1. Controller
ZENDROM LTD
Nicosia, Cyprus
Email: Contact us via our contact page
This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use LeadsDB (the "Service") in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.
2. Our Role Under GDPR
2.1 Data Controller
We act as the Data Controller for the following data:
- Your account information (managed via Clerk)
- Usage and analytics data
- Payment and billing information (processed via Paddle)
- Communications and support inquiries
As Data Controller, we determine the purposes and means of processing this personal data.
2.2 Data Processor
We act as a Data Processor for the lead data you upload to the Service. In this context, you are the Data Controller for your lead data, and we process it solely on your behalf and according to your instructions.
Important: You are responsible for ensuring that any personal data you upload to LeadsDB has been collected lawfully and that you have the appropriate legal basis to process it.
3. Information We Collect
3.1 Account Information
When you create an account, your authentication is handled by Clerk, Inc. ("Clerk"). Clerk collects and manages:
- Email address
- Name (if provided)
- Authentication credentials
- Profile information
Please refer to Clerk's Privacy Policy for details on how they handle your account data.
3.2 Your Content (Lead Data)
You may upload lead data to the Service. This data belongs to you, and we act only as a data processor on your behalf. The types of data you may store include:
- Business names and contact information
- Addresses and location data
- Phone numbers and email addresses
- Website URLs and social media links
- Business categories and attributes
- Notes and custom fields
3.3 Usage Information
We automatically collect certain information when you use the Service:
- IP address
- Browser type and version
- Pages visited and features used
- Date and time of access
- API usage patterns
3.4 Payment Information
Payment processing is handled by Paddle.com Market Limited ("Paddle"). Paddle acts as our Merchant of Record, meaning they are responsible for payment processing, billing, and related compliance. We do not store your credit card or payment details directly. Please refer to Paddle's Privacy Policy for information on how they handle payment data.
4. Legal Basis for Processing (GDPR Art. 6)
We process your personal data based on the following legal grounds:
4.1 Contract Performance (Art. 6(1)(b) GDPR)
Processing necessary to provide the Service you requested:
- Account creation and management
- Processing your lead data as instructed
- Processing payments and subscriptions
- Providing customer support
4.2 Legitimate Interests (Art. 6(1)(f) GDPR)
Processing necessary for our legitimate interests:
- Providing a secure and functional website and Service
- Analyzing usage patterns to improve the Service
- Detecting and preventing fraud or abuse
- Enforcing our Terms of Service
4.3 Legal Obligation (Art. 6(1)(c) GDPR)
Processing necessary to comply with legal requirements:
- Tax and accounting obligations
- Responding to lawful requests from authorities
5. How We Use Your Information
5.1 Your Lead Data
We do not use your lead data for any purpose other than providing the Service.
- We do NOT sell your data
- We do NOT share your data with third parties for their marketing purposes
- We do NOT use your data to train AI models
- We do NOT analyze your data for advertising
- We do NOT access your data except as necessary to provide technical support when requested
5.2 Account and Usage Data
We use account and usage information to:
- Provide, operate, and maintain the Service
- Process transactions and send related information
- Send administrative emails (password resets, security alerts)
- Respond to inquiries and provide customer support
- Monitor and analyze usage patterns to improve the Service
- Detect, prevent, and address technical issues or abuse
- Comply with legal obligations
6. Data Storage and Security
6.1 Data Location
Your lead data is stored on servers located in the European Union (EU).
Your account and authentication data is managed by Clerk, Inc., which may store data in the United States. By using the Service, you consent to the transfer of your account data to the United States.
4.2 Security Measures
We implement reasonable security measures to protect your data, including:
- Encryption of data in transit (HTTPS/TLS)
- Access controls and authentication
- Regular security assessments
- Secure API key management
However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. You acknowledge and accept this risk.
4.3 Data Retention
We retain your data for as long as your account is active. Upon account termination:
- Your lead data will be permanently deleted within 30 days
- Backups may be retained for up to 90 days
- We may retain certain information as required by law
5. Data Sharing and Disclosure
We do not sell, trade, or rent your personal information. We may share information only in the following circumstances:
5.1 Service Providers
We use third-party service providers to operate our Service:
- Clerk, Inc. - Authentication and account management
- Paddle - Payment processing and billing (Merchant of Record)
- Infrastructure providers - Cloud hosting in the EU
These providers have access only to the data necessary to perform their functions and are obligated to maintain confidentiality.
5.2 Legal Requirements
We may disclose information if required to do so by law or in response to:
- Valid legal process (subpoenas, court orders)
- Government requests
- To protect our rights, privacy, safety, or property
- To enforce our Terms of Service
5.3 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.
6. Your Rights
Depending on your location, you may have the following rights:
6.1 Access and Portability
You can access and export your data at any time using the export features in the Service.
6.2 Correction
You can update or correct your data through the Service interface.
6.3 Deletion
You can delete your data through the Service. You may also request complete account deletion by contacting us.
6.4 EU/EEA Residents (GDPR)
If you are in the European Union or EEA, you have additional rights under GDPR:
- Right to access your personal data
- Right to rectification of inaccurate data
- Right to erasure ("right to be forgotten")
- Right to restrict processing
- Right to data portability
- Right to object to processing
- Right to lodge a complaint with a supervisory authority
For your lead data, you are the data controller and we are the data processor. For account data, we are the data controller.
6.5 California Residents (CCPA)
If you are a California resident, you have the right to:
- Know what personal information is collected
- Know whether your personal information is sold or disclosed
- Say no to the sale of personal information (we do not sell your data)
- Access your personal information
- Request deletion of your personal information
- Not be discriminated against for exercising your privacy rights
7. Cookies
7.1 What Are Cookies
Cookies are small text files that are stored on your device when you visit a website. They are widely used to make websites work efficiently and provide information to website owners.
7.2 Cookies We Use
We only use strictly necessary cookies that are essential for the operation of the Service. These cookies are required for authentication and session management and cannot be disabled.
These cookies are set by our authentication provider, Clerk, Inc., and include:
- Session cookies - To keep you logged in during your visit
- Authentication cookies - To verify your identity and maintain secure access
- Security cookies - To protect against cross-site request forgery and other attacks
The legal basis for these cookies is Art. 6(1)(f) GDPR (legitimate interest in providing a secure and functional service). As strictly necessary cookies, they are exempt from consent requirements under the ePrivacy Directive.
7.3 No Tracking or Advertising Cookies
We do not use any analytics, tracking, advertising, or marketing cookies. We do not track your browsing activity across other websites, and we do not use cookies to serve you targeted advertisements.
7.4 Third-Party Cookies
Clerk, Inc. may set additional cookies necessary for authentication functionality. Please refer to Clerk's Privacy Policy for more information about their cookie practices.
8. Children's Privacy
The Service is not intended for use by individuals under the age of 16. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information, please contact us.
9. International Data Transfers
While your lead data is stored in the EU, certain service providers (Clerk, Paddle) may process data outside the EU. These transfers are conducted in compliance with applicable data protection laws, including:
- EU-US Data Privacy Framework (where applicable)
- Standard Contractual Clauses
- Other lawful transfer mechanisms
10. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date.
We encourage you to review this Privacy Policy periodically. Your continued use of the Service after any changes constitutes acceptance of the updated policy.
11. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us through our contact page.
Data Controller:
ZENDROM LTD
Nicosia, Cyprus
https://zendrom.com