Privacy Policy

1. Introduction

Leaders of Tomorrow ("LOT", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you participate in our digital exchange program, visit our website, or interact with our services.

By participating in the Leaders of Tomorrow program, you consent to the data practices described in this policy.

2. Information We Collect

2.1 Personal Information

We collect information that you provide directly to us, including:

• Name, age, and date of birth
• Email address and contact information
• Country of residence
• Educational background and English proficiency
• Application essays and interview responses
• Profile photos (optional)

2.2 Program Participation Data

During your participation in the program, we may collect:

• Attendance records for Dialogue Sessions and Video Calls
• Participation in digital platforms and cultural exchanges
• Project planning and collaboration activities
• Feedback and survey responses

2.3 Technical Information

We automatically collect certain technical information when you use our platforms:

• IP address and device information
• Browser type and version
• Usage data on our digital platforms
• Cookies and similar tracking technologies

2.4 Google Analytics Data Collection

We use Google Analytics to understand how visitors interact with our website. This includes:

• Pages visited and time spent on pages
• Geographic location (city and country level)
• Device type and browser information
• Traffic source and referral information
• User interactions and behavior patterns

Google Signals: We have enabled Google Signals, which collects additional data from users who are signed into their Google accounts and have consented to ads personalization. This allows Google Analytics to associate your website activity with Google's information about your account, including location, search history, YouTube history, and data from Google partner sites. This data is used to provide enhanced analytics insights and enable cross-device tracking.

Granular Location Data: We collect city-level location metadata and granular device details to provide location and device-based analytics capabilities.

Ads Personalization: Data collected through Google Analytics may be used for ads personalization purposes. We may export Google Analytics audiences and key events to linked advertising accounts for delivering personalized experiences.

3. How We Use Your Information

We use the information we collect to:

• Process your application and determine eligibility
• Place you in appropriate Virtual Host Families
• Facilitate communication and program activities
• Track attendance and program participation
• Issue Certificates of Distinguished Achievement
• Maintain our alumni network
• Send program updates and important communications
• Improve our program and services
• Analyze website traffic and user behavior through Google Analytics
• Deliver personalized content and experiences based on your interests
• Comply with legal obligations

Google Analytics Usage: Data collected through Google Analytics is used to improve our website, understand user behavior, create audience segments, and enable remarketing and advertising features. This data may be shared with Google Ads accounts for ads personalization when you have consented to such use.

4. Information Sharing and Disclosure

We may share your information in the following circumstances:

• Within Your Virtual Host Family: Your name, country, and basic profile information will be shared with your Facilitator and fellow participants in your Virtual Host Family.
• Service Providers: We may share information with third-party service providers who assist us in operating our program (e.g., platform providers, email services).
• Google Analytics: We share website usage data with Google through Google Analytics. Google may combine this data with other information they have about you from your Google account if you are signed in and have consented to ads personalization. This data may be accessed and deleted by you via Google's My Activity page.
• Advertising Partners: When ads personalization is enabled, we may share audience lists and key events with linked advertising accounts (including Google Ads) for delivering personalized advertising experiences.
• Legal Requirements: We may disclose information if required by law or to protect our rights and safety.
• With Your Consent: We may share information for other purposes with your explicit consent.

4.1 Third-Party Platforms for Program Delivery

We use the following third-party platforms to deliver our program and facilitate participant activities. By participating in LOT, you acknowledge that your information will be processed by these platforms according to their respective privacy policies:

Communication and Collaboration Platforms:

• Google Services (Google Drive, Google Meet): Used for document storage, sharing, video conferences, and collaborative work. Subject to Google's Privacy Policy.
• Microsoft Services (Microsoft Office, Outlook, OneDrive): Used for document creation, email communication, and file storage. Subject to Microsoft's Privacy Statement.
• Zoom: Used for video conferencing and virtual meetings. Subject to Zoom's Privacy Statement.
• Discord: Used for community communication, text chat, and voice channels. Subject to Discord's Privacy Policy.
• Telegram: Used for instant messaging and group communications. Subject to Telegram's Privacy Policy.

Data Shared with Third-Party Platforms:

Depending on the platform and your usage, the following information may be shared:

• Your name and email address (for account creation)
• Profile information you choose to add (photos, status, bio)
• Messages, files, and content you share through the platforms
• Meeting attendance and participation records
• Usage data and technical information collected by the platforms

Your Responsibility:

When using these platforms, you are subject to their terms of service and privacy policies. We encourage you to review these policies. We are not responsible for the data practices of these third-party platforms beyond our direct control.

