- Who we are.
- What we do.
- What “Your Rights” are.
- What Personal Data we collect.
- How we use your Personal Data and why.
- Who we share your Personal Data with.
- How we keep your Personal Data secure.
- How long we store your Personal Data.
- Our policy on children.
- Changes to this policy.
- Third party Links.
- Contact Us.
Who we are.
We are Lead 365 Limited. We are a UK company, company registration number 09973434. Our address is: 6th Floor, Alexandra Warehouse, West Quay, Gloucester, Gloucestershire, GL1 2LG.
What we do.
Lead 365 Limited is both a controller and a processor of personal data under the definitions of GDPR. A company acts as a “processor” when they are processing personal data on the instructions of someone else.
When we are acting as a “processor”
Our business is to help advertisers (our clients) acquire data about leads (people) for the purposes of their sales and marketing activities.
Our services to advertisers include campaign planning, data acquisition, compliance, data optimisation, measurement and analytics. We acquire data for advertisers via third party organisations (such as competition websites) who have a lawful basis (usually consent from the individuals concerned) to share that data with Lead 365 and our clients (“Data Collectors”).
When conducting the services described above we are acting solely on the instructions of our clients and as such we are acting as a processor only, when processing any personal data.
If you contact us about personal data that we are processing as a “processor” we will put you in touch with the applicable controller of that data, i.e. Data Collectors or advertisers.
When we are acting as a “controller”
We do not collect data from cookies whilst you browse our Website.
What "Your Rights" are.
Your Individual Rights in respect of personal data that we hold as a controller are:
A: Right to access – You have the right to request details of the personal data we have about you.
C: Right to Rectification – You have the right to ask us to rectify the information held on you if it's inaccurate or incorrect.
D: Right to erasure – This is also known as “the right to be forgotten”. This gives you the right, in certain circumstances, to request your information to be removed/erased.
E: Right to Restrict processing – You have the right, in certain circumstances, to tell us to stop processing your data but allowing us to keep enough information about you to ensure that your wishes are repeated in the future.
F: Right to portable data – This gives you the right, in certain circumstances, to ask for your information to be transferred to another business.
G: Right to Object – You can object to us processing your personal data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.
H: Rights related to automated decision making including profiling – To the extent that the legal basis we are relying on for processing your personal data is consent, and where the processing is automated, you are entitled to receive your personal data from us in a structured, commonly used and machine-readable format. However, you may not have this right if it would adversely affect the rights and freedoms of others.
I: Right to withdraw consent at any time – You have the right to withdraw your consent to us sending marketing communications to you at any time.
J: Right to lodge a complaint – If we cannot deal with your complaint to your satisfaction you have the right to complain to a relevant supervisory authority;
- The Information Commissioners Office - https://ico.org.uk/concerns/
What Personal Data we collect.
All the Personal Data we collect from you is outlined in the table below.
Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about a living individual, from which that individual is either directly identified or can be identified.
It does not include ‘anonymous data’ (i.e., information where the identity of an individual has been permanently removed).
However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).
|Category of Personal Data collected||What this means||How we collect it|
|Account Information||First name, last name, email address, telephone number, profile picture, passwords and security protocols of users who maintain an account for any of Lead 365 services. (both Data Collectors and advertisers)||Through your active submission (either directly through the platform or indirectly through Lead 365 or your organisation’s administrator) when you create an account with Lead 365.|
How we use your Personal Data and why.
Advertisers & Data Collectors
|Purpose||Category(ies) of Personal Data involved||Why do we do this||Our legal basis for this use of data|
|To provide you with access to the Lead 365 platform and tools||Account Information||Using this data helps us to provide you with a consistent experience.||To fulfil our contractual obligations to your organisation as a service provider.|
|To provide reporting to your organization||Account Information; Log Records||We use your Account Information and Log Records to prepare reports to report on your use of our services.||To fulfil our contractual obligations to your organisation as a service provider.|
|Troubleshooting||Log Records||We use Log Records to track issues that might be occurring on our systems.||To fulfil our contractual obligations to your organisation as a service provider.|
|To Contact you||Account Information||We use your Account Information to contact you regarding your account or our services, including to market our services to your organization.||Any processing regarding your account is conducted to fulfil our contractual obligations to your organisation as a service provider. We rely on our legitimate interests to send marketing communications to you and your organisation, including by email, in respect of other products and services that we offer.|
Who we share your Personal Data with.
The table below describes who we share your Personal Data with, what we share and why we share it.
We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls.
Advertisers & Data Collectors
|Recipients||Category(ies) of Personal Data we share.||Why we share this Personal Data|
|Advertisers & Data Collectors||Account Information & Personal Data||We share in order for decisions to be made when forming partnerships. Following the formation of a partnership, we process personal data between data controllers and further information related to campaign performance, necessary to calculate payments/commissions. This is made in the form of Data Collector ID in order to remain anonymous.|
|Hosting Provider||Account Information; Log Records||Our services are hosted by third parties sub processors. In order to facilitate our services, we have to pass data we hold (including your Personal Data) to our hosting provider.|
|Affiliates||Account Information; Log Records||As a group of companies, we rely on affiliates to provide certain services to us. All affiliates are required to adhere to the descriptions and specifications set out in this Interest|
|An acquirer or insolvency practitioner||Account Information; Log Records.||We may share Personal Data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding. All counterparties will be required to keep such information strictly confidential.|
|Law enforcement agencies and regulatory authorities||Account Information; Log Records.||We may share Personal Data as we believe necessary or appropriate:
• to comply with applicable laws; and/or
• to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements.
How we keep your Personal Data secure.
We have put in place appropriate security measures and use encryption through technology to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of this breach.
We ask all advertisers and Data Collectors to create unique passwords and usernames that only they know. Never share your password and in the event of losing/forgetting these, please contact your relevant Lead 365 contact to reset.
How long we store your Personal Data.
We will only retain your Personal Data for so long as we reasonably require it to use it for the purposes set out above, unless a longer retention period is required by law (for example for regulatory purposes).
The table below shows our standard retention practices:
|Category of Personal Data||Retention period|
|Account Information on Advertisers and Data Collector||We keep Account Information for a maximum of one (1) year from the date on which the organization account holder closes the applicable account or terminates its relationship with us.|
Our policy on children.
Our websites, products and services are not intended for use by children under the age of 16.
How we use your Personal Information is kept under regular review and changes are published on this page. This page was last updated on the date shown at the bottom of this policy.
Third Party Links.
The Site may contain links to the websites of third parties. If you follow a link to any third party website, please note that these websites will have their own privacy policies which we would encourage you read.
If/when you contact us with a question using our online enquiry form we collect your name, email address and any comments you have. We use this information (ONLY) to respond to and/or resolve your query/question. We will not share this with third parties for marketing purposes.
Lead 365 Ltd, 6th Floor, Alexandra Warehouse, West Quay, Gloucester, Gloucester, GL1 2LG
Tel: +44 (0)1452 260177