Last updated: July 3, 2019

Protecting your privacy and Personal Data are of great importance to us. We have therefore published this privacy policy (“Privacy Policy”) to explain how we, Leap Ltd. and its affiliates (“we” or “us”), collect, use, share and otherwise process Personal Data (defined below). This Privacy Policy is intended to cover our handling of Personal Data which we collect and receive from the users of and visitors to our website, (the “Site”), our business contacts (such as representatives of actual or potential customer, suppliers or service providers) and other third parties who provide us with Personal Data. “Personal Data” means information which relates to an identified or identifiable natural person.

Information we Collect and How we Use it

We collect and receive Personal Data from you in the following manner and use that information for the following purposes. 

  • Newsletter or Marketing Sign Up. In the event you sign up to receive promotions, newsletters or other commercial or marketing communications from us, we will use the information you provide (such as your name and email address) to send you such communications. You may contact us at any time to request that we stop sending you such communications or opt-out of such communications by using the “unsubscribe” link at the bottom of e-mails we send.
  • Business Contact Information. We collect information from our business contacts and customers in a number of ways, for example if you have provided us with your business card or contact card (including electronically); if you have sent us an e-mail which lists your contact information (for example as part of your e-mail signature); if you have signed up with us at a trade exhibition or at another event; or if you have entered into an agreement with us and have provided contact information as part of the agreement. We use such to contact our business contacts and customers regarding products or services they have purchased from us or which may be of interest to them, regarding business collaborations, or products or services we have purchased or may purchase from them, in the case of suppliers or service providers of ours.
  • Log Files. We use log files generated by your visits to and activity on our Services. Log files record information such as your internet protocol (IP) address, browser type, device type, Internet Service Provider (ISP) identity, a date/time stamp for user actions, the URLs referring/exit pages, the URL of clicked pages, error information. We will use this information to present relevant information to you and provide you with the Services, analyze activity on the Services, and improve our Services. 
  • Cookies. We use “cookies”, small text files sent to your computer and then sent back by your Web browser to a website or other online service to retrieve the information in the cookie (for instance, whether you visited a website previously, or have already logged into an online account). “Session” cookies are temporary cookie files that last until you close your browser at which point they are deleted. “Persistent” cookies remain on your device until you or your browser deletes them, or for the period set in the specific cookie. Cookies are used to enable the customization of online services to your preference or previous activity. Cookies might be used to store language preferences or other settings without having to reset them every time you visit a website. You may delete cookies or block cookies from your device, by changing the preferences in your browser. We use services like Google Analytics which use cookies on our Site, as described further below.
  • Usage Data and Analytics Services. We collect and analyze information about how you use and access the Site using services and tools provided by third parties (collectively, “Analytics Services“), such as (but not limited to) Google Analytics, as described further below. Google Analytics collects information such as how often users visit our Site, what pages or parts of the Site they visit and access, what other websites or applications they used prior to accessing our Site and IP addresses. Google Analytics makes use of technologies like cookies and other tracking technologies. We use the information we receive from Google Analytics to maintain and improve our Site and other products and services. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to our Services is governed by the Google Analytics Terms of Service, available at, and the Google Privacy Policy, available at You may learn more about how Google collects and processes data specifically in connection with Google Analytics at (in the section titled, “How Google uses data when you use our partners’ sites or apps”). You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at

Sharing Your Information with Third Parties

We do not disclose or share your Personal Data with other people or companies except to provide the Services, products or other services you’ve requested, or under the following circumstances:

  • We have your explicit consent to share the information.
  • We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
  • We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service, or as otherwise required by law.
  • We may transfer information that we collect if we will be acquired by or merged with another company. If that should occur, user information is typically one of the assets that get transferred. Similarly, if Fralis LLC or most of its assets were acquired, or in the unlikely event that we go out of business or enter bankruptcy, user information could be transferred or acquired. You should be aware that such events can occur, and you allow us to transfer your information in such event. If such event occurs, the buyer may continue to use your information. In such events, we will notify you before information about you is transferred and use best efforts to require our successor to comply with this privacy policy.
  • We may share your information with service providers who process data on our behalf in order to operate and improve the features and functionality of the Services; complete your payment transactions; fulfill your product or service requests, including sales, delivery and support requests; and help us communicate with you as described elsewhere in this policy; these providers are subject to strict data protection requirements.

Your Rights Under the GDPR

Subject to certain exceptions and exclusions, the following rights apply to individuals who are protected by Regulation (EU) 2016/679, known as the General Data Protection Regulation (the “GDPR”). This includes, but may not be limited to, individuals who reside in, and who are citizens of, EU member states. If you are such a person, then:

