The following has been drafted to cover both current and post GDPR processing requirements.
Leads2Market Privacy Policy
Leads2Market is committed to protecting and respecting your privacy.
Leads2Market and what we do
Leads2Market are a lead generation company, we generate leads using our network of websites.
We use paid search to generate targeted enquiries for niche insurance products.
Leads generated are transferred in real time.
Every lead is in response to a search enquiry online and is a customer looking for a quote.
Our aim at Leads 2 Market is to connect customers with insurance brokers who deliver the most competitive quotation.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
By visiting our websites you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 2018 (‘DPA’) and European General Data Protection Regulation (‘GDPR’) the data controller is Leads2Market Ltd
94/4 Innovation Building, Kent Science Park, Popjak Road, Sittingbourne Kent. ME9 8HL.
This Privacy Statement explains how we process your information and your rights under both DPA and GDPR.
Information we may collect from you
We may collect and process the following data about you:
Information you give us.
Contact and insurance risk information relating to your insurance requirements from our online form.
Including
- Customer Contact Details, to enable a broker to contact the you and provide a quotation
- Customer Basic Insurance Risk Details, to enable you to be referred to the most applicable broker on the panel
- Customer Driving Conviction Details, to enable you to be referred to the most applicable broker on the panel
Information we collect about you.
We do not collect information outside of that entered on the online form on our website.
Information we receive from other sources.
We do not receive information outside of that entered on the online form on our website.
Uses made of the information
We use information held about you in the following ways:
Information you give to us.
We will use this information, in conjunction with our Insurance Broker panel to provide you with competitive quotes from our FCA authorised partners or one of their designated data processors.
Information we collect about you.
We do not collect information outside of that entered on the online form on our website.
Information we receive from other sources.
We do not receive information outside of that entered on the online form on our website.
Disclosure of your information
We may share your personal information with
One or more of our Panel of Insurance Brokers for the purpose of contacting you by telephone, email or SMS to facilitate your request for an Insurance quotation
Rhubarb Insurance Solutions, for the purpose of contacting you by telephone, email or SMS to confirm your details and transfer you to a broker who will provide you with an Insurance quotation
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with [them or] you, including without limitation any data processor we engage.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site this will be in the form of anonymised data.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Leads2Market, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Marketing
You will not receive Marketing from Lead2Market Limited, you may receive phone calls, texts or emails from one or more of our panel of brokers, or one of their designated data processors, or Rhubarb Insurance Solutions.
Third Party Websites
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
How we comply with data protection law The DPA and GDPR apply to ‘personal data’ we process and the data protection principles set out the main responsibilities we are responsible for.
We must ensure that personal data shall be:
a) processed lawfully, fairly and in a transparent manner;
b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d) accurate and where necessary kept up to date;
e) kept for no longer than is necessary for the purposes for which the personal data are processed.
We operate a data retention policy that ensures we meet this obligation.
We only retain personal data for the purposes for which it was collected and for a reasonable period thereafter where there is a legitimate business need or legal obligation to do so.
We aim to retain data for no longer than 25 months from the date of collection.
For details of our current retention policy contact our privacy officer at [email protected].
f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
We ensure lawful processing of personal data by obtaining consent; or where there is a contractual obligation to do so in providing appropriate products and services; or where processing the data is necessary for the purposes of our legitimate interests in providing appropriate products and services.
In the majority of cases we process personal data based on your contract with the us. In other cases, we process personal data only where there are legitimate grounds for so doing.
To meet our Data Protection obligations, we have established comprehensive and proportionate governance measures.
Your rights under data protection law
Under the DPA and GDPR you have a number of specific rights In respect of your personal data:
1. The right to be informed about how we use personal data.
This Privacy Statement explains who we are; the purposes for which we process personal data and our legitimate interests in so doing; the categories of data we process; third party disclosures; and details of any transfers of personal data outside the UK.
2. The right of access to the personal data we hold. In most cases this will be free of charge
and must be provided within one month of receipt.
To obtain a copy of the personal information we hold on you, please write to us at the address below:
Leads2Market Registered Office: 94/4 Innovation Building, Kent Science Park, Popjak Road, Sittingbourne, Kent. ME9 8HL.
3. The right to rectification where data are inaccurate or incomplete. In such cases we shall make any amendments or additions within one month of your request.
4. The right to erasure of personal data, but only in very specific circumstances, typically where the personal data are no longer necessary in relation to the purpose for which it was originally collected or processed; or, in certain cases where we have relied on consent to process the data, when that consent is withdrawn and there is no other legitimate reason for continuing to process that data; or when the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
5. The right to restrict processing, for example while we are reviewing the accuracy or completeness of data, or deciding on whether any request for erasure is valid. In such cases we shall continue to store the data, but not further process it until such time as we have resolved the issue.
6. The right to data portability which, subject to a number of qualifying conditions, allows individuals to obtain and reuse their personal data for their own purposes across different services.
7. The right to object in cases where processing is based on legitimate interests, where our requirement to process the data is overridden by the rights of the individual concerned; or for the purposes of direct marketing (including profiling); or for processing for purposes of scientific / historical research and statistics, unless this is for necessary for the performance of a public interest task.
8. Rights in relation to automated decision making and profiling.
Please contact our privacy officer at [email protected] for more information about the GDPR and your rights under Data Protection law, or if you have a complaint relating to our processing of your data.
Our supervisory authority for data protection compliance Is the Information Commissioner’s Office (‘ICO’) (www.ico.org.uk):
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Cookies are pieces of information that a website transfers to your computer’s hard disk for record-keeping purposes. Cookies can make the internet more useful by storing information about your preferences on a particular site, such as your personal preference pages.
The use of cookies is an industry standard, and most websites use them to provide useful features for their customers. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer. Most browsers are initially set to accept cookies.
If you would prefer, you can set yours to refuse cookies. However, you may not be able to take full advantage of a website if you do so.
We use the following cookies:
| Cookie description | Purpose |
| Google Analytics | Tracking and Optimising User Experience |
| Bing Universal Tracking | Tracking and Optimising User Experience |
| Facebook Remarketing | Tracking and Optimising User Experience |
Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected].
Last updated: 14/04/20