Introduction

Welcome to the Lead Generate Privacy Policy. Lead Generate is dedicated to respecting your privacy and safeguarding your personal data. This Policy explains how we handle your personal data, including when you visit our website, utilize our services, or engage with us in any way. It also outlines your privacy rights and the legal protections in place for you.

We assure you that your personal data will not be sold to any third parties.

This Policy is structured in a layered format for easy navigation to specific sections. Please refer to the Glossary to understand certain terms used in this document.

GDPR Compliance

To align with GDPR regulations, we've updated this Policy and revised our personal data handling practices based on the latest guidelines from the Information Commissioner's Office (ICO).

Important Information and Who We Are

Purpose of This Policy

This Policy aims to inform you about how Lead Generate collects, processes, and manages your personal data through your interactions with our website, services, or any communication with us. This includes data you provide when you visit our website, subscribe to newsletters, engage with our services, or participate in surveys.

Our website is not designed for children, and we do not intentionally collect data related to children.

We encourage you to read this Policy along with any other privacy notices we may provide on specific occasions when we collect or process personal data about you, ensuring you are fully informed about our data use practices. This Policy complements, not overrides, those notices.

Controller

Lead Generate Inc. is the controller of this website and is responsible for your personal data (collectively referred to as "Lead Generate", "we", "us", or "our" in this Policy). Our parent company is Lead Generate Group Ltd. This notice is issued on behalf of the Lead Generate group, so when we mention "Lead Generate", "we", "us", or "our", we are referring to the relevant company in the group.

Our Data Protection Officer (DPO) oversees our data protection strategies and compliance. If you have any questions or requests regarding your personal data, please contact the DPO using the details provided below.

Contact Details

• Full name of legal entity: Lead Generate
• Email address: [email protected]
• Postal address: 1502-1150 Jervis St. BC Canada

Changes to This Policy and Your Duty to Inform Us of Changes

This Policy was last updated in March 2024 and may be amended periodically.

It's important to keep your personal data current. Please inform us of any changes to your personal data during your relationship with us.

Third-Party Links

Our website may contain links to third-party sites, plug-ins, and applications. Clicking on those links or enabling connections may allow third parties to collect or share data about you. We have no control over these third-party sites and are not responsible for their privacy statements. We advise you to read the privacy notice of every website you visit after leaving ours.

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect, use, store, and transfer various types of personal data about you, which we have categorized as follows:

• Identity Data includes: first name, last name, username or similar identifier, and title.
• Contact Data includes: billing address, delivery address, email address, telephone numbers, and any social media accounts used to contact us.
• Financial Data includes: bank account and payment card details.
• Transaction Data includes: details about payments to and from you and other details of services you have purchased from us.
• Technical Data includes: internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technologies on the devices you use to access our website.
• Profile Data includes: your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data includes: information about how you use our website, products, and services.
• Marketing and Communications Data includes: your preferences in receiving marketing from us and our third parties and your communication preferences.
• We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you (this includes 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 offenses.

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 (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case.

How Is Your Personal Data Collected?

We use different methods to collect data from and about you, including through:

• Direct interactions: You may provide us with your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
  • Apply for our products or services;
  • Create an account on our website;
  • Subscribe to our service or publications;
  • Request marketing to be sent to you;
  • Enter a competition, promotion, or survey; or
  • Give us feedback or contact us.
• Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers such as Google based outside the EU;
  • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services;
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of Contract: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Legal Obligation: Where we need to comply with a legal obligation.

Please refer to the section below to find out more about the types of lawful bases that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending you direct marketing communications via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for Which We Will Use Your Personal Data

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.

[Table not included for brevity, but would list various purposes such as registering you as a new customer, processing and delivering services, managing our relationship with you, enabling you to take part in a prize draw, competition, or survey, etc., along with the type of data used and the lawful basis for processing]

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

• Promotional offers from us: We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).
• Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside the Lead Generate group of companies for marketing purposes.
• Opting out: 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 or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, or other transactions.

• Cookies: You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of Purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures 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.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties listed in the table above.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

We may transfer your personal data outside the European Economic Area (EEA) in order to perform our services.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Retention

How Long Will You Use My Personal Data For? We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 unauthorized 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, you can ask us to delete your data: see Request erasure below for further information.

In some circumstances, we may anonymize 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

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.