Privacy Policy

1. Introduction

We, LeverX companies’ group (“Company” or “LeverX”), are committed to protect the rights and privacy of customers and ensure the security of their personal data. This privacy policy describes how we collect, store, use your personal data. This privacy policy is in effect when you access the Company's services, navigate our websites, and interact with the LeverX, DataLark, and Emerline trademarks.

1.1. Data controller

Unless otherwise specified in the service-specific privacy notice, the data controller responsible for processing your information depends on your location:

• LeverX Inc. (801 Brickell Avenue, Suite 1970, Miami, Florida, 33131, USA) for users of LeverX / DataLark/Emerline based in the USA or other countries, not listed in this section;
• LeverX International Company LLC (801 Brickell Avenue, Suite 1970, Miami, Florida, 33131, USA) for users of LeverX based in the USA;
• LeverX Lithuania, UAB (Lvivo g. 25-702, Vilnius) for users of LeverX / DataLark/Emerline based in Lithuania;
• LeverX GmbH (Bergheimer Strasse 147 EG, 69115 Heidelberg, Germany) for users of LeverX / DataLark/Emerline based in Germany;
• LeverX Poland LLC (Marszałka Józefa Piłsudskiego St. 69, 50-019, Wrocław, Poland) for users of LeverX / DataLark/Emerline based in the Republic of Poland and other European countries;
• LeverX Kazakhstan LLC (Republic of Kazakhstan, 010000, Astana city, Nura district, Kabanbay Batyr Avenue, building 15A, Business center Q, office A4-4) for users of LeverX / DataLark/Emerline based in the Republic of Kazakhstan;
• LeverX Georgia LLC (12 Merab Aleksidze St, 0171 Tbilisi, Georgia) for users of LeverX / DataLark/Emerline based in Georgia;
• LeverX Bulgaria EOOD (55 Nikola Y. Vaptsarov blvd, Expo-2000, phase 4, floor 5, Hladilnika Industrial zone, 1407 Sofia) for users of LeverX / DataLark/Emerline based in the Republic of Bulgaria;

Your requests or complains as data subjects can be addressed to any company listed above by email [email protected] or by address specified above.

The Company may process Your personal data as a separate controller, but the Company may also process personal data as a joint controller.

Agreements are concluded between the Company and the other data controller to determine the responsibilities for compliance with the obligations under the Regulation, to define the roles of the joint controllers, and to define the relationship with the data subject. The data subject shall be given access to the material provisions of this agreement upon written request of the data subject. The data subject may exercise his or her rights under the Regulation in relation to each of the controllers.

1.1. Privacy principles

When processing personal data, the Company ensures the inviolability of each person's private life, strictly complies with GDPR and other applicable legal acts, as well as these principles:

• Legitimacy, fairness and transparency
• Purpose limitation
• Data minimisation
• Accuracy
• Storage limitation
• Integrity and confidentiality
• Accountability

1.2. Terms of Use

By accessing, using, or availing yourself of the resources in any manner, or using, registering, downloading, or installing the applications, websites and services, You acknowledge that You have read this agreement and understand the rights, obligations, terms, and conditions set forth herein.

The websites, applications, and services are available only to individuals who are at least 18 years old.

2. How Do We Collect data about You?

Personal data processed by the Company can be obtained from the following sources:

• Directly from You (e.g., in order to apply for vacancies in the Company, you submit your resume, participate in virtual meetings);
• When using the Company's services, visiting the website (e.g., submitting inquiries by e-mail), for additional information please refer to Cookie Declaration;
• From third parties (e.g., the Company receives your data from Your company as a representative from your workplace).

3. What personal data do we process, for what purposes and legal bases as a data processor?

As a data processor, we meticulously gather and meticulously handle personal data on behalf of data controllers. We take the security and privacy of personal data seriously and adhere to all relevant data protection laws.

If you have any inquiries or concerns regarding the handling of your personal data or if you intend to exercise your rights as a data subject, kindly reach out to the respective data controller directly. Rest assured that we will promptly relay your inquiries and requests for the exercise of your rights to the relevant data controllers, facilitating swift and appropriate action.

