Privacy and Data Usage Policy

Effective May 25, 2018

Leadstra and CognaPoint take data privacy seriously. This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights.

We recommend that you read this privacy policy in full to ensure you are fully informed. However, to make it easier for you to review the parts of this privacy policy that apply to you, we have divided up the document into sections that are specifically applicable to Clients (Section 2), Contacts (Section 3), and Visitors (Section 4). Sections 1 and 5 are applicable to everyone.

If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 5.

The Basics

About Us

Leadstra is a Communication Consulting and Production company and CognaPoint is an eLearning Platform (the “Services”) operated by Leadstra, LLC, a company headquartered in the State of Indiana in the United States (“we,” “us,” “our,” “CognaPoint” and “Leadstra”).

The Services enable our Clients to, among other things, create marketing, training, and advocacy campaigns that utilize websites, automated emails, social media, and printed documents to engage and inform the public.

Key Terms

In this privacy policy, these terms have the following meanings:

“Contact” is a person who has subscribed or opted in to our electronic communication system. In other words, a Contact is anyone who has given us information. For example, if you filled out an online form on our website or registered for an eLearning course, you would be considered a Contact.

“Distribution List” is a list of Contacts managed on our platform(s) and all associated information related to those Contacts (for example, email addresses).

“Client” means any person or entity that is or has engaged with us to use our Services.

“Personal Information” means any information that identifies or can be used to identify a Member, a Contact, or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.

“Website(s)” means any website(s) we own and operate (such as www.leadstra.com or www.CognaPoint.com) or any web pages, interactive features, applications, widgets, blogs, social networks, social network “tabs,” or other online, mobile, or wireless offerings that post a link to this privacy policy.

“Visitor” means any person who visits any of our Websites.

“you” and “your” means, depending on the context, either a Member, a Contact, or a Visitor.

Privacy for Clients

This section applies to the Personal Information we collect and process from a Client or potential Client through the provision of the Services. If you are not a Client, the Visitors or Contacts section of this policy may be more applicable to you and your data. In this section, “you” and “your” refer to Clients and potential Clients.

Information We Collect

The Personal Information that we may collect broadly falls into the following categories:

Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you and your Contacts. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service (for example, when you choose to connect your e-commerce account with MailChimp), or communicate with us in any other way.

We will let you know prior to collection whether the provision of Personal Information we are collecting is compulsory or if it may be provided on a voluntary basis and the consequences, if any, of not providing the information. By giving us this information, you agree to this information being collected, used and disclosed as described in our Terms of Use and in this privacy policy.

This information may include:

Registration information: You need a subscription account to use the Services as a Client. When you register for an account, you will be asked to provide certain basic information, such as your name, email address, username, password, company name, occupation, location, and phone number (for example, if you are using two-factor authentication).

Billing and communications information: If you purchase our Services, you may also need to provide us with payment and billing information, such as your credit card details and billing address. Leadstra and CognaPoint will also maintain a record of your billing transactions and purchases, and any communications and responses.

Information we process on your behalf: To use certain features in your account, you may need to upload a Distribution List that provides us information about your Contacts, such as their names and email addresses. We use and process this information to provide the Services in accordance with your instructions.

Information we collect automatically: When you use the Services, we may automatically collect certain information about your device and usage of the Services. We use cookies and other tracking technologies to collect some of this information.

Information about Cookies

Information we collect via cookies may include:

Device information: We collect information about the device and applications you use to access the Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection.

Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.

Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services and your browsing activities (such as what portions of the Services are used). We also collect information regarding the performance of the Services, including metrics related to the deliverability of emails and other communications you send through the Services. This information allows us to improve the content and operation of the Services and facilitate research and analysis of the Services.

Information we collect from other sources: From time to time, we may obtain information about you or your Contacts from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.

Learn More

Information from the use of our mobile apps: When you use our mobile apps, we may collect certain device and usage-related information in addition to information described elsewhere in this privacy policy.

Device information: We may collect information about the type of device and operating system you use. We do not ask for, access, or track any location-based information from your mobile device at any time while downloading or using our mobile apps or Services.

Product usage data: We may use mobile analytics software (such as Fabric.io) to better understand how people use our application. We may collect information about how often you use the application and other performance data.

