to transfer your User Information within the leanGears products, services and to third parties as noted in the section above, in connection with the purposes set out in this Policy. For this reason, we may transfer your User Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. leanGears is a US registered company and so may not participate in the E.U. Privacy Shield Framework. However, leanGears is committed to the principles upon which the framework is founded. In certain situations, leanGears may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you are a European individual with a privacy related complaint, concern or question about leanGears’ privacy practices, please contact us by writing to gearmeup@leanGears.com and we will respond within a reasonable timeframe after receiving your request. Where we transfer your Personal Information from the EEA to recipients located outside the EEA who are not in a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Information, we do so based on standard contractual clauses. Please note that when you transfer any Personal Information directly to a Company entity established outside the EEA, we are not responsible for that transfer of your Personal Information. We will nevertheless Process your Personal Information, from the point at which we receive the data, in accordance with the provisions of this Privacy Policy.

11. Data Security

We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any Personal Information that you send to us is sent securely. We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances, we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties. Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us is sent securely.

12. Data Accuracy

We take every reasonable step to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.

13. Data Minimization

We take every reasonable step to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.

14. Data Retention

We take every reasonable step to ensure that your User Information is only retained for as long as it is needed. We take every reasonable step to ensure that your User Information is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfil a legitimate business need.

15. Controlling Personal User Information

You can directly take steps to change your preferences for newsletters and other Online Behavioral Advertising as outlined in this section. If you are an EU resident, you may have certain rights including: the right not to provide your Personal Information to us; the right of access to your Personal Information; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Information; the right to object to the Processing of your Personal Information; the right to have your Personal Information transferred to another controller; the right to withdraw consent; and the right to lodge complaints with supervisory authorities. We may require proof of or need to verify your identity before we can give effect to these rights. You may directly take steps to change your preferences as follows: You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive, or in your account settings. Please allow five to ten business days for changes to take effect. On some parts of the Service, member service-related communications are an integral part of such Services to which you subscribe, and you may continue to receive emails as part of that portion of the Services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided. We may send you push notifications from time-to-time to update you about any events or promotions that we may be running. Under those circumstances, we will provide you with the ability to turn these off by adjusting the permissions in your mobile device. Please note that opting out is limited to the device used and will not affect subsequent subscriptions or non-promotional communications, such as those about your account, transactions, servicing or leanGears’ ongoing business relations. There are a variety of tracking technologies that may be included in mobile applications. These are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier or other identifiers such as Ad IDs to associate app user activity to an app and to track user activity across apps. You can stop all collection of information via our mobile applications by uninstalling them. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device (which is usually located in the Settings area of your device). If we offer you the opportunity to link your leanGears account with certain third-party services, you will be provided with the ability to unlink your accounts at any time by visiting your leanGears account settings. Please note that unlinking your accounts will not affect any information previously shared through the linking, and leanGears may continue to use and share that information in accordance with this Privacy Policy. leanGears is not responsible for any third-party data practices, and we recommend that you carefully review their online policies. You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you turn off, purge, or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all the features, functions, or services available on the Services. For California Residents: in accordance with the California Online Privacy Protection Act, we may collect Personal Information about your online activities when you use the Services. While we give our users many avenues to opt out of providing Personal Information, we do not respond to Web browsers do not track signals. California’s Shine the Light law, Civil Code Section 1798.83, permits our users who are California residents to periodically request and obtain certain information about any Personal Information disclosed to third parties for direct marketing purposes. If you are a California resident and wish to make such a request or if you wish for us to refrain from gathering your Personal Information, please submit your request in writing to the contact details set out in Section 17 below. For EU Residents: GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases). Requests should be submitted by contacting us (using the contact instructions in Section 17 below). If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.

16. Terms and Conditions

For more information concerning your use of the Services, please visit the leanGears Terms and Conditions, which are incorporated by reference into this Privacy Policy. We recommend that you review our Terms and Conditions regularly, to review any changes, we might make from time to time.

17. Contact Details

If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of User Information carried out by us, or on our behalf, please contact us by email at gearmeup@leanGears.com or write to us at the following address:

leanGears LLC,

16192 Coastal Hwy, Lewes, Delaware, USA 19958

18. Changes in Privacy Policy

We may change this Privacy Policy from time to time, and all changes will be effective at the time we post them. If we believe there is a significant change to this Privacy Policy or our data collection and use practices, we will indicate on our websites that our Privacy Policy has changed prior to the change becoming effective. The then-posted version of the Privacy Policy supersedes all prior versions. Your continued access to or use of any of the Services shall be deemed your acceptance of the Privacy Policy. We urge you to come back to this web page and review this Privacy Policy regularly so that you remain aware of the terms and conditions that apply to you.

19. Third-Party Services

This is a list of third-party services we use in accordance with our legitimate interests, including internal administrative purposes. This list is subject to change and we recommend you revisit it from time to time. We have provided links, so you can easily see what these services do and read the privacy policies they provide.

• Amazon Web Services (AWS) - Privacy Policy
• Alexa – Privacy Policy
• Google Suite (GSuite)–Privacy Policy
• Slack – Privacy Policy
• Stripe Payment–Privacy Policy

We will also share data with legal authorities and other relevant agencies where required for legitimate purposes, including compliance with the law and prevention of fraud or other legal activities.