私隱政策

We are VaultUp Limited, a company registered in Hong Kong with number 77069021-000-09-24-0 and registered office at Unit 1603, 16F The L. Plaza, 367-375 Queen's Road Central, Sheung Wan, Hong Kong ("we", "us", "our" and "VaultUp"). We provide the Leapfrog platform available here: https://leapfrog-careers.com/ (the "Leapfrog Platform") and certain services and bundles offered via the Leapfrog Platform (the "Leapfrog Services"). This is our Privacy Policy (our "Policy").

We respect your privacy and are committed to protecting your personal data. This Policy is aimed at informing you how we look after your personal data when you use the Leapfrog platform. The Policy also tells you about your privacy rights and how the law protects you and your personal data.

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.

The Leapfrog Platform is not intended for children, and we do not knowingly collect data relating to children.

We keep our Privacy Policy under regular review. If you have any questions about this Policy, please contact us through our Contact Us form.

Section 1: The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, and profile image.
• Contact Data includes email address, billing address, and telephone number.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Leapfrog Platform.
• Profile Data includes your username and password, career information, qualifications, employer details, LinkedIn and social media profiles, CV and job history, and your interests, preferences and feedback.
• Usage Data includes information about how you use the Leapfrog Platform and Leapfrog Services.
• Transaction Data includes details about payments and services you have purchased from or through us.
• Payout Data, if you are a Mentor, includes the identifier of the account you hold with our third-party payment provider (Stripe), whether that account is ready to receive payouts, what the provider still needs from you, and the payouts sent to it. You give your bank account and identity details to Stripe directly, when you set up that account on Stripe's own pages; we do not collect or store them.
• Communications Data includes messages exchanged between Users on the Leapfrog Platform.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Section 2: How Your Personal Data Is Collected

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you register for an account on the Leapfrog Platform, book a Session or Credential Support, participate in any features of the Leapfrog Platform, or contact us.
• Automated technologies or interactions. As you interact with the Leapfrog Platform, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties, such as Google if you choose to link your Google account to the Leapfrog Platform, and, if you are a Mentor, our third-party payment provider (Stripe), which tells us the status of your payout account.

Section 3: If You Fail To Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to the Leapfrog Platform). In this case, we may have to cancel a service or account you have with us, but we will notify you if this is the case at the time.

Section 4: How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where you have provided your consent to us processing your personal data for a specific purpose.

Section 5: Purposes For Which We Will Use Your Personal Data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

• To register you as a new user and manage your account.
• To process and deliver your bookings for Sessions and Credential Support, including managing payments and collecting fees.
• If you are a Mentor, to set up your payout account with our third-party payment provider and to pay you the Fees you have earned, less Commission and any amounts you owe.
• To manage our relationship with you, including notifying you about changes to our Terms or Privacy Policy.
• To enable you to use the features of the Leapfrog Platform, including messaging and profile management.
• To administer and protect our business and the Leapfrog Platform, including troubleshooting, data analysis, testing, system maintenance, and security.
• To deliver relevant content and measure the effectiveness of communications.
• To use data analytics to improve the Leapfrog Platform, services, and user experience.
• To make suggestions and recommendations to you about services that may be of interest to you.

Section 6: Change Of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Section 7: Disclosures Of Your Personal Data

We may share your personal data with the parties set out below for the purposes explained in Sections 4 and 5 above:

• Other Users of the Leapfrog Platform as necessary to facilitate Sessions and Credential Support.
• Service providers acting as processors who provide IT and system administration services.
• Our third-party payment provider (Stripe) to process payments and, for Mentors, to set up payout accounts, verify identity as the law requires of it, and send payouts. Stripe processes that data under its own privacy policy.
• Professional advisers including lawyers, bankers, auditors and insurers.
• Regulators and other authorities who require reporting of processing activities in certain circumstances.

We may also share personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We, and many of our external third parties, are based outside Hong Kong so our processing of your personal data will involve a transfer of data outside Hong Kong. Whenever we transfer your personal data out of Hong Kong, we ensure a similar degree of protection is afforded to it by:

• ensuring we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
• putting in place specific contracts approved for use in Hong Kong which give personal data the same protection it has in Hong Kong.

Section 8: Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Section 9: Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

When you delete your account from Settings, you are signed out, you can no longer sign in, and your upcoming sessions are cancelled. We keep the account for 30 days after that, so that bookings, payments and any question about them can still be resolved. After 30 days we erase your personal data from it: your name, email address, password, profile details, profile photo, CV and uploaded documents.

We keep the records of the sessions you booked or held and of the payments made for them, with your name removed, because we need them for accounting and tax purposes and because they are also the records of the other person in the session. Messages you exchanged and reviews you wrote are kept in the same way, attributed to a deleted user.

Learners can also deactivate their account instead of deleting it. Nothing is erased then: your data is kept, and signing in again reactivates the account.

You can also ask us to delete your data: see Section 10 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Section 10: Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. A data subject shall be entitled to:

• ascertain whether a data user holds personal data of which he is the data subject;
• request access to personal data within a reasonable time, at a fee (if any) that is not excessive, in a reasonable manner, and in a form that is intelligible;
• be given reasons if a request for access is refused;
• object to a refusal of access;
• request the correction of personal data;
• be given reasons if a request for correction is refused;
• object to a refusal of correction; and
• request the deletion of personal data that is no longer needed for the purpose it was collected for. Deleting your account from Settings does this for you, as described in Section 9.

If you wish to exercise any of the rights set out above, please contact us through our Contact Us form. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.