Use of Personal Information

We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:

To bill and collect money owed to us by you.
To send you system alert messages.
To communicate with you about your account and provide customer support.
To enforce compliance with our Terms of Use and applicable law, and to protect the rights and safety of our Members and third parties, as well as our own.
To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
To prosecute and defend a court, arbitration, or similar legal proceeding.
To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
To provide, support and improve the Services. For example, this may include sharing your or your Contacts’ information with third parties to provide and support our Services or to make certain features of the Services available to you.
To provide suggestions to you.
For our data analytics projects. Our data analytics projects use to provide and improve the Services.
Combined information. We may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy.
Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.

Cookies and Tracking Technologies

We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and hidden fields on web forms. They also allow us to collect information such as the recipient’s IP address, browser, email client type and other similar details. We use this information to provide analytics information and enhance the effectiveness of our Services.

Other Data Protection Rights

Leadstra and CognaPoint operate exclusively in the United States. Anyone outside of the United States should not use our services including submitting data or even visiting or websites. We take reasonable caution to restrict viewing of any Leadstra or CognaPoint content from visitors from the EU where data requirements are more stringent.

Privacy for Contacts

This section applies to the information we process about our Client’s Contacts as a data controller pursuant to our legitimate business interests. Our Services are intended for use by our Clients. As a result, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Clients. Leadstra and CognaPoint are not responsible for the privacy or security practices of our Clients, which may differ from those set forth in this privacy policy. Please check with individual Clients about the policies they have in place. For purposes of this section, “you” and “your” refer to Contacts.

Information We Collect

The Personal Information that we may collect or receive about you broadly falls into the following categories:

Information we receive about Contacts from our Clients: A Client may use our Services to collect Personal Information about you and then follow up based on your request. For example, when a Client offers a course in CognaPoint in which you register to participate, you information will be stored in our system which may send you automated follow up material. Based on your response, the Client may be notified of your interest and follow up with you directly. Leadstra and CognaPoint are not responsible for any communication made by our Client to you.

Information we collect automatically: When you interact with a campaign that you receive from a Client or browse or purchase from a Client’s courses, we may collect information about your device and interaction with an email. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below:

Device information: We collect information about the device and applications you use to access emails sent through our Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection.

Product usage data: We collect usage data about you whenever you interact with emails sent through the Services, which may include dates and times you access emails and your browsing activities (such as what pages are viewed). We also collect information regarding the performance of the Services, including metrics related to the deliverability of emails and other electronic communications our Members send through the Services. This information allows us to improve the content and operation of the Services, and facilitate research and analysis of the Services.

Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as social media platforms and third-party data providers. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.

Use of Personal Information

We may use the Personal Information we collect or receive about you for our legitimate business interests, including:

To enforce compliance with our Terms of Use and applicable law. This may include developing tools and algorithms that help us prevent violations.
To protect the rights and safety of our Clients and third parties, as well as our own.
To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
To prosecute and defend a court, arbitration, or similar legal proceeding.
To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
To provide, support and improve the Services. For example, this may include sharing your information with third parties to provide and support our Services or to make certain features of the Services available to our Members.
For our data analytics projects.
Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes.

Cookies and Tracking Technologies

Legal Basis for Processing

We process Personal Information about you as a data controller as described in this section, where such processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing, and enhancing our technology, products and services; ensuring the security of the Services and our Website; and for our marketing activities.

Other Data Protection Rights

You may have the following data protection rights:

To access, correct, update or request deletion of your Personal Information. MailChimp takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating or deleting your Personal Information, or altering your data, by emailing us at info@leadstra.com. We will consider your request in accordance with applicable laws.

In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at info@leadstra.com.

You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.

As described above, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Clients. In such cases, if you are a Contact and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by Leadstra or CognaPoint as a processor on behalf of our individual Clients, you should contact the relevant Client that is using our Services, and refer to their separate privacy policies.

If you no longer want to be contacted by one of our Clients through our Services, please unsubscribe directly from that email message or contact us directly to update or delete your data. If you contact us directly, we may remove or update your information within a reasonable time.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity to help us respond efficiently to your request.

