1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use our marketing automation platform;|
|“Cookie”||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
|“personal data”||means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and|
|“We/Us/Our”||means Zymplify Limited T/a Lead Onion, a limited company registered in Northern Ireland under company number NI068866, whose registered address is 27/28 The Promenade, Portstewart, BT55 7AE.|
2. Information about us
|2.1||Our Site is owned and operated by us.|
|2.2||Our VAT number is 260155139|
|2.3||Our Data Protection Officer is Michael Green and can be contacted by email at firstname.lastname@example.org, by telephone on 02870878244 or by post at 27/28 The Promenade, Portstewart, BT557AE|
3. What Does This Policy Cover?
4. Your Rights
|4.1||As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:|
|4.1.1||The right to be informed about Our collection and use of personal data;|
|4.1.2||The right of access to the personal data We hold about you (see section 12);|
|3.3.3||The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);|
|4.1.4||The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);|
|4.1.5||The right to restrict (i.e. prevent) the processing of your personal data;|
|4.1.6||The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);|
|4.1.7||The right to object to Us using your personal data for particular purposes; and|
|4.1.8||Rights with respect to automated decision making and profiling.|
|4.2||If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.|
|4.3||For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.|
5. Use of the Subscription Service by Lead Onion
The Lead Onion Subscription Service
Our online Subscription Service allows any company that uses it (our customers and Lead Onion itself) to create and share marketing, sales and customer service content. The Subscription Service can also be used to help organize sales data about a company’s sales pipeline (e.g. leads, customers, deals, etc.). The information added to the Subscription Service, either by site visitors providing their contact information or when a Subscription Service user adds the information, is stored and managed on our service providers’ servers. This information is then used to contact visitors about their interest in the company’s goods or services and interact with the company. Lead Onion provides the Subscription Service to our customers for their own marketing, lead generation, and customer service needs, and we use it to meet Lead Onion’s related needs.
Use by Lead Onion
Use by Our Customers
Lead Onion collects information under the direction of its customers, and has no direct relationship with the individuals whose Personal Information it processes. If you are a customer of one of our customers and would no longer like to be contacted by one of our customer that use our Subscription Service, please contact the customer that you interact with directly. We may transfer Personal Information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.
This refers to credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver’s license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.
6. What Data Do We Collect?
|6.2||date of birth;|
|6.7||contact information such as email addresses and telephone numbers|
|6.8||demographic information such as post code, preferences, and interests|
|6.9||financial information such as credit / debit card numbers|
|6.11||web browser type and version|
|6.13||a list of URLs starting with a referring site, your activity on our Site, and the site you exit t.|
7. How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 8, below.
Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
Providing and managing your Account;
Providing and managing your access to Our Site;
Personalising and tailoring your experience on Our Site;
Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
Personalising and tailoring Our products and services for you;
Replying to emails from you;
Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the unsubscribe link in any of our emails;
Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and telephone and text message with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
Lead Onion uses the YouTube API Services for the collection of the following data where the user connects their YouTube account to the platform:
Number of subscribers
Views, average view duration, subscribers gained/lost
Likes, shares, dislikes and comments
8. How and Where Do We Store Your Data?
We only keep your personal data for as long as We need to in order to use it as described above in section 7, and/or for as long as We have your permission to keep it.
Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
When we share information of customers in the European Economic Area or Switzerland, we make use of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer.
Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
9. Do We Share Your Data?
We may share your data with other companies in Our group. This includes Our subsidiaries.
We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
10. What Happens If Our Business Changes Hands?
In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
11. How Can You Control Your Data?
When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Your Right to Withhold Information
You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com, or using the contact details below in section 15. Alternatively, please refer to Our Data Protection Policy
By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. For more details, please refer to section 6, above, and to section 14.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a popup requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 14.10, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|Website Tracking||Tracks your activity on our website for analytical purposes||No|
And the following third party Cookies may be placed on your computer or device:
|Name of Cookie||Provider||Purpose|
Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
The analytics service(s) used by Our Site use(s) the following Cookies:
|Name of Cookie||First / Third Party||Provider||Purpose|
|Google Analytics||Third||Tracks your activity on our website for analytical purposes|
|Website Tracking||First||Lead Onion||Tracks your activity on our website for analytical purposes|
In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. Contacting Us