Updated September 5th, 2024
Description
Leap Technologies Ltd (“Leap”) is committed to protecting and respecting your privacy.
This Privacy Policy (together with our terms and conditions) aims to outline how Leap will collect, process and store end user data when you visit our website, the Leap app or any other Leap service.
As a Parent or Guardian who has signed-up with a Child to use the Leap service, you are giving us explicit prior verifiable consent to collect, use and share their data in the ways specified in this policy. By providing a set of verified contact details for your Child, parents and guardians are explicitly giving their permission for their Child to be contacted.
Introduction
This Privacy Policy describes how Leap (“we”, “us” “our”) manages the Information that you provide to us. This Notice explains how we will use that Information, who we might share it with, and what steps we will take to make sure it stays private and secure. This Notice continues to apply even if your agreement for other products and services with us ends.
This Notice may be updated from time to time and our Website will indicate when the Notice has been updated. You may access the current version of this Notice at any time by clicking on the “Privacy” link on our Website. You are advised to review this Notice periodically for any changes. Changes to this Notice are effective when they are posted on this page. If we have provided you with separate or further information about how we collect and use your Personal Information for a particular product or service, those terms will also apply. If you interact with us in a different context, separate terms might apply to that interaction. Where we provide you with other terms, those terms will always take precedence over this Notice.
There may be times when links on our Website take you to a third party’s website which is not managed or connected to Leap. When this happens, that third party’s own privacy and information policies, which may be different to this Notice, will apply.
Collecting your personal data
In Short: We collect personal information that you provide to us.
When you sign up for a Leap account or use any of the Services provided via our Website or App, we will collect the following Information about you. This Information also helps us to verify who you say you are. This will include Information, such as:
your name, date and place of birth;
contact details, such as your home address, email and phone number;
information about your identity, such as a copy of your Emirates ID document;
information about your right to live in the UAE;
information about your employment, such as your employer name, employment sector and status;
any details you give us through the Leap chat feature on our Website, or Information we collect or generate about you when you get in touch with us, including Information we collect or generate when you use our Services, including any details that are submitted to us via webform, email, the Leap Website or any other digital or paper mechanism;
we may also request to send you push notifications regarding your account with Leap;
We will collect this information to give you Services in a safe and lawful way, and to keep improving them. This may include collecting:
details about services from us and our partners that you express interest in;
details about how you use our Website, App or any other Leap service;
the mobile network and operating system you use so we can analyse how our Website works and fix any issues; and
your location if you’ve authorised tracking, so we can help protect you against fraud;
We may also get Information about you from external sources to help us verify your identity and manage our business risk. This may include engaging with fraud prevention agencies and KYC (Know Your Customer) and AML (Anti Money Laundering) service providers to fulfil our legal duties.
We may when necessary, with your consent or as otherwise permitted by applicable law, process the following categories of sensitive information:
biometric data;
financial data.
Using your information
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
Leap collects and uses your Information for various purposes, and will always have a lawful basis for doing so. We may need to use your Personal Information for an agreement we have with you, or to enter into an agreement with you, to enable us to comply with the law; or we may use your Personal Information for our legitimate interests, or those of a third party (for example, to help product development and marketing, to manage our business risk, financial affairs and to protect our staff, or for security and maintenance).
We may also use your Information to:
facilitate account creation, authentication and otherwise manage user accounts;
develop, operate, provide, maintain, and improve our Services, now and in the future;
keep you up to date on the latest Service announcements, system enhancements, special offers, and other information;
provide and receive information, support, feedback and assistance related to our Services;
identify and analyse usage trends and the preferences of our Users, and to conduct questionnaires and surveys, in order to provide better Services (your completion of these questionnaires will always be voluntary);
contact you for administrative purposes, such as customer support;
send communications, including updates on promotions and events, relating to products and services offered by us;
personalise content and advertising to your preferences; and
protect, investigate, and deter against fraudulent, unauthorised, or illegal activity.
Your rights in relation to your personal information
In Short: You may review, change, or terminate your account at any time.
You have the right to be told how we use your Personal Information. These rights include:
the right to obtain information regarding the processing of your Personal Information and access to the Personal Information which we hold about you (we will notify you of the personal data in our databases, including available details about the origin of the data, the purpose and, where appropriate, the legal basis for the processing and the categories of the processed data, the parties involved in the data collection and the data recipients.
in certain circumstances, the right to withdraw your consent to our processing of your Personal Information. Please note, we may still be entitled to process your Personal Information if we have another legitimate reason for doing so and your withdrawal of consent will not affect the lawfulness of processing taken place previously;
in some circumstances, the right to receive copies of your Personal Information electronically and/or request that we transmit the Personal Information to a third party where this is technically feasible. Please note that this right only applies to Personal Information which you have provided to us;
the right to request that we rectify your Personal Information if it is inaccurate or incomplete;
the right to request that we erase your Personal Information in certain circumstances. Please note that there may be circumstances where you ask us to erase your information but we are legally entitled to retain it;
the right to lodge a complaint with the relevant regulator (for example, in the DIFC, you may lodge a complaint with the DIFC Commissioner of Data Protection if you think that any of your rights have been infringed by us. In the DIFC, you can find out more information about your rights by visiting difc.ae/laws-regulations/data-protection).
