Privacy Policy

1. PERSONAL INFORMATION WE COLLECT

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Information”) as follows:

• Communication Information: If you communicate with us, we may collect your name, contact information, and the contents of any messages you send (“Communication Information”).

• Social Media Information: We have pages on social media sites like X, and LinkedIn. When you interact with our social media pages, we will collect Personal Information that you elect to provide to us, such as your contact details (collectively, “Social Information”). In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.

• Log Data: Information that your browser automatically sends whenever you use our website(“log data”). Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with our website.

• Usage Data: We may automatically collect information about your use of the Services(“usage data”), such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, computer connection, IP address, and the like.

• Device Information: Includes name of the device, operating system, and browser you are using(“device data”). Information collected may depend on the type of device you use and its settings.

• Analytics: We may use a variety of online analytics products that use cookies (or similar tools, such as pixels) to help us analyze how users use our Services and enhance your experience when you use the Services (“analytics data”).

2. WHY WE USE PERSONAL INFORMATION

Certain laws, such as GDPR, describe various lawful reasons to “process” (i.e. collect, use, and share) Personal Information. Our reasons for processing are described below:

• Where users have given us valid consent to use their data in certain ways, we rely on that consent.

• Where users provide information in order to access our services, we rely on contractual necessity to process that information as necessary to perform those services.

• In certain cases we may process information where this is necessary to meet legal obligations, such as compliance with law enforcement subpoenas or warrants.

• In limited cases, for example to ensure the security of our services and the reliability of our data, we may process your information to further our legitimate interests, so long as any such legitimate interests are not overridden by your rights or interests.

3. YOUR RIGHTS AND CHOICES

Upon request, the Lean FRO will provide users with information about whether we hold any of their Personal Information. In certain cases, subject to relevant legal rights, users have the right to object to the processing of their Personal Information, to request changes, corrections, or the deletion of their Personal Information, and to obtain a copy of their Personal Information in an easily accessible format. In order to do this, users can contact us using the contact information set out at the bottom of this policy. We will respond to every request within a reasonable timeframe and may need to take reasonable steps to confirm identity before proceeding.

You can also withdraw your consent to our processing of your information and the use of our services, and/or delete your user account at any time, by using the contact information below to request that your Personal Information be deleted. If you are an EU resident and believe that our processing of your personal data is contrary to the EU General Data Protection Regulation, you have the right to lodge a complaint with the appropriate supervisory authority.

If you withdraw your consent to the use or sharing of your Personal Information for the purposes set out in this policy, we may not be able to provide you with our services. Please note that in certain cases we may continue to process your information after you have withdrawn consent and requested that we delete your information if we have a legal basis/need to do so.

To exercise any of these rights, please contact us as indicated in the “How To Contact Us” section below. If you are located in the European Economic Area (EEA), you also may lodge a complaint with the data protection authority in your country of residence.

4. DATA TRANSFERS

We may transfer your Personal Information to recipients in other countries that have different data protection laws. When we do so, we will protect that information as described in this Privacy Notice and will comply with applicable legal requirements, providing adequate protection for the transfer.

If we transfer Personal Information from the EEA, UK or Switzerland to a country that has not been recognized by the European Commission as providing an adequate level of data protection, we will use appropriate contractual terms with the recipients to safeguard the information. Further information about our data transfer safeguards may be obtained by contacting us as indicated in the “How To Contact Us” section below.

5. RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information for the duration of our relationship, plus a reasonable period to comply with the applicable statute of limitation periods and records retention requirements under applicable laws, or during the pendency of any legal claims or lawful requests or investigations.

We may also anonymize or de-identify your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, as described above, in which case we may use this information indefinitely without further notice to you.

6. HOW WE PROTECT PERSONAL INFORMATION

We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or email. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.

Under certain circumstances, such as a business transfer or due to legal requirements, your Personal Information may be disclosed to third parties.

7. CHILDREN’S PRIVACY

The Site and Services are intended for individuals at least 18 years of age. We do not knowingly collect Personal Information online from children under the age of 13.

8. UPDATES TO OUR PRIVACY NOTICE

This Privacy Notice may be updated periodically for clarity or to reflect changes in law or our practices. We indicate at the top of this Privacy Notice when it was most recently updated. We encourage you to check this page frequently to review any changes. If we make changes, we will notify you via the change log below. In some cases, we may provide additional notice such as a statement on our homepage or an email. Your further use of the Site or Services after a change to our Privacy Notice will be subject to the updated notice.

9. SPECIFIC SERVICES

9. HOW TO CONTACT US

We are responsible for processing Personal Information as described in this Privacy Notice.

If you have any questions, requests or comments about this Privacy Notice or to exercise your rights, please email us at contact@lean-fro.org. You also may write to: 160 Alewife Brook Pkwy #1212, Cambridge, MA 02138-1121, Attn: Lean FRO - Privacy.