Privacy Policy

LEO INC. PRIVACY POLICY

 

This Privacy Policy (“Policy”) is designed to help you understand the types of personal information we at LEO, Inc. (“LEO,” “we,” “us,” or “our”) collect, how we use it, when it may be disclosed, and the rights and choices you have with respect to your personal information. It also explains how we communicate with you and how you can make requests or submit inquiries to us about your personal information. We appreciate you taking the time to read this Policy and understand our data and privacy related practices. This Policy applies to all personal information that we collect during any written, electronic, and oral communications online or offline when you:

 

  • interact with our websites located at https https://www.leoinc.org/ and any other websites, pages, features or content we own or operate (collectively, the “Site(s)”);
  • apply for Federal and state programs online through LEO; or
  • otherwise interact with our products or services that direct you to this Policy (collectively, the “Service(s)”).

 

By continuing to use our Services, you acknowledge this Privacy Policy, and agree to our Terms and Conditions (“Terms”).  If you are not comfortable with any part of this Policy or do not agree with the Terms, please immediately discontinue access or use of our Services. We may make changes to this Policy from time to time. We will notify you of any material changes to this Policy and will update the Last Revised date at the beginning of this Policy. We encourage you to look for updates and changes to this Policy when you access our Services. We may also provide “just-in-time” disclosure or additional information about our information collection, use, and sharing practices of specific Services. These notices may supplement or clarify our privacy practices or provide you with additional choices about how we process your personal information.


  • PERSONAL INFORMATION WE COLLECT. LEO collects certain personal information about you and your use of our Services. Personal information is typically data that identifies an individual or relates to an identifiable individual. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Policy. The personal information that we collect depends on your interactions with us, and the choices you make.

 

Information You Voluntarily Provide to Us. We, or service providers that assist us in providing, maintaining, and operating our Services, as well as government agencies to which we submit applications or documentation on your behalf (see (f) below), may collect the following types of personal information from you:

  1. Donation Processing. We may collect your personal information when you make a donation through our Sites or App, including, for example, your first and last name, billing address, postal code, email address, and/or phone number
  2. Payment Information. We may collect your personal information when you make a donation through our Sites or App, including, for example, your first and last name, billing address, postal code, email address, and/or phone number. We may also collect certain payment information, such as your credit or debit card number or other payment details, which are processed securely by our third-party payment processor. We store your full payment card information on our systems only if you choose to make recurring donations.
  3. Survey Participation. We may collect your personal information when you choose to respond to a survey through our Sites or App. This may include, for example, your first and last name, email address, and any information you choose to provide in your survey responses. Participation in surveys is voluntary, and the specific information collected may vary depending on the survey.
  4. Event Request Forms. We may collect your personal information when you fill out an online form to request that our organization attend or participate in an event. This may include, for example, your first and last name, email address, phone number, event details (such as date, location, and description), and any additional information you choose to provide in the request.
  5. Career Information. When you apply to join our team, we may collect your first and last name, email address, phone number, home address, start date, and any employment-related information contained in your resume.
  6. Applications for Federal and State Program Benefits. When you apply with LEO for program services or benefits through programs administered by the Office of Head Start (Head Start), Massachusetts Department of Early Education and Care (EEC) or Executive Office of Housing and Livable Communities (EOHLC), we collect information required to determine eligibility, including:
    1. Household composition and demographic information;
    2. Income, employment, and financial information;
    3. Social Security numbers or other government-issued identifiers;
    4. Proof-of-residence documentation;
    5. Energy usage or housing-related information;
    6. Child and family information required for Head Start and EEC programs;
    7. Citizenship or immigration-related eligibility information;
    8. Any additional information required by the Head Start, EEC, or EOHLC

 

Information We Automatically Collect. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as when you interact with the Sites or use the Services. We may collect the following types of information automatically from you:

  1. Usage Data. When you browse our Sites, we automatically collect log data such as your web request, Internet Protocol (“IP”) address, browser type, domain names, referring and exit pages and URLs, pages viewed and the order of these page views, the date and time you access our servers, and other diagnostic data.
  2. Device Information. When you use your desktop or mobile devices to access our Services, we may be able to identify your device’s unique device identifier, MAC address, operating system, and your mobile device’s advertising ID.
  3. Location Information. When you use our Service, we may infer the generic physical location and geographic regions of your device from your Wi-Fi, Bluetooth, and other device settings. For example, your IP address may indicate your general geographic region. Upon your permission, we may collect your mobile device’s precise geo-location. You may choose not to share your location details with us by adjusting your mobile or desktop device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

 

Information From Third Parties. From time to time, we may obtain information about you from third-party sources.

  1. Social Media Platforms and Networks. If you interact with us on social media or use features, such as plugins, widgets, or other tools made available by social media platforms or networks (including Instagram, Facebook, X, Google, You Tube, and Pinterest) in connection with our website or Apps, we collect information that you share with us, or that the social media platforms share with us. For more information about the privacy practices of those social media platforms, please review the privacy policies and settings of the social media platforms and networks that you use.
  2. From Other Sources. We may obtain information about you from other sources, such as data analytics providers, marketing or advertising service providers, fraud prevention service providers, vendors that provide services on our behalf, or publicly available sources.


  • HOW WE USE YOUR PERSONAL INFORMATION. We use your personal information as described in this Policy for LEO’s purposes, or as disclosed to you prior to such processing taking place. We may process your personal information:
  1. To Provide Services. When you complete an online application, we use the information you provide to deliver and support the services you request, including preparing, processing, reviewing, and/or submitting applications for federal and state benefits programs. We also use your personal information to provide information or carry out the services you request, such as processing your donation, responding to your survey responses, or reviewing and managing your event participation request. For example, when you make a donation, we require your billing information to process your payment and contact information to send you a confirmation or acknowledgment. We will not be able to provide these services without such information. Third parties, such as payment processing providers or other service providers, may also access and/or collect your personal information when assisting us in fulfilling your request. 
  2. To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws and regulations which may require us to process your personal information. We may process and maintain your information to comply with recordkeeping, audit, reporting, and verification requirements imposed by federal and state programs. Without processing your personal information for such purposes, we cannot perform the Services in accordance with our legal and regulatory requirements.
  3. To Enforce Compliance with Our Terms, Agreements, and Policies. When you access or use our Services, you are bound to our Terms. To ensure you comply with them, we process your personal information by actively monitoring, investigating, preventing, and mitigating any alleged or actual prohibited, illicit, or illegal activities on our Services. This includes actions taken to review and validate information submitted in connection with applications for federal or state benefits programs, to ensure such applications are accurate, complete, and compliant with program requirements. Subject to the applicable law, we may also process your personal information to investigate, prevent or mitigate violations of our internal policies, program rules, agreements, or legal obligations, and to enforce our agreements with agencies involved in application processing or eligibility determination.
  4. To Detect and Prevent Fraud and Security Risks. We may process your personal information to help monitor, prevent, and detect fraud and abusive use of our Services, monitor, and verify your identity so that unauthorized users do not gain access to your information, enhance system security, and combat spam, malware, malicious activities, or other security risks that might result in financial loss.
  5. To Provide Customer Support or Respond to You. We collect any information that you provide to us when you contact us. Without your personal information, we cannot respond to you or ensure your continued use of the Services.
  6. To Research and Develop of Our Services. We may process your personal information and derive analytical and statistical data to better understand the way you use and interact with our Services to help us improve our existing Services and to build new Services. Please see our Cookies and Other Similar Tracking Technologies section for more information.
  7. To Facilitate Corporate Acquisitions, Mergers, and Transactions. We may process any information regarding your account and your use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.
  8. With Your Consent. For any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the services or other related services requested, with your permission or upon your direction.


  • HOW WE DISCLOSE YOUR PERSONAL INFORMATION. We disclose your personal information as needed to fulfill the purposes described in this Policy and as permitted by applicable law. We may disclose your personal information as described below.
  1. With Our Service Providers. We may disclose your personal information with third-party service providers acting on our behalf to help us operate our Services. Service providers and vendors provide us with support services such as credit card processing, eligibility processing, client management systems, website hosting, analytics services, surveys and research services, and network maintenance.
  2. With Government Agencies for Program Eligibility and Administration. If you submit an application for LIHEAP, Head Start, or EEC programs, we will disclose your application information to the agencies administering those programs.
  3. During Business Transaction or Other Asset Transfers. We may disclose and transfer information about you to buyers, service providers, advisors, potential transactional partners, or other third parties in connection with the advisors, potential transactional partners, or other third parties 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. By engaging with us or using our Services, you understand and agree to our assignment or transfer of rights to your personal information.
  4. For Energy Assistance Programs (LIHEAP and HEARTWAP). For the Massachusetts Low-Income Home Energy Assistance Program (LIHEAP) and the Heating Emergency Assistance Retrofit Task Weatherization Assistance Program (HEARTWAP), we disclose your personal information only in accordance with the Consent to Disclose Personal Information form applicable to those programs. You may withdraw your authorization for disclosure at any time by following the instructions provided in that form. 
  5. For Legal Compliance & Safety. We may access, preserve, and disclose information about you if we believe doing so is required or appropriate to (a) comply with law enforcement requests and legal processes, such as a court order or subpoena; (b) comply with requests from auditors, examiners, or other regulators; (c) exercise, establish or defend our legal rights; or (d) protect your, our, or others’ rights, property, or safety.
  6. With Your Consent. We may share your personal information with other companies if you give us permission or direct us to share your information.


  • COOKIES AND OTHER TRACKING TECHNOLOGIES. We and/or third parties on our behalf may use cookies or similar tracking technologies (collectively, “Tracking Technologies”) to collect information automatically as you interact with our Services, to help us customize your experience and optimize our user experience, including to:
  • Analyze our web traffic using an analytics package;
  • Identify whether you already visited our Services;
  • Store information about your preferences; and
  • Recognize you when you return to our Services.

 

Analytics. We may use third-party service providers to monitor and analyze the use of our career website, such as Google Analytics.  Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports website traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.

 

Interest-Based Advertising. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt-out of interest-based advertising from their members. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal, or visit the NAI’s opt-out portal.

 

Managing Cookies and Similar Tracking Technologies. You have the right to decide whether to accept cookies. If you do not want us to deploy cookies in your browser, you may exercise your preference by modifying your web browser setting to either (1) refuse some or all cookies or (2) notify you and ask for your permission when a website tries to set a cookie. If you want to learn the correct way to modify your browser settings, please use the “Help,” “Tools” or “Edit” menu in your browser or review the instructions provided by the following browsers: Internet Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile, and Android browser. If you choose to disable cookies in your browser, you can still use the Services, although your ability to use some of the features may be affected. If you want to exercise your rights regarding personal information collected via cookies and similar tracking technologies, please see the “Your Rights and Choices” section below.


  • HOW WE PROTECT YOUR PERSONAL INFORMATION. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. We maintain our Services and all associated information with technical, administrative, and physical safeguards to protect against the loss, unauthorized access, destruction, misuse, modification, and improper disclosure of your personal information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the internet. If you feel that the security of any account you might have with us has been compromised, please reach out immediately via the method listed in the “Contact Us” section below.


  • RETENTION OF YOUR PERSONAL INFORMATION. We will retain and use your personal information to the extent necessary to fulfill the purposes for which it was collected, including to assist with applications, eligibility determinations, to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. We also retain and destroy personal information as required under Federal and state laws and regulations, as well as the contractual, audit, oversight, and record-keeping obligations imposed by the government agencies with which we work. We maintain a written information security program consistent with Massachusetts law. We will cease to retain your personal information or remove the means by which the information can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal information was collected and is no longer necessary for legal or business purposes. If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us via the method listed in the “Contact Us” section below. Please note that we may still retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


  • YOUR CHOICES

 

Your Privacy Rights. Depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your personal information. If any of the rights listed below are not provided to you under the law that governs the processing of your personal information, we have absolute discretion in providing you with those rights. Please note, your rights in relation to your personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (i) when denial of the request is required or authorized by law; (ii) when granting the request would have a negative impact on another’s privacy; (iii) to protect our rights and properties; (iv) where the request is frivolous or vexatious; or (v) for other reasons.

  1. Right to Access. You may have the right to obtain a copy of the personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information.
  2. Right to Correct. You may have the right to correct any of your personal information in our files.
  3. Right to Delete. Under certain circumstances, you may have the right to the erasure of the personal information that we hold about you. This right is not absolute, and we may refuse your right to erasure if it is reasonably necessary for us to provide a service requested by you; to perform a contract between us; to maintain functionality and ensure security of our systems; to enable solely expected internal uses of your personal information; to exercise a right provided by law; to comply with a legal obligation; or if there are compelling legitimate grounds for keeping your personal information.
  4. Right to Portability. Under certain circumstances, you may have the right to receive personal information we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another controller.
  5. Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your privacy rights.
  6. Right to Object to Automated Decision-Making. We do not make any decisions based on algorithms or other automated processing that significantly affect you.
  7. Right to Appeal. You may have the right to appeal if we refuse to act on your rights request. Instructions on how to appeal will be provided to you upon such a denial, but in any event, such instructions will be substantially similar to those provided below for submitting requests.
  8. Right to Opt-Out of Sale and Targeted Advertising. You may have the right to opt-out of sale of your personal information, and the sharing of your personal information for targeting advertising purposes. We generally do not sell your personal information for profit, but like many websites, we use cookies, and similar technology, and we share personal information, such as your IP address or device identifiers, to certain third-party advertisers in order to improve your user experience and to optimize our marketing activities. To opt-out of having your personal information sold or shared for targeted advertising, please click the “Your Privacy Rights” link or contact us at https://www.leoinc.org/contact/

Under the broad definition of “sell” contained in California privacy law, this could be considered a sale. California residents may also opt-out of sharing and sales by using an opt-out preference signal for each participating browser system that you use.  We will honor and process the opt-out preference signal in a frictionless manner. To start using an opt-out preference signal, please refer to the instructions provided here. You will need to submit a separate opt-out of sharing request on each device and browser you use to visit our Site.  Please note that you may still receive generalized ads after opting out of targeted advertising.

  1. Right to Limit the Use of Sensitive Personal Information. California residents have the right to limit the use of sensitive personal information. 

 

California Residents’ Specific Rights. California residents specifically have the following rights: (a) Right to Know/Access; (b) Right to Correct/Rectification; (c) Right to Delete/Erasure; (d) Right to Portability; (e) Right Against Discrimination; (f) Right to Opt-Out of Automated Decision-making or Profiling (upon issuance of regulations by the California Privacy Protection Agency); (h) Right to Opt-Out of Sale and Sharing for Targeted Advertising; and (i) Right to Limit the Use of Sensitive Personal Information. If you apply for federal or state benefit programs, we may also collect the following categories of personal information: 

  • Sensitive personal information (e.g., Social Security number, financial information, information about children);
  • Government identifiers;
  • Eligibility determination based on state or federal benefit program rules.

 

Submitting a Request to Exercise Your Rights.  In addition to the methods specified above, you may exercise these rights by contacting us at https://www.leoinc.org/contact/. In your request, please make clear which right you would like to exercise. Before fulfilling your request, we are required by law to have you to verify the personal information we already have on file to confirm your identity. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes. You may use an authorized agent to submit a rights request on your behalf.  If you use an authorized agent to submit requests on your behalf, we will require you to directly verify your identity with us, or have you directly confirm with us that the authorized agent has been authorized to act on your behalf.


  • CHILDREN’S INFORMATION. Because we assist with applications and eligibility determinations for early education programs, including Head Start, we collect and maintain personal information about children (“PII”) as required to operate those programs, comply with federal and state regulations, determine eligibility, and provide appropriate services. Children’s PII includes any information that identifies or could be used to identify a specific child, such as a child’s name, a family member’s name, address, Social Security number, or any other information linked or linkable to the child. A child’s record includes any information directly related to the child that is maintained by us or by a party acting on our behalf, in any format. 

 

We collect children’s information only as necessary for program administration and do not use children’s PII for marketing or unrelated purposes.

How We Use and Share Children’s Information

We may use and disclose children’s PII only as permitted or required by law, including: 

  • Internal use. We may disclose children’s PII to our personnel who need the information to administer early education programs.
  • Emergency situations. We may disclose PII to appropriate parties when necessary to protect a child’s health or safety.
  • Transfers to other programs or schools. We may forward PII to a program, school, or school district where a child seeks or intends to enroll, or is already enrolled, unless you opt out of such disclosures. Upon request, we will provide you with a copy of any PII we intend to disclose in advance.
  • With parental consent. Except where a disclosure is otherwise permitted by law, we must obtain a parent or guardian’s written, signed, and dated consent before releasing PII from a child’s record to any third party. Consent is voluntary and may be revoked at any time.
  • Recordkeeping for disclosures. Every time information is released to someone who is not a program employee, we record the name, signature, and title of the person releasing the information; the date; the portions of the child’s record disclosed; the purpose of the disclosure; and the name and signature of the recipient. This disclosure log is available only to the child’s parent(s), our personnel responsible for record maintenance, and the Massachusetts Department of Early Education and Care as part of its regulatory function.

 

We may also secure digital surveillance systems in certain program locations. Any recordings that include a child’s image or voice are treated as confidential PII and handled in accordance with these procedures.

 

Parental Rights

Parents have specific rights regarding their child’s record, including the right to:

  • Inspect and review a child’s record;
  • Request copies of the record;
  • Request that we amend the record if information is inaccurate or misleading;
  • Request a hearing to challenge information in the record; and
  • Inspect written agreements with third parties who receive PII.

 

If you believe your child’s privacy rights have been violated or if you have questions about how we handle children’s PII, please contact us at: Director of Early Education, LEO Inc., PO Box 711, Lynn, MA 01903, Filing a complaint or exercising your rights will not affect the care or services your child receives from LEO. 

 

For more information, see LEO’s Annual Notice Regarding PII and Parental Rights.

 

If you are under 16, please do not attempt to fill out our forms or send any personal information about yourself to us. If we become aware that a child under 16 has provided us with personal information, we will terminate the user’s access to our Services and take steps to delete such information from our file systems, unless we have a legal obligation to keep it.


  • THIRD-PARTY WEBSITES. Our Services may contain links to other websites, products, or services, including partner agencies, that we do not own and are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit before providing any information to them. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services, and this Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. If you have any questions about how these other sites or services use information from or about you, you should contact them directly.


  • INTERNATIONAL USERS. LEO operates in the United States. Our Services are not intended for international users. Thus, when you access and submit personal information to LEO, your personal information may be processed, maintained, and used on computers, servers, and systems located in the United States, where privacy and data protection laws may be less stringent than the laws in your country of residence. By providing information to us through our Services, you authorize us to transfer, store, and process your information in the United States and in accordance with this Policy. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop accessing or using the Services.


  • ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS. The California Consumer Privacy Act, as amended by the California Privacy Rights Act (“California Privacy Law”) requires us to disclose the following additional information related to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of this Policy.

 

Categories of Personal Information Collected, Used, and Disclosed

In the preceding 12 months, depending how you interact with our Services, we may collect the following categories of personal information (as defined under Cal. Civ. Code §1798.140(v)(1)):

  • Identifiers, such as your name, shipping and billing address, unique personal identifier, email, phone number, or similar identifiers;
  • Commercial information, such as your transaction records, payment information;
  • Internet or other electronic network activity information, such as technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and information about your visit, including your browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, and system configuration information;
  • Geolocation data, such as geolocation, to the extent you have configured your device to permit us to collect such information; and
  • Inferences drawn from any of the information listed above, such as your preferences, characteristics, and behavior.

 

For more information about the personal information we collect, and how we collect it, please refer to Section 1 above, “Personal Information We Collect.” For more information about the business purposes for which we collect your personal information, please refer to Section 2 above, “How We Use Your Personal Information.”  To learn the categories of third parties with whom we may share your personal information, please refer to Section 3 above, “How We Share Your Personal Information.” Please see Section 7 to understand how to exercise applicable privacy rights under California Privacy Law. Please note, if you use an authorized agent to submit requests on your behalf, we will require you to directly verify your identity with us, or have you directly confirm with us, that the authorized agent has been authorized to act on your behalf. Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.


  • CONTACT US. We welcome questions, comments, and concerns about our privacy policy and privacy practices. If you wish to provide feedback or if you have questions or concerns, or wish to exercise your rights related to your personal information, contact us at https://www.leoinc.org/contact/ or reach out to our customer support.