Privacy policy

Last Modified: November 29, 2023

1. Introduction

1.1. In this privacy policy, you can learn more about how Leapwork ApS and affiliated companies Leapwork India Pvt Ltd, Leapwork LLC, Leapwork Germany GmbH, Leapwork The Netherlands B.V., Leapwork UK Limited, Leapwork France SAS and Leapwork Sweden AB (collectively "Leapwork", "we", "us", "our") process your personal data in various situations.

1.2. We provide you with this information as we are required to do so under the EU General Data Protection Regulation (the "GDPR").

1.3. For our privacy notice to California residents, please see here.

1.4. For a quick glance at our privacy setup, please refer to the below summarizing overview:

2. Data controller

2.1. The Leapwork entity acting as controller may vary depending on the purpose of the processing. Below, you can find information on the processing of your personal data in the following situations:

• when you visit our website or use our software (cookies and similar tracking and analytical technologies),
• when you request a demo of our software
• when you enter into a contract with us,
• when you communicate with us,
• when you visit our social media platforms,
• when you receive marketing material from us,
• when you are or represent a supplier, vendor or other third party, and
• when you apply for a job with us.

2.2. Below, you can read more about the various purposes of our processing of your personal data in the different situations. You can also see which data we process, what the legal basis for our processing is, for how long we store the personal data and who we share it with.

2.3. Further, in the section Your rights etc, you can read about your rights and how to contact us.

3. When you visit our website or use our software

3.1. We use cookies and similar tracking technologies to collect data about your visits and use when you use our website. This data includes:

• Internet Protocol (IP) addresses,
• device or mobile IDs and/or device model and type,
• browser information, operating system information, and/or language preferences,
• the location and the preceding and succeeding websites you have visited, including which pages/part/icons on the website you interacted with,
• applications you click on and how often, and
• the pages of our website you visit, and how long you spend on each page.

Further, we process your personal data, which includes statistical data, when you use our software. The purpose of this processing is to aggregate data to be able to create unique insights and to continuously improve the product for the benefit of our customers.

3.2. The above data may contain personal data. The controller is Leapwork ApS. We collect the data on your use of our website and services in order to ensure a stable, secure and user-friendly experience, as well as to keep statistics about our website visitors and software usage. In some cases, with regards to the website, data is processed in order to target marketing based on the web browser.

3.3. The legal bases for our processing are:

• for necessary (technical) cookies and similar technologies: Article 6(1)(f) of the GDPR, as we are pursuing our legitimate interest in ensuring functionality and security of our website,
• for other cookies and similar technologies: Article 6(1)(a) of the GDPR, as you have given your consent, e.g. to targeted marketing, and
• for our software usage data: Article 6(1)(f) of the GDPR, as we are pursuing our legitimate interest in ensuring the functionality, security, and constant improvement of our software.

3.4. Personal data contained in cookies will be deleted in accordance with the lifetime/period for each specific cookie. We disclose information to any third-party service providers that you have allowed to place cookies when you use the website, and we share your information with our group companies.3.5. You can read more about our cookies and other similar tracking technologies, including their lifetime and disclosure to third parties, in our Cookie Policy using the cookies widget in the lower left corner of your browser.

4. When you request a demo of our software

4.1. When you, as a company representative, request a demo of our software (e.g., via email or the contact form on our website) the communication will contain personal data, e.g., your contact details (including name and email address) and other personal data you may provide us with. The controller is Leapwork ApS or the entity you have contacted.

4.2. The legal basis for our processing of your name and contact details is article 6(1)(f) of the GDPR, as the processing is necessary for us to schedule with you and provide a free demo of our software.

4.3. Personal data pertaining to our general communication with you (such as email inquiries) will be deleted 5 years after the end of the financial year where your last inquiry has been handled/concluded. If your communication pertains to an order, personal data will generally also be deleted 5 years after the end of the financial year in which the order was placed. In specific situations, we may defer from our general retention periods (in case of e.g. complaints, objections or other specific situations).

