Privacy Policy

Last Updated: 5 January 2025

Version: 1.0


1. INTRODUCTION

LEADOO LTD ("we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website www.leadooltd.com (the "Website") or use our digital marketing services.

This policy is designed to comply with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR).

Important: Please read this Privacy Policy carefully. By accessing or using our Website or services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with this policy, please do not use our Website or services.

2. DATA CONTROLLER INFORMATION

Data Controller:

LEADOO LTD
Registered Office Address: 77 Camden Street Lower, Dublin, Dublin 2, Ireland

Contact for Privacy Matters:
Email: leadooltd@proton.me
Postal Address: 77 Camden Street Lower, Dublin, Dublin 2, Ireland

Data Protection Contact:
For all data protection queries, please contact us at: leadooltd@proton.me

EU Representative (Article 27 GDPR):
As we are established in Ireland and offer services to data subjects in the European Union, we comply with all EU GDPR requirements directly through our EU establishment.

Note: We are not required to appoint a Data Protection Officer (DPO) under current regulations, but we have designated a privacy contact person responsible for overseeing compliance with data protection laws.


3. INFORMATION WE COLLECT

We collect and process the following categories of personal information:

3.1 Information You Provide Directly

When you contact us via email or other communication channels, we may collect:

3.2 Information Collected Automatically

When you visit our Website, we automatically collect certain technical information:

3.3 Cookies and Similar Technologies

We use essential cookies necessary for the Website to function properly. For detailed information about our cookie usage, please refer to Section 10 (Cookie Policy).

We DO NOT collect:

4. LEGAL BASIS FOR PROCESSING

We process your personal data based on the following legal grounds under Article 6 of the UK/EU GDPR:

Processing Activity Legal Basis Description
Responding to inquiries and providing services Contract Performance (Art. 6.1.b) Processing is necessary to respond to your request or to perform a contract with you
Business communications and relationship management Legitimate Interest (Art. 6.1.f) We have a legitimate business interest in communicating with potential and existing clients
Website functionality and security Legitimate Interest (Art. 6.1.f) Ensuring our Website operates securely and efficiently
Marketing communications (where applicable) Consent (Art. 6.1.a) or Legitimate Interest (Art. 6.1.f) With your explicit consent or based on legitimate business interest for B2B marketing
Legal compliance and record-keeping Legal Obligation (Art. 6.1.c) To comply with legal and regulatory requirements

5. HOW WE USE YOUR INFORMATION

We use the personal information we collect for the following purposes:

5.1 Service Delivery

5.2 Business Operations

5.3 Marketing Communications (B2B Only)

Your Right to Opt-Out: You can unsubscribe from marketing communications at any time by clicking the "unsubscribe" link in our emails or by contacting us at leadooltd@proton.me.

B2B Marketing Legal Basis:
UK: Under PECR Regulation 22, we may send electronic marketing to corporate subscribers based on legitimate business interest, provided recipients can easily opt out.
EU: We comply with national ePrivacy laws. Where required by specific EU member states, we only send marketing communications with explicit prior consent.

5.4 Legal and Compliance


6. DATA RETENTION

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention Periods:

Data Category Retention Period Justification
Inquiry and correspondence data (non-client) 24 months from last contact Legitimate interest in maintaining business development records
Client relationship data (active clients) Duration of relationship + 6 years Legal obligation for tax, accounting, and potential legal claims
Marketing consent records Until consent is withdrawn + 3 years Legal obligation to demonstrate compliance with PECR and GDPR
Website analytics and logs 12 months maximum Legitimate interest in maintaining server logs for security and technical troubleshooting. We do NOT use Google Analytics or third-party tracking cookies
Financial and accounting records 7 years from end of financial year Legal obligation under Irish tax law and UK HMRC requirements

After the retention period expires, we will securely delete or anonymize your personal data. In some cases, we may retain anonymized or aggregated data indefinitely for statistical purposes.


7. DATA SHARING AND DISCLOSURE

We do not sell, rent, or trade your personal data to third parties. We may share your information only in the following circumstances:

7.1 Service Providers (Data Processors)

We engage trusted third-party service providers who process personal data on our behalf under strict contractual obligations:

Service Provider Category Purpose Location Safeguards
Web Hosting Website hosting and infrastructure EU/USA GDPR-compliant Data Processing Agreement, standard contractual clauses where applicable
Email Services Business email communications EU/Switzerland ISO 27001 certified, GDPR-compliant processors
IT Support Services Technical maintenance and support UK/EU Confidentiality agreements, limited access

All service providers are carefully selected and required to:

7.2 Legal Requirements

We may disclose your personal data if required by law, regulation, legal process, or governmental request, including to:

7.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the successor entity. We will notify you of any such change and the choices you may have regarding your personal data.

7.4 International Data Transfers

Some service providers may process data outside the UK/EEA (e.g., USA-based hosting infrastructure). Where such transfers occur, we implement appropriate safeguards:

You have the right to request copies of the safeguards in place by contacting leadooltd@proton.me.


8. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:

Security Measures:

Data Breach Notification: In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and inform you without undue delay, as required by Article 33-34 of the GDPR.

