Personal Data – any information relating to an identified or identifiable natural person; for California consumers, Personal Data is “Personal Information” as defined below.

Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.

Data subject – a natural person whose Personal Data is being Processed.

Child – a natural person under 16 years of age.

We/us (either capitalized or not) – Lapsus Next.

Personal Information (applicable to California consumers; also referred to as “Personal Data” in this Privacy Policy) – any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information includes but is not limited to, the following if it identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household:

• Identifiers – real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
• Commercial information – including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories of tendencies
• Biometric Information
• Internet or other electronic network activity information – including but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
• Geolocation data
• Audio, electronic, visual, thermal, olfactory, or similar information.
• Professional or employment-related information.
• Inferences drawn from any of the information identified in this definition of Personal Information, to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• Personal Information does not include publicly available information lawfully made available from government records or information that is deidentified or aggregated.

Data Protection Principles

We promise to follow the following data protection principles:

• Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
• Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
• Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
• Processing is limited with a time period. We will not store your personal data for longer than needed.
• We will do our best to ensure the accuracy of data.
• We will do our best to ensure the integrity and confidentiality of data.

Data Subject’s rights

The Data Subject has the following rights:

1. Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
2. Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
3. Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
4. Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
5. Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
6. Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
7. Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
8. Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
9. Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
10. Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
11. Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.

Data we gather

Information you have provided to us

Lapsus Next may obtain the following types of information from you or concerning your computer or device (“Information”), which may include information that can be used to identify you as specified below (“Personally Identifiable Information”):

• Name
• Email address
• Mailing address
• Telephone (or mobile) number(s)
• Credit card information
• Blog or website URL
• Social networking handle or username
• Photo
• Demographic information (e.g., age, gender, interests, and preferences)
• Professional title
• Company
• Industry
• Activities or content viewed on Lapsus Next
• Information collected automatically ( detailed below )
• Information received from Third Parties ( detailed below )

In certain cases, we may request that you provide some of the Information identified above in order to obtain specific products or services (such as registering for the Advanced Marketing Program or logging in to download LapsusNext.com reports). If you choose not to provide the Information we request, you may still use Lapsusnext.com, but you may be unable to access certain features or services.

When you register to receive any products or services from Lapsus Next or provide information to Lapsus Next in any other manner, you agree to provide only true, accurate, current and complete information.

Information automatically collected about you

Lapsus Next may automatically receive and log certain types of information when you visit or interact with our websites, services, mobile applications or other products, including:

• Browser information
• Operating system information
• Mobile device information (e.g., device identifier, mobile operating system, etc.)
• IP address
• Internet service provider
• Content viewed
• Geographic location
• Connection speed
• Time of visit
• Referring site, application, or service
• Registration time

Information collected if you provide your website and expressly consent

• Keywords your site ranks for
• Click volume
• Search volume
• Click volume from mobile versus desktop traffic

Information from our partners

If you choose to use any third-party website or service that is integrated with Lapsus Next, including a third party social networking or blogging site, such as LinkedIn, Facebook, Twitter or WordPress (“Third Party Websites”) – or if you use any Lapsus Next application provided through any Third Party Website – we may receive Information, including Personally Identifying Information, from such Third Party Websites, including, but not limited to:

• Name
• Nickname or username
• Photo or graphic avatar
• Unique Third Party website identifier (e.g., Facebook User ID)
• Biographical or demographic information (e.g. professional title, gender, college attended, etc.)
• Likes and interests
• Contacts/friends/associations
• Any information that is publicly available on Third Party websites

For example, Lapsus Next may offer the ability to use certain Third Party Websites to facilitate your registration on Lapsus Next. We may also use information about your profile and connections on Third Party Websites to allow you to share or connect with your friends and contacts on Lapsus Next or to personalize your experience. In addition, Lapsus Next offers “plugins” and “widgets” from various Third Party Websites that allow you to share Lapsus Next content off of our service, as discussed in “Disclosure of Information to Third Parties”.

Your decision to use, or share with, a Third Party Website when accessing or using Lapsus Next products and services is completely voluntary. Lapsus Next is not responsible for compliance with the policies or practices of any Third Party Website. You should ensure that you are comfortable with the information such Third Party Websites may make available to Lapsus Next by reviewing those Websites’ privacy policies and service terms, and by modifying your privacy settings and preferences on those Services.

Any information we receive from Third Party Websites will be governed by this Privacy Policy.

Publicly available information

We might gather information about you that is publicly available.

How we use your Personal Data

We use your Personal Data in order to:

• Provide Lapsus Next products and services
• Fulfill your requests
• Communicate with you
• Improve our products and services
• Develop new services or products
• Personalize and tailor your experience on Lapsus Next
• Operate our business
• Understand how users are engaging with Lapsus Next
• Protect Lapsus Next, our users, or others. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm Lapsus Next, our users, or others.

We use your Personal Data on legitimate grounds and with your consent.

On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:

• To identify you for communication purposes
• To provide you a service or to send/offer you a product
• To communicate either for sales or invoicing

On the ground of legitimate interest, we Process your Personal Data for the following purposes:

• To send you personalized offers (from us and/or our carefully selected partners);
• To administer and analyze our client base (purchasing behavior and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
• To conduct questionnaires concerning client satisfaction

As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behavior to be our legitimate interest.

With your consent we Process your Personal Data for the following purposes:

• To send you newsletters and campaign offers (from us and/or our carefully selected partners);
• To build a database of relevant search information to improve the quality, variety, and availability of our products and services;
• For other purposes we have asked your consent for

We Process your Personal Data in order to fulfill obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymize Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymized. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law.

We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:

• The link between purposes, context and nature of Personal Data is suitable for further Processing;
• The further Processing would not harm your interests; and
• There would be an appropriate safeguard for Processing.

We will inform you of any further Processing and purposes.

Who else can access your Personal Data

We do not share your Personal Data with strangers.

If you are not a registered client for our site, there is no personal information we can retain or view regarding yourself.

If you are a client with a registered account, your personal information can be accessed by:

• Our system administrators.
• Our supporters when they (in order to provide support) need to get the information about the client accounts and access.