4.4. Please see below regarding transfer of your personal data to third countries.    

5. When you enter into a contract with us

5.1. When you become a customer or partner with us, we process your personal data, including your full name and contact details, such as your email, phone number, company address, and any other information you provide us. The purpose of the processing is to manage our relationship with you. The controller is the Leapwork entity you have entered the agreement with.

5.2. The legal basis for our processing of your name and contact details is article 6(1)(b) of the GDPR, as the processing is necessary in order for us to fulfil our end of our agreement.

5.3. Further, we are obligated to store bookkeeping information, including information related to payments/transactions in accordance with the bookkeeping legislation. Based on the GDPR, our legal basis in that regard is article 6(1)(c).

5.4. The legal basis for our processing of any other information you may provide us is article 6(1)(f) of the GDPR, as we are pursuing our legitimate interests in tailoring our relationship to you.

5.5. As a starting point, we will delete your personal data 5 years after the end of the financial year where our agreement has ended. In specific situations, we may defer from our general retention periods (in case of e.g., complaints, objections or other specific situations).

5.6. We disclose personal data included in our account records to the relevant public authorities, including the tax and customs authorities, in connection with our statutory bookkeeping etc. Further, we disclose your personal data to our service providers and to our processors who e.g. host, develop and support our IT systems, and we share your information with our group companies.

5.7. Please see below regarding transfer of your personal data to third countries.

6. When you communicate with us

6.1. When you communicate with us directly (e.g., via email, telephone, the contact form on our website or with the Leapwork customer support or professional services teams) your communication will contain personal data, e.g., your contact details (including name and email address) and other personal data you may provide us with. The controller is Leapwork ApS or the entity you have contacted.

6.2.We process these personal data for the purpose of managing and answering your inquiries and offer support and/or training. The legal basis for the processing is article 6(1)(f) of the GDPR.

6.3.Personal data pertaining to our general communication with you (such as email inquiries) will be deleted 5 years after the end of the financial year where your last inquiry has been handled/concluded. If your communication pertains to a customer relationship, personal data will generally also be deleted 5 years after the end of the financial year in which the contractual relationship ended. In specific situations, we may defer from our general retention periods (in case of e.g. complaints, objections or other specific situations).

6.4. We disclose personal data included in our account records to the relevant public authorities, including the tax and customs authorities, in connection with our statutory bookkeeping etc. We also make your personal data available to our processors who e.g. host, develop and support our IT systems, and we share your information with our group companies.

6.5. Please see below regarding transfer of your personal data to third countries.

7. When you visit our social media platforms

7.1. If you visit our pages at Facebook or LinkedIn, we may process the personal data that you make available to us via the pages, including your reactions on content, likes and comments, and any sharing of our content etc. The controller is Leapwork ApS.

7.2. We process these personal data for the purpose of managing our social media platforms and communicating with our followers through these platforms. The legal basis for the processing is article 6(1)(f) of the GDPR, as we are pursuing the above-mentioned legitimate interests. Your personal data is deleted in accordance with applicable data protection policies in place to the relevant social media platforms (see the links below).

7.3. Please note that when using our social media platforms, the provider (such as e.g., Facebook) will also process your personal data for its own purposes, including for targeted marketing purposes. You may find further information on the processing activities in the relevant privacy notices:

• Facebook: https://www.facebook.com/about/privacy
• LinkedIn: https://www.linkedin.com/legal/privacy-policy
  
  

8. When you participate in surveys and questionnaires

8.1. During your relationship with Leapwork, we might send you invitations to participate in various surveys and questionnaires. For this purpose, we process your personal data, including your name and contact details, such as your email, phone number and other relevant information necessary for the specific survey in question. The purpose of the processing is to gain insights into our software or service offerings. The controller is Leapwork ApS.

8.2. The legal basis for our processing of your responses to our surveys and questionnaires is article 6(1)(f) of the GDPR, as we are pursuing our legitimate interests in continuously improving our product.

8.3. We will delete (or anonymize) your personal data 5 years after the end of the financial year where our contract has ended.

8.4. We disclose information only to any third-party service providers (marketing/survey automation platforms), and we share your information with only the relevant people in our group companies.

