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.
Policy may be amended or revised from time to time by Leap, and the latest
version will be available at privacy.
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
(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
(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
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
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
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
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
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
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
(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
#207 - 280 Nelson Street
Vancouver, BC V6B 2E2