LeaseAccelerator, Inc., and its affiliates, which include LeaseAccelerator Services, LLC (“LAS”) and EZLease, LLC (“EZLease”), (which are collectively referred to below as “we” or “us” and in the possessive “our”) are committed to protecting the privacy of individuals who visit our websites or otherwise seek additional information about us or our services (“Visitors”) or individuals, who are registered to use our services, including training and educational offerings (“Registrants”).  When we refer to a “User” in this Privacy Policy, we are referring to an individual who is either a Visitor or a Registrant.  When we refer to “you” or “your”, we are referring to any individual whose Personal Information we process.

Each of LAS and EZLease offers to its customers (each a “Customer”) certain commercial lease management, sourcing and accounting services to lessees, lessors and vendors as well as training and instruction to Users on the use of our Services and lease accounting generally (the “Services”).  LAS and EZLease use cloud-based applications (the “Applications”), seminars and presentations (including via video conferencing), videos and written documentation to provide the Services.  Each of LAS and EZLease is responsible for its processing of personal information covered by this Privacy Policy.

This Privacy Policy provides information on our collection, use and sharing of your personal information in connection with your use of our Services or in accessing or websites (collectively our “Websites”), including the following websites with our subdomains:

• www.leaseaccelerator.com
• www.ezlease.com
• www.leaseaccounting.com
• www.lessornetwork.com

This Privacy Policy may change over time, at our discretion, for example to comply with legal requirements or to meet changing business needs.  See “How do we implement changes to this Privacy Policy?” below for details.

In this Privacy Policy, we use the term “Personal Information” to refer to information relating to an identified individual or to an identifiable individual.  Examples of the types of Personal Information we may process are provided below.  We use the term “process” to mean any activity involving Personal Information, such as collection, storage, use, transmission or sharing.  This Privacy Policy is incorporated into and subject to our Terms of Use.  These Terms of Use are accessible from the home page of our Websites;  www.leaseaccelerator.com and www.ezlease.com.

1) What does this Privacy Policy cover?

This Privacy Policy describes our conduct, and the conduct of those individuals and companies that we engage, in processing of Personal Information.

The Privacy Policy does not apply to the collection and other processing of Personal information by our Customers.  Each Customer is responsible for its own Personal Information collection and other processing practices, including when a Customer uses our Services to process your Personal Information.  To find out more about a Customer’s processing of Personal Information about you, you are encouraged to review the relevant privacy policy of the company who collected your information from you.  Please consult that company directly if you have any further questions about its processing of the Personal Information you provided to it.

We may have entered into an agreement with our Customer that governs our processing of your Personal Information on the Customer’s behalf (a “Data Processing Agreement” or “DPA”).  Any rights reserved for you under a DPA with respect to your Personal Information we are processing on the Customer’s behalf are in addition to your rights described in this Privacy Policy to request information from us and to request that we take certain actions with respect to your Personal Information.

2) Why do we process Personal Information? 

Our goal in processing Personal Information of Registrants is to facilitate our provision of the Services to our Registrants and our Customers.  Our primary goal in collecting information from Visitors is to allow us to assess and respond to a Visitor’s need for our Services and to contact the Visitor in order to provide further information regarding our Services and engage in additional marketing of our Services to such Visitors and their companies.  More detail is provided below under the headings “What Personal Information do we process?” and “How do we use Personal Information we collect from and about Registrants?”.

3) What categories and specific Personal Information do we process?

(a) User Personal Information.  We collect and then otherwise process Personal Information that identifies or may be used to identify a User, including first and last name, company name, business email address, IP address, job responsibility or title, and telephone number.  This identifying Personal Information may, in turn, be used to process additional Personal Information arising from a User’s use of the Services, which includes log files, event files, and other trace and diagnostic files, as well as statistical and aggregated information that relates to the use and operation of our Services and the systems and networks these Services run on, information that may be derived from IP address, such as geographic location, and information about a device a User uses, such as browser, device type and operating system.  We do not process, and our Terms of Use, our Acceptable Use Policy and our contracts with our Customers prohibit any provision to us of, personal information that constitutes “sensitive personal information”, including, for example, governmentally assigned identification numbers, financial account numbers, or information about one or more factors specific to a person’s physical, physiological, mental, economic, cultural identity or social status.