8.5. Please see below regarding transfer of your personal data to third countries.

9. When you are or represent a supplier, vendor or other third party

9.1. When you communicate with us (e.g., via email) as or on behalf of supplier, vendor or another third party, your communication may often contain personal data, e.g. your contact details (including name and email address), as well as association with a certain company or other personal data you may provide us with. We may also receive such personal data from a third party, such as your employer.

9.2. We process these personal data for the purpose of managing and answering your inquiries and orders and to communicate with you/the company you represent.

9.3.The legal basis for the processing is article 6(1)(f) of the GDPR, as we are pursuing our legitimate interests in managing general inquiries and fulfilling any agreement, we may have concluded with the company you represent.

9.4. Personal data pertaining to our communication with you will generally be deleted 5 years after the end of the financial year in which our last contact with the business you represent took place.

9.5. We disclose personal data included in our account records to the relevant public authorities, including in connection with our statutory bookkeeping etc. We may also disclose your personal data to our relevant business partners, including external advisors. Finally, we make your personal data available to our processors who e.g., host, develop and support our IT systems, and we share your information with our group companies.

9.6. Please see below regarding transfer of your personal data to third countries.

10. When you receive marketing material from us

10.1. When you receive marketing material from us (e.g. newsletters), we process personal data on you (e.g. name and email address), as well as association with a certain company or other personal data you may provide us with.

10.2. To the extent we send you information on our products and services for marketing purposes, we will either ask for your consent (in accordance with article 6(1)(a) of the GDPR) before processing your information in this way or process your personal data based on our legitimate interests (in accordance with article 6(1)(f) of the GDPR.

10.3. We will process your personal data for as long as we have valid consent or reason to do so.

11. When you apply for a job with us

11.1. When you apply for a job with one of our European-based companies, we process your personal data in different situations, which you can read more about below. The controller is Leapwork ApS.

11.2. Receipt of applications etc.

11.2.1 When we receive your application, we will read it and select the persons who we will call for an interview. The selection is based on your qualifications in relation to the specific position(s). You will be called for the interview by email or telephone.

11.2.2 As part of the recruitment process, we will receive and process the personal data that you have included in your application, CV and any other material that you may have forwarded along with your application. We may also ask you to send us additional information. The information obtained in this connection will include information about your previous employments, including information relating to work assignments, skills and performance, and information about your personal appearance and interpersonal skills. We will also obtain other information about you if we consider such information to be necessary for the assessment of your application.

11.2.3 The legal basis for processing the personal data is article 6(1)(f) of the GDPR as we pursue the legitimate interest in the processing of the personal data being necessary for our assessment of you as a person and your skills in relation to the contents of the position.

11.2.4 Further, our processing of data that you make available to us on your own initiative is deemed to be performed on the basis of your consent (in accordance with the relevant consent provisions of the GDPR and/or national data protection laws[1]).

11.3. Social media

11.3.1. If relevant, we will obtain available information published by you on social media, such as LinkedIn and Facebook.

11.3.2.The legal basis for processing the personal data published by you is article 6(1)(f) of the GDPR as we pursue the legitimate interest in the processing of the personal data being necessary for our assessment of you as a person in relation to the contents of the position.

11.4. References

11.4.1. If we wish to obtain information about you from your current or former employer using your references, we will first ask for your consent. Unless you are otherwise specifically notified by us, the information we obtain in that connection will include the following categories: Information about your previous employments, including information relating to work assignments, skills and performance, your personal appearance and interpersonal skills, and the reason for not being or no longer wanting to be employed by the employer in question.

11.4.2. The legal basis is the consent you give for the purpose of using your references, in accordance with article 6(1)(a) of the GDPR.

11.5. Use of personality and competency tests

11.5.1. During the recruitment process relating to some positions, we may use a personality test and/or a competency test. Typically, the tests are taken after our first interview with you. The purpose of the tests is to identify your personal preferences and skills, forming a basis for a dialogue with you about your personal resources and conduct. The tests will be part of the overall basis for selecting the right candidate for the position.

11.5.2.The legal basis for processing the personal data is article 6(1)(f) of the GDPR as we pursue the legitimate interest in the processing of the personal data being necessary for our assessment of your personal skills based on the tests.

