Leapfrog Power Privacy Policy

Last Updated: January 20, 2023


Leapfrog Power, Inc. and its affiliates (“Leap,” “we,” “our,” and/or “us”) value the privacy of individuals who use our website, https://www.leap.energy/ (the “Site”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose Personal Information from users of the Site. As used in this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual. By using the Site, you agree to the collection, use, and disclosure of your Personal Information as described in this Privacy Policy.



INFORMATION WE COLLECT AND RECEIVE

We may collect a variety of information from or about you or your devices from various sources, as described below. If you do not provide your Personal Information when requested, you may not be able to use the Site if that Personal Information is necessary to provide you with the Site or if we are legally required to collect it.


A. Information You Provide to Us

Registration Information. When you sign up for notifications or updates, we ask you for your Personal

Information, including your name and email address.

Communications. If you contact us directly, we may receive additional Personal Information about you. For

example, when you email us, we will receive your name, email address and any additional information you

choose to provide]. If you contact us for technical support or to learn more about how to become a partner with us, we will receive your name, email address, company name, and any additional information you choose to provide.

Demo Request. If you contact us to schedule a product demo, we will receive your name, email address,

company name, and any additional information you choose to provide.

Careers. If you decide to apply for a job with us, you may submit your contact Personal Information and your resume online. We will collect the Personal Information you choose to provide us as part of your job application, such as your contact information, current employment information, and other Personal Information you choose to submit with your application and on your resume. If you apply for a job with us through a third-party platform, we will collect the information you make available to us through such third-party platforms.


B. Information We Collect When You Use the Site

Location Information. When you use the Site, we may infer your general location information. For example,

your IP address may indicate your general geographic region.

Device Information. We receive information about the device and software you use to access the Site,

including internet protocol (IP) address, web browser type, operating system version, and device identifiers

(including unique device identifiers and MAC addresses).

Usage Information. To help us understand how you use the Site and to help us improve it, we automatically

receive information about your interactions with the Site, such as the pages or other content you view and the times of your visit.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain

analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to

https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.


Information from Cookies and Similar Technologies. We may collect Personal Information using Cookies,

which are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer’s hard drive. We and our third-party partners may also use pixel tags and web beacons on the Site. These are tiny graphic images placed on web pages or in our emails that allow us to determine whether you have performed a specific action. We use cookies, beacons, invisible tags, and similar technologies (collectively “Cookies”) to collect information about your browsing activities and to distinguish you from other users of the Site. This aids your experience when you use the Site and allows us to improve the functionality of the Site. Cookies can be used for performance management (i.e., collecting information on how the Site are being used for analytics purposes). They can also be used for functionality management, enabling us to make your visit more efficient by, for example, remembering language preferences, passwords, and log-in details. Below is an overview of the types of Cookies we and third parties may use to collect Personal Information.


• Strictly Necessary Cookies. Some Cookies are strictly necessary to make the Site available to you.

We cannot provide you with the Site without these types of Cookies.

• Functional Cookies. Functional Cookies are used to recognize you when you return to the Site. This

enables us to adapt our content for you and remember your preferences. For example, we use

functional Cookies to remember your choice of language or region.

• Analytical or Performance Cookies. We also use Cookies for website analytics purposes to operate,

maintain and improve the Site. We may use our own analytics Cookies or use third-party analytics

providers. These providers may also collect information about your use of other websites, apps, and

online resources.


Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please

note that if you delete or choose not to accept Cookies from the Site, you may not be able to utilize the features of the Site to their fullest potential.


HOW WE USE THE INFORMATION WE COLLECT

We may use the Personal Information we collect:

• To provide, maintain, improve, and enhance the Site;

• To understand and analyze how you use the Site and develop new products, services, features, and

functionalities;

• For marketing and advertising purposes, such as developing and providing promotional and advertising

materials that may be relevant, valuable, or otherwise of interest to you;

• In de-identified and aggregated form for any lawful purpose;

• To find and prevent fraud, and respond to trust and safety issues that may arise;

• For compliance purposes, or as may be required by applicable laws and regulations or requested by

any judicial process or governmental agency;

• To process your job application; and

• For other purposes for which we provide specific notice at the time the Personal Information is collected.

LEGAL BASES FOR PROCESSING EUROPEAN INFORMATION

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we only process your Personal Information when we have a valid “legal basis”, including as set forth below.

• Consent. We may process your Personal Information where you have consented to certain processing

of your Personal Information. For example, we may process your Personal Information to send you

marketing communications or to use Cookies where you have consented to such use.



LEGAL BASES FOR PROCESSING EUROPEAN INFORMATION

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we only process your Personal Information when we have a valid “legal basis”, including as set forth below.

• Consent. We may process your Personal Information where you have consented to certain processing

of your Personal Information. For example, we may process your Personal Information to send you

marketing communications or to use Cookies where you have consented to such use.