4. What personal data do we process, for what purposes and legal bases as a data controller?

4.1. Personal data processing for the purpose of recruitment

In order to carry out the recruitment process and conclude an employment contract when you apply for vacancies on the website career.leverx.com/vacancies, we process the following personal data of candidates: name, surname, date of birth, personal phone number and e-mail address, information about education (educational institution, period of study), information about qualifications, work experience and language skills as well as other information provided in the submitted documents.

Legal basis for data processing: the data subject's consent (Article 6(1)(a) GDPR).

Personal data retention period: 5 years after the end of the selection for the job position.

More information can be found here.

4.2. Personal data processing for the purpose of maintaining communication with business clients and their representatives

In order to maintain communication with business clients and its representatives, we process the following personal data: name, surname, phone number, email, workplace, job position.

Legal basis for data processing: the legitimate interest of the controller in ensuring communication with business customers (Article 6(1)(f) of GDPR).

Personal data retention period: 10 years after the end of the contractual relationship.

4.3. Personal data processing for the purpose of responding to Your request for information, order or support

In order to provide response (online or offline) in connection with a request for information, to order a product or service, to provide You with support or to participate in a forum, we process the following personal data: name, surname, contact information (telephone number, e-mail address) details about Your request.

Legal basis for data processing: legitimate interest of the controller in ensuring communication with business clients (Article 6(1)(f) of GDPR).

Personal data retention period: 1 year after the resolution of the request.

4.4. Personal data processing for the purpose of providing customer service

In order to provide customer service using the live chat function on our website, we process the following personal data: IP address, data collected by cookies, other information provided during communication.

Legal basis for data processing: legitimate interest of the controller in ensuring communication (Article 6(1)(f) GDPR).

Personal data retention period: 1 year.

4.5. Personal data processing for the purpose of administration of the Company documents (Correspondence)

In order to administrate received documents, we process the following personal data of our clients and other persons who submitted the document: name, surname, personal ID number, date of birth, other data specified in the document.

Legal basis for data processing: legitimate interest of the controller in ensuring document administration (Article 6(1)(f) of GDPR).

Personal data retention period: data is stored according to the legal provisions, depending on the category of the document, but no longer than it is necessary to achieve the purpose.

4.6. Personal data processing for the purpose of promoting recognition (administration of social networks)

In order to administrate social network profiles, we process the following personal data of visitors and followers of social networks whose accounts are administered by the Company: information You provide including messages, use of the "Like" and "Follow" fields, and other communications.

Legal basis for data processing: legitimate interest of the controller in ensuring promotion of the Company (Article 6(1)(f) of GDPR).

We can collect your data when you visit Company’s social profiles, press Follow or Like, use direct messages, or the data are published on your social profiles. The information You provide on social network profiles operated by the Company is controlled by the social network manager. We therefore recommend that You read the privacy notices of the social network manager, in which data processing operations and storage terms are described in detail.

As the administrator of the Company’ social networking account, we select the appropriate settings based on our target audience and our performance management and promotion objectives. The social network manager may have limited the ability to change certain, essential settings by providing the Company with the ability to create and manage a social network account, and thus we cannot influence what information the social network manager will collect about You once the Company has created a social network account.

4.7. Personal data processing for the purpose of providing registration to courses

In order to provide courses when you apply on the website leverx.com/career/courses, we process the following personal data of our clients and other persons who submitted the application: name, surname, date of birth, phone number, email, English level, education, work experience in IT.

Legal basis for data processing: fulfillment of a contract (Article 6(1)(b) GDPR).

Personal data retention period: 10 years after the end of a contract.

More information can be found here.

4.8. Personal data processing for the purpose of providing registration to events and meetups

In order to provide events and meetups when you apply on the website https://leverx.com/career/external-events, we process the following personal data of our clients and other persons who submitted the application: name, surname, email, phone number, job position, company name.

Legal basis for data processing: contract (Article 6(1)(b) GDPR). A b f

Personal data retention period: data is 1 year.

More information can be found here.

4.9. Personal data processing for the purpose of providing registration to education courses

In order to provide educational programs courses when you apply on the website https://career.leverx.com/intro-to-it, we process the following personal data of persons who submitted the application: Name, surname, email, phone number, job position, company name.

