Privacy Policy

Thank you for visiting the LeadingResponse® website located at www.leadingresponse.com (the “Site”). The Site is an Internet property of LeadingResponse (“Company,” “we,” “our” or “us”). This LeadingResponse® Privacy Policy (“Privacy Policy”) covers our treatment of personal information and other information that we collect when an end-user visitor to the Site (“User,” “you” or “your”): (a) accesses or uses the Site; (b) accesses and/or views any of the videos, audio, stories, testimonials, text, photographs, graphics, artwork, information and/or other content featured on the Site, including information pertaining to Company’s marketing products, services and technology (collectively, the “Content”); (c) accesses links to Company’s social media pages/accounts (collectively, “Social Media Pages”) on third-party social media websites, such as Facebook®, LinkedIn® and Twitter® (collectively, “Social Media Websites”); (d) accesses information concerning various employment opportunities available with Company (“Career Opportunity Services”); and/or (e) utilizes the contact form and/or other functionality as a means to request to be contacted by Company (collectively, “Contact Services,” and together with the Site, Content, Social Media Pages and Career Opportunity Services the “Site Offerings”).  Please note, if you are a resident of a European Union Member State, you are not permitted to use the Site and/or Site Offerings.

Capitalized terms not defined herein shall have the meanings set forth in the LeadingResponse® Website Terms and Conditions (“Terms”).  IF YOU DO NOT AGREE TO TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SITE OFFERINGS.

Facebook® is a registered trademark of Facebook, Inc. (“Facebook”).  LinkedIn® is a registered trademark of LinkedIn Corporation (“LinkedIn”).  Twitter® is a registered trademark of Twitter, Inc. (“Twitter”).  Please be advised that Company is not in any way affiliated with Facebook, LinkedIn or Twitter, and the Site Offerings are not endorsed, administered or sponsored by Facebook, LinkedIn or Twitter.

Your California Privacy Rights

Shine the Light.  If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please: e-mail us at: [email protected]; call us at: (800) 660-2550; or send us U.S. Mail to: LeadingResponse, 36181 East Lake Road, #124, Palm Harbor, FL, 34685.

Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third party for marketing purposes, please: e-mail us at: [email protected]; call us at: (800) 660-2550; or send us U.S. Mail to: LeadingResponse, 4805 Independence Parkway, Suite 250, Tampa, FL 33634.  Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.

California Consumer Privacy Act of 2018 (“CCPA”).  In addition to the foregoing, if you are a resident of the State of California certain other privacy-related rights may apply to you in accordance with the CCPA, including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information.  Please see our “Privacy Provisions for California Residents” below for a more complete description of your rights under the CCPA as a California State resident.

Personal Information Collected

For the purposes of this Privacy Policy, “personal information” shall mean individually identifiable information from or about an individual. We collect personal information when you access certain of the Site Offerings and complete the required information request form and/or otherwise provide such information to us.

Where a User attempts to utilize the Contact Services, that User may be required to submit, and Company may collect, some or all of the following information: (a) the User’s full name; (b) the Entity’s name; (c) the User’s or Entity’s primary e-mail address; (d) the User’s or Entity’s primary telephone number; (e) the Entity’s market interest; (f) mailing address; (g) resume-related information, where you utilize the Career Opportunity Services; and (h) any other information requested on the applicable form (collectively, “Initial Contact Data”).

Use of Personal Information

Company will never share, sell, rent, exchange or barter your personal information to or with any third party for financial gain or marketing purposes.  By making that personal information available to Company, you grant Company the right, subject to applicable law, to use that personal information to contact you regarding your use of the Site Offerings and/or with information regarding other Company products and/or services that we think may be of interest to you.  If you wish to stop receiving future communications from us, please follow the instructions at the end of each such e-mail message or see the “Opt-Out/Unsubscribe” section below.

Where you submit personal information, we use the personal information that you make available to personalize your experience with the Site and to facilitate the provision of the applicable Site Offerings to you, including in connection with customer service and to otherwise respond to any inquiries made by you. You also agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Site Offerings, and to keep you informed of our other products and services.

We may also employ other companies and individuals to perform certain functions on our behalf. Examples include sending direct and electronic mail, removing duplicate information from User lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our Users’ personal information as needed to perform these functions for us, but we do not permit them to use User personal information for other purposes.

We will also use your personal information for customer service, to provide you with information that you may request, to customize your experience with the Site Offerings and/or to contact you when necessary in connection with your use of the Site Offerings. We may also use your personal information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the Site Offerings. We may also combine the information we have gathered about you with information from other sources.

By submitting your personal information by and through the Site Offerings, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.

