Privacy policy

This Privacy Policy explains how Lulo Solutions LLC (“Lulo Solutions”, the “Company”, “we”, or “us”) collects, uses, shares, retains, and protects personal information in connection with Leepr (“Leepr”, offered as “Leepr by Exlink”), whether you visit our website at leepr.app or use the Leepr application at app.leepr.app and on an organisation’s own address on leepr.app.

Leepr is a business-to-business platform: a customer relationship management and sponsor-connection platform used by international student recruitment agencies (each, an “Agency”). Much of the personal information in Leepr is entered by an Agency about its own students, applicants, their families and other contacts, or comes from the sponsor organisations the Agency chooses to connect. Where we process that information on an Agency’s instruction, the Agency is the controller of that information and we act as processor on the Agency’s documented instructions, as set out in our Data Processing Addendum. For the information we hold for our own purposes, such as the accounts of Agency staff, billing details and messages sent through this website, we are the controller.

Relationship to the Terms of Service. This Privacy Policy forms part of the Terms of Service. In the event of any conflict between this Privacy Policy and the confidentiality or security provisions of the Terms of Service, this Privacy Policy governs.

Information We Collect

Visitors to this website

If you write to us through the contact form on leepr.app, we receive your name, your agency, your country, your email address and your message. Before the form is sent, Cloudflare Turnstile checks that the request comes from a person; it processes technical information about your browser and connection for that purpose.

This website does not use cookies and does not use analytics or advertising tools. Our hosting provider, Cloudflare, processes the technical information every request carries, such as IP address and browser type, to deliver and protect the website.

People who use Leepr for an Agency

When you create an account or are invited to one, we collect your name, email address, password (stored only as a one-way hash), your language and time zone, the roles your Agency gives you and, if you turn it on, your two-factor authentication settings. If you sign in with Google or Microsoft, we receive your name, email address and an account identifier from that provider.

We also collect technical and usage information automatically when you use Leepr, such as IP address, browser type, sign-in activity and the changes you make, which are recorded in your Agency’s audit log.

If you connect your calendar, we collect the information described under Third-Party Calendar Integrations below.

Billing

For an Agency that adds a payment card, we collect the billing contact’s name and email address, the billing address and country, the Agency’s VAT number where it has one, and the type, country and last four digits of the card. The card itself is collected and held by our payment processor, Stripe; we never receive the full card number. VAT numbers are checked with the European Commission’s VIES service or the UK’s HM Revenue & Customs.

Information Agencies keep in Leepr

On an Agency’s behalf, Leepr holds the information the Agency enters, imports or receives about its leads, students, applicants, their parents, guardians and other contacts. This can include, but is not limited to: name, email address, telephone number, address, date of birth, gender, nationality, education and program details, application answers, documents and images such as passports and transcripts, government-issued identification numbers (which Leepr stores encrypted), emails and attachments exchanged through Leepr, notes, tasks, meetings and the source of an enquiry.

People who fill in an Agency’s forms, its application or its booking pages on leepr.app provide their information to that Agency. Those pages do not use cookies; Cloudflare Turnstile protects them from automated abuse.

Information from sponsors

An Agency can connect Leepr to the sponsor organisations it works with (each, a “Sponsor”), such as sponsors that use Exlink. When an Agency member starts a connection, Leepr looks up the member’s email address in Exlink’s directory to list the Sponsors that know it. The member then signs in at the Sponsor and approves Leepr; Leepr never receives the member’s password at the Sponsor.

Through the connection, Leepr keeps a summary of the Agency’s students at that Sponsor, such as their names, email addresses, programs, statuses and what the Sponsor is waiting for from the Agency. Further detail is read from the Sponsor when a member opens it and is not stored. Each Sponsor is responsible for the information in its own system as a controller independent of us and of the Agency.

The assistant

If an Agency uses Leepr’s assistant to draft fields, forms or the mapping of its application to a Sponsor’s form, the request sent to our provider, Anthropic, contains configuration (such as field names, form outlines and Sponsors’ lists of questions) and the descriptions or blank forms a member provides, with names, email addresses and phone numbers removed from the descriptions. It does not contain the records of the Agency’s leads, students or contacts.

Errors

When something goes wrong in Leepr, an error report is sent to our diagnostics provider, Sentry, so that we can fix it. Error reports contain technical information, such as the page, the organisation’s address and the sequence of events leading to the fault, and are configured not to include personal information.

