Introduction

Leadfreak Limited (“we”, “us” or “our” within this privacy notice) is committed to protecting and respecting your privacy.

This privacy policy explains how we use any personal information we collect about you. This privacy policy specifically regards personal data collected on our site https://leadfreak.co.uk and any subdomains there of. This includes information collected when you purchase a product or service, sign up to our newsletter, sign up to receive downloadable resources, or take part in a competition.

Age

By providing us with your personal data and consenting to receive marketing information, you confirm that you are over 13 years of age.

Our Status

Leadfreak Limited is the data controller and we are responsible for your personal data.

Our Contact Details

Our full details are:

Company name: Leadfreak Limited
Company Number: 09968142 (Company registered in England & Wales)
Email address: [email protected]
Telephone Number: +44 (0) 1442 915 255
Company Address: 90A High Street, Berkhamsted, Hertfordshire, HP4 2BL

Complaints

If you are not happy with any aspect of how we collect and use your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s data protection supervisory authority for data protection issues (https://ico.org.uk/concerns/).

We would appreciate being contacted first if you do have any issues, so that we may look to resolve.

Keeping Data Up To Date

It is important that the personal data we keep is accurate and, where necessary, kept up to date. If, at any time, your personal information changes please inform us using the email address [email protected].

Why we use your personal data

In accordance with the EU’s GDPR, all personal data shall be processed lawfully, fairly, and in a transparent manner. We will only use your personal data in circumstances where we are legally permitted to do so. The most common uses of your personal data are:

  1. Where you have consented to receive marketing communications from us via email or text; To fulfil contractual obligations between us;
  2. Where it is necessary for our legitimate interests or those of a 3rd party except where the interests, rights, and freedoms of you override those interests;
  3. Where we need to comply with a legal or regulatory obligation.

Please see Your Rights with regard to your management of all personal data collected.

What Personal Data Do We Collect

Personal data is any information relating to an identifiable person who can be directly or indirectly identified by that data. It does not include anonymised data.

The personal data categories we may process are as follows:

  1. Identity - this may include your first name, last name, username, title, date of birth and gender.
  2. Contact Data - this may include your billing address, delivery address, email address and phone numbers.
  3. Financial Data - this may include your bank account and payment card details.
  4. Transaction Data - this may include details about payment between us and other details of purchases made by you.
  5. Technical Data - this may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
  6. Profile Data - this may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
  7. Usage Data - this may include information about how you use our website, products and services.
  8. Marketing and Communications Data - this may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

In failing to provide the personal data required to fulfil delivery of our products or services we may not be able to deliver in accordance with our contractual obligation. In this event, we reserve the right to cancel a contract. In this event we will notify you at that time.

Sensitive Data

We do not collect sensitive data about you. Sensitive data refers to race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

How Do We Collect Your Personal Data

We collect personal data through a variety of different methods, including:

  1. Direct engagement: We may receive your data when you fill out forms on our site, or through communicating with us by post, phone, email.
  2. Technology engagement: We may automatically collect personal data in the form of technical data about your equipment, browsing actions and usage patterns. We use cookies to collect this data.
  3. Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources including:

Technical Data from the following:

  • Analytics providers such as Google based outside the EU;
  • Advertising networks such as Facebook, Twitter, LinkedIn, Google Plus, based outside the EU;
  • Search information providers such as Google based outside the EU;

Contact, financial, and transaction data from technical, payment and delivery services such as Stripe and GoCardless based outside of the EU

Identity and contact data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

How Do We Collect Your Personal Data

We use your personal data in the following way:

Purpose/Activity Type of data Lawful basis for processing
To register you as a new customer (a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you

(b) Necessary for our legitimate interests to recover debts owed to us
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) 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 (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you

(b) 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 and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) 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

(b) Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) 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, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests to define types of customers for our products and services, to keep our site 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 (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests to develop our products/services and grow our business

Purpose of processing your personal data

The personal data we collect will be processed only in line with that specified at the time of collection. Your personal data will not be processed in a manner that is incompatible with those purposes.

In the event that we need to process your personal data for purpose unrelated to the purpose for which we collected the data, we will provide you with the legal justification as to the processing required.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

How long we hold your data for

We will retain your data for as long as is required to fulfil the legitimate purpose the data has been collected for.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

As an individual, you have the following legal rights with regards to the personal data collected about you:

  • The right to be informed: Individuals have the right to be informed about the collection and use of their personal data.
  • The right of access: Individuals have the right to access their personal data and supplementary information.
  • The right to rectification: individuals have the right to have inaccurate personal data rectified, or completed if it is incomplete.
  • The right to erasure: individuals have the right to have personal data erased.
  • The right to restrict processing: Individuals have the right to request the restriction or suppression of their personal data.
  • The right to portability: individuals have the right to obtain and reuse their personal data for their own purposes across different services
  • The right to to object: individuals have the right to object to the processing of their personal data

You can see more about your individual rights at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/?q=retention

If you wish to exercise any of these rights, please email us at [email protected]

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within 28 days. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Transfer of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table above:

  1. Service providers who provide IT and system administration services. Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  2. HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
  3. Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

International Transfer

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Some of our third parties service providers, such as our accounting platform XERO, are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

  1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
  2. Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  3. Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Data Security

Your personal data is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

We restrict access to your data to those within Leadfreak, and to third parties, that have a legitimate business need to access.

Where 3rd parties have access to your personal data, we have in place data processor agreements that enforce the correct usage and protections of your data.

We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so in no more than 72 hours.

3rd Party Links

This website may include links to third parties, including websites, plug-ins, and applications. Clicking on those links may allow 3rd parties to collect or share data about you. We do not control these 3rd party websites and are not responsible for their data processing policies. We encourage you to read the privacy notice of every website you visit.