PRIVACY POLICY
Last updated: August 8, 2025
Effective date: August 8, 2025
1. Who we are
This privacy policy ("Privacy Policy") describes how LeadSpring collects and processes users' personal data in compliance with EU Regulation 2016/679 ("GDPR") and applicable national legislation.
Data controllers:
- Snowinch S.L. – Developer and owner of the LeadSpring platform
- Address: Calle las Dalias, 12, Canary Islands 35100, Spain
- Email: info@snowinch.com
- Adevolution S.L. – Seller and responsible for marketing activities
- Address: Calle las Dalias, 12, Canary Islands 35100, Spain
- Email: info@adevolution.eu
Important notes:
- The Controllers act as joint controllers for joint activities (e.g., management of registered users, billing, marketing).
- Snowinch S.L. also acts as a data processor for data collected from end users through quizzes created by clients.
2. Types of data processed
Data provided directly by the user:
- First name, last name
- Email address
- Phone number
- Payment information (managed through secure external providers, e.g., Stripe)
- LeadSpring account login credentials
- Content entered in quizzes created by the user
Data collected automatically:
- IP address
- Log data and platform usage
- Device and browser information
- Cookies and similar technologies (see Cookie Policy)
Data collected through user quizzes:
- When you use LeadSpring to create quizzes and collect data from third parties, Snowinch S.L. acts as a data processor on your behalf.
- You remain the owner of the collected data and are responsible for providing appropriate privacy information to your respondents.
- Data is saved on secure storage systems (e.g., DynamoDB database) and will only be accessible to the registered user who owns the quiz ("owner").
Anonymous/aggregated data on quiz responses:
- In addition to the personal data mentioned above, LeadSpring collects and generates anonymous and/or aggregated data related to responses provided in quizzes (e.g., completion rates, choice distribution, average response times).
- This data does not allow direct or indirect identification of the data subjects and is used exclusively for statistical analysis, benchmarking, and platform improvement.
- Anonymous/aggregated data is not subject to GDPR rights as it does not constitute personal data.
3. Purposes and legal bases of processing
| Finalidad / Purpose / Zweck / Propósito / Finalité / الغرض | Base giuridica / Legal Basis / Rechtliche Grundlage / Base legal / Base juridique / الأساس القانوني |
|---|---|
| User account creation and management | Contract (Art. 6.1.b GDPR) |
| Payment processing and management | Contract / Legal obligation (Art. 6.1.b/c GDPR) |
| Customer support and technical assistance | Contract (Art. 6.1.b GDPR) |
| Sending commercial communications and newsletters | Consent (Art. 6.1.a GDPR) |
| Platform improvement and statistical analysis | Legitimate interest (Art. 6.1.f GDPR) |
| Tax and legal compliance | Legal obligation (Art. 6.1.c GDPR) |
| Security management and fraud prevention | Legitimate interest (Art. 6.1.f GDPR) |
4. Providers and sub-processors
For service delivery, we use trusted providers who act as data processors:
- Hosting providers (servers located in the European Union)
- Online payment services (e.g., Stripe, PayPal)
- Email marketing and CRM platforms
- Analytics services (e.g., Google Analytics, subject to anonymization or consent)
The updated list of sub-processors is available upon request by writing to support@leadspring.app.
5. Extra-EU data transfers
If some providers process personal data outside the European Economic Area, we ensure that the transfer occurs:
- To countries with adequacy decision from the EU Commission; or
- Based on Standard Contractual Clauses approved by the EU Commission and additional security measures where necessary.
6. Data retention
- Account data: until deletion request or account closure + 24 months
- Billing data: 10 years (legal obligation)
- Data collected through quizzes: for the duration of the subscription and up to 90 days from its termination, unless early deletion is requested
- Cookies and navigation data: as specified in the Cookie Policy
7. User rights
The user can exercise the following rights:
- Access to their personal data
- Rectification or update
- Deletion ("right to be forgotten")
- Limitation or opposition to processing
- Data portability
- Revocation of consent at any time
- Complaint to the Data Protection Authority
To exercise their rights, the user can send a request to support@leadspring.app.
8. Security
We adopt appropriate technical and organizational measures, including:
- Encryption of data in transit and at rest
- Regular backups and disaster recovery procedures
- Role-based access controls
- System activity monitoring and logging
9. Cookies and similar technologies
The use of cookies and similar technologies is governed by our Cookie Policy, available on the website.
10. Changes to this policy
We may update this Privacy Policy at any time. The updated version will be published on the site with indication of the modification date.