The short version: You control your data. We collect your information only when you submit it voluntarily through Leadova's platform. We share your profile only with businesses that have subscribed to your specific vertical (e.g., OFW Employment). You can withdraw consent and have your data deleted at any time.
1. Who We Are
Leadova ("Leadova," "we," "us," or "our") is a consent-first lead generation platform that connects individuals seeking services or opportunities with verified businesses in their relevant industry vertical. Our platform is operated by Leadova and is available at leadova.polsia.app.
We act as a Personal Information Controller under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") with respect to personal data we process on our platform.
For privacy inquiries, you may reach us at: privacy@leadova.com
2. Information We Collect
We collect information in the following contexts:
2.1 Information You Submit as a Lead (Data Subject)
When you submit your profile through a Leadova landing page, field agent, or AI chatbot, we collect:
- Identity information: Full name, date of birth, gender, nationality
- Contact information: Mobile number, email address, home address
- Professional information: Work experience, skills, certifications, educational background, employment history
- Vertical-specific information: For OFW Employment — preferred destination countries, desired job categories, passport status, existing visas; for other verticals, relevant intake fields
- Consent records: Timestamp, method of consent (web form, agent signature, chatbot transcript), IP address, device information at time of submission
2.2 Information Collected Automatically
When you visit our platform, we may automatically collect:
- Device type, operating system, browser type
- IP address and approximate geographic location
- Pages visited, time spent, referral source
- Session identifiers (stored locally in your browser)
2.3 Information from Subscribing Businesses
When a business subscribes to the platform, we collect their business registration details, authorized representative information, and subscription payment information.
2.4 Information from Field Agents
Agents who capture leads on behalf of Leadova provide their own identity and contact information, and are required to document consent for each lead they collect.
3. How We Use Your Information
We use the personal information we collect for the following purposes:
- Core service delivery: Creating and maintaining your profile in our lead database so that subscribed businesses in your vertical can discover and contact you
- Consent management: Recording, storing, and honoring your consent decisions, including processing withdrawal requests
- Quality assurance: Verifying the accuracy and completeness of your submitted information
- Platform operations: Maintaining the security and integrity of our systems
- Legal compliance: Meeting our obligations under the DPA and other applicable laws
- Analytics: Aggregate, anonymized reporting to understand platform usage (no individual profiling)
We do not: sell your personal data to third parties, use your information for advertising targeting, profile you for automated decision-making with legal effects, or share your data with any business that has not subscribed specifically to your vertical.
4. How We Share Your Information
Your profile is shared only under the following conditions:
4.1 Subscribing Businesses (Your Vertical Only)
When you submit your profile, you consent to it being visible to businesses that have subscribed to the vertical you are enrolled in. For example, if you submit as an OFW employment seeker, your profile is accessible only to businesses subscribed to the OFW Employment vertical. A business subscribed to Real Estate cannot access your profile. This vertical isolation is enforced at the platform level.
4.2 Service Providers
We share limited data with trusted service providers who help us operate the platform, including cloud hosting, database management, and email delivery. These providers are contractually prohibited from using your data for any purpose other than providing services to us and are required to maintain appropriate security standards.
4.3 Legal Requirements
We may disclose your information when required by applicable law, court order, or government authority, or when necessary to protect the rights, property, or safety of Leadova, our users, or the public.
4.4 Business Transfers
In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the successor entity. We will notify you of any such change and ensure that your rights under this policy continue to be honored.
4.5 What We Never Do
- We do not sell or rent your personal data
- We do not share data across verticals you have not consented to
- We do not share your data with businesses whose subscriptions have lapsed
- We do not allow businesses to resell or re-share your data
5. Your Rights Under RA 10173 (Philippine DPA)
As a data subject under the Philippine Data Privacy Act, you have the following rights, which you can exercise at any time:
- Right to be informed: You have the right to know when your personal data is being collected, the purposes for collection, and how it will be used
- Right to access: You may request a copy of the personal information we hold about you
- Right to correction: You may request that inaccurate, incomplete, or outdated information be corrected
- Right to erasure or blocking: You may request deletion of your personal data, subject to our legal retention obligations
- Right to object: You may object to the processing of your personal data for specific purposes
- Right to data portability: You may request your data in a structured, machine-readable format
- Right to file a complaint: You have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines
- Right to withdraw consent: You may withdraw your consent at any time (see Section 6 below)
To exercise any of these rights, contact us at privacy@leadova.com with your full name and the right you wish to exercise. We will respond within 15 business days.