Legal basis for data processing: performance of a contract (Article 6(1)(b) GDPR).

Personal data retention period: 10 years after the end of education courses.

4.10. Personal data processing for the purpose of providing free trial of DataLark software

In order to provide a free trial version of DataLark software, we process the following personal data of persons who are seeking to download trial version: name, surname, email (business), company, comment information.

Legal basis for data processing: performance of a contract (Article 6(1)(b) GDPR).

Personal data retention period: 10 years.

4.11. Personal data processing for the purpose of providing virtual meetings

In order to provide virtual meetings We use video conference systems (Zoom, Microsoft Teams, WebEx or another system) to hold conference calls, online meetings, video conferences and/or webinars (hereinafter “online meetings“). We process the following personal data of persons who are attending virtual meetings: Name, email, image, voice.

Legal basis for data processing: legitimate interest of the controller in effective execution of online meetings. (Article 6(1)(f) GDPR).

Personal data retention period: 1 year.

4.12. Personal data processing If you use Emerline or DataLark services

You can find all the information related to data processing for Emerline service by visiting the provided link, or alternatively, for the DataLark service, by visiting this link.

4.13. Managing the live chat function on websites

To ensure optimal user experiences and customer service while visiting the Company's websites and utilizing the live chat feature, we handle the following personal data of individuals engaging with the Company: correspondence and the accompanying personal data, initiated by the data subject themselves, IP address.

Legal basis for data processing: legitimate interest of the controller providing customer service on the website and answering queries (Article 6(1)(f) GDPR).

Personal data retention period: 1 year

5. Personal data recipients and processors

We as a data controller may disclose personal information that we collect or You provide as described in this Privacy Policy:

• Public bodies and institutions, individuals entrusted with statutory functions (such as law enforcement agencies, bailiffs, notaries, tax authorities, regulatory bodies, and financial crime investigators)
• Accredited auditors, as well as legal and financial advisors
• Legal entities under your representation
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

We may also disclose Your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our clients, our customers, or others.

We may use data processors who will process personal data in accordance with our instructions and to the extent determined by us, to the extent necessary to achieve the purposes of the processing. When we use processors, we aim to ensure that the processors have also implemented appropriate organizational and technical security measures and maintain the confidentiality of personal data.

6. Transfer of personal data outside the EU/EEA

Your personal data may be transferred outside the European Union, subject to the signing of agreements with data processors that comply with European Union law.

Data may be transferred outside the European Union where the transfer is necessary for the conclusion and performance of contracts and the proper provision of services to the Company's customers. In such a case, the Company shall take steps to ensure that any transfer of personal data outside the EU/EEA is properly executed and that the privacy rights of data subjects are maximally protected. The Company's transfer of personal data outside the EU/EEA shall be guided by:

• A foreign country adequacy decision issued by the European Commission;
• A certification mechanism approved in the foreign country;
• A decision adopted by the European Commission on standard contractual clauses.

The third country outside the EU/EEA where the recipient of the personal data is located is required by a decision of the European Commission to ensure an adequate level of protection of personal data.

7. Profiling and automated decision-making

The Company does not engage in profiling and automated decision-making that would result in significant consequences for You or have a significant impact on You.

8. Your rights regarding the personal data you provide to us

All data subjects are entitled to:

• ask what information we hold about them and why; This means that You can ask us what personal data of Yours is processed. You can also ask for clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties which have access to information. You have a right to request from us Your personal data in a structured, commonly used, and machine-readable format.
• have inaccurate personal data corrected or removed; This means You can require all the inaccurate personal data concerning You being corrected. You can also complete the personal data if You feel there is a need to do so;
• prevent us from processing information or request that it is stopped if the processing of such data is likely to cause substantial, unwarranted damage or distress to the individual or anyone else, etc.;

In some cases, prescribed by the applicable laws You can object to the processing of Your personal data.

You have a right to object to the processing of Your personal data when the processing is related to the performance of our task carried in the public interest or in the exercise of official authority vested in us, or we process Your data to pursue our or third party’s legitimate interests, and You believe that such interests are overridden by Your interests or fundamental rights and freedoms.

