Privacy policy
General Privacy Policy
Table of Contents
- Definitions
- Who we are
- Our Services
- What Data we collect and how
- How we use your Data
- With whom do we share your Data
- International Transfers of your Data
- Storing and Retention of your Data
- Security
- Legal grounds for processing
- Your privacy rights
- Contact
Last updated: October 2023
This “Privacy Policy” explains how Leads.io (“we” or “us”) collects, uses, discloses, retains, and protects the user’s (“you”, “your”) Personal Data.
This Privacy Policy applies to any website, application, product or service (“Services”) which links to this policy. Please be aware that certain types of Services or target regions (like California) may have separate, more specific privacy policies in place. You are encouraged to read through the specific privacy policies before using those Services.
By continuing to access the Services, you acknowledge that you had the chance to review and read through this Privacy Policy and your continued usage shall be taken as your consenting to the terms and conditions mentioned in this Privacy Policy its entirety.
You have certain privacy rights which are described under Section 10 of this Privacy Policy. You can exercise those at any time by contacting us.
We reserve the right to modify this Privacy Policy at any time without any prior notification and as such users are advised to refer to the Privacy Policy from time to time so that your usage of our website is in sync with the privacy practices that are prevailing at that time.
1. Definitions
“Affiliates” means third-party companies that participate in our affiliate programme and generate website traffic or Data for us.
“Customers” means individuals who request a quotation or quotations.
“Controller” means an organization that determines the purposes and means of processing Personal Data. In some jurisdictions also referred to as “Organization”, “Data User” or “Business”.
“Data Protection Laws” means all applicable laws relating to the processing of Personal Data.
“Business Partners” means companies, partnerships and sole traders who have registered or partner with us on the website or in any other form; our Business Partners can be Affiliates Registered Traders or Marketplace Providers.
“Marketplace Providers” means companies that own, operate or control electronic marketplace websites and facilitate the sale of products and services of traders.
“Registered Traders” means providers who can offer quotation for the selected product or services shown on our websites.
“Processor” means organization that processes Personal Data on behalf of and in accordance with the instructions of a Controller. In some jurisdictions also referred to as “Supplier”, “Contractor”, “Service Provider” or “Data Intermediary”.
“Personal Data” (“Data”) has the meaning as used in information security and privacy laws that is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Also known as “Personally Identifiable Information” or “Personal Information”.
2. Who we are
This Privacy Policy applies to all Services offered by “Leads.io”.
We have different offices worldwide that are functioning as ‘Controller’ in relation to your Data:
- For the UK: Leads.io Ltd., a company incorporated in England and Wales with the company registration number 6873930.
3. Our Services
We connect people (“Customers”) who are looking to purchase a product or service with relevant providers (“Registered Traders” or “Marketplace Providers”) who can offer quotation for the selected product or service (“Quotes”).
- As a Customer: To receive Quotes or more information for the product or services shown on the website, you must fill out the webform (“Quote Form”) with your contact details.
- As a Business Partner: To register with our Services, you must complete and submit our published registration form or get registered by us.
4. What Data we collect and how
This section describes how we may collect Data from you directly or automatically:
4.1. CONTACT
You can contact us by telephone, fax, SMS, email, post, chat app or other channels such as social medial portals. We may process your contact Data such as name, email address and phone number. We also may process information provided voluntarily by you (Information Requests).
4.2. OUR SERVICES
4.2.1. FOR CUSTOMERS
You can request quotes on our website to use our Service as Customer. We may ask you to fill up a Quote Form which may include your name, address, email address, and telephone number (Quotes).
Additionally, we may also ask you to provide additional information about product preferences or requirements (such as what type of home you live in) for reasons of qualification (Qualification). Sometimes we also share IP addresses with Registered Traders or Marketplace Providers to enable them to verify the request.
Sometimes grants, schemes or benefits (Grants) are available for a specific product or service (such as for energy-efficient boiler) for certain types of groups (such as low-income households). As an element of your Quote enquiry, we may ask you for information necessary to check your eligibility for such Grants. The type of information (such as income, disability-benefits and other) depends on the eligibility criteria of the specific Grant.
