Privacy notice for members of the Loc Leaders community

Loc Leaders Community is operated by Phrase a.s. with its registered office at Spálená 108/51, 110 00 Prague 1, Czech Republic (“Phrase a.s.”, “we”, “us” and “our”) (acting as a data controller). We value your privacy and care about the way in which your personal data and personal information (“personal data”) is treated. We want you to understand how and why your personal data is collected, used, and shared by Phrase.

What personal data do we collect about you?

We collect the following personal data in connection with your relationship with us: your name and surname, job title and details about your job position, name of your organization, information about your professional career, user name, email address, phone number, information from your LinkedIn profile, information about your participation in conferences, information about our historic interaction with you or your organization, IP address of the device and type of Internet browser you use to connect to Phrase. These personal data fall under the following California Consumer Privacy Act categories: identifiers, commercial information and usage (information on your interaction with Phrase).

How do we obtain your personal data?

We obtain personal data about you from three different sources. We obtain some of the personal data directly from you, such as your name, surname and contact details. Then there are certain personal data that are created in the course of our relationship with you or your organization, such as information about our interaction with you and through your use of Loc Leaders Community. Finally, we also collect some personal data about you from public sources such as your LinkedIn profile.

How do we use your personal data?

Your personal data is processed for the following purposes:

  • to enable you create an account in the Loc Leaders Community;
  • to enable you to participate in the Loc Leaders Community
  • to maintain our business relationship with you or your organization;
  • our internal reporting;
  • to ensure network and information security;
  • to analyse and understand how Loc Leaders Community is being used and to enhance its functionality;
  • for future marketing, including sending you updates and marketing materials about Loc Leaders Community by email (unless you have indicated that you do not want to receive these marketing materials).

The above listed purposes are the following categories of business purposes under Section 1798.140(d)(3), (5), (6) and (7) of California Consumer Privacy Act (the “business purposes”).

We use your personal data on the following basis:

  • processing your personal data to enable your use of Loc Leaders Community is necessary so that we can operate this community;
  • processing of your personal data to comply with our legal obligations; and
  • processing of your personal data for other purposes listed in the Section “How do we use your personal data?” is based on our legitimate interest in processing personal data for these purposes: (i) to help us to maintain a productive business relationship with you, (ii) to improve our ability to understand your (business) needs; (iii) to improve and enhance the community; and (iv) to ensure network and information security.

How long will we keep your personal data?

If you are a member of the Loc Leaders Community, we will always keep your personal data for the period for which you will be participating in the community. We will also keep your personal data where required by law or where we need to do so in connection with potential or actual legal action or an investigation involving Phrase a.s.

With whom do we share your personal data?

Your personal data will be accessible to employees and, in certain specific cases, also, to authorized employees of certain suppliers of Phrase including, in particular, employees of Slack (our main communication tool), Notion (our main tool for project management and knowledge sharing) , HubSpot (our main marketing tool), (our provider of customer relationship management software), Google Inc. (our email and document storage provider ), or any additional or replacement suppliers we may appoint from time to time who provide Phrase with various services.

In the preceding twelve (12) months we have disclosed to the entities listed above the following categories of personal data for business purposes: identifiers, commercial information and usage (information on your interaction with Loc Leaders Community).

Transfers of your personal data outside of your home country

Your personal data may be transferred to countries outside the European Economic Area. These countries include: USA, Canada and Japan. The countries to which we transfer personal data may not have data protection laws that provide an adequate level of protection to your personal data.

We therefore take steps (which may include entering into data transfer agreements based on the model clauses approved by the European Commission) to ensure that the persons to whom we transfer data in those countries commit to ensure an adequate level of protection for your personal data. You can find more information about data transfer agreements here.

Protecting your personal data

Phrase a.s. may share your personal data with its suppliers under a written agreement which commits the suppliers to appropriate safeguards in relation to handling of your personal data (including in relation to maintaining confidentiality of your personal data and implementing appropriate technical and organizational security measures).

Phrase a.s. will take appropriate legal, organizational and technical measures to protect your personal data consistent with applicable privacy and data security laws.

Phrase a.s. does not sell your personal data.

Your rights

You may be entitled to:

  • opt out from processing of your personal data for direct marketing purposes;
  • request information regarding the processing of your personal data (including the categories of personal data collected about you, categories of sources from which the personal data is collected, the business or commercial purpose for collecting the personal data and the categories of third parties with whom we share the personal data), including to be provided with a copy of your personal data;
  • request the correction and/or deletion of your personal data, or object to the processing of your personal data;
  • request the restriction of the processing of your personal data;
  • request receipt or transmission to another organization, in a machine-readable form, of the personal data that you have provided to us; and
  • complain to your local data protection authority, or to a court of law, if your data protection rights are violated. You may be entitled to claim compensation for damages or distress incurred or suffered as a result of unlawful processing of your personal data.

You are not required by law to provide your personal data to us, however, if you don’t, then we may not be able to provide you or your organization with our services. If you object to the processing of your personal data, we will respect that choice in accordance with our legal obligations. Depending on the scope of your request, this could mean that we will not be able to provide you or your organization with our services. We will not discriminate against you for exercising any of your legal rights.

If you would like to exercise any of your rights, please let us know by getting in touch using the contact details below.

Contact us

If you have questions or requests regarding the processing of your personal data or require additional information, please contact:


This Privacy Notice was last updated on: 10 October 2022