If You make a request objecting to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing;

Please note that when the processing of Your personal data is carried out for direct marketing purposes, You have the right to object at any time to such processing without providing any justification. We will no longer process Your data for such direct marketing purposes. You may refer to relevant sections of this Privacy Policy to learn whether we process Your data for direct marketing purposes;

• require us to ensure that no decision which significantly affects an individual is solely based on an automated process for the purposes of evaluating matters relating to him/her, such as to conduct or performance;
• be informed of what we are doing to comply with our obligations under the applicable data protection laws.

Subject to the personal data protection regulations applicable to You, You may request us to erase Your Personal Data without undue delay. The request shall be made on the legal grounds provided in the information protection regulations applicable to You, which include among others:

-  the personal information is no longer necessary in relation to the purposes for which they were collected or otherwise processed;

-  You withdraw Your consent on which the processing is based according to the provisions of the applicable to You information protection regulations and where there is no other legal ground for the processing;

-  You object to the processing pursuant to the applicable information protection regulations and there are no overriding legitimate grounds for the processing or the information subject objects to the processing;

-  the personal information has been unlawfully processed;

-  the personal information has to be erased for compliance with a legal obligation in the USA, European Union, or the law to which we are subject.

-  lodge a complaint with the State Data Protection Inspectorate or a court in relation to the processing of personal data.

You may lodge a complaint against the actions or omissions of the Company in relation to the exercise of the data subject's rights to the data protection supervisory authority. A list of supervisory authorities and contact details can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

You may also ask us to receive Your Data and have it transferred to another Data controller. In this case, You have the right to receive Your Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

If You cannot access certain information and personal data collected by LeverX, You can always contact LeverX by using our contact form. We will respond to requests to access or delete Your personal data within 30 days.

Any requests to exercise Your rights can be directed to us through the contact details provided below.

9. How do we protect your information?

The security of Your Personal Data is important to us. We follow generally accepted standards to protect the Personal Data submitted to us, both during transmission and after it is received. We process Your Data using computers and/or other IT-enabled tools. We take technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage. We also guide and train our personnel to process Your data securely according to our internal data protection policies. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage, and processing practices to update our physical, technical, and organizational security measures. We may suspend Your use of all or part of the services without notice if we suspect or detect any breach of security. If You believe that Your account or information is no longer secure, please notify us immediately at [email protected].

All LeverX companies, all our staff, and third parties whenever we hire them to provide support services, are required to observe our privacy standards and to allow us to audit them for compliance.

10. Changes to the policy

LeverX reserves the right to modify or amend this Privacy Policy at its own discretion from time to time. The changes can be viewed here or elsewhere on LeverX websites, services, and applications. Your continued use of LeverX websites, services, and applications constitutes Your acceptance of those changes.

This version was last updated in February 2025, and previous versions can be obtained by contacting LeverX.

11. Contact details

If there are any questions regarding this privacy policy, You may contact us using the information below.

• LeverX Lithuania, Lvivo g. 25-702, Vilnius, Lithuania;
  Email: [email protected]
• LeverX Inc., 801 Brickell Avenue, Suite 1970, Miami, Florida, 33131, USA;
  Email: [email protected]
• LeverX GmbH, Bergheimer Strasse 147 EG, 69115 Heidelberg, Germany;
  Email: [email protected]
• LeverX Poland LLC, Marszałka Józefa Piłsudskiego St. 69, 50-019, Wrocław, Poland;
  Email: [email protected]
• LeverX Kazakhstan LLC, Republic of Kazakhstan, 010000, Astana city, Nura district, Kabanbay Batyr Avenue, building 15A, Business center Q, office A4-4;
  Email: [email protected]
• LeverX International Company LLC, 801 Brickell Avenue, Suite 1970, Miami, Florida, 33131, USA;
  Email: [email protected]
• LeverX Georgia LLC, 12 Merab Aleksidze St, 0171 Tbilisi, Georgia;
  Email: [email protected]
• LeverX Bulgaria EOOD, 55 Nikola Y. Vaptsarov blvd, Expo-2000, phase 4, floor 5, Hladilnika Industrial zone, 1407 Sofia;
  Email: [email protected].