Privacy Policy - Lead Forensics
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Privacy Policy

Lead Forensics Privacy Statement 

Lead Forensics is software that reveals the identity of your anonymous website traffic and turns them into actionable leads within a
business to business environment.  As a leading provider of SaaS solutions, we are committed to providing a high calibre data led solution for all of our clients, as part of that we take data compliance extremely seriously and are pro-active in ensuring the compliance of both the SaaS solutions we provide to our customers as well as ensuring compliance as a business entity in our own right.

The purpose of this statement is to provide information regarding how and why Lead Forensics collect, process and store data, as well
as providing the appropriate contact information should you wish to request the information we hold about you, withdraw from processing or request deletion of any data we hold about you.

Under the EU General Data Protection Regulation (GDPR) there are six lawful basis for processing personal data.  These are detailed as follows:

      Consent

The individual has given clear consent for you to process their personal data for a specific purpose

      Contract

The processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract

      Legal Obligation

The processing is necessary for you to comply with the law (not including contractual obligations)

      Vital Interests

The processing is necessary to protect someone’s life

      Public Task

The processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function
has a clear basis in law

      Legitimate Interests

The processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)

Further information regarding the lawful basis for processing personal data can be found at ico.org.uk 


Lead Forensics Marketing and Sales Data

As an organisation that processes business related data, Lead Forensics has assessed all six grounds for lawful processing of personal data and has selected ‘Legitimate Interests’ as the most suitable lawful ground for the processing of data for the purposes of Lead Forensics marketing and sales.

Lead Forensics collects, processes and stores data relating to businesses and decision makers.  We believe that the individuals that we
processes the data of, are likely to have an interest in the Lead Forensics product.  Deemed as ‘Legitimate Interest’ this is based upon specific criteria including the business industry sector, size of organisation as well as the individual’s job function within the organisation.  Our typical segmentation includes those within marketing, sales, business development, MD and owner related job functions, although this list is not exhaustive and other variables may apply.

We will only ever collect, process and store the essential information required for making contact with the data subjects within a business environment.  The personal data we collect is limited to first name, last name, email address, social profiles (limited to LinkedIn) as
well as business IP address.  Other business related data may also be processed including business name, job function, turnover and business address, however we will never collect further personal data such as those classed under ‘Sensitive Personal Data’.

The data collected will be used to communicate marketing and sales messages relating to the Lead Forensics product, based upon the job function held by the data subject.  Lead Forensics specifically only sends messages to those we believe are likely to be interested in the Lead Forensics product based upon the organisation they are employed by and based upon their job function within that organisation.
Messages from Lead Forensics could be delivered via email, social media, via telephone or any other business to business (B2B) marketing methods that may be relevant.

When you send Lead Forensics an enquiry or booking form via our website or one of our micro sites you will be asked to provide your contact details. We will use the data you provide to process your request and may use it to inform you by email, telephone or mail about other Lead Forensics products and services that we feel may be of interest to you, it is deemed that as you have visited the Lead Forensics
website and provided us with your contact information that you are legitimately interested in our products and services. You have the right to object from any method of correspondence at any time, using the unsubscribe button on an email, by informing the telephone operator or by contacting us via any of the methods below.

Screening phone numbers against TPS/CTPS Lists

All phone numbers that are collected are checked against the TPS (Telephone Preference Service) and CTPS (Corporate Telephone Preference Service) lists daily. This will ensure that our team does not contact via telephone any individual or business that has registered their phone number on either of these lists.


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’.  If you have received correspondence from us, we will have procured your data in one of the following ways:

      You have requested information from Lead Forensics on a previous occasion

      Someone has sent us your e-mail address requesting information about our articles and/or services be sent to you

      You or someone else has expressly shared your contact details with us for the purpose of receiving information now and/or in
the future

      We have previously met at an event and your business card or contact details were handed to us willingly

      You or a business colleague has visited our website and we believe that there is a genuine legitimate interest in our
services

      You have previously connected with a member of our team via LinkedIn and discussed our services

      A member of our team has found your business and your contact details online, believing that your business would genuinely be interested in the Lead Forensics product, based upon your job function aligning with our typical customer profiles they have made contact to introduce you to our product