Children’s privacy
In short: A parent and/or guardian is responsible for their Childs use of Leap Services.
This includes but is not limited to:
Your Child’s use of our Services;
You are giving us consent to collect, use and share Your Child’s Personal Information in accordance with this Notice;
You are giving us consent to contact Your Child as further detailed under this Notice.
Our Website and App is not intended for use by individuals under the age of 6 or over the age of 18. We do not knowingly collect Personal Information from individuals under the age of 6. If you are a parent or guardian and become aware that a Child has provided us with Personal Information, please contact us immediately. If we become aware that we have collected Personal Information from a Child without parental consent, we will take steps to remove that information from our servers.
We are reliant on you providing accurate information in order to implement our Privacy Policy and cannot be held responsible if you circumvent age restrictions by providing incorrect date of birth information.
We encourage Parents and Guardians to explain to their Child how their information will be used, as set out in this policy.
Unsubscribing and opting out
In Short: You may opt out and unsubscribe from all marketing emails
We may use your Information for marketing purposes. Each promotional email you receive from Leap or any of our affiliated third parties will include instructions on how you can unsubscribe from that category of mailing or from receiving emails from that third party. You may also unsubscribe from Leap’s promotional emails by sending an email, including your name and email address to the contact details below.
Usage information and location data
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We may analyse and evaluate your Information in an automated manner.
These may be used for business-related checks, individual management and the provision of offers and information that we, or our third parties, may make available to you.
When providing you with our Services, we may make decisions about you by automated means. For example, we use technology that helps us identify the level of risk involved in User or account activity (i.e. for credit, fraud or financial crime reasons). We may also use information received by third party providers to identify if someone else is using your Leap account without your permission.
You have a right to certain information about how we make these decisions. We ensure that a suitable contact person is available if you wish to express a view on any automated individual decision where such opportunity to express a view is required by law. Please contact us using the contact details below for more information.
In some instances, Leap may collect non-personal (aggregate or demographic) data through cookies, web logs, and web beacons. This Information may include, but is not limited to, information such as your computer’s internet protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, App usage and other diagnostic data.
When you access our Website or App with a device, the Information may also include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of internet browser you use, unique device identifiers and other diagnostic data.
This information allows us to better understand and improve the usability, performance, and effectiveness of our Website and to correct any problems that may occur. Please read the “Cookies” section below for more information. We may also collect and store your location data when you access our Website via a mobile device or computer. You can enable or disable location services when you use our Website at any time through your device settings.
Sharing your personal information
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.
We may share your data with third-party vendors, service providers, contractors or agents (“Third Parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our Third Parties, which are designed to help safeguard your Personal Information. This means that they cannot do anything with your Personal Information unless we have instructed them to do it. They will also not share your Personal Information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. We may share and transfer your Personal Information within Leap and with our Service Providers and any Third Parties engaged by us where:
we need to for the purposes of providing you with products or services you have requested (i.e. application development and providing User support);
we have a public or legal duty to do so (i.e. to assist with detecting fraud, regulatory reporting, litigation or defending our legal rights);
we have a legitimate reason for doing so (i.e. verify your identity, or assess your suitability for products and services); or
We have asked you for your permission to share it, and you have agreed.
We only share your Personal Information to the extent that the other party reasonably needs it to complete or utilise the requested product or transaction, or to perform their function. All of our affiliated companies, Service Providers and any third parties engaged by us are not permitted to use your Personal Information except for the specific purposes, as agreed with Leap.
On occasion we may transfer and disclose your Information in other cases including:
in response to subpoenas, court orders, legal process or according to the requirements of applicable laws. We will only share such Information if required to do so, if we in good faith believe it is necessary, or if it is otherwise advisable to cooperate with law enforcement or other governmental agencies;
to establish or exercise our legal rights or defend against legal claims;
to investigate, prevent, or take action against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Leap’s terms of service, or as otherwise that we believe in good faith is required by applicable law;
when there is a sale or transfer of all or part of Leap’s business or assets (which could include any merger, financing, acquisition, or bankruptcy).
We may also share aggregated and/or anonymised data with others, such as our financial institution partners, for their own uses, or to meet our reporting obligations, or to indicate our Users’ interests, habits, and usage patterns. For example, we may share such information publicly to show trends about the general use of our Services. However, you will not be able to be individually identified from this information.
Transfers of your personal information
In Short: We may need to transfer and store your data outside of the DIFC.