Privacy for Visitors

This section applies to Personal Information that we collect and process through our Websites and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities. In this section “you” and “your” refers to Visitors.

Information We Collect

Information you provide to us on the Websites or otherwise: Certain parts of our Websites may ask you to provide Personal Information voluntarily. For example, we may ask you to provide certain Personal Information (such as your name, contact details, company name, profile information) in order to request assistance or learn more about our Services. We may also collect Personal Information, such as your contact and job details and feedback, when you attend our events, take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records.

The Personal Information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Information. We will also let you know prior to collection whether the provision of the Personal Information we are collecting is compulsory or may be provided on a voluntary basis and the consequences, if any, of not providing the information.

Information we collect automatically through the Websites: When you visit our Websites, we may also collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered Personal Information under applicable data protection laws.

Learn More

Specifically, the information we collect automatically may include your IP address, your operating system, your browser ID, your browsing activity, and other information about your system and connection and how you interact with our Websites and other websites. We may collect this information as a part of log files as well as using cookies or other tracking technologies. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement here.

Use of Personal Information

We may use the information we collect through our Websites for a range of reasons, including:
To provide, operate, optimize, and maintain our Websites.
To send you information for marketing purposes, in accordance with your marketing preferences.
For recruitment purposes if you have applied for a role with Leadstra or CognaPoint.
To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
To manage our Websites and system administration and security.
To improve the navigation and content of our Websites.
To identify any server problems or other IT or network issues.
To process transactions and to set up online accounts.
To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.
To carry out research and development to improve our products and services.
To customize content and layout of the Websites.
To carry out other legitimate business purposes, as well as other lawful purposes.

In addition, we may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Information.

Public Information and Third-Party Websites

Blog. We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us here. If we are unable to remove your information, we will tell you why.

Social media platforms and widgets. Our Websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly.

Learn More

Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms, including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

Links to third-party websites. Our Websites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and use Personal Information about you, including to serve interest-based advertising. For further information about the types of cookies and tracking technologies we use, why, and how you can control them, please see our detailed Cookie Statement in section 2 of this document.

Other Data Protection Rights

You have the following data protection rights:

To access, correct, update, or request deletion of your Personal Information. MailChimp takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating, or deleting your Personal Information, or altering your data or marketing preferences by emailing us at info@leadstra.com. We will consider your request in accordance with applicable laws.

Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

General Information

How We Share Information

We may share and disclose your Personal Information to the following types of third parties for the purposes described in this privacy policy (for purposes of this section, “you” and “your” refer to Members, Contacts, and Visitors unless otherwise indicated):

Our service providers: Sometimes, we share your information with our third-party service providers, who help us provide and support our Services and other business-related functions.

Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.

A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition.

Any other person with your consent.

Legal Basis for Processing Personal Information (EEA Persons Only)

If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.

If you are a Client, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.

Where required by law, we will collect Personal Information only where we have your consent to do so.

Your Choices and Opt-Outs

Members and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the “unsubscribe” link at the bottom of our marketing messages.

Our Security

We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. For further information about our security practices, please see our Security page here. If you have any questions about the security of your Personal Information, you may contact us at privacy@leadstra.com.

Leadstra and CognaPoint accounts require a username and password to log in. Clients and Contacts must keep their username and password secure, and never disclose it to a third party. Because the information in an account is so sensitive, account passwords are hashed, which means we cannot see a password. We cannot resend forgotten passwords either. We will only provide Members with instructions on how to reset them.

International Transfers

We operate in the United States

Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering our Members a data processing agreement.

We are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us using the information at the end of this document.

California Privacy

Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, and (b) the names and addresses of all such third parties. To request the above information, please contact us through our contact form or email us at privacy@leadstra.com.

Changes to this Policy

We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Websites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Website.

Questions & Concerns

If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please use our contact form to send us a message. You may also contact us by postal mail or email at:

Leadstra, LLC
Attn. Privacy Officer
privacy@leadstra.com
11216 Fall Creek Road, Suite 112
Indianapolis, IN. 46236

The Basics

Privacy for Clients

Privacy for Contacts

Privacy for Visitors

General Information

Site Navigation

About Leadstra