California Consumer Privacy Act - Lead Forensics
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California Consumer Privacy Act

Lead Forensics Privacy Policy

 
The Lead Forensics Product
 
The Lead Forensics product is a market leading B2B sales and marketing enablement tool. It is SaaS
(Software as a Service) and provides businesses with insight relating to their website visitors. Lead Forensics works on the basis of reverse business IP tracking. A small tracking code is placed on a business’ website(s) which then enables them to identify the business IP addresses of their website visitors. Lead Forensics matches the identified business IP address to a wholly owned global database of businesses and business information.
 
The Lead Forensics software is almost entirely focused on leveraging business-related information to effectively match a business IP address with wider business data to provide valuable businessrelated visitor information to our customers. Lead Forensics does not identify any personal IP addresses, mobile devices or any other data than that associated with the business.
 
Business related data is not applicable under the CCPA – which has the intention of protecting personal data. Therefore, the majority of the Lead Forensics solution and its features are not relevant to the CCPA.
 
 
Contact Data
 
An additional feature of Lead Forensics aside from the main solution, is to provide customers with the contact information of key decision makers at the organisations that have pro-actively visited the company website. As this information contains details including first name, last name and email address, this aspect of Lead Forensics could constitute the processing of personal data and therefore required to be compliant with CCPA.
 
Lead Forensics will only ever collect business IP addresses, which are then matched to a business profile, from there Lead Forensics offers customers the opportunity to purchase the contact details of relevant decision makers within the matched business. This data will have been collected from various publicly available data sources such as LinkedIn. The data available will only relate to decision makers at the organisations that have pro-actively visited a customer’s website. It is anticipated that Lead Forensics customers will select the most appropriate point of contact from the data provided by Lead Forensics to convey a highly relevant, targeted message either by email, telephone or by post to the business address. Any correspondence will be based upon their likely interest in the organisation’s product or service following their visit to the organisation’s website.
 
Under CCPA, Lead Forensics will only ever process necessary personal data, which is limited to first name, last name, and email address. Lead Forensics will process further business-related data such as business IP, business name, job function and business telephone numbers. No sensitive personal data will be collected or processed in any way. Lead Forensics customers have the option of using Lead Forensics without leveraging contact data, in which case the Lead Forensics solution is unrelated to CCPA on the basis that it will only process business data. Lead Forensics customers also have the option of using Lead Forensics where contact data for any business located California is disabled. Where a customer opts to use the contact data feature of Lead Forensics, it is deemed that the customer will be responsible for ensuring the data used is further processed within their business in a method that is compliant with CCPA – each customer will be responsible for conducting their own due diligence checks and producing their own policies as applicable to their business.
 
Lead Forensics has carried out various Assessments such as LIA, DPIA and personal data risk assessments. Based upon these assessments it is deemed that the rights and freedoms of any data subject would not be overridden in our processing of the personal data and that in no way would a data subject be caused harm by the Lead Forensics processing. Based upon our segmentation by organisation and by specific job function, coupled with our processing of personal data within the context of a business environment, it is deemed that any processing of data will be limited to business matters, and therefore any risk of personal compromise is extremely unlikely. It is also deemed that direct marketing and sales is necessary in the context of following up with website visitors in order to better serve visitors and to generate business sales.
 
 
CCPA compliance requirements covered by Lead Forensics
 
• Delegate CCPA compliance oversight to a knowledgeable employee or team.
• Maintain and regularly update a business-wide privacy policy.
• Implement and maintain reasonable security practices.
• Maintain procedures to respond to requests for access to personal data and specific pieces of information.
• Maintain procedures to respond to requests to delete personal information.
• Maintain procedures to respond to requests to opt-out of sale of personal information.
• Update vendor contracts to comply with CCPA and avoid being characterized as “selling” personal information to vendors.
• Maintain procedures for collection and use of personal information of minors (as applicable).
• Conduct appropriate privacy training for personnel depending on their job function.
• Assess affiliates’ need to comply with the CCPA and implement group-wide compliance if necessary.
• We have identified a legitimate ground for processing
• We understand our responsibility to protect the individual’s interests, rights and freedoms
• We have conducted risk assessments and kept a record of it
• We will review our processes regularly
• We have checked that the processing is necessary and there is no less intrusive way to achieve the same result
• We have done a balancing test, and are confident that the individual’s interests are not overridden in the interests of our customers or our own
• We only use individuals’ data in ways they would reasonably expect
• We are not using people’s data in ways they would find intrusive or which could cause them harm
• We do not process the data of children
• We have considered safeguards to reduce the impact where possible
• We will always ensure there is an opt-out / ability for a data subject to object to processing
 
 
How we Process Data
 
The Lead Forensics solution provides businesses with the details of organisations that have visited their website based upon business IP tracking. Lead Forensics matches this data to a database of business points of contact, presenting this information to its customers as potential contacts from the visiting organisation, that based upon the pro-active business visit could be interested in the products/services on offer. In order to do this, Lead Forensics will process first name, surname and business email address along with business data in order to present that information to its customers. The data is presented to customers via a secure, unique log in access to the Lead Forensics portal. Customers have the option of purchasing relevant points of contact, including email addresses and names from the visiting organisations. From that point the data limited to email address, name, and supporting business information including business telephone number will be transferred to the customer, again via the secure portal. Lead Forensics acts as a data processor in this regard, Lead Forensics is not liable for the onward processing of the data via each customer, although we strongly advise all customers to ensure compliance with CCPA in all aspects of personal data processing.
 