How We Use Personal Information

We use personal information for the following purposes: to provide and maintain Leepr; to process information on behalf of Agencies as they instruct; to communicate with Agencies and their members about their accounts, billing, security and the functioning of Leepr, including invitations, notifications and reminders; to bill Agencies and meet our tax obligations; to answer messages sent through this website; to maintain the security of accounts and detect and prevent abuse and unauthorized access; to comply with applicable legal requirements; and to improve and enhance Leepr.

Where the General Data Protection Regulation applies to our own processing, we rely on the performance of our contract with the Agency for providing Leepr and billing; on our legitimate interests in keeping Leepr secure, answering messages and improving the service; and on legal obligations for tax and accounting records.

How We Share Personal Information

We may share personal information with the following categories of recipients: individuals who have provided their consent; service providers and contractors engaged by us to support the operation of Leepr, which are listed with their purpose and location in our Data Processing Addendum; the Sponsors an Agency chooses to connect, when the Agency sends them information through Leepr; the tools an Agency connects through Leepr’s API and webhooks; payment processors and tax authorities as needed to bill and meet our tax obligations; governmental authorities and legal requirement responders as required by applicable law; and parties involved in safety and fraud protection contexts where disclosure is necessary to protect the rights, property, or safety of the Company, its Agencies, or others.

We do not sell personal information, and we do not share it for advertising purposes.

International Data Transfers

Leepr’s servers, database, stored files and email are located in the European Union. Some of our service providers, and the Company itself, are located in the United States and other countries, which may have different data protection laws than your country of residence. Where personal data is transferred from the European Economic Area, the United Kingdom or Switzerland to such a country, we use the safeguards required by law, such as the European Commission’s standard contractual clauses.

Your Rights

If you are a student, applicant, parent, guardian or other contact of an Agency, your information in Leepr is held on behalf of that Agency, and the Agency, as controller of the information, administers requests to access, correct, update, or delete it. Direct such requests to the Agency. Requests that reach us at privacy@exlink.org are referred to the relevant Agency, and we assist the Agency in responding.

If you use Leepr for an Agency, or have written to us through this website, you may ask us for access to the personal information we hold about you, to correct or delete it, to restrict or object to its use, or to receive a copy of it in a portable format, by writing to privacy@exlink.org. Your Agency can also change or remove your account. If you are in the European Economic Area or the United Kingdom, you may also lodge a complaint with your data protection supervisory authority.

Retention

We retain the information Agencies keep in Leepr for as long as the Agency has an account with us. When an Agency closes its account, the Agency may ask for an export of its information for thirty (30) days; we then delete it, and it is deleted from our backups as they expire, within a further thirty (30) days, except where the law requires us to keep it. Agencies and their members can delete leads, contacts and other records in Leepr at any time, and the files attached to them are deleted with them.

The following categories are subject to shorter retention periods, which apply in place of the general period described above:

(a) Backups. Database and file backups are kept for thirty (30) days.

(b) Incoming email. Raw copies of the emails Leepr receives for an Agency are deleted after thirty (30) days; the messages themselves stay in the Agency’s conversations.

(c) Sponsor and webhook records. Notifications received from Sponsors are deleted thirty (30) days after they are processed, and the log of webhook deliveries to an Agency’s own tools after thirty (30) days.

(d) Assistant drafts. Drafts from the assistant that are never applied are deleted after thirty (30) days.

(e) Error reports. Error reports are kept for ninety (90) days.

(f) Calendar integration data. The OAuth tokens and related identifiers described under Third-Party Calendar Integrations below are retained only while the calendar remains connected.

(g) Billing records. Invoices and the records needed for tax and accounting are kept for as long as the law requires.

(h) Messages through this website. Messages sent through the contact form are kept for as long as needed to answer them and follow up with you.

Cookies

This website does not set cookies.

The Leepr application uses only first-party cookies that are necessary to operate it: a session cookie that keeps you signed in across Leepr’s addresses on leepr.app, and a token cookie that protects the forms you submit. We do not use advertising or third-party tracking cookies. You may delete or block cookies in your browser settings, but the application cannot function without them. The public forms, application and booking pages that Agencies share use no cookies.

Third-Party Calendar Integrations

Leepr lets you connect your Google or Microsoft calendar so people can book meetings with you and so those meetings stay in sync. The data we access is used solely to provide this scheduling feature — we do not sell it, share it for advertising, or use it for any unrelated purpose.

