Lead5050 treats all your personal information as private and confidential, except where we are required by law, to disclose it and except when it is with a 3rd party software provider that we have engaged to deliver or propose our services to you. 

You may request to see copies of the records we hold for you, or to be removed from our database or mailing lists, at any time you choose.

We seek to fully comply with the General Data Protection Regulation (GDPR).

For further information please contact Lead5050 at sarah@lead5050.com


INTRODUCTION

This Privacy Policy explains what we do with your personal data. It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

We aim for our Privacy Policy to be compliant with all applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) and the German Federal Data Protection Act 2017 and related legislation (BDSG).


You can get in touch with us:

  • to access, amend or take back the personal data that you have given to us

  • if you suspect any misuse or loss of or unauthorised access to your personal information

  • to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data)

  • with any comments or suggestions concerning this Privacy Policy.

Alternatively, you can click the unsubscribe link in any marketing e-mail we send to you. 


Legal basis for processing your data

Lead5050 relies on the Legitimate Interest basis for processing your data where processing is necessary under the Legitimate Interests of the Controller or Third Party, unless these interests are overridden by the individual’s interests or fundamental rights.


Legitimate interests

Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”
You have the right to object to us processing your personal data on this basis.


How long do we keep your personal data for?

We will delete your personal data from our systems if we have not had any meaningful contact with you for some time as it is likely your data will no longer be relevant for the purposes for which it was collected.

When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. We will also consider it meaningful contact if you communicate with us, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will count as meaningful contact


How can you access, amend or take back the personal data that you have given to us?

One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect to your data, even once you have given it to us.

To get in touch about these rights, please contact us at sarah@lead5050.com. We will seek to process with your request without undue delay, and in any event within 30 days (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.


Right to object

This right enables you to object to us processing your personal data where we do so for one of the following four reasons:

  • our legitimate interests;

  • to enable us to perform a task in the public interest or exercise official authority;

  • to send you direct marketing materials; and

  • for scientific, historical, research, or statistical purposes.

The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our website users, customers and suppliers. If your objection relates to us processing your personal data because we deem it necessary for our legitimate interests, we must act on your objection by ceasing the activity in question unless we can show that we have compelling legitimate grounds for processing which overrides your interests; or we are processing your data for the establishment, exercise or defence of a legal claim.

If your objection relates to direct marketing, we must act on your objection by ceasing this activity.


Right to withdraw consent

Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.


Data Subject Access Requests (DSAR)

You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.


Right to erasure

You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:

  • the data is no longer necessary for the purpose for which we originally collected and/or processed it;

  • where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;

  • the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);

  • it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or

  • if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

We would only be entitled to refuse to comply with your request for one of the following reasons:

  • to exercise the right of freedom of expression and information;

  • to comply with legal obligations or for the performance of a public interest task or exercise of official authority;

  • for public health reasons in the public interest;

  • for archival, research or statistical purposes; or

  • to exercise or defend a legal claim.

When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.


Right to restrict processing

You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either:

One of the circumstances listed below is resolved;

  • you consent; or

  • further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.

The circumstances in which you are entitled to request that we restrict the processing of your personal data are:

  • where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;

  • where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;

  • where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and

  • where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.

If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.


Right to rectification

You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.


Right to lodge a complaint with a supervisory authority

You also have the right to lodge a complaint with your local supervisory authority. If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please contact us by email at sarah@lead5050.com

You may withdraw your consent to receive marketing communications only or all consent to receiving any communication from Lead5050. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.