 
How we Procure Data
 
At Lead Forensics we procure data in a variety of ways, collected in line with the lawful basis of ‘Legitimate Interests’. The following are ways in which we collect and process data: Business Data
Although business data is not relevant under CCPA, Lead Forensics is committed to providing a transparent solution so that customers can effectively assess their own compliance. Lead Forensics collects business data via the following methods:
• Primary research – Lead Forensics has a UK based in-house team who gather data relating to business from publicly available information, using search engines and other online tools to research global businesses.
• Secondary research – Lead Forensics has a UK based in-house team who use existing publicly available sources of data to enhance the business data.
• Purchase – Lead Forensics purchases business information from a number of selected third-party data vendors who are vetted to ensure the quality and validity of the business data provided.
 
 
Personal Data
 
Lead Forensics collection and processing of personal data is limited to:
• First name
• Last name
• Email address
 
Lead Forensics procures this personal data in the following ways:
• Primary research – Lead Forensics has a UK based in-house team who gather data relating to key decision makers at organisations from publicly available sources including the website of each business.
• Secondary research – Lead Forensics has a UK based in-house team who use existing publicly available sources to gather the information relating to key decision makers including the Directors’ Register at Companies House, Dun & Bradstreet, Duedil, LinkedIn and Hootsuite.
• Purchase – Lead Forensics purchases data from selected third party data vendors with key segmentation criteria to ensure that only decision makers from registered businesses are procured. All third-party data vendors have been checked for CCPA compliance and to ensure the validity and accuracy of data.
 
Lead Forensics also uses automated scripts and algorithms to collect, process and validate both business data as well as the personal data detailed above. These automated processes are subject to the same compliance checks as all manual processes and consent is obtained from individual data subjects.
 
 
How we Ensure Data Validity and Currency
 
Lead Forensics has a UK based in-house data verification team who are responsible for ensuring the validity and currency of the data contained within the Lead Forensics solution. The team continually cleanse the data held within the Lead Forensics software, completing a full cleanse cycle of both business and personal data at least once every 12 months. Any records found to be out of date are placed into a deletion queue which is securely purged four times in a 12-month period.
The data verification team use both manual methods as well as automated scripts and algorithms via an extensive multi-staged process to ensure the utmost validity and currency of data. Lead Forensics takes data cleansing extremely seriously as this ensures a highly compliant solution as well as a high calibre solution for all of the Lead Forensics customers.
 
 
Data Storage and Retention
 
The data held within the Lead Forensics solution is processed and stored in the UK within a secure environment. Lead Forensics has a continual cycle of cleansing and refreshing data, all data within the Lead Forensics solution is verified at least once in a 12-month cycle. Any invalid records are placed into a deletion queue, which is then securely purged four times in a 12-month period.
 
The data held within the Lead Forensics solution is processed and stored in the UK within a secure environment. Lead Forensics has a continual cycle of cleansing and refreshing data, all data within the Lead Forensics solution is verified at least once in a 12-month cycle. Any invalid records are placed into a deletion queue, which is then securely purged four times in a 12-month period.
 
 
Consumer Request Procedures
 

Request to Object
Any individual who has been identified as a website visitor by Lead Forensics has the right to object to receiving correspondence from a Lead Forensics customer by contacting them directly and requesting to object, you can find their specific processes for this by visiting their company website and reviewing their privacy policies.
 
Should any individual wish to withdraw from Lead Forensics processing your personal data for use by the Lead Forensics software and its customers, please make your request in writing: By emailing:
 
data-compliance@leadforensics.com
 
Or by writing to:
Data Compliance, Lead Forensics, Building 3000, Lakeside, North Harbour, Portsmouth, PO6 3EN. All requests will be processed within 30 days. Your details will be added to a suppression file to ensure that your details cannot be processed by the Lead Forensics software in future. Please note that this applies only to the processing of your personally identifiable data, not that of the business data which does not fall under the remit of CCPA.
 
 
Request for Deletion
 
It is important to understand the difference between a right to object and a request for deletion. If you request deletion, we will remove any data we hold about you from the Lead Forensics software. This will also mean that we will remove you from our suppression files. If you are removed from our suppression files, there is a risk that your data may be processed again in the future if your details are re-added to our software by our data procurement team. If you do not wish for Lead Forensics to process your personal data in the future, we would recommend you request to object rather than a request for deletion, as this will ensure that your details are always suppressed from processing.
The option however is yours, and in either case we will process your request within 30 days. Please make your request in writing by emailing:
 
data-compliance@leadforensics.com
 
Or by writing to:
Data Compliance, Lead Forensics, Building 3000, Lakeside, North Harbour, Portsmouth, PO6 3EN.
 
Request for Data Held You may request that we send you all the data we hold that relates to you. Please make your request in writing;
By emailing:
 
data-compliance@leadforensics.com
 
Or by writing to:
Data Compliance, Lead Forensics, Building 3000, Lakeside, North Harbour, Portsmouth, PO6 3EN. We will process and respond to your request within 30 days, this service will be free of charge.
 
 
You can opt out of sale of your data by following this link:
 
Do Not Sell My Personal Information
 
 
This policy was last reviewed and updated on the 05th June 2020. Policies are periodically reviewed to ensure compliance with the current compliance environment. For questions relating to this policy, please contact data-compliance@leadforensics.com
 
Registered Data Protection Officer:
Name: Lindsay Evans

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