This Privacy Policy (“Policy”) describes how LeanOnMe (“we”, “us” or “our”) collects, protects, and uses the personally identifiable information (“Personal Information”) you (“User”, “you” or “your”) may provide on the website, services, or applications we offer, including our AI-based mental health support bot Leany on WhatsApp and other platforms (collectively, “Website” or “Services”).

It also describes the choices available to you regarding our use of your Personal Information, how you can access and update this information, and your rights under applicable data protection laws, including the General Data Protection Regulation (GDPR). This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

The information collected through our website will be under the responsibility and charge of:

• Company Name: LeanOnAI Inc. 
• Website: leanonme.ai
• Contact Email: info@leanonme.ai

1. Collection of Personal Information

We receive and store any information you knowingly provide to us when you interact with our services, including but not limited to:

a) Online Forms and Surveys: We collect information such as your name, country, chosen user name, email address, phone number, and other relevant data. This information is used to provide and personalize our services, respond to inquiries, and improve our offerings.

b) Onboarding and Assessment Data: During the onboarding process, we collect your chosen user name, age range, and your current safety status, including whether you are in an emergency situation. We also administer assessments such as the Generalized Anxiety Disorder 7 (GAD-7) and Perceived Stress Scale (PSS-4) to understand your mental health status. The collection of health-related data is considered special category data under applicable data protection laws and requires explicit consent, which we obtain at the time of data collection.

c) Session Summaries and Data Collection: We collect and store summaries of each session to enhance the personalized support provided by our AI bot, Leany. This includes data on the topics discussed, user interactions, and any follow-up actions suggested. The information helps us continue conversations from where they left off and refine the quality of our support. The data collected during sessions is pseudonymized to protect user identity and is used solely for improving service quality.

You can choose not to provide us with certain information, but then you may not be able to take advantage of some of the bot features. Users who are uncertain about what information is mandatory are welcome to contact us.

2. Collection of Non-Personal Information

We collect non-personal information automatically when you visit our website. This information includes:

a) Device Information: This encompasses data such as your IP address, browser type, operating system, and unique device identifiers. This information helps us understand how our users access our services and enables us to optimize the user experience.

b) Usage Data: This includes information about how you interact with our website, such as pages visited, time spent on pages, search queries, and the date and time of access. This data is crucial for analyzing user engagement and improving the content and structure of our website.

c) Aggregated Statistics: We compile aggregated data to analyze website traffic and user behavior trends. This data does not contain personal identifiers and is used for understanding overall user patterns and preferences.

Purpose of Collection and Use:

• Analytics: Non-personal information is used to analyze trends, monitor the effectiveness of our services, and understand user interactions.
• Service Improvement: This data helps us enhance our platform, optimize content delivery, and improve the overall user experience.
• Security and Fraud Prevention: Non-personal data assists in detecting and preventing security threats, fraud, and other harmful activities, ensuring the safety and integrity of our services.

3. Use and Processing of Collected Information

We process your data for the following purposes:

• Providing and Personalizing Our Services: The data we collect helps us tailor our services to better suit your needs, including personalized content and support from our AI bot, Leany.
• Improving Customer Service: Your data enables us to respond to your inquiries more efficiently and improve our overall customer service experience.
• Communications: We may use your data to send you newsletters and updates, provided you have given your consent. You can unsubscribe from these communications at any time.
• Monitoring and Analyzing Trends: We use data to analyze usage trends and monitor the effectiveness of our services, allowing us to make necessary improvements.
• Health Data and Explicit Consent: For any health-related information, considered special category data, we obtain your explicit consent before processing it. This includes data collected during assessments and any health-related information discussed during sessions.

6. Information Sharing

We do not sell your personal information. However, we may share your data with trusted third parties in the following circumstances:

• Service Providers: We share data with service providers who assist in delivering our services, such as hosting, analytics, and customer support.
• Legal Obligations: We may disclose data if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency). This is done in compliance with applicable laws and regulations.

These disclosures are made under strict contractual obligations to ensure that your data is processed securely and lawfully.

7. Data Retention and Security

We implement reasonable administrative, technical, and physical security measures to protect your information. However, no data transmission over the internet can be guaranteed as 100% secure. While we strive to protect your Personal Information, you acknowledge the inherent risks associated with data transmission over the internet.

Data Retention Periods:

• Personal Data: We retain your personal data only for as long as is necessary for the purposes outlined in this Policy, such as providing our services, complying with legal obligations, and resolving disputes. The specific duration may vary depending on the nature of the data and the purpose for which it is processed. For instance, session summaries and assessment data are retained to ensure continuity of care and service quality.

• Health Data: Health-related data, considered special category data, is treated with additional care and is only retained for the period necessary to fulfill the purposes for which it was collected. This data is securely deleted when it is no longer needed, unless a longer retention period is required by law or necessary for legal proceedings.

• Anonymized Data: Data that has been anonymized or pseudonymized may be retained for a longer period for research, statistical analysis, and service improvement purposes, as this data cannot be used to identify individual users.

Circumstances for Extended Retention:
In certain circumstances, we may retain your data for longer periods if it is necessary to comply with legal obligations, resolve disputes, enforce our agreements, or for other legitimate business purposes. For example, if you have a legal dispute with us, we may retain relevant data until the matter is resolved.

