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Privacy Policy

Last update: May 27, 2026

This Privacy Policy (the “Policy”) governs your use of our Website and application (collectively referred to as the “Service”). It outlines the types of data we collect, how we store it, how it may be used, with whom it may be shared, and your choices regarding these uses and disclosures. It also describes certain legal rights you may have, subject to applicable law, and how you can exercise them.

By accessing, using the Service, submitting your personal information to us or otherwise interacting with the Service you agree to any processing and transfer of your personal information in accordance with this Policy.

Please be sure to carefully read the entirety of this Policy when using the Service.

For the purposes of this Policy:

“personal information” and/or “personal data” refers to data about identified or identifiable individuals (such as their name, mobile phone number, email address etc.); it may also include, where required by applicable law, the scope of the definition provided therein, e.g., as per the: 1) relevant U.S. federal or state legislation; and/or 2) the European Union’s law.

“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

“EEA” includes all current Member States of the European Union as well as Iceland, Liechtenstein, and Norway. For the purpose of this Policy, EEA shall also include the United Kingdom of Great Britain and Northern Ireland.

“Process”, in respect of personal data, includes to collect, store, use, and disclose to others.

Terms not defined in this Policy shall have the meanings set out in the GDPR, unless stated otherwise.

Check Leaply Terms of Use & Service (the “Terms”) for the meaning of defined words (those with capital letters) not explicitly defined in the Policy.

Any translation from the English version is provided for your convenience only. In the event of any difference in meaning or interpretation between the English language version and any translation, the English language version will prevail. The original English text shall be the sole legally binding version.

1. Personal data controller

Momentumix Limited with registered office at: Georgiou A, 83, Shop 17, Potamos Germasogeias, 4047, Limassol, Cyprus will be the controller of your personal data.

2. What categories of personal data do we collect?

We collect data you make available to us voluntarily (for example, email address, phone number, name, date of birth). We also collect data automatically when you use the Service (for example, your IP address, device type).

2.1. Data you provide to us

You provide us data about yourself when you register for and/or use the Service, for example, when you create a user profile (“Profile”), respond to our emails, or report a problem. The data that you provide to us includes:

Profile data and other materials you post on the Service. This includes your name, username, date of birth, email address. You may also provide us your phone number, voice and image (in any content you upload) and additional data on your Profile. This may include, but is not limited to: your gender and age, other personal characteristics and demographic data, any ideas, comments, testimonials you share and post, as well as images, photographs and videos.

By providing this information you agree and understand that this data may be publicly available (unless otherwise explicitly stated in a particular case). Please do not provide personal data to your Profile that you would not want to be publicly available.

2.2. Data we collect automatically

Data about how you found us. We collect data about your referring URL (that is, the place on the Web where you were when you tapped on our ad).

Cookies and other similar technologies. As further described in our Cookie Policy, our Service uses cookies that record data about the use of our Service to distinguish you from other users. You can control cookies through your browser settings.

In our mobile application, we may also use software development kits (SDKs). SDKs help us understand how you interact with our mobile applications and collect certain information about the device and network you use to access the application.

For example, we may use Smartlook SDK, a third-party analytics and session-recording service, to help us improve the performance and usability of the Service. Smartlook may collect information about how you interact with our application or website, including screen views, taps, gestures, session durations, device information (such as device model, operating system version, app version), and diagnostic data (such as crashes or errors). The information collected is used for internal analytics purposes only, helping us understand feature usage, detect issues, and enhance user experience. We have configured Smartlook so that it does not capture sensitive personal data.

Browser and Device data. We collect data from or about the devices from which you access the Service, depending on the permissions you’ve granted. We may associate the data we collect from your different devices, which helps us provide consistent services across your devices. Examples of such data include: language settings, IP address, location, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.

We also collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

Transaction data. When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data and data about the transaction, including: date, time and amount of the transaction, and the type of payment method used.

Usage data. We record how you interact with our Service. For example, we log the features, and content you interact with, how often and long you use the Service, what sections you use, and other interactions.

3. For what purposes do we process your personal data?

We process your personal data:

3.1. to provide services to you.

This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues. For example, we use your data to authenticate you and authorize access to our Service.

We utilize Google Gemini and OpenAI as third-party providers for AI chat functionality within our Service. Chat data may be shared with them and retained by OpenAI for up to 30 days, and by Google Gemini for up to 55 days, solely for security and misuse monitoring purposes. These providers do not use this data to train or improve AI models. They also implement security measures, including data encryption and audit controls, to protect data on their end.

To provide personalized support and enhance your experience with our AI assistant, we process general information about how you interact with the chat. This includes details on which features you access, such as chat refresh actions, popups viewed and responded to, prompt clicks, exit actions, and the frequency of use, helping us better understand overall engagement patterns, including your feedback.

3.2. to research and analyze your use of the Service.