Additionally, for our online educational programs and seminars, we may process the Personal Information a User provides to register as well as additional Personal Information resulting from a User’s use of such Services.  We may provide this Personal Information to a User’s company (as identified by the User and/or as evidenced by the User’s use of the company’s email domain), regarding a User’s online educational program participation, a User’s performance (e.g. in taking tests for self-assessments or certifications), and a User’s educational program history.

If one of our Customers is registering a User for access to and use of our Services, the Customer must provide all relevant notices to and obtain any consents from those Users required to share the Personal Information with us and such notices and consents must sufficiently inform such Users of the purposes for which Personal Information is being processed by us.

(b) Transaction Information. Because LAS and EZLease only provide Services with respect to lease transactions between businesses (each a “Transaction”).  Personal information included within a Transaction is generally limited the name, job title, email address, office address and phone number of individuals who are identified in the Transaction communications as contacts and in notice or contact provisions of or as signatories to the lease documentation as representatives of the lessee, lessor or other party to the Transaction.

(c) Sourcing Application Information.  Requests for proposals (“RFPs”) by Users seeking lease financing (“RFP Authors”) and any Personal Information included in those RFPs are available to multiple financing sources for bidding (“RFP Bidders”).  RFPs and RFP Bidders’ proposal responses (“Proposals”) are private among the RFP Author, the responsive RFP Bidder and us.

(d) Visitor Usage Information. Like most web-based services, we (or our service providers) may automatically collect information from a Visitor’s browser or device when using the Websites.  See “How do we use cookies and similar technologies?” below.  This could include the time and duration of each visit.  If we combine any automatically collected information with Personal Information, we will treat the combined information as Personal Information, and it will be protected in accordance with this Privacy Policy.

4) How do we use a Registrant’s Personal Information we process?

The following are examples of how we currently use Personal Information of our Registrants.  These examples are not exclusive, but in all events, we use the Personal Information of our Registrants solely in connection with the provision of our Services.

• We use Personal Information of Registrants to administer our Customers’ contract with us, to provide support and respond to requests and inquiries, to improve the Services for all users, to monitor progress of a Users’ training and instruction and to log use of the Services, primarily for administration and security purposes.
• We use the Personal Information we capture in our Applications to facilitate communications with stakeholders involved in the leasing process and in lease accounting.
• We use any Personal Information that might be included in Registrant information and Transaction information to manage our business, verify the eligibility of users for our Application, validate the authenticity of the user, monitor compliance with our Customer contracts, Terms of Use and policies, process user requests and Transactions, contact users regarding their use of, changes to, or new Services available through our Applications, and for billing purposes, and do internal research on our Users’ interests and behavior to better understand and serve our users.
• We collect source IP addresses for all system activity in order to ensure audit trailing and to determine the source of any malicious use of the system.
• If you attend an event (including by telephone or video conferencing) , we may process information about you gathered in relation to the event and can share information about your attendance with your company.

5) What Personal Information do we disclose to third parties and why do we disclose it?

We share User Personal Information throughout our organization, which includes our affiliates and with third parties.  The following are examples of how we currently may share Personal Information.  These examples are not exclusive, but we share the Personal Information solely in connection with our provision of the Services, to protect our rights or the rights of our Customers and our Users or as required by law or compulsory process.  We never sell Personal Information of our Users to third parties.

• We may share Personal Information with third-party service providers (for example, data hosting/storage, virtual assistance and learning, service/support management, credit card processing services, order fulfilment, analytics, event/campaign management, website management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar service providers) in order for those service providers to perform business functions on our behalf.
• We may share Personal Information with relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock;
• We may share Personal Information with our Customer or its affiliates with whom the User is employed, engaged or deals, directly or indirectly, in connection with a Transaction or otherwise deals using our Applications.
• We may share Personal Information in the course of a Customer’s RFP activities – e.g. to allow sourcing participants to solicit, send out or respond to an RFP.
• We may share Personal Information when we believe in good faith that disclosure is necessary to protect our rights, protect a User’s safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside a User’s country of residence, for national security and/or law enforcement purposes or to comply with compulsory process, such as a subpoena.

In sharing Personal Information with such third-parties, we take reasonable steps, to assure that the information is only processed in accordance with this Privacy Policy.

