UNITED STATES OF AMERICA
Effective Date January 15, 2015, updated on August 03, 2020
Leeward is a Software Development and IT Staff Augmentation firm that provides small businesses with human resources (namely software developers) to construct web, mobile, desktop, cloud, and IOT software applications.
We understand that when you use Leeward’s platform you are placing your trust in us to handle your data appropriately, including the personal information of you and your end users. That is why we take a “No Nonsense” approach to data protection.
Part of our “No Nonsense” approach is to make sure that you, the customer, have information about how we process personal information in connection with your use of our products and services, including our website. We want to enable you to make informed decisions about your personal information when building your software applications on Leeward’s platform. We also want to provide you with relevant information to help your end users make informed decisions about their personal information when they use your software applications built on Leeward’s platform.
If you have read this document in its entirety and you still have more questions or concerns about how we’re processing personal information, or you would like to know more about how to exercise your rights; You can contact our Privacy Team in the Office of the Data Protection Officer by either emailing us at firstname.lastname@example.org or, by writing to us at:
17901 Von Karman
Leeward processes two broad categories of personal information when you use our products and services:
Your personal information as a customer (or potential customer) of Leeward’s services — information that we refer to as Customer Account Data, and the personal information of your Professional Temporary Employees (“PTE’s”) that use or may be assigned to your projects that you’ve subscribed to build via Leeward’s platform. This category contains both your Customer Usage Data (e.g., communications metadata) and your Customer Content (e.g., the contracts, records management, and time-tracking of work and communications).
Leeward processes these categories of personal information differently because the direct relationship we have with you, our customer, is different than the relationship we have with PTE’s.
2. How Leeward Processes Your Personal Information
Data protection laws and privacy laws in certain jurisdictions, like the European Economic Area (EEA), differentiate between “controllers” and “processors” of personal information. A controller decides why and how to process personal information.
A processor processes personal information on behalf of a controller based on the controller’s instructions. When Leeward processes your Customer Account Data, the Leeward entity with whom you are contracting is acting as a controller.
Broadly speaking, we use Customer Account Data to further our legitimate interests to: understand who our customers and potential customers are and their interests in Leeward’s product and services, manage our relationship with you and other customers, carry out core business operations such as accounting, filing taxes, and fulfilling regulatory obligations and help detect, prevent, or investigate security incidents, fraud and other abuse and/or misuse of our products and services.
3. What Personal Information Leeward collects
The following is a brief summary of the categories of personal information that might be found in the Customer Account Data and Customer Usage Data that we collect from our customers and their end users, so you can know at a glance what we’re talking about.
We collect and process your personal information:
When you visit a Leeward public-facing website like www.leewardx.com, sign up for a Leeward event, or make a request to receive information about Leeward or our products, like a Leeward whitepaper or a newsletter; When you contact our Sales Team or Customer Support Team; and When you sign up for a Leeward account and use our products and services.
We call this personal information Customer Account Data. We also collect Customer Usage Data from you when you send or receive communications through your use of our services.
When you visit our website, sign up for a Leeward event or request more information about Leeward, we collect information automatically using tracking technologies, like cookies, and through web forms where you type in your information. We collect this information to provide you with what you request through the web form, to learn more about who is interested in our products and services, and to improve navigation experience on our pages.
When You Communicate with Our Sales or Customer Support Teams, you may share personal information, like your contact information, with a member of our Sales or Customer Support Team when you communicate with them. We keep a record of this interaction.
When you sign up for an account with us, we ask for certain information like your contact details and billing information so we can communicate with you and so you can pay for our products and services. We also collect some information automatically, like your IP address when you log in to your account. We use this to understand who is using our services and how, and to detect, prevent and investigate fraud, abuse, or security incidents.
We may collect information about you, as our customer, from publicly available sources so we can understand our customer base better.
4. How Long We Store Your Customer Account Data
Leeward will store your Customer Account Data as long as needed to provide you with our services and to operate our business. If you ask Leeward to delete specific personal information from your Customer Account Data (see ‘How To Make Choices About Your Customer Account Data’ below), we will honor this request unless deleting that information prevents us from carrying out necessary business functions, like billing for our services, calculating taxes, or conducting required audits.
5. How to Make Choices About Your Customer Account Data
You can make various choices about your Customer Account Data through the account portal, such as accessing it, correcting it, deleting it, or updating your choices about how it is used, when you log into your Leeward account or through the marketing preferences center. Any other requests about your data you cannot make through these self-service tools, you can request by emailing email@example.com, or by directly contacting Customer Support.
6. California Consumer Access and Deletion Rights
For those customers that would like more information about our use of Customer Account Data or Customer Usage Data, you have the ability to request:
- that we provide details about the categories of personal information that we collect about you, including how we collect and share it;
- that we provide you access to the personal information we collect about you; and
- that we delete the personal information we have about you.
Please be aware that when you ask us for these things, we will take steps to verify that you are authorized to make the request.
7. When and Why We Share Your Personal Information
We do not sell or allow your Customer Account Data to be used by third parties for their own marketing purposes, unless you ask us to do this or give us your consent to do this. Further, we do not sell your end users’ personal information. We also do not share it with third parties for their own marketing or other purposes, unless you instruct us to do so.
You can read more in our CCPA Notice.
8. Transfers of Personal Information Out of the EEA and Switzerland
When you use our account portal, or our other products and services, personal information of you and your end users processed by Leeward may be transferred to the United States, where our primary processing facilities are located, and possibly to other countries where we or our service providers operate. These transfers will often be made in connection with routing your communications in the most efficient way.
Leeward employs appropriate safeguards for cross-border transfers of personal data, as required by applicable local law, including Binding Corporate Rules and the EU–U.S. Privacy Shield and Swiss–U.S. Privacy Shield Frameworks.
9. Automated Decision Making
Leeward may use automated decision making using a variety of signals derived from account activity to help identify and suspend accounts sending spam or engaged in other abusive or fraudulent activity. Holders of accounts suspended under these circumstances are notified of the suspension and given an opportunity to request human review of the suspension decision.
10. Handling disputes relating to our data protection practices
We hope we can resolve any disputes relating to our data protection practices between us. You can raise your concern or dispute by emailing our Privacy Team at firstname.lastname@example.org or by writing to us at:
Leeward Digital, LLC
17901 Von Karman Suite: 600
Irvine, California, USA – 92614
For individuals in the EEA, you have additional rights to make a complaint to a competent data protection authority or commence proceedings in a court of competent jurisdiction in accordance with applicable data protection laws.
11. How We Secure Personal Information
We use appropriate security measures to protect the security of your personal information both online and offline. These measures vary based on the sensitivity of the personal information we collect, process and store and the current state of technology. We also take measures to ensure service providers that process personal data on our behalf also have appropriate security controls in place.
As a matter of top priority at Leeward, we take data security very seriously. For this reason, we use a uniquely high level of encryption technology within and throughout our digital and online platforms. For more information, please see our Security Overview.
12. Other Information You May Find Useful
For additional information about our privacy practices, such as how we handle certain types of data like children’s data or protected health information, how we handle do-not-track signals, what to expect if we make changes to our notice, and the legal bases for processing personal information; please contact us at email@example.com.
13. Your attestation
WHEN YOU SIGN UP FOR SERVICES, YOU WILL BE ELECTRONICALLY SIGNING THIS DOCUMENT WITH YOUR FULL NAME, EMAIL ADDRESS, AND IP-ADDRESS. IF YOU DO NOT AGREE WITH THESE TERMS, THEN DO NOT USE THE SERVICES.