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We conduct surveys, research, and test features in development. We analyze the data we have to evaluate our Service, and conduct audits and troubleshooting activities to improve our Service content and layouts. As a consequence, we often decide how to improve the Service based on the results obtained from this processing. For example, if we discover that users do not often use certain section of the Service, we may focus on improving this section.

3.3. to customize the Service for you.

We select the payment processor available to you; we may also use your data to determine your eligibility for promotions, sweepstakes, and contests.

3.4. to process your payments.

We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment for paid features of the Service.

3.5. to enforce the Terms and to prevent, detect, investigate, and resolve disputes and/or remediate malicious activities, fraud, other cybercrimes, take legally-required actions, or make sure you are a real person and avoid the creation of fake accounts.

We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with the Terms).

3.6. to communicate with you regarding your use of our Service.

We may communicate with you, for example, by email or directly on the Service, including through push notifications.

3.7. to show and/or send you marketing communications.

We process your personal data for our marketing campaigns. We may add your email address to our marketing list. As a result, you will receive information about our Service, features, offers, promotions, contests, and events or provide other news or information about third party services that may be of interest to you. You can opt out of advertisement and/or commercial emails by contacting us at support@theleaply.com.

3.8. to provide you customer service and support.

As a result of such processing, we will send you messages about the availability of our Service, security, payment transactions, status of your orders, legal notices, or other Service-related information.

When you contact support, your inquiry may be handled fully or partially by an AI assistant. Messages sent to our support may be processed by third-party AI providers as described in Section 6.

3.9. to personalize our ads.

We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time.

3.10. to comply with legal obligations.

We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

3.11. for participation in surveys.

From time to time, we may start surveys/feedback for research purposes and we may contact you to find out if you would like to take part. Such activities are optional. If you do not wish to be contacted to take part in a survey or marketing campaign, please contact us at support@theleaply.com. If you do not want to contact us but you also do not want to participate in our activities, please ignore our messages.

4. Legal basis for data processing (EEA only)

In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users.

We process your personal data under the following legal grounds:

A. Consent.

Where required by law, as well as in other cases, we handle personal information on the basis of implied or express consent.

B. To perform our contract with you.

We process your personal information on this basis in order to:

  • provide the services;

  • customize your experience;

  • communicate with you regarding your use of the Service;

  • verify your identity;

  • manage your account;

  • provide you customer service and support;

  • process your payments.

C. Legal compliance.

We may need to use and disclose personal information in certain ways to comply with our legal obligations. Under this legal basis we, in particular, verify your identity.

D. Legitimate interest.

For our (or others’) legitimate interests unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.

We rely on legitimate interests:

  • to communicate with you regarding your use of our Service. This includes, for example, sending you notifications. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often. We also take into account the potential benefits to you.

  • to research and analyze your use of the Service. Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Service easier and more enjoyable, or to introduce and test new features).

  • to send you marketing communications. The legitimate interest we rely on for this processing is our interest to promote our Service in a measured and appropriate way. Depending on your jurisdiction, we may rely on your consent for this processing instead.

  • to personalize our ads. The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way. Depending on your jurisdiction, we may rely on your consent for this processing instead.

  • to enforce the Terms and to prevent and combat fraud. Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorized use of the Service, non-compliance with the Terms.

5. Data retention

We will retain personal data for the period necessary to fulfill the purposes outlined in the Policy unless a longer retention period is required or permitted by law.

Please note that we have a variety of obligations to retain the data that you provide to us, including to ensure that transactions can be appropriately processed, settled, refunded, or charged-back, to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers. Accordingly, even if you disable/delete your Profile, we will retain certain data to meet our obligations.

6. With whom do we share your personal data?

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes indicated in the Policy. The types of third parties we share information with include, in particular:

6.1. Service providers

We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:

  • cloud infrastructure and storage providers (e.g. Amazon Web Services, Google Cloud Platform, servers.com);

  • data analytics providers (e.g. Facebook, Google, Amplitude, Smartlook);

  • marketing partners (e.g. Google Ads, Facebook Ads, social media networks, marketing agencies, email delivery services);

  • communication service providers (e.g. Zendesk, Firebase);

  • support services providers (e.g. EverHelp);

  • AI service providers that enable in-app chat and content-processing features (OpenAI, Google Gemini);

  • gateway service providers and payment processors (e.g. Solidgate, PayPal and Stripe).

6.2. Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce the Terms, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

6.3. Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

7. Links to Other Websites and Third-Party Content

We may provide links to third-party websites, services, and applications that are not operated or controlled by Leaply. This Policy does not apply to the privacy practices of those third parties. The fact that we link to a website, service, or application is not an endorsement, authorization, or representation of our affiliation with that third party. We encourage you to review the privacy policies of any third-party service before providing any personal information to or through them.

8. International data transfers

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and for purposes indicated in the Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the EU-U.S. Data Privacy Framework (details available here), or (iii) the European Commission adequacy decisions about certain countries (details available here).