5. Data Security

We implement appropriate technical and organizational measures to protect your personal information. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

The third-party platforms we use (Google, Microsoft, Zoom, Discord, Telegram) employ their own security measures. We select reputable service providers and encourage participants to use strong passwords and enable two-factor authentication where available.

6. Your Rights (GDPR & Data Protection)

Depending on your location, particularly if you are in the European Economic Area (EEA), United Kingdom, or other jurisdictions with comprehensive data protection laws, you have the following rights regarding your personal information:

6.1 Your Data Subject Rights

• Right to Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can request correction of inaccurate or incomplete data.
• Right to Erasure ("Right to be Forgotten"): You can request deletion of your personal data under certain circumstances.
• Right to Restrict Processing: You can request that we limit how we use your data.
• Right to Data Portability: You can request a copy of your data in a machine-readable format.
• Right to Object: You can object to processing based on legitimate interests or for direct marketing.
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time.
• Right to Lodge a Complaint: You can file a complaint with your local data protection authority.
• Right to Opt-Out: You can opt-out of analytics tracking, cookies, and ads personalization at any time.

6.2 How to Exercise Your Rights

To exercise any of these rights, please contact us at lot@lotep.org with:

• Your full name and email address
• A clear description of your request
• Any relevant information to help us locate your data

We will respond to your request within 30 days (or as required by applicable law).

6.3 Cookie Management

Manage Cookies: You can change your cookie preferences at any time using our cookie consent banner (appears when you first visit) or through your browser settings.

Google Analytics Opt-Out: Install the Google Analytics Opt-out Browser Add-on or manage preferences through Google My Activity.

6.4 Supervisory Authority

If you are located in the EEA or UK and believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your local data protection supervisory authority:

• EEA: Find your local authority at EDPB Member List
• UK: Information Commissioner's Office (ICO)

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required by law.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for such transfers.

The third-party platforms we use (Google, Microsoft, Zoom, Discord, Telegram) operate globally and may transfer and process your data in various countries. These platforms implement appropriate safeguards such as Standard Contractual Clauses (SCCs) and comply with applicable data protection regulations.

9. Children's Privacy

Our program is open to participants aged 14-24. We take special care to protect the privacy of minors and comply with applicable children's privacy laws.

10. Legal Basis for Processing (GDPR)

Under GDPR, we process your personal data based on the following legal grounds:

• Consent: When you apply to our program, accept cookies, or opt-in to communications, you provide explicit consent for data processing.
• Contractual Necessity: Processing is necessary to fulfill our obligations under the program agreement with participants.
• Legitimate Interests: We process data to improve our program, maintain security, prevent fraud, and communicate with participants, where such processing does not override your rights and freedoms.
• Legal Obligations: We may process data to comply with applicable laws, regulations, and legal processes.

You have the right to withdraw consent at any time where processing is based on consent. This does not affect the lawfulness of processing before withdrawal.

11. User Data Collection Acknowledgement

By using our website and services, you acknowledge that:

• We have the necessary privacy disclosures and rights from our end users for the collection and processing of their data
• You consent to the association of your data with Google's information when you use our website while signed into your Google account (if you have provided consent for analytics cookies)
• You understand that data collected may be used for analytics, measurement, and ads personalization purposes (subject to your consent)
• You have been informed about Google Signals data collection and its implications
• You understand that you can manage your privacy settings and opt-out of tracking at any time
• You can withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal

We adhere to the Google Advertising Features Policy, including rules around sensitive categories.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the new policy on this page with an updated "Last Updated" date
• Providing notice through our website or email (for material changes)
• Requesting renewed consent where required by applicable law

We encourage you to review this Privacy Policy periodically. Continued use of our services after changes constitutes acceptance of the updated policy.

13. Contact Us & Data Protection

If you have questions about this Privacy Policy, wish to exercise your data subject rights, or have concerns about how we handle your data, please contact us:

Email: lot@lotep.org
Subject Line: "Privacy Inquiry" or "Data Subject Rights Request"
Location: Baghdad, Iraq

We will respond to all requests within 30 days or as required by applicable law.

For EU/EEA Residents: If you are not satisfied with our response, you have the right to lodge a complaint with your local supervisory authority.