PRIVACY POLICY

1. Scope

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This Privacy Policy applies to personal information collected by LeaderyHub from users of the Site. It outlines our duties and your rights under:

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• Protection of Personal Information Act (“POPIA”), 2013 — South Africa
• General Data Protection Regulation (“GDPR”) — European Union
• And any other applicable global data protection regulations.

2. Who We Are

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• Entity Name: LeaderyHub PTY Ltd
• Headquarters: South Africa (operating globally)
• Contact Email: info@leaderyhub.com

We act as the “Responsible Party” (under POPIA) and “Data Controller” (under GDPR) for any personal information we collect from you in connection with our Site.

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3. Information We Collect

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We collect personal information in various ways, including when you sign up for a membership, download resources, or otherwise interact with the Site. This may include:

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1. Account Registration Details
   • Name
   • Email Address
   • Password (stored in encrypted format)
2. Usage & Device Information
   • IP address
   • Browser type and version
   • Time zone settings
   • Operating system, device type
3. Communication Data
   • Email interactions (e.g., when you contact us or subscribe to our newsletters)
   • Support requests
4. Payment Information (Future Implementation)
   • Once paid memberships or products become available, we may collect billing information (e.g., credit card details). We will use third-party payment processors compliant with POPIA, GDPR, and PCI-DSS standards.

We do not currently enable user-generated content or comments. If this changes, we will update this Privacy Policy accordingly.

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4. How We Use Your Information

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We use personal information to:

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1. Provide and Maintain Our Services
   • Create and manage your account.
   • Grant access to downloadable resources.
2. Communicate with You
   • Send important account or administrative messages.
   • Provide newsletters, updates, or promotional materials, where consent has been given.
3. Improve Our Site
   • Analyze user activity to enhance content and user experience.
   • Debug, identify errors, and troubleshoot technical issues.
4. Ensure Legal Compliance
   • Detect and prevent unauthorized or illegal activities.
   • Comply with legal requirements, court orders, and other legal obligations.
5. Future Paid Services
   • If you purchase premium memberships or digital products, we will process billing and payment information and provide customer support related to those transactions.

5. Legal Bases for Processing (GDPR)

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If you are located in the European Economic Area (EEA), our legal basis for processing your personal information may include:

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• Consent (Article 6(1)(a)): Where you have expressly given us permission (e.g., subscribing to our newsletter).
• Contractual Necessity (Article 6(1)(b)): Where processing is necessary to perform our obligations under a contract, such as providing our membership service.
• Legal Obligations (Article 6(1)(c)): When we are legally required to process your information (e.g., complying with a court order).
• Legitimate Interests (Article 6(1)(f)): Where processing is essential for our legitimate interests (e.g., improving our Site) and doesn’t override your fundamental rights.

6. Lawfulness of Processing (POPIA)

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Under POPIA, we process your personal information in a manner that is reasonable, lawful, and does not infringe your privacy. We collect only what is necessary for legitimate business purposes, such as providing our services and fulfilling our contractual or legal obligations.

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7. Data Sharing and Disclosure

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We do not sell your personal information. We only share personal information in the following circumstances:

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1. Service Providers
   • We may engage trusted third parties (e.g., hosting providers, payment processors) to help us provide services. These parties are bound by confidentiality and data protection agreements.
2. Legal and Regulatory Compliance
   • We may share information if required by law or to respond to valid legal requests (e.g., court orders, subpoenas).
3. Business Transfers
   • In the event of a merger, acquisition, or sale of assets, user information may be transferred to the acquiring entity, subject to the same confidentiality standards.

8. International Transfers

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LeaderyHub operates globally. If we transfer your personal information across borders (e.g., from the EEA or South Africa to other countries), we will ensure that:

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• Appropriate safeguards are in place (e.g., EU Standard Contractual Clauses, POPIA requirements).
• We comply with the laws governing international data transfers to protect your rights and freedoms.

9. Data Retention

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We retain personal information for as long as necessary to:

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1. Fulfill the purposes for which it was collected,
2. Comply with legal obligations,
3. Resolve disputes,
4. Enforce our agreements.

Once personal data is no longer needed, we securely delete or anonymize it.

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10. Your Rights

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Under POPIA, you have the right to:

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• Access: Request a copy of your personal information.
• Rectification: Ask us to correct inaccurate or incomplete information.
• Deletion: Request that we delete personal information (unless retention is required by law).
• Objection: Object to the processing of your personal information under certain circumstances.
• Complaints: Lodge a complaint with the Information Regulator in South Africa if you believe we are not compliant with POPIA.
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Under GDPR, EU/EEA residents have rights including:

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• Right to Access: Obtain confirmation as to whether personal data is processed and a copy of said data.
• Right to Rectification: Correct inaccurate or incomplete data.
• Right to Erasure (“Right to be Forgotten”): Request deletion of personal data under certain conditions.
• Right to Restrict Processing: Limit how we use your personal data in certain situations.
• Right to Data Portability: Receive your data in a structured, commonly used format and transmit it to another controller.
• Right to Object: Object to processing based on legitimate interests or direct marketing.
• Right to Withdraw Consent: Withdraw previously given consent at any time without affecting the lawfulness of processing before withdrawal.
• Right to Lodge a Complaint: With a supervisory authority in the EU (e.g., in your country of residence).

If you wish to exercise any of these rights, please contact us at info@leaderyhub.com.

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11. Cookies and Similar Technologies

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We may use cookies or similar tracking technologies to enhance your user experience, analyze site usage, and tailor content to user preferences. You can control how cookies are used by adjusting your browser settings. For more details, please see our [Cookie Policy] (if available) or contact us at info@leaderyhub.com.

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12. Security Measures

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We implement reasonable technical and organizational measures to secure your personal information against unauthorized access, loss, alteration, or disclosure. These measures include:

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• Encrypted data transmission (HTTPS)
• Encrypted passwords for user accounts
• Secure data storage with access controls

While we strive to protect your information, no method of transmission or storage is 100% secure. Please use strong passwords and safeguard your login credentials.

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13. Children’s Privacy

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Our Site is not specifically directed at children, and we do not knowingly collect personal information from individuals under the age of majority. If you become aware that a child has provided us with personal information without parental consent, please contact us at info@leaderyhub.com, and we will take steps to remove such data promptly.

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14. Changes to This Privacy Policy

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We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, regulatory, or operational reasons. If we make material changes, we will notify you by:

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• Posting a notice on our Site, or
• Sending you an email (if we have your email address on file).

Your continued use of our Site after these changes indicates your acceptance of the revised Privacy Policy.

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15. Contact Us

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If you have questions, concerns, or complaints about how we handle your personal information, please contact us:

• Email: info@leaderyhub.com

We will respond to your request as soon as reasonably possible and in compliance with applicable data protection laws.