Where you provide “prior express consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive telephone calls from Company, including artificial voice calls, pre-recorded messages and/or calls (including SMS text messages) delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide this consent in order to obtain access to the Site Offerings, and your consent simply allows Company to contact you via these means. Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: (a) have your telephone number reassigned to another person or entity; (b) give up your telephone number so that it is no longer used by you; (c) port your telephone number to a landline or vice versa; or (d) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify Company of the Phone Number Change via e-mail at:  [email protected], or by using one of the methods set forth in the “Contact Us” section below.

We reserve the right to release current or past personal information: (i) in the event that we believe that the Site Offerings are being or have been used in violation of the Terms or to commit unlawful acts; (ii) if the information is subpoenaed or requested pursuant to any court order or legal proceeding; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena/court order, prior to disclosure of any personal information pursuant to a subpoena; (iii) (iii) if we are sold, merge with a third-party or are acquired by a third-party (collectively, “M&A Transactions”) (including where we share your personal information in connection with the due diligence process associated with a potential M&A Transaction); or (iv) if we are the subject of bankruptcy proceedings; provided, however, that if Company is involved in a bankruptcy proceeding or M&A Transaction, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.

You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with third-parties for suppression purposes in compliance with applicable law, including the CAN-SPAM Act of 2003, as amended from time to time. Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third-parties without permission.

Non-Personal Information Collection and Use

IP Addresses/Browser Type

We may collect certain non-personally identifiable information about you and your desktop computer and/or mobile device when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Site Offerings and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze usage of the Site Offerings.

Cookies

When a User visits the Site, we send one (1) or more cookies and/or gif files (collectively, “Cookies”) to assign an anonymous, unique identifier to the applicable User’s computer. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the Site Offerings, including for storing User preferences and tracking Site-User trends (such as pages opened and length of stay at the Site).

Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even in the case where a User rejects a Cookie, he or she may still use the Site Offerings; provided, however, that certain functions of the Site Offerings may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.

Behavioral Tracking

Company, as well as third party entities such as Google®, Bing® and Facebook®, use Cookies, pixels and other tracking technology (collectively, “Tracking Technology”) in connection with the Site for purposes of tracking Users’ activities (such as websites visited, advertisements selected and pages viewed) after they leave the Site. Company, and its third-party partners, use this Tracking Technology to target applicable Users with advertisements featuring Company products and/or services, as well as third-party products and/or services, that may be of interest to applicable Users.

In general, Users may be able to disable some, but not all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers. In addition, Users may be able to opt-out of this form of tracking utilizing the options made available by the Network Advertising Initiative or Digital Advertising Alliance.

Further, users can opt-out of certain Google®-related tracking technology, and customize the Google® Display Network ads that they receive, by visiting the Google® Ads Settings at: http://www.google.com/settings/ads. Google® also recommends installing the Google® Analytics Opt-out Browser Add-on for your web browser, which is available here: https://tools.google.com/dlpage/gaoptout. To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third-parties in connection with the Site.

Cross Device Tracking

Company tracks Users’ use of the Site Offerings across various devices, including your personal computer and mobile device, in order to optimize and personalize your Site Offerings experience. Company may collect certain of your personal information across various devices.

Aggregate Data

Company reserves the right to transfer and/or sell aggregate or group data about Users of the Site Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of Site Offerings Users as a group, without disclosing personally identifiable information.

Social Media Websites

If you engage in any interaction with Company, other end-users or any third-party on any Social Media Pages, you should be aware that: (a) the personal information that you submit by and through such Social Media Pages can be read, collected and/or used by other users of these websites/services (depending on your privacy settings associated with your accounts with the applicable Social Media Websites), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; and (b) where Company responds to any interaction on such Social Media Pages, your account name/handle may be viewable by any and all members/users of Company’s social media accounts.

We are not responsible for the personal information that you choose to submit on any Social Media Websites. The Social Media Websites operate independently from Company, and we are not responsible for such Social Media Websites’ interfaces or privacy or security practices. We encourage you to review the privacy policies and settings of the Social Media Websites with which you interact to help you understand those Social Media Websites’ privacy practices. If you have questions about the security and privacy settings of any Social Media Websites that you use, please refer to their applicable privacy notices or policies.

Third-Party Websites

This Site may contain links to third-party owned and/or operated websites including, without limitation, the Social Media Websites. Company is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Company has no responsibility or liability relating to them.

Security

We endeavor to safeguard and protect our Users’ personal information. When Users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Where our registration/application process prompts Users to enter sensitive information (such as financial information), and when we store and transmit such sensitive information, that information is encrypted with advanced TLS (Transport Layer Security).

Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. All of our Users’ personal information is restricted in our offices, as well as the offices of our third-party service providers. Only employees or third-party agents who need User personal information to perform a specific job are granted access to User personal information. Our employees are dedicated to ensuring the security and privacy of all User personal information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store User personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control.

Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site, other Site Offerings or otherwise via the Internet or wireless networks, is done at your own risk.

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Minors

Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Site. Company does not knowingly solicit or collect information from visitors under eighteen (18) years of age. Company encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Opt-Out/Unsubscribe

To opt-out of receiving e-mail and other forms of communications from us, you can: (a) follow the instructions included in the applicable e-mail message or other communication; or (b) e-mail us at: [email protected].

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Site Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving Site Offerings-related and/or inquiry response-related messages from Company, you must cease requesting and/or utilizing the Site Offerings and/or cease submitting inquiries to Company, as applicable.

Deleting, Modifying and Updating Your Information

At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected. You may do so by e-mailing us at: mailto:[email protected]. We ask individual Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Please be advised that deleting your personal information may terminate your access to certain of the Site Offerings. If you wish to continue using the full complement of Site Offerings, you may not be able to delete all of the personal information that we have on file for you.

Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Transfer of Personal Information Internationally

If you are visiting the Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international boundaries. By visiting the Site and/or otherwise communicating electronically with us, you consent to such transfers. Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Policy.

Changes to this Privacy Policy

Company reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site that we are changing our Privacy Policy. If the manner in which we use personal information changes, Company will notify Users by: (a) sending the modified policy to our Users via email; and/or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you opt-in to such use.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices in general, you may: email us as at: [email protected]; call us at: (800) 660-2550; or send us U.S. Mail to: LeadingResponse, 36181 East Lake Road #124, Palm Harbor, FL, 34685.

Privacy Provisions for California Residents

This Privacy Provisions for California Residents (“Privacy Provisions”) apply solely to residents of the State of California (“CA Users”).  We adopt these Privacy Provisions in compliance with the California Consumer Privacy Act of 2018 (“CCPA”).  Any terms defined in the CCPA have the same meaning when used in these Privacy Provisions.  CA Users with disabilities who wish to access these Privacy Provisions in an alternative format can contact us by emailing us at: [email protected]; by calling us at: (800) 660-2550; or sending us U.S. Mail to: LeadingResponse, 4805 Independence Parkway, Suite 250, Tampa, FL 33634.

Categories of Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or device (“personal information”). In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:

CategoryExamplesCollected
A. Identifiers.A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers.YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, physical characteristics or description, postal address, telephone number, passport number, driver’s license or State identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.YES
C. Protected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).YES
D. Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.NO
E. Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.NO
F. Internet or other similar network activity.Browsing history, search history, information on a CA User’s interaction with a website, application or advertisement.YES
G. Geolocation data.Physical location or movements.NO
H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.NO
I. Professional or employment-related information.Current or past job history or performance evaluations.YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NO
K. Inferences drawn from other personal information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.NO

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated CA User information.
  • Information excluded from the CCPA’s scope, such as:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above (including (a) full name; (b) e-mail address; (c) telephone number; (e) mailing address; and (d) resume-related information) from the following categories of sources:

  • Directly from our CA Users. For example, from online registration forms that our CA Users submit to us in connection with a job application, or in connection with the products and/or services that we offer by and through the Site. (Categories A, B. C and I)
  • Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them. (Categories A, B. C, F and I)
  • Directly and indirectly from activity on the Site. This includes the type of browser that the CA User uses (e.g., Safari, Chrome, Internet Explorer), CA User IP address, the type of operating system used by the CA User (e.g., Windows or iOS) and the domain name of the CA User’s Internet Service Provider.  In addition, we obtain certain Site usage details and analytics as same are collected automatically by us and our third party partners. (Category F)
  • When our CA Users interact with us on our social media accounts, including commenting on and/or liking our posts. (Categories A, B. C, F and I)
  • From third-parties that interact with us in connection with the products and/or services that we offer to our CA Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from CA User lists, analyzing data and providing marketing analysis. (Categories A, B. C, F and I)

Use of Personal Information

We may use or disclose the personal information that we collect (including (a) full name; (b) e-mail address; (c) telephone number; (e) mailing address; and (d) resume-related information) for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your request for the products and/or services featured on the Site, we will use that information to process your request. (Categories A, B. C, F and I)
  • To evaluate your application for employment with Company. (Categories A, B. C, F and I)
  • To provide you with information, products or services that you request from us.
  • To create, maintain, customize and secure your account with us. (Categories A, B. C, F and I)
  • To provide you with e-mail, direct mail and telemarketing messages concerning certain Company products and/or services, as well as third-party products and/or services, that we believe may be of interest to you. (Categories A, B. C, F and I)
  • To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (Categories A, B. C, F and I)
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Site’s Terms and Conditions. (Categories A, B. C, F and I)
  • To improve the Site and better present its contents to you. (Categories A, B. C, F and I)
  • For customer service purposes and to respond to inquiries from you. (Categories A, B. C, F and I)
  • For testing, research, analysis and product development. (Categories A, B. C, F and I)
  • As necessary or appropriate to protect our rights, property or safety, and that of our customers or others. (Categories A, B. C, F and I)
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Categories A, B. C, F and I)
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA. (Categories A, B. C, F and I)
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred. (Categories A, B. C, F and I)

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice.