9. Changes to the Policy

We may from time to time update this Policy to reflect changes to our practices. If such changes take place, we will post an updated version of the Policy on the Service and indicate when the revision took place. In case of material changes to this Policy, we may also notify you through the Service or by other available means.

By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Policy. You are advised to regularly check the Policy to stay up-to-date.

10. Age limitation

We do not knowingly process personal data from persons under 18 years of age. If you learn that anyone younger than 18 has provided us with personal data, please contact us at support@theleaply.com.

11. Privacy rights

To be in control of your personal data at Leaply your rights include, but are not limited to the following:

Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided to us. You control your Profile; thus, you may access your Profile data at any time and correct or update it at any time by logging in to the Service. You may also request a copy of your personal data collected during your use of the Service at support@theleaply.com.

Deleting your personal data. You can request erasure of your personal data by sending us an email at support@theleaply.com.

When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.

Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request to support@theleaply.com.

The right to lodge a complaint with supervisory authority (EEA residents). We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.

Withdraw consent. Where the processing of your personal data is based on your consent (for example, marketing communications or AI chat features), you have the right to withdraw that consent at any time by contacting us at support@theleaply.com. The withdrawal does not affect the lawfulness of processing based on consent before the withdrawal.

The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send a respective request to support@theleaply.com.

You may submit requests through an authorized agent, in which case we will need to verify the agent’s identity, your identity, and their authority to act on your behalf before we can process the request.

12. Privacy Rights of the Residents of Certain States of the U.S.

Depending on the state in which you reside (including but not limited to California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, and other states to the extent they enact privacy laws), you may be entitled to specific privacy rights under state law. These rights apply only to the extent that the relevant state privacy law is applicable to you and to our processing of your personal data. The scope of these rights can vary, and they may be subject to legal conditions or exceptions. If you are uncertain whether these rights apply to you or would like further clarification, you may reach out at support@theleaply.com.

For California residents, this also serves as our California Notice at Collection.

12.1. Non-Discrimination.

You have the right to exercise your privacy rights without fear of discrimination or retaliation. We will not deny you services, charge different prices, or provide a different level or quality of service because you exercised any of your privacy rights, except as permitted by applicable law.

12.2. Appeals.

If your privacy rights request is denied, you may appeal our decision in states where such right is granted by law (such as Colorado, Connecticut, and Virginia). The appeal must identify the original request and state the grounds for the appeal. We will respond within the timeframe required by applicable law. If the appeal is denied, you may escalate the matter to your state’s Attorney General.

12.3. How to opt out of personalized advertising on your device:

  • iOS: Settings → Privacy → Apple Advertising → deselect Personalized Ads.

  • Android: Settings → Privacy → Ads → enable “Opt out of Ads personalization”. You can also reset your advertising identifier in the same section.

  • macOS: System Preferences → Security & Privacy → Privacy → Apple Advertising → deselect Personalized Ads.

  • Windows: Settings → Privacy → turn off “Let apps use advertising ID to make ads more interesting”.

You may also opt out of interest-based advertising via:

12.4. “Shine the Light”.

If you are a resident of California, you may request that we provide you with the information that we have shared with third parties for electronic/online direct marketing purposes, if such sharing has occurred; such information can be provided to you once a year free of charge, and will cover information shared during the past twelve (12) months.

Information will be provided within forty-five (45) days of your request, or we will inform you that we need additional time to fulfill your request. If you are a California resident and wish to make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing to us at support@theleaply.com.

Any such request must include “California privacy rights request” in the first line of the description and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this address. Information shared for purposes other than direct marketing will not necessarily be included in our response to such request. We reserve the right to request and confirm proof of identity as we determine necessary in our sole discretion, and retain your request for at least two years for auditing and user management purposes.

13. Brazil data subject rights

In accordance with Article 18 of the General Personal Data Protection Law (“LGPD”) the following rights are stipulated for individuals in Brazil:

  • Confirmation of the existence of processing;

  • Access to personal data;

  • Correction of incomplete, inaccurate, or outdated data;

  • Anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;

  • Portability of data to another service or product provider, upon express request, in accordance with Brazilian regulations and subject to commercial and industrial secrecy;

  • Deletion of personal data processed with the data subject’s consent, except in the cases provided for in Article 16 of the LGPD;

  • Information on public and private entities with which personal data has been shared;

  • Information about the possibility of refusing consent and the consequences of such refusal;

  • Revocation of consent, pursuant to Article 8(5) of the LGPD.

You can submit a request to exercise these rights at support@theleaply.com. Please note that in certain circumstances, full compliance with a request may not be possible (for example, if the request is manifestly unfounded, impractical, affects the rights of others, or is not required by law). In such cases, a response will still be provided to inform the requester of the decision.

14. How do we handle “do not track” requests?

Except as otherwise stipulated in the Policy, the Service does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

15. Contact us

If you have any questions or concerns about this Privacy Policy or our collection, use, or storage of your data, please do not hesitate to contact us at:

E-mail: support@theleaply.com