Google Calendar

When you connect Google Calendar, you grant Leepr permission to:

• See and edit events on your calendars (calendar.events) — create the meeting event (with a Google Meet link) when someone books you, update it on reschedule, delete it on cancellation, and watch for changes you make directly in Google Calendar so they sync back to Leepr.
• View free/busy information (calendar.events.freebusy) — used only to find your open times so your booking page offers genuinely available slots; we do not read the titles, attendees, or details of your other events.
• View your list of calendars (calendar.calendarlist.readonly) — so you can choose which calendar Leepr writes to and reads availability from.
• Your basic Google profile (name, email) — to identify the connected account.

Limited Use. Leepr’s use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Microsoft / Outlook Calendar

When you connect a Microsoft (Outlook or Microsoft 365) calendar, you grant Leepr permission to:

• Read and write your calendars and events (Calendars.ReadWrite) — create the meeting event (with a Microsoft Teams link) when someone books you, update it on reschedule, delete it on cancellation, read your availability so your booking page only offers open slots, list your calendars so you can choose which one Leepr uses, and subscribe to changes so edits you make in Outlook stay in sync with Leepr.
• Sign you in and read your basic profile (User.Read) — your name and email, to identify the connected account.
• Maintain the connection (offline_access) — so Leepr can perform the above on your behalf without asking you to sign in every time.

Leepr’s access to and use of Microsoft data complies with the Microsoft APIs Terms of Use.

Data Storage and Disconnection

We store the OAuth access and refresh tokens for your connected account (encrypted at rest) so Leepr can act on your behalf, together with the identifiers of the events we create and the calendars you select. We retain this only while your calendar is connected. You can disconnect at any time from your calendar settings in Leepr, which deletes our stored tokens. You can also revoke Leepr’s access directly through your provider — Google at myaccount.google.com/permissions, Microsoft at myaccount.microsoft.com (work/school accounts) or account.live.com/consent/Manage (personal accounts).

Children and Minors

Leepr’s accounts are for Agency staff and are not directed to children. Agencies recruit students, many of whom are minors, and keep their information in Leepr as controllers; personal information relating to a student who is a minor is provided by the Agency, or by the student’s parent or legal guardian through the Agency’s forms and application, and the Agency obtains any consent required by the law of the student’s own country — including any parental consent required under Article 8 of the General Data Protection Regulation where the applicable digital-consent age applies.

Where a minor’s personal information is processed on an Agency’s instruction, that Agency is the controller of that personal information and we act solely as processor on the Agency’s documented instructions.

A parent or legal guardian who believes that a child has provided personal information directly to us may contact us at privacy@exlink.org.

How We Protect Your Data

Leepr safeguards the data it holds — including data obtained from Google APIs, such as your calendar events and free/busy information — with the measures described in our Security Policy, including:

• Encryption in transit and at rest. Data is encrypted in transit using TLS (HTTPS). The OAuth access and refresh tokens for connected calendars, and government-issued identification numbers, are stored encrypted.
• Access controls. Each Agency’s information is separated from every other Agency’s, access within an Agency follows the roles it gives its members, and access by our staff is limited on a strict need-to-know basis.
• Retention and deletion. We retain Google user data only while your calendar remains connected. You can disconnect at any time, which deletes the stored OAuth tokens and the associated Google data we hold.
• Incident response. If we confirm unauthorized access to your data, we notify the affected Agency’s designated security contact within 24 hours.

Limited Use. Leepr’s use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. We use Google user data solely to provide the calendar scheduling features you request; we do not sell or transfer this data, use it for advertising, or allow humans to read it except (a) with your consent, (b) for security purposes, (c) to comply with applicable law, or (d) as strictly necessary to operate and improve the feature.

Governing Language

This Privacy Policy is made in the English language. Any translation is provided for convenience only. In the event of any conflict or inconsistency between the English version and a translation, the English version governs.

Changes to This Policy

We may update this Privacy Policy from time to time. The version number and last-updated date at the top of this page indicate when it was last revised. Material changes will be posted at leepr.app/legal.

Contact Us

Questions about this Privacy Policy, or requests to access, correct, or delete personal information, should be directed to privacy@exlink.org.

Suspected security incidents or unauthorized access should be reported to security@exlink.org.