Security Measures:
We maintain reasonable administrative, technical, and physical safeguards to protect against unauthorized access, use, modification, and disclosure of Personal Information under our control and custody. These measures include encryption, access controls, and regular security audits to ensure the ongoing integrity and confidentiality of your data.

Despite our best efforts, please be aware that no security measures are perfect or impenetrable. We cannot guarantee absolute security of your data, especially during transmission over the internet. In the event of a data breach, we will take appropriate measures to mitigate the impact and notify affected individuals as required by law.

8. Information Transfer and Storage

We may transfer and store your personal data internationally, including in countries outside the European Economic Area (EEA). When we do so, we ensure that appropriate safeguards are in place to protect your data. This includes:

• Legal Bases for Transfers: We rely on legally approved mechanisms such as the Standard Contractual Clauses (SCCs) adopted by the European Commission, ensuring compliance with EU data protection requirements.

• Adequate Safeguards: We implement additional safeguards where necessary, including encryption and data minimization, to protect your data during transfer.

• EU Representative (in process): See info above.

In the interim, if you have any concerns or questions regarding the processing of your personal data or require further information on our compliance with EU data protection laws, please contact us at info@leanonme.ai.

9. The Rights of Users

Under applicable data protection laws, including GDPR, you have specific rights regarding your personal data. These rights include:

• Access Your Personal Data: You have the right to request a copy of the personal data we hold about you and to confirm how we use your data.

• Correct Incomplete or Inaccurate Data: You have the right to request that we correct any inaccurate or incomplete data we hold about you.

• Erase Your Personal Data: You can request that we delete your personal data, under certain conditions, such as if the data is no longer necessary for the purposes for which it was collected.

• Restrict Our Handling of Your Personal Data: You have the right to request that we limit the processing of your personal data in certain circumstances, such as if you contest the accuracy of the data or if the processing is unlawful but you oppose the deletion of the data.

• Transfer Your Personal Data: You can request that we provide you or a third party with a copy of your personal data in a structured, commonly used, and machine-readable format.

• Object to How We Are Using Your Personal Data: You have the right to object to our processing of your personal data when the processing is based on our legitimate interests, public interest, or direct marketing.

• Withdraw Your Consent: If we rely on your consent to process your personal data, you can withdraw your consent at any time. Please note that withdrawing your consent does not affect the lawfulness of processing based on consent before its withdrawal.

Please note that these rights are not absolute and may be subject to certain conditions and exceptions under applicable law.

If you have any concerns about how we handle your personal data, you also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO). If you are based outside the UK, you can find your relevant supervisory authority here.

For further information or to exercise your rights, please contact us at contact@leanonme.ai.

10. System Logs and Maintenance

For operational and maintenance purposes, our website and any third-party services it utilizes may collect system logs. These logs may include your IP address, details about your device, and the times you accessed our services. This data is used solely for ensuring the smooth and secure operation of our services and is not used for other purposes.

11. Information Not Contained in This Policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

12. Do Not Track Signals

Our website does not currently recognize or respond to browser-initiated Do Not Track signals. This means that we do not alter our data collection and usage practices when we detect such a signal from your browser. However, some third-party services we use may track your browsing activities. We encourage you to review the privacy policies of these third-party services to understand their practices regarding Do Not Track signals.

13. Privacy of Children

We do not knowingly collect any Personal Information from children under the age of 16. If you are under the age of 16, please do not submit any Personal Information through our website or Service.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through our website or Service without their permission.

If you have reason to believe that a child under the age of 16 has provided Personal Information to us through our website or Service, please contact us. You must also be at least 16 years of age to consent to the processing of your personal data in your country (in some countries we may allow your parent or guardian to do so on your behalf).

14. Newsletters

We offer electronic newsletters to which you may voluntarily subscribe at any time. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.

15. Cookies

The website uses “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer.

Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. We may use cookies to collect, store, and track information for statistical purposes to operate our website and Services.

To learn more about cookies and how to manage them, visit internetcookies.org.

Visit this link to read our Cookie Policy.

16. Google Remarketing Tag

You can opt out of Google Marketing Platform’s use of cookies by visiting the Google Marketing Platform opt-out page or the Network Advertising Initiative opt-out page.

17. Links to Other Websites

Our website contains links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or third parties.

We encourage you to be aware when you leave our website and to read the privacy statements of each website that may collect Personal Information.

18. Information Security

We secure the information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody.

However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

19. Data Breach

In the event, we become aware that the security of the website has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities.

In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the website, and send you an email.

20. Legal Disclosure

In the event, we go through a business transition, such as a merger or acquisition by another company, or the sale of all or a portion of its assets, your user account, and personal data will likely be among the assets transferred.

21. Legal Information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

22. Changes and Amendments

We reserve the right to modify this Policy relating to the website or Services at any time, effective upon posting of an updated version of this Policy on the website. When we do, we will revise the updated date at the bottom of this page. Continued use of the Website after any such changes shall constitute your consent to such changes.

23. Acceptance of This Policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the website or its Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Website and its Services.

Owner and Data Controller

• Company Name: LeanOnAI Inc.
• Website: leanonme.ai
• Message: info@leanonme.ai

This document was last updated on Dec, 2024