This privacy policy (this "Policy") describes the practices of NuCaptcha Inc. ("Leap") with respect to its collection, use, storage and disclosure of personal information from its customers and from users of its various services, all as set out below.

 

Please note that, consistent with the Terms of Use, this Policy may be amended or revised from time to time by Leap, and the latest version will be available at privacy.

 

1. Introduction

Leap respects and upholds individual's right to privacy and the protection of personal information.

 

The Personal Information Protection and Electronic Documents Act (Canada), or similar privacy legislation applicable in your Province ("Applicable Privacy Legislation"), regulates the way private sector organizations operating in Canada may collect, use, keep, secure and disclose personal information. "Personal information" means all information about an identifiable individual.

 

As required by Applicable Privacy Legislation, Leap has appointed a Privacy Officer who is responsible for compliance with this Privacy Policy and Applicable Privacy Legislation. Information on how to contact the Privacy Officer can be found below.

 

2. Collection and Use of Personal Information

Leap offers a variety of services (the "Services") including public access to the Leap website (the "Website") and access to Leap's web-enabled security platform software applications (the "Software"). For greater certainty, Leap's "NuCaptcha" software product is included in the definition of Software.

 

Leap collects and uses personal information from (a) individuals who have the right to use the Software on the Internet in connection with authenticating online human interactions and who have set up an account to access the Services, ("Customers"), (b) individual users of the Customers' websites who utilize the Services to verify their online human interactions ("Users"), and (c) as well as individuals who otherwise visit the Website

 

Generally, Leap will collect personal information as necessary to operate, provide and maintain the Services. In furtherance of this, the following types of information may be collected through your use of the Services:

 

(a) if you request information via the Website, Leap may collect personal information (e.g. name, address, company, contact information) to enable a direct response to your request;

 

(b) if you subscribe to or purchase a license to use the Software, Leap may collect personal information (e.g. name, address, contact information, credit card number) to verify your identity and to charge you for the license;

 

(c) when you use the Software, Leap may collect personal information on individuals using the Software on your website;

 

(d) if you are a Customer, Leap will collect personal information from you to verify your identity and to administer your account;

 

(e) when you login to your Customer account, Leap will collect personal information from you to verify your identity and to prevent unauthorized access to the Services;

 

(f) if you request support, additional information about the Software, or if you request a demonstration version of the Software, Leap may collect personal information from you so that Leap can contact you and provide you with these services;

 

(g) in using the Services, Leap may collect data to provide the Services to you, including information concerning traffic on, and use of, the Services for statistical analysis in order to improve the Services; and

 

(h) Leap may collect personal information to inform you of product updates, special offers, new services and products, partners, promotions, events and updated information that may be pertinent to you and to generally keep you informed about Leap and its customers via newsletters.

 

The personal information that Leap may collect from you for the purposes identified above may include, but is not limited to: name, email address, address, telephone number, facsimile number, or other contact information; credit card number and other billing information; a password you choose for your account, and any secret question(s) and answer(s) in case you forget your password and any personal information you choose to post to or enter into your Customer account; information about your use of the Software including about any websites, links and referrals; and any other such information as is required by the Leap for the purposes of managing your use of the Services. Leap may also collect data concerning traffic on, and use of, the Services and may include non-personal data such as, IP address, page tags, user site performance, and other such information required for logfile analysis and web analytical purposes.

 

A "cookie" is a small text file sent to your browser to store information. Leap and its Customers use session ID and persistent cookies to keep track of your interactions with the Services and the websites using them. These cookies may be removed by you through your Internet browser; see the product documentation for more information. Leap does not control the use of cookies on websites incorporating the Services other than those owned and managed by Leap itself; accordingly, we are not responsible for any personal information collected through such cookies.

 

In order to provide the Services, Leap will use, process and store any information (which may include personal information) that you may post to or enter into your Customer account.

 

3. Sharing of Personal Information

The only circumstance under which Leap may disclose your personal information to a third party is for the fulfillment of any of the purposes identified above, as required by law or as authorized by Applicable Privacy Legislation.

 

In order to provide the Services, Leap may hire other companies or contractors to provide limited services on its behalf, for example to provide Services hosting services, and support with respect to the Services. Such service providers are only permitted access to and/or use personal information necessary to provide the service. They are required to protect your personal information and must agree to adhere to this Policy.

 

If you interact with a website that uses the Service, any data or personal information you submit may be accessed, used or otherwise processed by other individuals, groups or organizations, that are outside of Leap's control. The Customer that has engaged us to provide certain web security measures on their website, and has control over all information submitted to that website. If you are concerned about who may access personal information you submit to such a website you should contact the owner thereof.

 

Leap limits the personal information it collects and uses to that which is necessary to fulfill the purposes identified above. Leap will not collect, sell, distribute or use personal information for any other purposes without your further consent, as required by law or as authorized by Applicable Privacy Legislation.

 

4. Retention of Personal Information

Leap will keep personal information used to make a decision that directly affects an individual for at least one year after it makes such a decision. Subject to this one-year retention requirement, Leap will only retain personal information for as long as necessary to fulfill the purposes identified in this Policy or as long as required for legal or business purposes.

 

5. Security of Personal Information

Leap has implemented security measures to protect your data from unauthorized access, loss or theft, modification and other threats. Personal Information is protected by security safeguards that are appropriate to the sensitivity level of the information. Our employees, affiliates and other third party parties providing Services on our behalf are required to sign contracts obliging them to protect the privacy and confidentiality of personal information provided to them, and to observe the intent of this agreement, in order to perform their function. This obligation remains in effect even after employees, affiliates and other third party parties leave the employ of or association with Leap. Appropriate controls are in place over computer systems and these controls are reviewed on an ongoing basis to ensure compliance with our security and privacy policy. Except as is required by law, when personal information is no longer required, the documentation records are destroyed.

 

6. Legal Disclosure

Leap may also disclose personal information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our policies or may be causing injury to or interference with (either intentionally or unintentionally) our rights, property, users, or anyone else that could be harmed by such activities. Leap may disclose or access personal information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain service, and improve our Services.

 

7. Requests for Access to and Correction of Personal Information

Applicable Privacy Legislation allows any individual the right to access and/or request the correction of errors or omissions in his or her personal information that is in the custody or under the control of Leap. Leap's Privacy Officer will assist the individual with the access request. This includes:

 

(a) identification of personal information under Leap's custody or control;

 

(b) information about how personal information under Leap's control may be or has been used by Leap; and

 

(c) the names of any individuals and organizations to which the individual's personal information has been disclosed.

 

Leap will respond to requests within the time allowed by Applicable Privacy Legislation and will make every effort to respond as accurately and completely as possible.

 

In certain exceptional circumstances, Leap may not be able to provide access to certain personal information it holds about an individual. If access cannot be provided, Leap will notify the individual making the request, in writing, of the reasons for the refusal.

 

8. Concerns or Questions regarding the Leap's Compliance

Questions or concerns regarding Leap's compliance with this policy may be directed to the Privacy Officer:

 

Michel Giasson, Privacy Officer

NuCaptcha Inc.

#207 - 280 Nelson Street

Vancouver, BC V6B 2E2

Canada

michel.giasson@nucaptcha.com

604-862-5161