After submitting the form, you may receive an automated SMS with a link you need to click on to verify your indicated phone number from the Quote Form (often referred to as “Double Opt-in”). This is used as verification method (Verification).
After your Quote request, our team may follow up via phone to talk you through the Quote options (Follow-Up). For this we may process communications data that may include content and metadata. This Data may be processed for the purposes of communicating with you, call recording and record-keeping, for example, for quality control.
4.2.2. FOR BUSINESS PARTNERS
You can register with us to use our website or Service as Business Partner. We may ask you to fill up the registration form (Registration) with your company details and other information that may be necessary (like insurance coverage), to create a business account (Accounts) for which you receive also log-in and password. The account may be processed for providing our Services, operating our Affiliate programme, ensuring the security of our website and Services, maintaining back-ups of our databases and communication with you.
We also process billing Data including purchase transactions of our Services (Payments). We process this Data to provide our Services, making Affiliate payments, and keeping proper records of transactions.
We may publish business information on our website, including business listings (Listings).
4.3. MARKETING, ANALYTICS AND WEBSITE ACTIVITIES
You can sign up to receive Our newsletter or other marketing messages or activities (Newsletter).
We may also collect Data from your devices automatically (including mobile devices) that you may use to access our website. We may do this using cookies or similar technologies such as pixels, beacons, or log files (as described in our Cookie Statement).
We may collect the device identification number and type, geographical location Data and connection Data such as statistics on your page views, traffic to and from the sites, length of visit and frequency of use, referral URL, ad Data, your IP address, your browsing history, browser type and version, operating system and your web log Data (Technical Data and Website Analytics).
5. How we use your Data
This section of the Privacy Policy explains how we use the collected Data from you:
5.1 CONTACT
We respond to you (Information Request): When you wish to receive information or advice from us, you can contact us. We use this Data only to respond to your request and provide you with the requested information or advice.
5.2. OUR SERVICES
5.2.1. FOR CUSTOMERS
We connect you with the relevant Registered Traders or Marketplace Providers: When you leave your Data via our website at the Quote Form, we will pass your request on to one or more Registered Traders. In some cases, we may obtain your quote requests from our Affiliate networks (Quotes).
After the Quote enquiry, we may qualify your request (Qualification). This may involve an element of automated decision-making. On some occasions, we may automatically assess with help of our technology platform your product or service preferences and pass your request to the appropriate Registered Traders or Marketplace Providers. You have the right to object to such automated decision-making and you can do so by contacting us.
We may also contact you also by phone, SMS, email or through a chat feature to verify your information and confirm some details or product requirements (Verification and Follow-up).
The Registered Traders or Marketplace Providers after receiving your Data act as ‘Controllers’ of your Data, so if you wish to understand how these Registered Traders or Marketplace Providers may process your Data, please take the time to read their Privacy Policy and Terms. They may contact you by telephone, text/SMS, or email based on your Quote request. Please note that some of our Registered Traders or Marketplace Providers use local service providers (“Processors”) to perform the specific service in your area.
We may also contact you to ask about your experience using our website and Service, and dealing with the Registered Traders or Marketplace Providers which we connected you with (Review and Customer Satisfaction).
We may occasionally contact you to participate in surveys to hear more about your experience with us and our Business Partners. The survey may ask for some Data (like gender, age, location), service or product-related questions (like if you made a purchase after a Quote request), or general opinions (like what you think about government schemes). We do this to improve our Service and for market research (including marketing). You can always unsubscribe (object) from receiving those emails (Survey).
5.2.2. FOR BUSINESS PARTNERS
We connect with the relevant Customers (Service): In order to register as Registered Trader or Affiliate, you must complete and submit our registration form or get registered by us. After an account is created, you will have access to our Services. As Marketplace Provider you need to have a contract with us in place.
5.3. FOR MARKETING, ANALYTICS AND WEBSITE ACTIVITIES
We may message you about other Offers (Newsletter): When you use our website, we would like to contact you via email, SMS or telephone about similar products or services to the one you have shown interest in and we think you might like. You can always unsubscribe (withdraw) from receiving those emails, SMS or telephone calls and we won’t contact You again.
We may create custom and lookalike/similar audiences (Custom Audiences): We work with Facebook, Google, and other platforms (“Platforms”) to reach out to you with ads from other offers or to create similar audiences or custom audiences. Data is aggregated and pseudonymized by the Platforms and you can always object to this activity by contacting us or by, for example, using the cookies settings at the bottom of all pages in our site.
We may use automated-decision making and profiling (Profiling): We may analyze your Data to build individual profiles, which also includes collection and (statistical) analysis of the Data. Individual profiling is used to predict future interests and provide you with offers that are relevant and interesting for you. Profiling is based on the Data you have provided to us through the contact form and on your behavior when surfing the Internet. You have the right to object to profiling by contacting us.
We may use Technical Data (Website Operations and Analytics): We collect this Data to tune our Services to your needs and to better align structure, navigation and content of the website. This will, for example, facilitate your browsing, store your preferences and make the interaction between you and the website faster and easier. We also place cookies to provide you with personalized advertising. We may place our own cookies or third parties may set and access their cookies, web beacons, embedded script or other technologies on your device, and they may otherwise collect or have access to Data about you that is governed by the third parties’ privacy policies. You can find more information on this in our Cookie Statement.
We may use Listings and Reviews (Listings and Reviews): We may process Data that you post for publication on our website or through our Services, including business listings and reviews. The information may be processed for the purposes of enabling such publication and administering our website and Services.
6. With whom do we share your Data
We share your Data in the following way:
- Our Offices: We may share your data with our offices (affiliates) to respond to a request or provide and develop our Service. Companies and brands owned and operated by us can be found on our website https://leads.io/
- Our Service Providers: We work with several service providers, who process Data on our behalf (“Processors”). These include, for example cloud storage providers, payment service providers, call centers or website analytics or marketing tools. We have appropriate Data Processing Agreements in place with such Processors to ensure the protection and confidentiality of Data.
- Advertisers and Advertising Networks: Our website may include social media plug-ins (like the Facebook like button), widgets (like the “Share” button), or other tools made available by third parties such as social media companies or advertising network.
- Our Registered Traders: To provide our Service we share your Data with Registered Traders so you can receive a quote for their products or services. For example, HomeLogic.
- Our Marketplace Providers: To provide our Service we may share your Data with Marketplace Providers so they can match you with the registered traders (like local professionals) connected to their own marketplace websites.
- Professional Advisors, Insurers: We may disclose your Data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- Authorities and Courts: We may share your Data if we are obliged to do so by statutory law or instructions from a public authority or court. We may let you know in advance in line with Data Protection Laws.
- Corporate Mergers and Acquisition Activity: In the event that Leads.io or its affiliates acquires or is acquired by another business operation, or in the event of a reorganization, merger, or other similar event, your Data may be shared with the acquiring, acquired, or resulting entities.
7. International Transfers of your Data
We generally store Data (such as contact information) from Customers and Business Partners on servers in the European Union (EU).
Data in the EU is protected by Data Protection Laws, but other countries do not necessarily meet the same privacy standards. To provide our Service to you, we may be required to transfer some of your Data outside the territory of the UK or EEA (which means all EU countries including Norway, Iceland, and Liechtenstein) because some of our servers may be hosted in the US or other territories outside of the UK or EEA.
We may also use service providers (“Processors”) based outside of the UK or EEA to help us provide our websites and Services to you (for example, platform providers who help us deliver our Services, or advertising) and this means that we may transfer your Data to service providers outside the UK or EEA for the purpose of providing our applications, advertising, and Services to you.
By using our website or Services or by interacting with us in the ways described in this Privacy Policy, you agree to the transfer of your Data outside the UK or EEA in the circumstances set out in this Privacy Policy. If you do not want your Data to be transferred outside the UK or EEA, you should not use our website or Services.
8. Storing and Retention of your Data
We will retain your Data for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with Leads.io’s Data Retention Policy, or as otherwise permitted by applicable Data Protection Laws. We generally store non-qualified enquiries for 2 years and qualified enquiries for 7 years subject to exceptions where local retention laws require something else. Where we no longer need your Data, we will delete it in a secure manner (without further notice to you).
9. Security
We implement reasonable security measures to protect Data from loss, misuse, alteration, or destruction. However, since no method of transmission over the Internet, or method of electronic storage is 100% secure, there might be a very small chance that the Data collected by us may be compromised. If you believe that any Data has been compromised, please contact us. If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with the provisions of the applicable law.
10. Legal grounds for processing
For Europe: Under the (UK) GDPR, ‘Controllers’ are obligated to have a valid lawful basis for each processing activity that they undertake. The table below sets out our lawful basis for each processing activity.
Legal Grounds of Leads.io
- Information Requests: Article 6 (1) (b) – Performance of Contract
- Provision of Service: Article 6 (1) (b) – Performance of Contract. For example, we transfer your Data and connecting you with Business Partners so you can receive the requested Quotes.
- Review and Customer Satisfaction: Article 6 (1)(b) – Performance of contract.
- Survey: Article 6 (1) (f) – Legitimate Interest.
- Marketing (like newsletter): Article 6 (1) (a) – Consent
- To create custom and similar audiences: Article 6 (1) (f) – Legitimate Interest
- Automated decisions and profiling: Article 6 (1)(a) or (f) – Consent or Legitimate Interest
- Listings and Reviews: Article 6 (1) (a) – Consent
- Usage of technical information (Website Operations and Analytics): Article 6 (1)(a) or (f) – Consent or Legitimate Interest
- Compliance with legal obligation: Article 6 (1) (c) – Legal Obligation
Legal Grounds of Business Partners
After receiving your Data, Business Partners act as independent (new) ‘Controllers’ of your Data. To continuously process your Data after transfer of Leads.io (for example contacting you by telephone, text/SMS or email based on your Quote request) they also need a legal ground. This may be Consent, Contract or Legitimate Interest based on their own choice. You will find more information about how Business Partners process your Data in their Privacy Policy and Terms. For example, HomeLogic. responds to a Quote as received by Leads.io on the basis of as explained in their own privacy policy: www.homelogic.co.uk/privacy
11. Your privacy rights
If you are based within the UK, EEA or within another jurisdiction having similar Data Protection Laws, in certain circumstances you have the following rights:
- Right of access: The right to be told how we use your Data and obtain access to your Data;
- Right to rectification: The right to have your Data corrected. If we hold any Data about you which is incorrect or if there are any changes to your details, please let us know so that we can keep our records accurate and up to date;
- Right to deletion and restriction: The right to have your Data deleted or place restrictions on processing your Data;
- Right to data portability: The right to have any Data you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible;
- Right to object: The right to object to the processing of your Data e.g., for direct marketing purposes;
- Right to withdraw consent: Where the processing of your Data is based on your consent, the right to withdraw that consent. If you withdraw your consent to the use of your Data for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our websites and Service;
- Right in Relation to Automated Decision-making and Profiling:The right to object to any decisions based on the automated processing of your Data, including profiling;
- Right to lodge complaint: The right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g., in the UK, the Information Commissioner’s Office). You can find a good overview of EU data protection authorities via the website of the European Data Protection Board.
12. Contact
For further information about our Privacy Policy or our processing of Data about you or if you have any queries about your rights under local law, how to update your records, or how to obtain a copy of the Data that we hold about you, or to exercise any other rights given to users under applicable Data Protection Laws please contact us:
Leads.io
Legal Department
Nieuwe Steen 27
1625 HV, Hoorn
The Netherlands
Online:
You can contact us via:
For the UK: compliance.UK@leads.io
If you like to contact one of our local offices via phone, you can do so via https://leads.io/
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