  • Right of Access. You may request that we confirm to you whether or not we store Personal Data about you and to provide you with a copy of the Personal Data we maintain about you and information about: (a) the purposes of the processing of the Personal Data; (b) the categories of Personal Data being processed; (c) the names of the recipients or the categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations; (d) if possible, the period we believe we will store the Personal Data, or the criteria we use to determine that period; (e) the sources of the Personal Data, if not collected from you; and (f) whether we use automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
  • Right to Rectify. You may request that we rectify any Personal Data about you that we maintain that is incorrect. Depending on the purpose for which the data is used, this may also include the right to complete incomplete Personal Data.
  • Right to Erasure (“Right to be Forgotten”). You may request that we erase or suppress Personal Data that relates to you in the following cases: the data is no longer needed by us; when the data is collected with your consent and you withdraw that consent; when you have a right to object to our use of the data (as described below under, “Right to Object”); we are not lawfully processing the data; or we are otherwise required by law to delete the data. However, there may be circumstances in which we may retain your data or we may refuse your request, for example when we review the data to defend ourselves or make legal claims or exercise are own rights. In addition, this right may not apply to the display or access of your Personal Data outside of the European Union. 
  • Right to Restrict Processing. You may request that we restrict our use or processing of your Personal Data if: you claim the Personal Data is inaccurate, during the time we investigate your claim; our processing of the Personal Data was unlawful; we no longer require the Personal Data; we processed the Personal Data for our legitimate interests and you object to this use (as you are permitted to do under Article 21(1) of the GDPR), during the time that we investigate whether our legitimate interests override your request. However, there may be circumstances in which we are legally entitled to refuse your request.
  • Right to Data Portability. You may request that we provide you with your Personal Data that we process based on your consent or to fulfill a contract with you or that we process using automated means, in a structured, commonly used and machine-readable format, and to transfer your Personal Data to another entity or have us transfer it directly to such entity.
  • Right to Object. You may, based on reasons specifically relating to you, to object to our processing of your Personal Data, when: (i) the data is used for our legitimate interests and our interests in processing the data does not override your interests, rights and freedoms and we do not require use of the data for the establishment, exercise or defense of our legal claims or rights; and (ii) we use the data for direct marketing purposes or profiling for direct marketing purposes. 
  • Right to Object to Automated Decision Making. You may request that you not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you.
  • Right to Withdraw Consent. Where we process Personal Data relating to you based on your consent (such as by clicking a check box adjacent to a statement of consent), you may withdraw your consent and request that we cease using your Personal Data for the purpose for which you have your consent, or altogether, depending on the situation. 
  • Right to Make a Complaint. You may file a complaint regarding our practices with the data protection authority in your place of habitual residence, place or work, or the place of the alleged infringement. For a list of data protection authorities in the European Economic Area, please see here:   

You can exercise your rights that apply to us by contacting us by email at [email protected]

We may be permitted by law (including the GDPR and local national laws) to refuse or limit the extent to which we comply with your request. We may also require additional information in order to comply with your request, including information needed to locate the information requested or to verify your identity or the legality of your request. To the extent permitted by applicable law, we may charge an appropriate fee to comply with your request.

Transfer of Information Outside Your Jurisdiction

We may store and process information in sites located throughout the world, including in sites operated and maintained by cloud based service providers. For information on our cloud service providers and sub-processors please contact our support at [email protected].


If you are an individual protected by the GDPR, you may contact us at [email protected] in order to obtain additional information regarding the basis for the transfer of Personal Data relating to you to countries outside the European Economic Area. Please note that information or copies of documents we may provide to you in connection with such requests may be limited or redacted in order to protect the rights of third parties or to comply with contractual obligations we may have (such as obligations of confidentiality).

Information Regarding Children

We do not collect any identifiable information from children under the age of 16. If you believe that a child has provided us with personally identifiable information without the consent of his or her parent or guardian, please contact us at [email protected].

If we become aware that a child under age 16 has provided us with personally identifiable information, we will remove it.

Your California Privacy Rights 

If you are a California resident you have the right under California law to make certain requests in connection with our use of Personal Data relating to you, as described below. To make such a request, please contact us by email at [email protected]. Please note that certain exceptions may apply.

  • Disclosure of Direct Marketing Practices. Under California Civil Code Section 1798.83, one time per year you may request the following information regarding our disclosure of your Personal Data to third parties for their direct marketing purposes: a list of the categories of the personal information disclosed to such parties during the preceding calendar year, the names and addresses of such third parties, and if the nature of the parties’ businesses is not clear from their names, examples of the products or services marketed by such third parties.
  • Removal of Public Information. If you are under the age of 18 and have an Account, under California Business and Professions Code Section 22581, you may request the removal of content or information you have publicly posted that is identified with you or your account. Please be aware that certain exceptions may apply and we may not be able to completely remove all such information.

California Do Not Track Notice

We do not track individuals’ online activities over time and across third party Web sites or online services (though we do receive information about the webpage you visited prior to accessing the Site). However, we analytics service-providers like Google to collect personally identifiable information about an individual consumer’s online activities when a consumer uses the Sites as part of our use. We do not respond to Web browser “do not track” signals or similar mechanisms.

Anonymous or Aggregated Data

We do not treat information we collect or receive which cannot be connected to any particular person or which is anonymized or aggregated such that it can no longer be connected to or used to identify any particular person as Personal Data even if it was originally linked to or stored with Personal Data. Such information cannot be used to identify you or any other person. We use anonymous information internally for a variety of purposes, may share it with third parties or even publish it for any reason.

Changes to this Policy

We may update this policy from time to time. We will notify you about significant changes in the way we treat information by sending a notice to the primary email address specified you provided us and by placing a prominent notice on our website, and require your consent if required by law, in light of the nature of the changes.

If you do not agree to be bound by the terms of the new or modified Privacy Policy, you agree to stop using the Site or the application, as applicable. 

You may contact us with any questions at [email protected].