11.6. Criminal record

11.6.1. During the recruitment process, we may ask you to show your criminal record certificate. Whether a criminal record certificate is required depends on the position, including the responsibilities and powers involved. If we consider it to be relevant to the position for which you have applied, we will ask you to request a personal criminal record certificate.

11.6.2. Please note that no processing of personal data takes place regarding criminal records, as you will in any case only be asked to show us a physical copy of the criminal record certificate (and you are thus not asked to send us a copy via email or otherwise provide us with a copy for us to keep).

11.7. Background checks

11.7.1. During the recruitment process, we may, depending on your role and the location, ask for your consent to perform a background check to verify your identity as well as, in some situations and to the extent permitted by applicable law, we may also collect data related to criminal offences and proceedings.

11.8. Job interviews

11.8.1. If you progress in the recruitment process, we will conduct interviews where we will focus on your professional and personal skills as well as the challenges etc. of the job. We will write down some of the information disclosed during the interview(s). We only use the relevant information in the assessment of whether you should be offered a position.

11.8.2.The legal basis for processing the personal data is article 6(1)(f) of the GDPR as we pursue the legitimate interest in the processing of the personal data being necessary for our assessment of you as a person and your skills in relation to the contents of the position.

11.9. Drafting of employment agreement

11.9.1. If we offer you a position, we will process the personal data necessary for staff administration purposes. In that case, you will receive further information on this.

11.9.2. The legal basis for processing the general personal data stated in the application documents may (also) be 6(1)(b) of the GDPR as it may be necessary to process the personal data in question for the purpose of drafting an employment agreement, if relevant.

11.10. Recipients of your personal data

11.10.1. Certain data will be made available to our processors, for example our IT system providers etc., and if relevant, we share your information with our group companies.

11.10.2. Please see below regarding transfer of your personal data to third countries.

11.11. Storage of your personal data

11.11.1. We will store your personal data for the period necessary for us to fulfil the purposes for which they were collected. Leapwork is committed to driving inclusive recruitment processes and believes in equal opportunity for all our job applicants. To document these processes, your personal data will be kept by us for three years for documentation purposes in the event of a legal claim. For that reason, we have established a maximum time limit of three years for the storage of job applications. As a general rule, we erase or anonymise your personal data according to this time limit unless it is necessary that we continue to store them, e.g. for the purpose of particular cases or the like.

11.11.2. If we employ you, the personal data that we have processed during the recruitment process will, if relevant, be stored in your personnel file in accordance with the applicable retention periods of your employment. In that case, you will be further notified of the processing of your personal data.

11.12. Mandatory processing of personal data

11.12.1. Under the data protection rules, you are entitled to be informed of whether the provision of personal data is a statutory requirement, or a requirement necessary to enter into a contract, and of whether you are obligated to provide the personal data and of the possible consequences of failure to provide such data.

11.12.2. It should be noted in that respect that under certain national legislations, including the Danish Health Information Act (helbredsoplysningsloven), an employee must state of its own motion or at the employer's request to that effect whether the employee knows that (s)he suffers from an illness or shows symptoms of an illness which will significantly affect the employee's ability to carry out the work in question.

11.12.3. Further, as a potential future employee, you are subject to the general duty of transfer which means that you must not knowingly withhold information that may be relevant to your opportunity for being employed.

11.12.4. Moreover, it should be noted that if you are offered a position, we will use certain personal data about you to draft your employment agreement, including your name and address.

11.12.5. If you do not wish to provide the information that you are required to provide under the provisions of the Danish Health Information Act or similar legislation and/or according to your duty of transfer or the information necessary for drafting an employment agreement, or any other information which we are required to collect from you by law, we will be unable to offer you a position. 

12. Transfer of your personal data to third countries

12.1. We transfer your personal data to countries outside the EU and EEA, when making data available to our processors, including to the US. Further, we also transfer your personal data to the UK, US and India when we share personal data with our group companies located in the UK, US and India.