We may occasionally aggregate our User information or Transaction Information and disclose such information to third parties in aggregate form for a number of business purposes, including running and enhancing our Application and Website.  In these situations, we do not disclose any information that could be used to identify an individual.

6) How long do we retain Personal Information?

Personal Information about our Registrants that we collect in performing our Services for a Customer will be retained for the duration of the services contract with the Customer and thereafter, as necessary for us to comply with our post termination obligations to the Customer and to comply with applicable law.

Personal Information about our Visitors will be retained so long as we determine that such information may still facilitate our sales or marketing efforts.

7) How do we manage processing of Personal Information by Customers?

The Applications provide each Customer the opportunity to process Personal Information of its users’.  Each Customer is solely responsible for, and we have no control over and do not audit, a Customer’s processing activities using our Applications.

8) How do we use cookies and similar technologies?

We use cookies and similar technologies to assist us in securing a User’s transactions and to enhance the performance of our Application.  Cookies are small text files that contain a string of characters and uniquely identify a browser on a device connected to the Internet. We place cookies in your browser on your computer when you visit our Websites.

Modern browsers provide an option to reject cookies.  Learn how to use your browser to disable / block cookies here https://www.wikihow.com/Disable-Cookies.  Visitors to our Websites may block cookies.  Registrants desiring to access and use our Applications are required to accept all cookies in order for the features and security mechanisms to function.

Additionally, we will collect unique identifiers about each Visitor and track the web pages visited, files downloaded, and videos played.  The information collected is used to enhance the user experience, assist our sales and marketing to such Visitor and for website design.  It is not shared with third parties.

9) How do we protect User Personal Information?

We have implemented appropriate technical, physical and organizational measures intended to safeguard Personal Information from unauthorized or unintended access, loss, damage, alternation, disclosure or other processing.

10) How do we manage Q&A and collaboration of Users?

The Application enables inter- and intra-company Q&A communication and collaboration communications directly between Users. Q&A communications are private between parties to Transactions. Collaboration communications are private within a User’s organization and cannot be viewed by any third-party Users. Q&A communications between Users and collaboration communications between or among individuals within a User’s organization are secure utilizing the same technology as described in Section 7, above. E-mail communications between Users and between the Users and us are subject to the limitations of general Internet security.

11) What happens in the event of inadvertent disclosure of confidential information?

In the event that a User receives information which the User knows was not intended to be disclosed to the User, per this Privacy Policy we ask that the User advise us by email of the disclosure and request instruction on what to do.  We will contact the disclosing person and get direction of what should be done with the disclosed information. We may request that a User delete or otherwise destroy the information or take action to return the information to the disclosing User.  Each User agrees to comply with such requests.

12) Is this a consumer website?

No. Our Application and Website is intended for business/commercial use only. Our Application and Website is not intended for consumer use. Each User agrees not to use our Website to provide or store any consumer information, including without limitation, social security numbers, credit card numbers or individual bank account information. Each User agrees not to disclose Personal Information, other than as described in Section 3(a), about any other individual when using our Applications.

13) How do we implement changes to this Privacy Policy?

We will occasionally update this privacy policy. We will change the “Last Updated” date at the top of this Privacy Policy when we make those changes. Please revisit this page from time to time to stay aware of our Privacy Policy. Your continued use of our Services (including the Websites) constitutes your agreement to this Privacy Policy and any future revisions. However, if we make a material change in the way we collect, use and/or share Personal Information, we will notify our Users by sending an email to the email address we have for the User and/or posting a notice on our Application and/or Websites.

14)  What are your privacy rights?

You have privacy rights for the information we process about you.  You can choose to opt-out of third party sharing and object to, or restrict our use of your Personal Information.  You can ask us to delete, change or correct your Personal Information or access your Personal Information.  We encourage Registrants to initiate these requests by contacting the company (e.g. our Customer) that provided Registrant’s Personal Information to us.  Otherwise, these requests may be initiated by sending an e-mail to: privacy@leaseaccelerator.com.

In cases of sharing with third parties of data of EU, UK and Swiss individuals received pursuant to the GDPR, EU-US Privacy Shield and Swiss-US Privacy Shield (see “How do we manage GDPR Compliance for EU data subjects?” and “How do we handle Privacy Shield Framework requirements?” below), we remain liable for the transfer of personal data to agent third parties unless we can prove we were not a party to the events giving rise to the damages.