      Your data has been purchased by a registered third party data supplier, which will have been segmented by industry, organisation size and job function based upon our typical customer profiles. (Due diligence checks around GDPR compliance will have been conducted accordingly)

Legitimate Interest Assessment (LIA)

Lead Forensics has carried out a Legitimate Interest Assessment (LIA) as advised by the ICO.  Based upon that assessment it is deemed that the rights and freedoms of the data subjects would not be overridden in our correspondence regarding Lead Forensics and that in no way would a data subject be caused harm by our correspondence.  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, we believe that any individual that receives correspondence from Lead Forensics in a direct marketing or sales capacity, could be legitimately interested in the Lead Forensics solution.  It is also deemed that direct marketing and sales is necessary in the context of promoting Lead Forensics to professionals in business in order to increase awareness of our SaaS solution in the marketplace.

Per the ICO guidance, Lead Forensics can confirm:

      We have checked that legitimate interests is the most appropriate basis

      We understand our responsibility to protect the individual’s interests

      We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our
decision

      We have identified the relevant legitimate interests

      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 do not override those legitimate interests

      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 to object

      Our LIA did not identify a significant privacy impact, and therefore we do not require a DPIA

      We keep our LIA under review every six months, and will repeat it if circumstances change

      We include information about our legitimate interests in our privacy notice

Lead Forensics has an in-house data verification team, who are responsible for ensuring the validity and quality of the data contained within the Lead Forensics CRM system ‘Cyclone’.  The team continually cleanse the data held within the CRM system, completing a full cleanse cycle 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.


Data Storage and Retention

The data held within the Lead Forensics CRM system is processed and stored in the UK within a secure environment.

Lead Forensics has a continual cycle of cleansing and refreshing data contained with our CRM system, all data 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.

Call Recordings

In the interest of our employees, customers, and prospective customers, all calls are recorded for training and monitoring purposes. Please see our Call Recording Policy for more information.

 

Request to Object

In all correspondence with you we will give you the right to object from receiving further correspondence from
Lead Forensics.  On any emails you
receive from Lead Forensics there will be the option to ‘unsubscribe’ from
receiving any further email correspondence.
If you receive a

telephone call from us, you have the right to request not to receive any further calls.  Lead Forensics has a companywide CRM system, your request to object will be logged within our CRM system to ensure that you do not receive any further calls.

Should you wish to object to receiving communication from Lead Forensics, you can do so in a variety of ways:

      Please follow the unsubscribe instructions at the bottom of every email

      If you have received a call, please tell the representative that you do not wish to receive any further communication

      Please call 0207 206 7293 and ask to speak with the Data Compliance Team

      You can also 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 CRM system in the future.  Please note 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 GDPR.


Request for Deletion 

In the event that you make a request for deletion, a minimal amount of your personal data will be kept in our suppression files. This enables Lead Forensics to fulfil our legal obligation under Article 6(1)(c) of the GDPR to ensure that you are not contacted again.

If you are not added to our suppression file, there is a risk that your data may be processed again in the future if your details are re-added to our software by out data procurement team. Therefore, we will keep a minimal amount of data (name, business phone number, and business email or LinkedIn URL where applicable) in a suppression file with a note to say that you no longer wish to receive communication so that you are not contacted again in the future.

All requests will be processed 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 of 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.

This policy was last reviewed and updated on the 5th 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

Brexit

In the event of a no-deal Brexit, the UK will leave the EU and become a Third Country according to the GDPR. A Third Country may need to have a representative inside the EU in order to keep EEA data flowing to the UK without restrictions.

Lead Forensics applies the exemption as per Article 27(2) of the GDPR, Lead Forensics does not have a designated EU representative for the following reasons:

• Our processing does not involve processing of special categories of data

• Our processing does not involve personal data relating to criminal convictions and offences

• Our processing is unlikely to result in a risk to the rights and freedoms of natural persons.

 

Furthermore, as per Article 46 of the GDPR and Article 26 of the e-Privacy Directive, Lead Forensics has taken appropriate measures to enable cross-border data transfers. We will make use of Standard Contractual Clauses to ensure that our EEA-based customers and service providers can continue to transfer personal data to us.

This policy was last reviewed and updated on the 5th 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

Lead Forensics Limited is registered with the Information Commissioner’s Office under registration reference: Z3646774

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