• Contractual Necessity. We may process your Personal Information where required to provide you

with the Site. For example, we may need to process your Personal Information to respond to your

inquiries or requests.

• Compliance with a Legal Obligation. We may process your Personal Information where we have a

legal obligation to do so. For example, we may process your Personal Information to comply with tax,

labor and accounting obligations.

• Legitimate Interests. We may process your Personal Information where we or a third party have a

legitimate interest in processing your Personal Information. Specifically, we have a legitimate interest

in using your Personal Information for product development and internal analytics purposes, and

otherwise to improve the safety, security, and performance of the Site. We only rely on our or a third

party’s legitimate interests to process your Personal Information when these interests are not

overridden by your rights and interests.


HOW WE SHARE THE INFORMATION WE COLLECT

We do not share or otherwise disclose Personal Information we collect from you except as described below or otherwise disclosed to you at the time of the collection.

Partners and Affiliates. We may share information with our partners, corporate affiliates, parents, or

subsidiaries for any purpose described in this Privacy Policy.

Vendors and Service Providers. We may share any information we receive with vendors and service

providers retained in connection with the provision of the Site.

Marketing. We do not rent, sell, or share information about you with nonaffiliated companies for their direct

marketing purposes unless we have your permission.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain

analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to

https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

As Required by Law and Similar Disclosures. We may access, preserve, and disclose your Personal

Information if we believe doing so is required or appropriate to: (i) comply with law enforcement requests and legal process, such as a court order or subpoena; (ii) respond to your requests; or (iii) protect your, our, or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. We may disclose and transfer your Personal Information to service

providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets.

Consent. We may also disclose Personal Information from or about you or your devices with your permission.


YOUR CHOICES

Sharing Preference. To change whether certain information is publicly viewable, you can adjust the settings in your account.

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the

emails. Even if you opt out of receiving promotional messages from us, you will continue to receive

administrative messages from us.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not

respond to such signals. If you choose not to provide us with the Personal Information we collect, some features of the Site may not work as intended.


Your European Privacy Rights. If you are located in the EEA or the UK, you have additional rights described

below.

• You may request access to the Personal Information we maintain about you, update and correct

inaccuracies in your Personal Information, restrict or object to the processing of your Personal

Information, have your Personal Information anonymized or deleted, as appropriate, or exercise your

right to data portability to easily transfer your Personal Information to another company. In addition, you

also have the right to lodge a complaint with a supervisory authority, including in your country of

residence, place of work or where an incident took place.

• You may withdraw any consent you previously provided to us regarding the processing of your Personal

Information at any time and free of charge. We will apply your preferences going forward and this will

not affect the lawfulness of the processing before you withdrew your consent.


You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy.

Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain Personal Information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.


How to Block Cookies. You can block Cookies by setting your internet browser to block some or all Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies), you may not be able to access all or parts of the Site. By using the Site, you consent to our use of Cookies and our processing of Personal Information collected through such Cookies, in accordance with this Privacy Policy. You can withdraw your consent at any time by deleting placed Cookies and disabling Cookies in your browser, or as explained below. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse the Site using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of Cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of the Site may not function properly if you do not accept Cookies or these technologies. Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device.


THIRD PARTIES

The Site may contain links to other websites, products, or services that we do not own or operate (“Third-Party Services”). We are not responsible for the privacy practices of these Third-Party Services. Please be aware that this Privacy Policy does not apply to your activities on these Third-Party Services or any information you disclose to these Third-Party Services. If you have any questions about how these other sites use your Personal Information, you should contact them directly. We encourage you to read their privacy policies before providing any information to them. We may receive additional information about you from third parties such as data or industry partners and combine it with other information we have about you. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.


RETENTION

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it unless we are required by law to keep this information for a longer period. When we process Personal Information for our own purposes, we determine the retention period taking into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrollment with the Site, the impact on the Site we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.


SECURITY

We make reasonable efforts to protect your Personal Information by using physical and electronic safeguards designed to improve the security of the Personal Information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your Personal Information.


INTERNATIONAL VISITORS

The Site is hosted in the United States (“U.S.”) and intended for visitors located within the U.S. If you choose to use the Site from the EEA, the UK or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the U.S. for storage and processing. We may transfer your Personal Information from the EEA or the UK to the U.S. and other third countries based on European Commission-approved Standard Contractual Clauses, or otherwise in accordance with applicable data protection laws. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Site. By providing any information, including Personal Information, on or to the Site, you consent to such transfer, storage, and processing.


CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use Personal Information from children under 16 years of age (“Minors”), and no parts of the Site are directed to Minors.


CHANGES TO THIS PRIVACY POLICY

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share Personal Information previously collected from you through the Site, we will attempt to notify you through the Site, by email, or by other means.


CONTACT INFORMATION

If you have any questions, comments, or concerns about our processing activities, please email us at

info@leap.energy