Privacy Policy

What does this Website Privacy Policy Cover?

We want to be transparent with you (consumers, our clients and our network of publishers) about how we collect and use your Personal Data when you visit our website available at www.lead365.com or any other Lead 365 web property or services referencing this Website Privacy Policy (collectively, the “Website”).  We understand the importance of privacy, and we strive to keep personal information confidential.

With that in mind, this Website Privacy Policy is designed to describe:

 

Incoming, EU-wide data protection legislation known as the “General Data Protection Regulation” or “GDPR” (a copy of which is posted here), took effect from May 25th, 2018. The Website Privacy Policy is intended to meet our duties of Transparency under the GDPR and all other applicable privacy laws.

We will post any modifications or changes to this Website Privacy Policy on this page.

Who we are.

We are Lead 365. We are a UK company, company registration number 09973434. Our address is: 6th Floor, Alexandra Warehouse, West Quay, Gloucester, Gloucestershire, GL1 2LG.

When we refer to “L365”“we” or “us” in this Website Privacy Policy, we are referring to Lead 365 Limited.

We haveappointed a “Data Protection Officer”, this is a person who is responsible for overseeing and advising us in relation to our compliance with the GDPR and our compliance with this Privacy Policy. If you want to contact our Data Protection Officer directly, you can email: dataprotection@lead365.co.uk.

 

What we do.

Lead 365 Limited is adata processor under the definitions of GDPR.

We are a client services agency that specialises in helping both advertisers and publishers across a multi-channel and geo basis for any and all lead generation / data acquisition requirements.

Our offering involves campaign planning, buying, management, compliance, delivery, optimisation, measurement and analytics for advertisers and agencies and we enable publishers to use Lead 365 as a single point of industry contact to access multiple campaigns.

 

Cookies.

We do not collect data from cookies whilst you browse our public pages of the Site.

 

What “Your Rights” are.

 

When we process your personal data, we will retain a copy of all “Personal Data” processed in respect of each “Customer Campaign” for a period of six months after such “Customer Campaign” has been completed (“Retention Period”) to enable us to respond to any enquiries in respect of such Customer Campaign; we then delete any Personal Data held related to any Customer Campaign on expiry of the Retention Period.  Similar with our clients and advertisers, we will retain a copy of your personal data for Lead 365 account information for a period of six months after you may decide to deactivate your account for the same purpose of responding to enquires on any Customer Campaign you may have been party too.

 

Your Individuals Rights

A: Right to be informed – When we process data, the processing is fair and deemed necessary in the fulfilment of a contract.  We have ensured our Privacy Policy is up to date to detail our processing activities and your rights as a consumer.  We aim to help you with any queries you may have, please use the contact us area to get in touch.

B: Right to access – You own the right to contact us in writing to request details of the data we have about you. To clarify, Lead 365 is a data processor, our visibility on your personal data may be limited based on the processing activities we may have undertaken.  We do NOT own your data, but we retain a digital footprint of the data controller whom we’ve processed personal data on behalf and will be able to assist any consumer with your right to access.

C: Right to Rectification – You have the right to ask us to rectify the information held on you if it’s inaccurate or incorrect.   Lead 365 will be able to assist in putting you in contact with the data controllers whom we have processed your information on their behalf, or you the publishers who holds an account with Lead 365.

D: Right to erasure – This is also known as “the right to be forgotten”. This gives you right to request your information to be removed/erased verbally or in writing. We maintain a list of the people who have asked not to be contacted and ensure that you get no further marketing from our clients, we will also put you in touch with the originating data controller to perform the same action.

E: Right to Restrict processing – You have the right 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 right to ask for your information to be transferred to another business. It enables you to take advantage of applications and services which you may with to use.

G: Right to Object – You have the right to object to the processing of your information for marketing purposes and profiling for marketing uses. You likewise hold the right to ask us to cease processing based on a data controllers legitimate interest, where there is no overriding justification for the processing of your information. Your rights and freedoms override a data controllers interests.

H: Rights related to automated decision making including profiling – We don’t use automated decision-making processes which would cause a potentially damaging effect to you.

I: Right to withdraw consent at any time – You have the right to withdraw your consent at any time.  Lead 365 is not the generator/originator of any personal data, we are a data processor, therefore we have no list to remove your consumer information from.  We will however from our processing activities be able to assist you in contacting the data controllers to execute your right to withdraw your consent. If you are a publisher, please refer to the comments based on your rights to de-activate your account.  Please see below ways in which we can help:

By Email – dataprotection@lead365.co.uk

By Phone – +44 (01)1452 250177

In Writing – The Compliance Manager/ Data Protection Officer, Lead 365 Limited, 6th Floor, Alexandra Warehouse, West Quay, Gloucester Docks, Gloucester, Gloucestershire, GL1 2LJ

You can also withdraw your consent for live or automated calls from anyone by registering your telephone number on the Telephone Preference Service. Details can be found at www.tpsonline.org.uk

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 which include;

 

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 an 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 publishers 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.
Consumer Information First name, last name, email address, plus any additional information you share 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.

 

How we use your Personal Data and why.

 

Advertisers & Publishers

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. We have obtained your consent in the creation of an publisher/advertiser account with Lead 365, as well as those of your organization. We need to provide you with access to administer our platforms and services and 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. Your consent and the legitimate interests, as well as those of your organization. We need to be able collect information regarding your usage of our services to report back to your organisation.
Troubleshooting Log Records We use Log Records to track issues that might be occurring on our systems. Your consent and the legitimate interests, as well as those of your organization. We need to monitor and ensure the proper operation of our systems and services to administer our services and fulfil our contractual obligations to your organisation.
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. Your consent and the legitimate interests, as well as those of your organization. We need to contact your organisation to administer our platform and services, to fulfil our contractual obligations, and to keep your organisation informed about additional product and service offerings.

 

Consumer

Purpose Category(ies) of Personal Data involved Why do we do this Our legal basis for this use of data
We process your data between data controllers to fulfil a contract Your personal Information, this could include, Name, Address, Date of Birth, Email address, Telephone numbers and any other non sensitive information you may have shared with the data controllers. To fulfil a contract This could be either explicit consent where you have asked to be contacted by an advertiser whom Lead 365 processes data on their behalf or a publisher whom relies on legitimate interest about certain products or services whom wishes to share your personal data with an end advertisers whom Lead 365 process data on their behalf.

 

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. In addition, where relevant, when we share Personal Data with third parties who are not directly subject to the GDPR, we make sure:

that party is either:

 

 

Advertisers & Publishers

 

Recipients Category(ies) of Personal Data we share. Why we share this Personal Data
Advertisers & Publishers 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 Publisher 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.

 

Consumers

Recipients Category(ies) of Personal Data we share. Why we share this Personal Data
Advertisers Personal data

 

Your personal Information, this could include, Name, Address, Date of Birth, Email address, Telephone numbers and any other non sensitive information you may have shared with the data controllers. To fulfil a contract.  The processing of your information could be done to either explicit consent or legitimate interest to facilitate the safe transfer between an advertiser and/or publisher that uses the services of Lead 365 Limited.

 

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 publishers 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 Publisher 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.
Personal Information on Consumers

We retain a copy of all Personal Data processed in respect of each Customer Campaign for a period of six months after such Customer Campaign has been completed (“Retention Period”) to enable us to respond to any enquiries in respect of such Customer Campaign; we then delete any Personal Data held related to any Customer Campaign on expiry of the Retention Period.

 

Our policy on children.

Our websites, products and services are not intended for use by children under the age of 16.

Lead 365 Limited, 6th Floor, Alexandra Warehouse, West Quay, Gloucester, Gloucestershire, GL1 2LG

 

Changes to this Privacy Policy.

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.

 

Contact Us.

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

Email: Dataprotection@lead365.co.uk

Tel: +44 (0)1452 260177

 

 

This Privacy Policy was last updated on 8thMarch 2020