Leadstoyou limited

privacy policy – 2020

1.
Introduction and Terms

Leadstoyou Limited (“We” or “us”) are committed to protecting and respecting your personal data and privacy.

This privacy policy relates to how we use and collect personal data from you through your use of this website, our mobile application or when you purchase a product or service from us. It also relates to our use of any personal information you provide to us by telephone, in written correspondence (including letter and email), by SMS and in person. Please note that this website, our mobile application and our services are not intended for children under the age of 18 and we do not knowingly collect data relating to children.

Whenever you provide personal data, we are legally obliged to use your information in line with all applicable laws concerning the protection of such information; including the Data Protection Act 1998 and 2018 (DPA), and The General Data Protection Regulation
2016 (GDPR) together, and with other subsequent laws “Data Protection Laws”. 
This privacy policy also
forms part of our terms of business and is not intended to override them. This policy may be amended or updated from time to time and any revisions will be posted to this page.

2.
WHO WE ARE AND How to contact us

2.1
For the purpose of the Data Protection Laws, the data controller is Leadstoyou Limited, registered company number 07464294. If
you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below:

FAO: Privacy Officer

Leadstoyou Limited

Palatine House

Matford Court

Sigford Road

Matford

Exeter

EX2 8NL

Email: dp@leadstoyou.net

Telephone: 01392 348790 and ask to speak to the Privacy Officer.

3.
The data we collect about you

3.1
We collect and process personal data. Typically the personal data we collect and process will include identity, contract, financial, transactional, technical, profile, usage and marketing and communications data such as:

3.1.1
Identity Data
includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and images.

3.1.2
Contact Data
includes billing address, delivery address, email address and telephone numbers.

3.1.3
Financial Data
includes bank account and payment card details. 

3.1.4
Transaction Data
includes details about payments to and from you and other details of products and services you have purchased from us.

3.1.5
Technical Data
includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

3.1.6
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey
responses.

3.1.7
Usage Data
includes information about how you use our website, products and services.

3.1.8
Marketing and Communications
data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Please note that we may collect and/or process other personal data from time to time.

3.2
We also collect, use and share aggregated data, such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data, but is not considered to be personal data in law as it will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate a percentage of users accessing a specific feature of our services. However, if we combine or connect your aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used solely in accordance with this policy.

3.3
We do not collect the following special categories of personal data about you: details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

3.4
We only collect data from you directly or via third parties (see the section Third Parties below).

4.
if you fail to provide personal data

Where we need to collect
personal data by law, or under the terms of a contract we have with you, and
you fail to provide that data when requested, we may not be able to perform the
contract we have or are trying to enter into with you (for example, to provide
you with our services). In this case, we may have to cancel a product or
service you have with us but we will notify you if
this is the case at the time.

5.
How
your data will be used

5.1
We use
information held about you to:

5.1.1
carry
out our obligations arising from any contracts entered into between you and us
and provide our services;

5.1.2
carry
out feedback and research on our services; and

5.1.3
notify
you about changes to our services.

5.2
We never sell your data to third parties or
allow third parties to contact you without your permission.

5.3
We share your data with third parties where
there is a legal obligation for us to do so or we have identified a valid
lawful basis as set out in the table below (please also see clause 7 below, lawful
basis). We may process your personal data without your knowledge or consent
where this is required or permitted by law.

5.4
You can ask us or third parties to stop sending
you marketing messages at any time by following the opt-out links on any
marketing message sent to you.

5.5
We have set out below in a table format, a
description of all the ways we plan to use your personal data, and which of the
legal bases we rely on to do so. We have also identified what our legitimate
interests are where appropriate. Note that we may process your personal data
for more than one lawful ground depending on the specific purpose for which we
are using your data. Please contact us if you need details about the specific
legal ground we are relying on to process your
personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

Type of data

Lawful basis for processing
including basis of legitimate interest

To register you as a new user and customer.

We will share your personal data with our approved partners and third party product providers so that they can return a
quote to you.

Identity

Contact

Marketing and Communications

Consent

 

 

To process and deliver your order including:

Manage payments, fees and charges

Collect and recover money owed to us

Identity

Contact

Financial

Transaction

Marketing and Communications

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

Notifying you about changes to our terms or privacy policy

Asking you to leave a review or take a survey

Identity

Contact

Profile

Marketing and Communications

Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to keep our records updated and
to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a
survey

Identity

Contact

Profile

Usage

Marketing and Communications

Performance of a contract with you

Necessary for our legitimate interests (to study how customers use our
products/services, to develop them and grow our business)

To administer and protect our business, this website (including troubleshooting,
data analysis, testing, system maintenance, support, reporting and hosting of
data) and our mobile application.

Identity

Contact

Technical

Necessary for our legitimate interests (for running our business,
provision of administration and IT services, network security, to prevent
fraud and in the context of a business reorganisation or group restructuring
exercise)

Necessary to comply with a legal obligation

To deliver relevant website and mobile application content and
advertisements to you and measure or understand the effectiveness of the
advertising we serve to you

Identity

Contact

Profile

Usage

Marketing and Communications

Technical

Necessary for our legitimate interests (to study how customers use our products/services,
to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, mobile application,
products/services, marketing, customer relationships and experiences

Technical

Usage

Necessary for our legitimate interests (to define types of customers
for our products and services, to keep our website updated and relevant, to
develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services
that may be of interest to you

 

 

Identity

Contact

Technical

Usage

Profile

Marketing and Communications

Necessary for our legitimate interests (to develop our
products/services and grow our business)

Employment

Identity

Contact

Health

Financial

Technical

Education and Employment History

Necessary for performance of a contract with you.

Necessary for our legitimate interests (to employ you and process
certain data about you).

Necessary to meet our legal requirements (Inland Revenue etc.)

6.
lawful basis for processing

6.1
We only process your data (which may include
providing it to a third party) where we have identified a valid lawful basis to
do so. These are as follows:

6.1.1
Contractual
obligation
– Where processing is necessary to comply with our obligations
arising out of a contract, for example, where you have bought products from us we will use the personal data you provide to fulfil our
contractual obligations.

6.1.2
Legitimate
Interest
– Where we use legitimate interests we
will record our decision on making this decision. We rely on legitimate
interest where processing of the data we hold on you does not, in our opinion,
affect your rights or freedoms and is proportionate to our interests e.g. keeping
you up to date with our latest products or obtaining your feedback on our
service.

6.1.3
Consent
– We will seek to obtain your consent to process your data outside our
contractual obligations (see above) unless we have identified a Legitimate
Interest (see above).

6.1.4
Legal
– processing is necessary for compliance with a legal obligation to which the
controller is subject.

7.
THIRD
PARTIES and sharing information

7.1
We will
keep your information within the organisation except where disclosure is
required or permitted by law or when we use third party service providers (data
processors) to supply and support our services to you. We have contracts in place with our data
processors. This means that they cannot do anything with your personal data
unless we have instructed them to do so. They will not share your personal data
with any organisation apart from us. They will hold it securely and retain it
for the period we instruct.

7.2
Please
see below the list which set out the categories of recipients of personal data::

 

SERVICE PROVIDERS WHO MAY RECEIVE YOUR PERSONAL DATA

IT Support Services

Email Provider

Secure document disposal service

Banks

Online payment providers

Office cleaning services

Accountants

Solicitors

Feedback aggregators and
collectors

When we
share personal data (leads) with our
approved partners and third party product providers (our “Clients”)
we only do so where we have a written
contract in place with them. We list the companies that we share personal data
with at the point at which we collect your personal data via the online form you
complete on our various websites and at this point we will ask for your consent
to share your personal data with those companies. You will
only be contacted by a maximum of three (3) companies from this list.

We will only
share your personal data with your prior consent.

Once our
Clients receive your personal data (in accordance with the consent you have
given us) they will process your personal data in accordance with their privacy
policies. We would suggest you check the
relevant approved partner or third party product
provider’s privacy policy before providing your consent to us passing your
details to them. In accordance with the
contracts we have with them our Clients are only permitted to use you personal data for the purpose of contacting you
regarding the quote you have enquired about via our various websites and are
not permitted to use it for any other purpose.

7.3
In addition,
third parties may provide us with personal data and
they should only do so where the law allows them to.

8.
WHERE
YOUR DATA IS HELD

8.1
Your
data is stored by us and our processors in the UK or EEA. Where your personal
data is transferred outside of the UK or the EAA, we have ensured that:

8.1.1an adequacy decision has been made by the European Commission permitting
the transfer of data to that country; or

8.1.2 standard
contractual clauses (SCCs) are in place and we have received assurances that an
adequate level of protection of the personal data is achieved (based on a case
by case assessment of the circumstances of the transfer), including adequate
technical and operational measures in place to protect the personal data.

9.
APPLICATIONS
to work for us

If you apply to work for us (directly or indirectly) in any role we may
receive data about you from third parties. In addition, we will keep the
details of your application and any additional information provided to us by
you or others during your application so that we can keep you informed of
future opportunities that you may be interested in. If you do not wish for us
to keep your details for this reason, please let us know by contacting us using
the details provided in this policy.

10.
DATA RETENTION

Our data retention policy is dictated by the Data Protection Laws and is
available for inspection by submitting a written request using the contact
details provided in this policy.

11.
Your
rights

11.1
Under the Data Protection Laws your rights are:

11.1.1
To be
informed
– We must make this privacy policy (sometimes referred to as a
privacy notice) available with the emphasis on transparency over how we process
your data.

11.1.2
Access
– You are entitled to find out what details we may hold about you and why. We
strive to be as open as we can be in terms of giving people access to their
personal data. Individuals can find out if we hold any of their Personal Data
by making a formal request under the Data Protection Laws. Such requests should
be in writing to the contact details provided in this policy. If we do not hold
information about you we will confirm this in writing
at the earliest opportunity. If we do hold your personal data
we will respond in writing within one calendar month of your request (where
that request was submitted in accordance with this policy). The information we
supply will:

(a)   confirm
that your data is being processed;

(b)   verify
the lawfulness and the purpose of the processing;

(c)    confirm
the categories of personal data being processed;

(d)    confirm
the type of recipient to whom the personal data have been or will be disclosed;
and

(e)   let
you have a copy of the data in format we deem suitable or as reasonably
required by you.

11.1.3
Rectification
– We are obliged to correct or update your details. We will correct or update
your data without delay provided you make the request in writing to the contact
details provided in this policy, clearly specifying which data is incorrect or
out of date.

11.1.4
Erasure
This is also known as the request to be forgotten. Under Data Protection Laws
you have the right to erasure under specific circumstances. A request for your
personal data to be deleted will be decided on a case by case basis and should
be submitted in writing to the contact details provided in this policy.

11.1.5
Restrict
processing
– You have the right to ‘block’ or suppress the processing by us
of your personal data.

11.1.6
Portability
– You have the right to obtain and reuse your personal data that you have
provided to us.

11.1.7
Object
– You have the right to object to us processing your data in relation to direct
marketing and or profiling.

11.1.8
Rights in
relation to automated decision making and profiling
– We do not use
automatic decision making or profiling.

11.2
Please
note that you may need to provide identification in order to prove who you are
if you wish to invoke any of your rights as provided by the Data Protection
Laws and as summarised above.

11.3
If you
agree, we will try to deal with your request informally, for example by
providing you with the specific information you need over the telephone.

12.
Changes

We keep our privacy policy under regular review
and you should check back regularly to ensure you are aware of changes to it.
We may display this notice to you from time to time to help ensure you are
aware of its contents.

13.
Complaints

You have the right to complain about the processing of your personal
data. Please contact us using the details provided above. If you are still
unsatisfied you have the right to complain to the
Information Commissioners Office.

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