1. Introduction
   This Privacy Policy explains how Leader Alpha uses the Client’s Personal Data. Leader Alpha provides access and services through its platform via software, Application Program Interface (API), technologies, products, and functionalities (hereafter “the Service”). In order to provide the Service, improve it, and abide by the laws in the jurisdiction that Leader Alpha operates, Leader Alpha needs to collect and store personal information about the Client. Leader Alpha does not disclose any personal information about the Client to any non-affiliated third parties, except as described below.
   Leader Alpha has the right to update this Privacy Policy at any time by posting its amended version on this Website and by indicating the effective data of the amended version.
   Leader Alpha will announce about any changes in this Privacy Policy via email.
2. Definition
   “Personal Data” means any information relating to an identifiable natural person (i.e., an individual human being), such as a name, an ID number, location data, an online identifier. Personal Data also refers to one or more factors specific to the physical, economic, cultural, or social identity of the Client as a natural person.
3. Collection of Personal Data
   Leader Alpha collects, processes, and stores Personal Data gathered via the Client’s use of the Service or where the Client has given consent.
   This Personal Data may include contact details, copies of identification documentation provided by the Client or derived from publicly accessible databases, and a government identification number. Information about devices and internet service, such as IP address and a MAC number, is also classified as Personal Data. Leader Alpha gathers Persona Data during the registration and onboarding processes, regardless whether they are completed, incomplete, or abandoned.
   Leader Alpha gathers, uses, stores, and transfers Personal Data, which includes the following:
   • Operating within the European Economic Area (“EEA”).
   • Leader Alpha collects, stores, and processes Personal Data in accordance with the Best Practices of Data Collection in the European Union (EU), in addition to the General Data Protection Regulation (GDPR) – EU Regulation 679/2016.
   • Types of Clients defined in Appendix A.
4. Collection and Storing of Data Outside the EU
   As mentioned above, Leader Alpha may collect Personal Data from the Client located in the Economic European Area (EEA). To facilitate the services that it provides to clients located in the EEA, Leader Alpha requests explicit consent to transfer Personal Data from the EEA to outside the area. If the Client is an individual located in the EEA and declines to consent to such transfer, the Client will not be able to use Leader Alpha’s services.
5. Personal Data Usage
   Leader Alpha uses Personal Data to communicate with the Client and to administer, deliver, improve, and personalize the Service. Leader Alpha may also generate generic data out of any Personal Data collected and use it for its purposes.
   Leader Alpha may also use such data to communicate with the Client in relation to its other products and services or in relation to services and products offered by its partners. Leader Alpha does not share Personal Data with third parties (except partners connected to its services), save those cases when the Client has given consent or other cases defined below.
6. Cases When Personal Data Can be Shared with Third Parties
   Leader Alpha may share Personal Data with third parties, when it considers that sharing it is necessary to enforce the terms of its Service.
   Leader Alpha may share Personal Data to comply with government agencies, including regulators, law enforcement, and justice departments.
   Personal Data may be sent to third parties providing services to Leader Alpha, among which are administration or technical services.
   i Leader Alpha shares Personal Data in connection with the sale or transfer of its business or any part thereof.
   Leader Alpha has implemented international standards to prevent money laundering, terrorist financing, circumventing trade, and economic sanctions. It will implement final rules and regulations when effective and will require checking its clients’ Personal Data. This may include the use of data supplied by third-parties or service providers which Leader Alpha will cross-reference with the Client’s Personal Data.
7. Storage of Personal Data
   The Personal Data that Leader Alpha collects from the Client may be transferred to and stored at any location outside the European Union (EU).
   Personal Data may be processed by employees operating outside of the European Union who work for Leader Alpha or its suppliers. By submitting the Client’s Personal Data, the Client agrees to this transfer, storing, or processing. This does not apply to clients located in the EEA, as detailed above.
   Personal Data provided to Leader Alpha is stored on its own or a third party’s cloud servers.
8. Access to and Correction of Personal Data
   The Client has the right to obtain a copy of Personal Data upon request and ascertain whether the information Leader Alpha holds about the Client is accurate and updated.
   If any part of Personal Data is inaccurate, the Client may request to update the information.
   The Client may also request to delete Personal Data. Leader Alpha, however, may refuse to delete the Client’s Personal Data in certain circumstances, such as compliance with law, or for legal purposes. The Client should contact Leader Alpha for data access, correction, or deletion requests.
   In response to data access, correction, or deletion request, Leader Alpha will verify the Client’s identity to ensure that the Client is legally entitled to make such request. Leader Alpha aims to respond to such requests free of charge. However, it reserves the right to charge the Client a reasonable fee should the request be repetitive or difficult to fulfill.
9. Marketing
   Leader Alpha communicates news, promotions, and information about its products and services. Therefore, it may share Personal Data with third parties for marketing purposes. By using Leader Alpha’s services, the Client agrees to receive such marketing communication.
   The Client may refuse to receive marketing communication from Leader Alpha. In this case, clients need to ask Leader Alpha via email to stop sending them promotional and marketing material.
   The Client does not have the right to opt out from such marketing communications as operational notifications and policy and terms updates.
10. Information Security
    Leader Alpha strives to protect the Client from unauthorized access, alteration, disclosure, or destruction of Personal Data that it collects and stores. Leader Alpha takes various measures to ensure information security, including encryption of the communication with SSL, required two-factor authentication for all sessions, periodic review of Leader Alpha’s Personal Data collection, storage, and processing practices. Leader Alpha also provides restricted access to the Client’s Personal Data on a need-to-know basis for its employees and vendors, who are subject to strict contractual confidentiality obligations.
11. Contacting Leader Alpha about Privacy Concerns
    If clients have questions about this Privacy Policy or the use of Personal Data, they should send Leader Alpha an email with the subject Privacy Request.
12. Changes to Privacy Policy
    Any changes made to Leader Alpha’s Privacy Policy in the future will be posted on this website. The company will also notify the Client about any changes or modifications by sending an email.

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