12.2. The bases for such transfers are

• for all third countries other than UK (and the US – if the US organization does not participate in the EU-US Data Privacy Framework): the Commission Decision of 4 June 2021 on standard contractual clauses for the transfer of personal data of third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council, and
• for the UK: an EU Commission adequacy decision based on article 45 of the GDPR.
• for the US, if the US organization participates in the EU-US Data Privacy Framework: an adequacy based on article 45 of the GDPR.

11.3. If you want additional information about our transfer of personal data outside the EU and EEA, you can make a request for such additional information by contacting us (see contact information below).

13. Your rights etc.

13.1. You have special rights to help you control your personal data, and we wish to make it easy for you to exercise those rights:

13.2. Right to withdraw consent

Where you have given your consent for our processing of your personal data, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us, see below under "Contact".

If you wish to unsubscribe to our newsletters, you can also withdraw your consent by unsubscribing in the emails you receive from us.

If you withdraw your consent, the withdrawal will not affect the lawfulness of processing that has already been carried out based on your consent.

13.3. Right of access

You have the right to have confirmed whether we collect or process your personal data, and, if so, you have the right to request a copy of your personal data in a digital format.

13.4. Right of rectification

You have the right to require that we correct any inaccurate personal data concerning you, and that we complete incomplete personal data.

13.5. Right of erasure

In certain circumstances, you have the right to request that we erase personal data concerning you; for example, if it is no longer necessary for the purposes for which it was originally collected.

13.6. Right to restrict processing

In certain circumstances, you have the right to request that we restrict the processing of your personal data, e.g., if you believe that the personal data is not accurate or lawfully processed.

13.7. Right to object to the processing

In certain circumstances, you have the right to request that we stop processing your personal data.

13.8. Right to data portability

In certain circumstances, you have the right to receive the personal data you have provided us with in a structured, commonly used, machine readable format, and the right to have us transmit the data to another entity, where technically feasible.

13.9. Complaint to a supervisory authority

13.9.1. If you want to lodge a complaint with a supervisory authority about our processing of your personal data, you can do so by contacting the Danish Data Protection Agency via their website, File a complaint (datatilsynet.dk).

13.9.2. You may also contact your local regulator (outside Denmark) to receive guidance on how to file a complaint, see: Our Members | European Data Protection Board (europa.eu).

13.9.3. Further, if you are a resident in the United Kingdom, detailed information on the full content of your rights (and any conditions that may apply) is provided by the United Kingdom’s Information Commissioner’s Office and is available on their website: https://ico.org.uk/your-data-matters.

13.9.4. You can read more about your rights in the Danish Data Protection Agency's guidelines on data subjects' rights, which is available at datatilsynet.dk (in Danish). Please contact us if you wish to exercise your rights. The relevant contact details are stated below.

14. Contact

You can contact our headquarters at

Leapwork ApS
CVR no. 36 92 42 25
Store Kongensgade 72
1264 Copenhagen
Denmark

Please check our other locations on our website for an overview of the other Leapwork companies.

You can always reach us at email: privacy@leapwork.com.

15. Privacy Notice to California Residents

If you are a consumer located in California, we process your personal information in accordance with the California Consumer Privacy Act (CCPA). This section provides additional details about the personal information we collect and use for purposes of CCPA.

The sections above describe the personal information we may have collected about you within the last twelve (12) months, including the categories of sources of that information. We collect this information for the purposes of, as well as disclose it, as described in the above sections.

Your CCPA Rights and Choices. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:

• Exercising the right to know: You may request the following information about the personal information we have collected about you (see above under Your Rights Etc.):
  • the categories and specific pieces of personal information we have collected about you;
  • the categories of sources from which we collected the personal information;
  • the business or commercial purpose for which we collected the personal information;
  • the categories of third parties with whom we shared the personal Information; and
  • the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.
• Exercising the right to delete: You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
• Exercising the right to opt-out from a sale: You may request to opt out of any “sale” of your personal information that may take place. We do not use, share, rent or sell the personal information of our customers for interest-based advertising. We do not sell or rent the personal information of our customers or our site visitors.
• Non-discrimination: The CCPA provides that you may not be discriminated against for exercising these rights.

[1] Relevant provisions may be: Articles 6(1)(a) and 9(1)(a) of the GDPR, depending on the specific information provided by you.