15) How do we manage GDPR Compliance for EU data subjects?

We are a global corporation with operations in multiple countries and Personal Information may be processed globally as necessary in order for us to provide or support our Services. If Personal Information is transferred to an LAS or EZLease recipient in a country that does not provide an adequate level of protection for such information, we will take adequate measures designed to protect the Personal Information, such as ensuring that such transfers are subject to the terms of the Standard Contractual Clauses or other adequate transfer mechanism as required under relevant data protection laws.

In the event the services agreement between us and our Customer references the LAS or EZLease Data Processing Agreement (“DPA”), further details on the relevant data transfer mechanism that applies to your Personal Information are available in the DPA.

If you are located in the European Economic Area (the “EEA”), you may have the following rights to the extent provided by law:

• Request access to and receive information about the Personal Information we may 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 deleted, or exercise your right to data portability to easily transfer your Personal Information to another company.
• Lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place.
• 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 your consent withdrawal.

For Personal Information collected about you in the EU/EEA, the UK and other relevant jurisdictions, our basis for processing is set forth above under the headings “Why do we process Personal Information?” and “How do we use a Registrant’s Personal Information we process?”  As described in these sections and elsewhere in this Privacy Policy, we rely on these legitimate interests in processing your Personal Information.

Please access the link provided for more information regarding our supervising Data Protection Authority:

http://ec.europa.eu/justice/article-29/structure/dataprotection-authorities/index_en.htm

16) How do we manage California privacy requirements?

If you reside in California, you have the right to request that we disclose to you the following information covering the 12 months preceding your request:

• The categories and specific pieces of Personal Information we have collected about you;
• The categories of sources from which the Personal Information is collected;
• Our purposes for collecting or selling your Personal Information; and
• The categories of Personal Information that we have disclosed to third parties and the categories of third parties with whom we share your Personal Information.

If you are a California resident, you also have the right to request deletion of any Personal Information about you that we have collected from you, subject to certain exceptions and to request that we not sell your Personal Information.

Any of such requests must be submitted to us in writing at the e-mail address or physical address indicated under how to contact us below.  To protect your privacy and security, we will also take reasonable steps to verify the your identity before taking any action

17) How do we handle Privacy Shield Framework requirements?

In addition, LeaseAccelerator Inc. complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union, United Kingdom, and Switzerland to the United States, respectively.  LeaseAccelerator Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Our operations primarily are located in the United States, Canada, Europe, UK, India, and Australia. EU, UK and Swiss User information will be transferred out of the Switzerland to the United States, Canada, the UK, India and Australia. By registering as a User under our Terms of Use, he or she consents to the storage and use as described in this Privacy Policy of any Personal Information provided us.

In compliance with the Swiss-US Privacy Shield Principles, LeaseAccelerator Inc. commits to resolve complaints about your privacy and our collection or use of your Personal Information. Swiss individuals with inquiries or complaints regarding this privacy policy should first contact LeaseAccelerator Inc. at Privacy@Leaseaccelerator.com.

We are further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

To protect a User’s privacy and security, we will also take reasonable steps to verify the User’s identity before taking any action.

18) What is the main U.S. regulatory agency that governs us?

We are subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).

19) Do we link to other websites?

The Websites may contain links to websites or services provided by third parties. Any information you provide on or to third-party websites or services is provided directly to that third party and is subject to that third party’s policies governing privacy and security. This Privacy Policy does not apply to such third-party websites or services.

The fact that we provide links to a given website is not an endorsement, authorization or representation that we are affiliated with that third party, neither is it an endorsement of their privacy or information security policies or practices. These other websites may place their own cookies or other files on your computer, collect data, or solicit Personal Information from you. We are not responsible for the content or privacy and security practices and policies of third-party websites or services. We encourage you to learn about third parties’ privacy and security policies before providing them with Personal Information.

20) How to contact us?

If you have any questions or concerns about this Privacy Policy, please contact us by email at privacy@leaseaccelerator.com or mail to:

LeaseAccelerator Inc.
10740 Parkridge Blvd. Suite 701
Reston, VA 20191
United States