For the purposes of providing services to you, any Personal Information that we hold and the data we collect from you may be transferred to, and stored at, a destination outside the Dubai International Financial Centre (“DIFC”). By submitting your Personal Information, you agree to this transfer, storing and processing by us. We will take all steps reasonable necessary to ensure that such transfers comply with data protection laws and your data is treated securely and in accordance with this Privacy Policy.
Depending on the kind of product or Service that is used, your Personal Information may also be disclosed to third parties domiciled in jurisdictions which do not have an appropriate level of data protection. If data is transferred to such a country, we take appropriate measures (for example, relying on contractual arrangements such as the DIFC Standard Contractual Clauses or other precautions or justifications) so that your Personal Information continues to receive the appropriate protection.
Security of your personal information
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
Leap is committed to protecting the Personal Information you share with us. We rely on a combination of industry-standard security technologies, procedures, and organisational measures to help protect your Personal Information from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your Personal Information transmitted, stored or otherwise processed by us.
We advise that you take every precaution to protect your Personal Information when you are accessing our Website and using our Services. For example, we recommend that you change your passwords regularly, use a combination of letters, numbers and symbols when creating passwords, and make sure you use a secure browser.
How long we will keep your personal information
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including to satisfy any legal, regulatory, accounting or reporting requirements.
On occasion, we may retain your Personal Information for a longer period, and even after you stop using our Services, in order to:
to respond to enquiries and complaints;
to comply with laws and regulations;
in accordance with our internal policies and procedures; or
to protect our interests.
What we expect from you
In Short: You must inform us if there are any changes to your information.
You are responsible for making sure the information you give us is accurate and up to date. You must tell us if anything changes, as soon as possible. If we ask you for any information and you do not provide it to us, we may stop providing existing Services to you.
Cookies
In Short: We may use cookies and other tracking technologies to collect and store your information.
Leap uses technologies such as Cookies, web beacons and pixels, which allow us to make your visit to our Website and App easier, more efficient and more valuable by providing you with a customised experience and recognising you when you return.
remembering information (such as usernames)
enabling functions on a website
A Cookie cannot read Personal Information off your device or read Cookie files created by other websites. The only Personal Information a Cookie can contain is information you supply yourself. Accepting the Cookies used on our Website may give us access to information about your browsing behaviour, which we may use to personalise your experience and track your User traffic patterns, and to merge this information when you register. We do this in order to determine the usefulness of our Website information to our Users and to see how effective our navigational structure is in helping Users reach that information.
In addition, we use web beacons in conjunction with Cookies to understand User behaviour. Web beacons are a convenient way of gathering basic statistics and managing Cookies and do not give away any extra information. Turning off your browser’s Cookies will prevent web beacons from tracking your specific activity. We do not use Cookies to “see” other data on your computer or determine your email address.
Types of cookies we drop and the information collected using them include:
Essential
Google Tag Manager – helps make tag management simple, easy and reliable by allowing marketers and webmasters to deploy website tags all in one place.
Site Analytics
Google Analytics – gives website owners the digital analytics tools needed to analyse data from all touchpoints in one place, for a deeper understanding of the customer experience.
Customer Interaction
Live Chat – lets website owners chat with customers and give them real-time support.
Advertising
DoubleClick – a subsidiary of Google which develops and provides Internet ad serving services.
Twitter Advertising – enables website owners to track and measure the actions users take after viewing or engaging with ads on Twitter.
Facebook Advertising – lets website owners measure, optimise and build audiences for advertising campaigns.
LinkedIn Analytics – enables website owners to promote their company updates to targeted audiences on desktop, mobile, and tablet.
Most browsers accept and maintain Cookies by default. Check the ‘Help’ or ‘Settings’ menu of your browser to learn how to change your Cookie preferences. You can choose to alter Cookies settings related to the use of our Website Services, but this may limit your ability to access certain areas of the Website.
Alternatively you may wish to visit an independent source of information, www.aboutcookies.org, which contains comprehensive information on how to alter settings or delete Cookies from your computer as well as more general information about Cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual or network operator for advice.
Service providers
In Short: We may share information in specific situations to a service provider contracted by us.
Leap may engage third party Service Providers from time to time. These Service Providers will have access to your Personal Information only to the extent necessary to perform the tasks assigned to them by us. All Service Providers engaged by Leap are legally required to maintain the confidentially of your Personal Information, have in place systems and controls to protect against any loss or damage to your Personal information, and must not disclose or use your Personal Information for any other purpose other than as they are instructed.
Use of Apple Pay
If you choose to use Apple Pay as a payment method in our app, please note the following:
Apple Pay does not store or access your actual card number. Instead, it generates a unique token (known as a Device Primary Account Number, or DPAN) to process your transactions securely.
Leap does not collect or store your card details when you use Apple Pay. Your card information is securely transmitted between Apple Pay, your card issuer, and the payment processor.
We may receive limited information about your transaction, such as the transaction date, amount, and status, which is used solely for record-keeping and reporting purposes in accordance with this Privacy Policy.
You can view more about how Apple Pay protects your information by reviewing Apple's Privacy Policy here.
