PRIVACY POLICY

What we do.

Lead 365 Limited is a data processor under the definitions of the 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.

How we use your Personal Data and why.

Advertisers & Publishers

PurposeCategory(ies) of Personal Data involvedWhy do we do thisOur legal basis for this use of data
To provide you with access to the Lead 365 platform and toolsAccount InformationUsing this data helps us to provide you with a consistent experience.We have obtained your consent in the creation of a 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 organizationAccount Information; Log RecordsWe 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.
TroubleshootingLog RecordsWe 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 youAccount InformationWe 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.

Consumers

 

PurposeCategory(ies) of Personal Data involvedWhy do we do thisOur legal basis for this use of data
We process your data between data controllers to fulfil a contractYour 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 contractThis 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:

  • based in a country that has laws and institutions in place; or
  • part of a sector or participates in a framework,
  • that the European Union considers ensures that your Personal Data will be adequately protected; or
  • adequate safeguards are in place to ensure your Personal Data will be protected in line with the requirements of the GDPR.

 

Advertisers & Publishers

RecipientsCategory(ies) of Personal Data we share.Why we share this Personal Data
Advertisers & PublishersAccount Information & Personal DataWe 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 ProviderAccount Information; Log RecordsOur 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.
AffiliatesAccount Information; Log RecordsAs 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 practitionerAccount 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 authoritiesAccount 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 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.
Third Party Data Providers Your Personal Information, this could include your Postal Address and Telephone Number that you may have shared with the data controllers. To fulfil a contract. We may share your Personal Information with third party data providers who may append additional information about you or your postal address to your Personal Information and return to us for profiling and segmentation purposes. This may include information about your utility supplier, meter type and also your utility tariff.Using the appended data, Lead 365 Limited will, under written instruction from an Advertiser that uses the services of Lead 365 Limited, profile and segment your Personal Information which we will then share with the Advertiser to enable them to determine and tailor relevant marketing offers and communications to you.
Third Parties To share your data with third parties who will append property level information including current energy supplier, meter type, meter install date and meter point administration number (a) Necessary for our legitimate interests (to define types of customers for our products, services and clients)

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 DataRetention period
Account Information on Advertisers and PublisherWe 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 ConsumersWe 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. 

Changes to this Privacy Policy.

This Privacy Policy is kept under regular review and changes are published on this page. This Privacy Policy was last updated on 24th July 2023.