While we strive to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security but will take all reasonable steps to protect your information.


9. YOUR DATA PROTECTION RIGHTS

Under the UK GDPR and EU GDPR, you have the following rights regarding your personal data:

9.1 Right of Access (Article 15)

You have the right to request a copy of the personal data we hold about you, along with information about how we use it.

9.2 Right to Rectification (Article 16)

You have the right to request correction of inaccurate or incomplete personal data we hold about you.

9.3 Right to Erasure / "Right to be Forgotten" (Article 17)

You have the right to request deletion of your personal data in certain circumstances, such as:

9.4 Right to Restriction of Processing (Article 18)

You have the right to request restriction of processing your personal data in certain situations, such as when you contest the accuracy of the data or object to processing.

9.5 Right to Data Portability (Article 20)

Where processing is based on consent or contract and carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller.

9.6 Right to Object (Article 21)

You have the right to object to:

9.7 Right to Withdraw Consent (Article 7.3)

Where processing is based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing before the withdrawal.

9.8 Right Not to be Subject to Automated Decision-Making (Article 22)

You have the right not to be subject to decisions based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you.

Note: We do not engage in automated decision-making or profiling.

How to Exercise Your Rights:

To exercise any of these rights, please contact us at:

Email: leadooltd@proton.me
Subject Line: "Data Subject Rights Request"
Include: Your full name, email address, and specific request details

Response Time: We will respond to your request within one month of receipt. In complex cases, we may extend this by a further two months, and we will inform you of the delay and reasons.

Verification: To protect your privacy, we may ask you to verify your identity before processing your request.

No Fee: Exercising your rights is free of charge, unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable administrative fee or refuse the request.

9.9 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority if you believe we have processed your personal data unlawfully or violated your rights:

Ireland Data Protection Commission:

Website: www.dataprotection.ie
Phone: +353 (0)761 104 800
Email: info@dataprotection.ie

UK Information Commissioner's Office (ICO):

Website: www.ico.org.uk
Helpline: 0303 123 1113
Online Reporting: ico.org.uk/make-a-complaint

EU Supervisory Authority:

If you are located in the EU, you may contact your local data protection authority. A list of EU authorities can be found at: edpb.europa.eu

We encourage you to contact us first so we can address your concerns directly.


10. COOKIE POLICY

Our Website uses cookies and similar technologies to enhance your browsing experience and ensure the Website functions properly.

What are Cookies?

Cookies are small text files stored on your device when you visit a website. They help websites remember your preferences and improve functionality.

Cookies We Use:

Cookie Name Type Purpose Duration Legal Basis
PHPSESSID Strictly Necessary Maintains session state for Website functionality Session (deleted when browser closes) Legitimate Interest
cookie_consent Strictly Necessary Remembers your cookie consent preferences 12 months Legal Obligation
wordpress_* Strictly Necessary WordPress technical cookies for site functionality Session / 1 year Legitimate Interest
Important: We do NOT use: All cookies we use are strictly necessary for the Website to function and do not require your consent under PECR Regulation 6(1)(a).

Technical Logs: We maintain server logs (IP addresses, timestamps, pages accessed) for security and troubleshooting purposes. These logs are kept for 12 months and do NOT constitute profiling or tracking cookies.

Managing Cookies:

You can control and manage cookies through your browser settings:

Please note: Disabling strictly necessary cookies may affect Website functionality.


11. THIRD-PARTY WEBSITES

Our Website may contain links to third-party websites for your convenience and information. We are not responsible for the privacy practices or content of these external sites.

When you click on a third-party link, you leave our Website and are subject to that website's privacy policy. We encourage you to read the privacy policies of any third-party websites you visit.

This Privacy Policy applies only to information collected by LEADOO LTD through our Website and services.


12. CHILDREN'S PRIVACY

Our Website and services are intended for business-to-business (B2B) use and are not directed at individuals under the age of 16.

We do not knowingly collect personal data from children under 16. If we become aware that we have inadvertently collected personal data from a child under 16, we will take steps to delete that information as soon as possible.

If you are a parent or guardian and believe your child has provided us with personal data, please contact us at leadooltd@proton.me.


13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational, legal, or regulatory reasons.

When we make material changes to this policy, we will:

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.

Your continued use of our Website and services after any changes constitutes your acceptance of the updated Privacy Policy.


14. CONTACT US

Data Protection Queries:

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us:

LEADOO LTD
Privacy Contact
Email: leadooltd@proton.me
Postal Address: 77 Camden Street Lower, Dublin, Dublin 2, Ireland

Response Time: We aim to respond to all privacy-related inquiries within 5 business days.

Complaints:

If you are not satisfied with our response, you have the right to complain to:

Data Protection Commission (Ireland)
21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
Website: www.dataprotection.ie
Phone: +353 (0)761 104 800

Information Commissioner's Office (ICO) - UK
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Website: www.ico.org.uk
Helpline: 0303 123 1113


15. LEGAL FRAMEWORK

This Privacy Policy is governed by and operates under the following legal frameworks:


16. DEFINITIONS

For the purposes of this Privacy Policy: