Last Updated March 28, 2025
This Privacy Policy describes how Leonardo247, Inc. (“Leonardo”, “we”, “us” or “our”) handles personal information that we collect through our digital properties that link to this Privacy Policy, including our website, our mobile application, and our branded NAA Click & Comply application (collectively, the “Service”), as well as through social media, our marketing activities, and other activities described in this Privacy Policy.
We provide an operations and maintenance solution for real estate owners and operators. Our Service is designed for enterprise customers and their representatives. This Privacy Policy does not apply to information that we process on behalf of our enterprise customers (such as businesses and other organizations) while providing our platforms and services to them. Our use of information that we process on behalf of our enterprise customers may be governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of an enterprise customer, please direct your concerns to that enterprise customer.
Index
Personal information we collect
How we use your personal information
How we share your personal information
Your choices
Other sites and services
Security
International data transfer
Children
Changes to this Privacy Policy
How to contact us
Personal Information We Collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
• Contact data, such as your first and last name, salutation, email address, mailing address, professional title and company name, and phone number.
• Account data, such as the username and password that you may set to establish an online account on the Service and any other information that you add to your account profile.
• Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
• Research data, such as your responses to surveys that we might ask you to complete for research purposes related to our business.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• User-generated content data, such as photos, images, blog comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Data providers, such as information services and data licensors that provide demographic and other information.
• Marketing partners, such as joint marketing partners and event co-sponsors.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, geolocation, unique device identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or general geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:
• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
How We Use Your Personal Information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
• provide, operate and improve the Service and our business;
• personalize the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
• establish and maintain your user account on the Service;
• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events in which you participate;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Marketing. We, our service providers and our third-party partners may collect and use your personal information for marketing purposes:
• Direct marketing. We may send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
• Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.
Compliance and protection. We may use your personal information to:
• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:
• Technical operation. To allow the technical operation of the Service.
• Functionality. To enhance the performance and functionality of our services.
• Advertising. To help us and our third-party advertising partners collect information about how you use the Service and other online services over time, which we and our partners use to show you ads on other online services they believe will interest you and measure how the ads perform.
• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. To provide this service, Google Analytics may collect certain information about you from your computer using cookies. You can learn more about Google Analytics and how it collects and processes data by visiting: www.google.com/policies/privacy/partners. You can opt-out of the use of Google Analytics here: https://tools.google.com/dlpage/gaoptout?hl=en.
Events, promotions and contests. We may use your personal information to:
• administer promotions and contests;
• communicate with you about promotions or contests in which you participate; and
• contact or market to you after collecting your personal information at an event.
How We Share Your Personal Information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.
Affiliates. Our affiliates for purposes consistent with this Privacy Policy.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as maintenance services, database management, hosting, information technology, customer support, email delivery, consumer research, marketing, and website analytics).
Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested.
Business and marketing partners. Third parties with whom we co-sponsor events, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in Leonardo (including, in connection with a bankruptcy or similar proceedings).
Your Choices
In this section, we describe the choices available to you.
Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
• Browser settings. Changing your internet web browser settings to block third-party cookies.
• Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
• Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites:
o Google: https://adssettings.google.com/
o Facebook: https://www.facebook.com/about/ads
• Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
o Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp.
o Digital Advertising Alliance: optout.aboutads.info.
• Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Other Sites and Services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
International Data Transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Children
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.
How to Contact Us
To exercise your choices or if you have questions about this Privacy Policy or our privacy practices, please contact us at privacy@leonardo247.com.