Privacy Policy

Thank you for choosing to be part of our community at Jemcode International Limited, doing business as Leal (“Leal”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our notice, or our practices with regards to your personal information, please contact us at [email protected].

When you visit our website https://www.tryleal.dev, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Sites and our services.

This privacy notice applies to all information collected through our website (such as https://www.tryleal.dev), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy notice as the “Services”).

Please read this privacy notice carefully as it will help you make informed decisions about sharing your personal information with us.

Store owners and their customers

Leal is used by businesses (“store owners”) to run loyalty programmes for their own customers (“shoppers”). We handle these two groups’ information in different roles:

• Store owners, and visitors to tryleal.dev. We decide how this information is used, so we are the data controller. This policy describes what we do with it.
• Shoppers who join a store’s loyalty programme. The store decides what to collect and how to use it, so the store is the data controller and we are its data processor. We only use shoppers’ information to run that store’s loyalty programme, on the store’s instructions, under our Data Processing Agreement. If you are a shopper, please contact the store about your information. We will help the store with your request.

1. What information do we collect?

Information you give us

In Short: We collect the information you provide when you sign up, use Leal or contact us.

• Account information: your name, email address and password (stored as a one-way hash), and the stores, cards, rewards and locations you set up.
• Billing information: if you upgrade, our payment processor Stripe collects your payment details. We receive your billing name, address and subscription status, but never your full card number.
• Support conversations: messages you send us by email or through the in-app chat.

Information we hold for stores

When a shopper joins a store’s loyalty programme, we store the details that store’s sign-up form asks for (such as name, email address, phone number and birthday), their loyalty card, stamps, rewards and redemptions, and the identifiers needed to deliver and update their Apple Wallet or Google Wallet pass. We hold this on the store’s behalf, as described above.

Information automatically collected

In Short: Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies, as described in section 4.

2. How do we use your information?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

This section covers information we control. Shoppers’ information is only used to provide the store’s loyalty programme, as instructed by the store.

We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.

We use the information we collect or receive:

• To create and manage your account, and to provide the Services you use.

• To bill for subscriptions. Payments are processed by Stripe.

• To send administrative information to you, such as account, security and billing emails, product and feature updates, and changes to our terms and policies.

• To send you our newsletter. When you create an account we add you to our email newsletter of product news and tips, which we send using Kit. You can unsubscribe at any time using the link in any newsletter email. We never use shoppers’ details for our own marketing.

• To check sign-ups. We check the email address used to sign up with Usercheck to block disposable addresses and abuse.

• To provide support, including through the in-app chat (Crisp).

• To post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location, and contact information.

• Request Feedback. We may use your information to request feedback and to contact you about your use of our Services.

• To protect our Services, for example for fraud monitoring and prevention, and to enforce our terms, conditions and policies.

• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

• To improve the Services and measure our marketing. We analyse how the Services are used, and measure which of our own adverts lead to sign-ups, as described in sections 3 and 4.

3. Will your information be shared with anyone?

In Short: We don’t sell personal information or share it with anyone for their own marketing. We use trusted providers to run Leal, and we measure our own advertising on tryleal.dev and in the Leal dashboard.

We do not sell, rent or trade personal information, and we do not share it with third parties for their own marketing purposes. We share information only in the following situations:

• Service providers that run Leal. Providers that host, store or deliver parts of the Services process information on our behalf and may only use it to provide their service to us. The providers that handle shoppers’ information are listed in Annex 2 of our Data Processing Agreement. For store owners’ information we also use Stripe (billing), Crisp (support chat), Kit (newsletter), Usercheck (sign-up checks) and Mapbox (looking up store addresses).

• Analytics and advertising measurement. On tryleal.dev and in the Leal dashboard, we use Google Analytics to understand how the Services are used, Google Ads and the Meta Pixel to measure the results of our own adverts (for example, whether an ad led to a sign-up), and Revshare to credit referrals from our affiliate partners. These providers collect information such as pages visited, device and browser details, and IP address through cookies and similar technologies, and Google and Meta may also use it under their own privacy policies. These tools are not used on the pages shoppers use to join a store’s loyalty programme, and shoppers’ details are never sent to them. We do not show third-party adverts on the Services.

• Integrations you connect. If you connect another service to Leal, such as Zapier, a point-of-sale or e-commerce platform, your own email or SMS provider, an AI assistant, or a webhook endpoint, we send it the information needed for that integration, on your instruction.

• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Our main hosting and database are in the EU. Some providers, including Stripe, Google, Meta and Apple, are based in the United States. Where information is transferred outside the European Economic Area, we rely on the EU-US Data Privacy Framework or the European Commission’s standard contractual clauses.

4. Do we use cookies and other tracking technologies?

In Short: Yes. We use essential cookies to run Leal, and analytics and advertising cookies on tryleal.dev and in the Leal dashboard.

We use cookies and similar technologies (like pixels) for these purposes:

• Essential: keeping you signed in, security and remembering your preferences. The Services can’t work without these.
• Analytics: Google Analytics, to understand how tryleal.dev and the Leal dashboard are used.
• Advertising measurement: Google Ads and the Meta Pixel, to measure the results of our own adverts.
• Referrals: Revshare sets a cookie for 30 days to credit sign-ups referred by our affiliate partners.
• Support: Crisp, to run the in-app chat for signed-in store owners.

You can block or delete cookies in your browser settings, and you can manage how Google and Meta use information for advertising in your Google ad settings and Meta ad preferences. Blocking essential cookies may stop parts of the Services from working.

5. How long do we keep your information?

In Short: We keep store owners’ information while their account is open. When a store deletes its account, its shoppers’ information is deleted within 10 business days, and from backups within 30 days.

Store owners’ account information is kept while your account is open. Cancelling a paid plan does not delete your account or your data. When you delete your account, we delete your account information from our live systems. We may keep limited records to prevent fraud, resolve disputes or comply with legal requirements, and no such record is kept for longer than 1 year after your account is deleted, except billing records, which we keep for as long as tax and accounting law requires.

Shoppers’ information is controlled by the store:

• A store can export its customers, with their stamps and rewards, at any time from its dashboard, including before closing its account.
• A store can delete an individual customer at any time. That customer’s information is deleted from our live systems straight away.
• When a store deletes its Leal account, its shoppers’ information is deleted from our live systems and those of our providers within 10 business days, as set out in section 9 of our Data Processing Agreement.

Backups. Deleted information can remain in our encrypted backups until they expire, within 30 days. Until then it is kept secure and isolated from any further processing.

Newsletter. If you unsubscribe, we keep your email address on a suppression list so that we don’t email you again.

6. How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.

7. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at [email protected].

8. What are your privacy rights?

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. Our lead supervisory authority is the Data Protection Commission in Ireland, and you can find the contact details for other authorities on the European Data Protection Board website.

If you have questions or comments about your privacy rights, you may email us at [email protected].

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can log into your account settings and update your user account.

When you delete your account, we delete your account information, and your stores’ customer information, from our active databases, as described in section 5. Some limited records may be retained to prevent fraud, assist with any investigations, enforce our Terms and/or comply with legal requirements, for the periods set out in section 5.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. See section 4 for the cookies we use and how to manage advertising settings with Google and Meta.

Opting out of email marketing: You can unsubscribe from our newsletter at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the newsletter – however, we will still need to send you service-related emails that are necessary for the administration and use of your account.

9. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

10. Do California residents have specific privacy rights?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.

11. Using Leal with AI assistants

In Short: If you connect an AI assistant such as Claude, ChatGPT or Cursor to Leal, we only receive what the assistant sends to Leal’s tools. We never see your conversations, and the assistant can’t read your customers’ details.

Leal runs a Model Context Protocol (MCP) server at https://mcp.tryleal.dev/mcp that AI assistants can connect to so you can set up and change your loyalty programme by chatting. How it works is described at https://www.tryleal.dev/mcp.

What we receive. Only the details an assistant passes to a Leal tool to carry out your request, for example a website address, your store’s name, card colours and design choices, reward names, a store address, and links to logos or images. We do not receive your chat history, the rest of your conversation, the assistant’s memory, or files you share with it. Like any web request, we also receive the connecting service’s IP address and software name, which we use for security and rate limiting.

Websites and images. When you ask for a design based on a website, Leal fetches that public web page and the logo and images it links to, to suggest your name, colours and logo. Only public web addresses are fetched. Results are cached for up to one day so repeat requests are fast; logos and images you choose to use are stored with your card like any image you upload.

Signing in and connected apps. Design previews work without an account. Anything that reads or changes your stores asks you to sign in to Leal (or create a free account) in your browser and approve the connection. We store which app you connected, when it was connected and last used, and the access tokens issued to it, which we keep only as one-way hashes. Access tokens expire after one hour and refresh tokens after 90 days, and expired or revoked tokens are deleted within 30 days. If the app asks for it, we also share your Leal account’s email address, whether it has been verified and an opaque account identifier with that app, so it can recognise which Leal account is connected. You can see and disconnect connected apps at any time in Settings → AI agents.

What assistants can see and do. A connected assistant can read and change your stores, loyalty cards, rewards, signup posters and store locations. It cannot read your customers’ names, email addresses, phone numbers or birthdays, cannot delete anything, and cannot see or change billing. Records it creates are part of your Leal account and are kept and deleted like the rest of your account data (see section 5).

The assistant’s provider. Information Leal returns to an assistant is processed by that assistant’s provider (for example Anthropic, OpenAI or Anysphere) under their own terms and privacy policy, not this one.

12. Do we make updates to this policy?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. How can you contact us about this policy?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Rikki Pitt, by email at [email protected].

The data controller for the information described in this policy (other than shoppers’ information, which is controlled by the store) is Jemcode International Limited, 6 Fern Road, Sandyford, Dublin D18 FP98, Ireland. You can contact us about how we process your information by email at [email protected].

How can you review, update, or delete the data we collect from you?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us at [email protected]. We will respond to your request within 30 days.