5.1 Adaptability for International Users
While Leadova is currently operated under Philippine law, we recognize the rights of data subjects in other jurisdictions. Users in the European Economic Area have rights under the GDPR (including the right to access, rectification, erasure, restriction, portability, and objection). Users in California have rights under the CCPA/CPRA. We honor these rights on a best-efforts basis and will expand our formal compliance posture as we grow internationally.
6. Consent and How to Withdraw It
Your consent is the legal basis for our processing of your personal data. Consent on Leadova is:
- Explicit: You actively check a box, sign a form, or verbally confirm to a field agent — we do not use pre-ticked boxes or assumed consent
- Informed: At the point of consent, you are told exactly what data is being collected, who will see it, and for what purpose
- Voluntary: Submission is entirely optional; there is no penalty for declining
- Specific: Consent is captured per vertical — consent for OFW Employment does not extend to other verticals
6.1 Withdrawing Your Consent
You can withdraw your consent at any time, with no questions asked, using any of the following methods:
- Email: Send a withdrawal request to privacy@leadova.com from the email address associated with your profile
- In-app: Use the "Withdraw Consent" button in your profile dashboard (if you have account access)
- One-click unsubscribe: Any communication from Leadova or a subscribed business includes an unsubscribe link that triggers immediate consent withdrawal
Upon receiving your withdrawal request, we will:
- Remove your profile from the active lead database within 48 hours
- Notify all businesses that had accessed your profile that your consent has been withdrawn
- Retain a minimal record (your name and withdrawal timestamp) for 12 months for audit purposes, then permanently delete it
- Send you a confirmation of the withdrawal within 3 business days
Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal.
7. Data Retention
We retain your personal data for the following periods:
- Active profiles: Retained for as long as your consent is active and you have not requested deletion. Profiles inactive for 24 months will be sent a renewal notice; if no response is received within 30 days, the profile will be deactivated and scheduled for deletion.
- Withdrawn consent: Profile data is deleted within 48 hours of withdrawal. Minimal audit records (name, withdrawal timestamp, consent method) are retained for 12 months per our legal compliance obligations.
- Deleted profiles: Permanently purged within 30 days of deletion request.
- Business subscriber data: Retained for the duration of the subscription plus 3 years for billing and legal compliance purposes.
- Consent audit logs: Retained for 5 years to comply with the DPA's requirement that we be able to demonstrate consent was obtained.
8. Security
We implement appropriate technical and organizational measures to protect your personal data, including:
- Encryption of personal data in transit (TLS 1.2+) and at rest
- Access controls ensuring that only authorized personnel can access personal data
- Regular security assessments and monitoring
- Data minimization — we only collect what is necessary for our stated purposes
No system is 100% secure. In the event of a data breach affecting your personal information, we will notify you and the National Privacy Commission within 72 hours of discovery, as required by the DPA.
9. Children's Privacy
Leadova is not directed to individuals under 18 years of age. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a minor, please contact us immediately at privacy@leadova.com and we will delete it promptly.
10. International Transfers
Leadova is primarily operated from the Philippines. Our servers and service providers may be located in other countries, including the United States. When we transfer data internationally, we take steps to ensure that appropriate safeguards are in place consistent with the requirements of the Philippine DPA and applicable international frameworks.
11. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes, we will:
- Update the "Last updated" date at the top of this page
- Send a notice to any email address we have on file for you
- Post a prominent notice on our platform for 30 days
Your continued use of the platform after the effective date of any changes constitutes acceptance of the updated policy. If you do not agree to the updated policy, you may withdraw your consent and request deletion of your data.
12. Contact Us
For any privacy-related questions, to exercise your rights, or to file a complaint, contact our Privacy Officer:
- Email: privacy@leadova.com
- Response time: Within 15 business days
You also have the right to file a complaint with the National Privacy Commission of the Philippines:
- Website: www.privacy.gov.ph
- Email: complaints@privacy.gov.ph