Sharing Personal Information

Subject to your right to opt-out of such sharing/sale, we may share your personal information (including (a) full name; (b) e-mail address; (c) telephone number; (e) mailing address; and (d) resume-related information) for the business purposes set forth above.

When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract.  Please note, we do not collect information from CA Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of CA Users that we actually know are less than eighteen (18) years of age.  Without limiting the foregoing, we have not shared or sold the personal information of CA Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.

In the preceding twelve (12) months, we have disclosed the following categories of personal information (including (a) full name; (b) e-mail address; (c) telephone number; (e) mailing address; and (d) resume-related information) for a business purpose:

Category A     Identifiers.
Category B     California Customer Records personal information categories.
Category C     Protected classification characteristics under California or federal law.
Category F      Internet or other similar network activity.
Category I       Professional or employment-related information.

We disclose your personal information (including (a) full name; (b) e-mail address; (c) telephone number; (e) mailing address; and (d) resume-related information) for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you authorize us to disclose your personal information in connection with the products and/or services that we provide to you.

In the preceding twelve (12) months, we have not sold personal information to third parties.

Your Rights and Choices

The CCPA provides CA Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Opt-Out from the Sale of Your Personal Information

You have the right to opt-out of our sale of your personal information to third parties.  To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable CA User request to us by either:

  • Clicking here
  • Calling us at: (800) 660-2550;
  • Emailing us at: [email protected]; or
  • Sending us U.S. Mail to: LeadingResponse, 36181 East Lake Road, #124, Palm Harbor, FL 34685.

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.

Opt-Out from the Sharing of Your Personal Information

You have the right to opt-out of our sharing your personal information with third parties.  To exercise your right to opt-out of our sharing your personal information with third parties, please submit a verifiable CA User request to us by either:

  • Clicking here
  • Calling us at: (800) 660-2550;
  • Emailing us at: [email protected]; or
  • Sending us U.S. Mail to: LeadingResponse, 36181 East Lake Road, #124, Palm Harbor, FL, 34685.

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.

Opt-Out from the Use and/or Sharing of Your Sensitive Personal Information

You have the right to limit our use of your sensitive personal information, including any sensitive information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law) and/or Professional or employment-related information), to those uses which: (i) are necessary to perform the services or provide the goods requested by you; (ii) help us to ensure security and integrity of your personal information to the extent the use of your sensitive personal information is reasonably necessary and proportionate for these purposes; (iii) are short-term, transient uses including, but not limited to, non-personalized advertising shown as part of your then-current interaction with the Site, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the then-current interaction with the Site; (iv) involve performing services on behalf of Company, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of Company; and (v) include activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by, Company, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by, Company.

You also have the right opt-out of our sharing your sensitive personal information with third parties, including any sensitive information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law) and/or Category I (Professional or employment-related information).

To exercise your right to limit our use of your sensitive personal information and/or opt-out of our sharing your sensitive personal information with third parties, please submit a verifiable CA User request to us by either:

  • Clicking here
  • Calling us at: (800) 660-2550;
  • Emailing us at: [email protected]; or
  • Sending us U.S. Mail to: LeadingResponse, 36181 East Lake Road, #124, Palm Harbor, FL, 34685.

We endeavor to act on all such requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we have shared that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract/relationship with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech rights, ensure the right of another CA User to exercise her/his free speech rights or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, but only if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with CA User expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability and Deletion Rights

To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:

  • Clicking here
  • Calling us at: (800) 660-2550;
  • Emailing us at: [email protected]; or
  • Sending us U.S. Mail to: LeadingResponse, 36181 East Lake Road, #124, Palm Harbor, FL, 34685.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information.

You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:

  • Provide sufficient information that allows us to reasonably verify that you are: (1) the person about whom we collected personal information; or (2) an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you.  Making a verifiable CA User request does not require that you create an account with us.  We will only use personal information provided in a verifiable CA User request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof.  If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option.  Any disclosures that we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request.  The response that we provide will also explain the reasons that we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable CA User request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; and/or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to this Privacy Notice

We reserve the right to amend these Privacy Provisions in our discretion and at any time. When we make changes to these Privacy Provisions, we will notify you by email or through a notice on the Site’s homepage.

Contact Information

If you have any questions or comments about these Privacy Provisions, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either: