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PRIVACY POLICY
What does this 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.co.uk or any other Lead 365 web property or services referencing this Privacy Policy. We understand the importance of privacy, and we strive to keep personal information confidential.
With that in mind, this Privacy Policy is designed to describe:
Cookies.
What are “Your Rights” over your Personal Data.
What Personal Data we collect.
How we use your Personal Data and why.
Who we share your Personal Data with.
How we keep your Personal Data secure.
How long we store your Personal Data.
Our policy on children.
Changes to this policy.
Third party Links.
Contact Us.
EU-wide data protection legislation known as the “General Data Protection Regulation” or “GDPR” took effect from May 25th, 2018. Following the UK’s withdrawal from the European Union on 31st January 2020, the GDPR has been retained in domestic law as the UK General Data Protection Regulation “UK GDPR” (a copy of which is posted here), but the UK has the independence to keep the framework under review. The UK GDPR sits alongside an amended version of the Data Protection Act 2018.
This website Privacy Policy is intended to meet our duties of Transparency under the UK GDPR, the Data Protection Act 2018 and all other applicable privacy laws.
We will post any modifications or changes to this Privacy Policy on this page.
This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.
Who we are.
We are Lead 365 Limited, a UK company with company registration number 09973434 and Information Commissioner’s Office (ICO) registration number ZA214185. Our address is: Lead 365, Suite 3 Sanctus House, Olympus Park, Gloucester, Gloucestershire, England, GL2 4DH.
When we refer to “L365”, “we” or “us” in this Privacy Policy, we are referring to Lead 365 Limited.
We have appointed a “Data Protection Lead”, 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 Lead directly, you can email: [email protected].
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.
Cookies.
Cookies help websites remember you so things run smoothly. They let you add items to a shopping basket, and they can keep you logged in to sites where you have an account. Cookies can also be used to collect demographic information so companies can better understand the people that use their website. Typically, they only contain two pieces of information; a site name and a unique user I.D.
When you visit our website or any other Lead 365 web property you have the opportunity to select which cookies and associated information you are happy for Lead 365 to collect
| Name | Category | Duration | Sensitivity | Description |
|---|---|---|---|---|
| _ga_D2DESGKNLS | Analytics | 2 years | non-necessary | This cookie is installed by Google Analytics. |
| _gat_gtag_UA_90310844_1 | Analytics | 1 minute | non-necessary | Set by Google to distinguish users. |
| _gat_UA-90310844-1 | Analytics | 1 minute | non-necessary | A variation of the _gat cookie set by Google Analytics and Google Tag Manager to allow website owners to track visitor behaviour and measure site performance. The pattern element in the name contains the unique identity number of the account or website it relates to. |
| _gid | Analytics | 1 day | non-necessary | Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website’s performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously. |
| _ga | Analytics | 2 years | non-necessary | The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. |
| elementor | Necessary | never | non-necessary | This cookie is used by the website’s WordPress theme. It allows the website owner to implement or change the website’s content in real-time. |
| cookielawinfo-checkbox-advertisement | Necessary | 1 year | non-necessary | Set by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the “Advertisement” category . |
| CookieLawInfoConsent | Necessary | 1 year | non-necessary | Records the default button state of the corresponding category & the status of CCPA. It works only in coordination with the primary cookie. |
| cookielawinfo-checkbox-others | Necessary | 11 months | necessary | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Other. |
| cookielawinfo-checkbox-analytics | Necessary | 11 months | necessary | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Analytics”. |
| cookielawinfo-checkbox-performance | Necessary | 11 months | necessary | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Performance”. |
| cookielawinfo-checkbox-functional | Necessary | 11 months | necessary | The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category “Functional”. |
| cookielawinfo-checkbox-necessary | Necessary | 11 months | necessary | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Necessary”. |
| viewed_cookie_policy | Necessary | 11 months | necessary | The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data. |
What are “Your Rights” over your Personal Data.
Under data protection law you have rights regarding how we process your data.
You are not required to pay any charge for exercising your rights. We have one month to respond to you, and you may be asked for ID to confirm your identity.
To exercise any of the following rights, please use the contact details listed at the bottom of this section:
Your Individuals Rights as a Data Subject:
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. You can read more about this here.
B: Right to Access – You have 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 their right to access. You can read more about this here.
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 with whom we have processed your information on their behalf, or with the publishers who holds an account with Lead 365. You can read more about this here.
D: Right to Erasure – This is also known as “the right to be forgotten”. This gives you the right to request your information be removed/erased verbally or in writing. We maintain a list of the people who have asked not to be contacted and ensure that they will not receive any further marketing from our clients, we will also put you in touch with the originating data controller to perform the same action. You can read more about this here.
E: Right to Restrict processing – Where certain conditions apply, 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. You can read more about this here.
F: Right of Portability – 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 use. You can read more about this here.
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. You can read more about this here.
H: Rights related to automated decision-making including profiling – We do not use automated decision-making processes which would cause a potentially damaging effect to you. You can read more about this here.
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 – [email protected]
By Phone – +44 (01)1452 250177
In writing – The Data Protection Lead, Lead 365, Suite 3 Sanctus House, Olympus Park, Gloucester, Gloucestershire, England, GL2 4DH.
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 includes;
The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. https://ico.org.uk/make-a-complaint/ Tel: 0303 123 1113
The Claims Management Regulator – https://www.gov.uk/complain-about-claimscompany
What Personal Data we collect.
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, Personal Data is 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 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 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. |
Consumers
| 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, IP 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 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 UK and 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
| 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 party 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 | Your Personal Information, this could include, Name, Address, Date of Birth, Email address, IP 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 utility 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) |
Third Party Industry Sectors:
The industry sectors you may be contacted from including those from which third-party Advertisers & Publishers are included include the following. We may update the list of sectors from time to time accordingly.
Automotive / Retail / Finance / Gambling / Insurance / Travel / Lifestyle / General / Utilities / Security / Mobile
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 an 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 your login credentials.
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.
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 reviewed and updated on 3rd December 2024.
Third Party Links.
Our website – www.lead365.co.uk or any other Lead 365 web property 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 you contact us with a question using our online enquiry forms, 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, Suite 3 Sanctus House, Olympus Park, Gloucester, Gloucestershire, England, GL2 4DH.
Email: [email protected]
Tel: +44 (0)1452 260177
