PRIVACY POLICY

1.  General

Lead Wolf client name (“we” “us” “our”) are committed to protecting and respecting your privacy. For the purposes of data protection legislation, we are the data controller and we will process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 and national laws which relate to the processing of personal data. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

2. Visitors to our website

2.1. We may collect and process personal data about you in the following circumstances:

2.1.1.  When you complete forms on our website at www.lead-wolf.co.uk ( “Website”). This includes where you complete our ‘Book appointment’, ‘Book a free home measure’ and ‘Request a brochure’, ‘Instant online quote’ forms. We will collect details such as your name, address, email address and telephone number so we can contact you about the services you have requested and respond to your enquiry;

2.1.2. whenever you provide information to us when reporting a problem with our Website, making a complaint, making an enquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence;

2.1.3.  details of your visits to our Website (including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access) to help us build a profile of our users. This data will be aggregated or statistical, which means that we will not be able to identify you individually. For information on our use of Cookies please see section 2.2.2 below; and

2.1.4. whenever you disclose your information to us, or we collect information from you in any other way, through our Website.

2.2.   We may also collect data in the following ways:

2.2.1.  Ip addresses: We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

2.2.2. Cookies: We place a cookie on your machine with an ID that allows us to track how you use our Site now and in the future. We may also join this website behavioural data with other data sources. We use this to help us improve our website, service and marketing efforts. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy   

2.3.   We may use your personal data for our legitimate interests in order to:

2.3.1.  Provide you with information, or services that you requested from us;

2.3.2.  Allow you to participate in interactive features of our Website, when you choose to do so;

2.3.3. Ensure that content from our Website is presented in the most effective manner for you and for your device;

2.3.4. Improve our Website and services

2.3.5. Process and deal with any complaints or enquiries made by you; and

2.3.6. Contact you for marketing purposes where you have signed up for these.

3. Customers

3.1. We will collect details such as your name, address, telephone number and email address when you order goods or services from us in one of our showrooms or over the phone. We will use this information to process your order, comply with our contractual obligations and, where you have set up an online account with us, to help manage your account. We may also collect contact details from you relating to a third party we may contact (with your consent) to discuss an order which you have placed. We may also use your information including your address and the type of product purchased from us to help inform the sale of our products to future customers.

3.2.   In order to perform our contract with you, we may also need to share personal data with third parties such as payment providers, suppliers, postal service or other delivery organisations and installers, in order to assist in the delivery and performance of the goods and services you have ordered.

3.3.   We may also instruct third parties to conduct customer experience surveys on our behalf.

3.4.   We may also publish your feedback on our Website and in other marketing materials (subject to obtaining your prior consent where necessary).

3.5.   We will also use your personal data in the ways described in sections 6, 7 and 9 of this policy.

4. If you fail to provide personal data: Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide the data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with our goods or services). In this case, we may have to cancel the order you have placed with us, and we will notify you if this is the case at that time.

5. Marketing

5.1. In addition to the uses described in sections 2-3 above, where you have purchased our products or services, indicated that you would like to receive marketing correspondence from us, subscribed to our mailing lists or newsletters, entered into any of our competitions or provided us with your details at networking events, we may use your personal data for our legitimate interests in order to provide you with details about our goods and services which we think may be of interest.

5.2.   You have the right to opt-out of receiving marketing correspondence from us at any time. To opt-out of receiving such information you can:

5.2.1.  click the unsubscribe button contained in any marketing email which we send you; or

5.2.2. email us at [email protected] providing us with your name and contact details.

6. Monitoring and recording

6.1. We may monitor and record communications with you (such as telephone communications) for the purpose of quality assurance, training, fraud prevention and compliance.

6.2.  We have CCTV cameras installed in our premises the purpose of crime prevention and for health and safety reasons.

7. Legal basis for processing your personal data

7.1. We will only use your personal data where the law allows us to. Most commonly, we will use your personal data in the following circumstances:

7.2.   for performance of a contract we enter into with you;

7.3.   where necessary for compliance with a legal or regulatory obligation we are subject to; and

7.4.   for our legitimate interests (as described within this policy) (but only if your interests and fundamental rights do not override these interests)

8. Disclosure of personal data to third parties

8.1. As well as set out elsewhere in this policy, we may disclose your information to the following parties, because we have a legitimate interest in doing so:

8.2.   staff members and third-party suppliers in order to facilitate the provision of goods or services to you;

8.3.  IT software providers that host our Website and store data on our behalf;

8.4.  our professional advisers including consultants, legal advisors, bankers and insurers; and

8.5.  HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;

8.6.  We may also disclose personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms and conditions and other agreements; or to protect our rights, property, or safety of our customers, or others.

8.7.   We will not sell or distribute personal data to other organisations

9. Cross-border data transfers

9.1. Our IT software providers and developers may process your personal data to the United States and other jurisdictions outside the European Economic Area (‘EEA’). We will ensure that adequate levels of protection approved by the European Commission are in place for the security of the processing of your personal data outside the EEA.

10. Data Security

10.1. 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 information transmitted to our Website; any transmission is at your own risk.

10.2. Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.

11. Access to, updating, deleting and restricting use of personal data

11.1.   It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes.

11.2.  Data protection legislation gives you the right to object to the processing of your personal data in certain circumstances, and to withdraw your consent to the processing of your personal data where this has been provided, although we may have the right to process your data without your consent in certain circumstances, as set out elsewhere in this policy. You also have the right to access information held about you and for this to be provided in an intelligible form. If you would like a copy of some or all of your personal information, please send an email to our Data Protection Officer at [email protected] . In certain circumstances we reserve the right to charge a reasonable fee to comply with your request.

11.3.  You can also ask us to do the following

11.3.1.update or amend your personal data if you feel this is inaccurate;

11.3.2. remove your personal data from our records entirely;

11.3.3. send you copies of your personal data in a commonly used format, and transfer your information to another entity; or

11.3.4. restrict the use of your personal data.

11.3.5. If you make this type of request we may request specific information from you to help us confirm your identity and verify your request. Data protection legislation may allow or require us to refuse your request. If we refuse your request we will inform you of the reasons why, subject to any legal or regulatory restrictions.

11.3.6. Please send any requests relating to the above in writing to our Data Protection Officer at [email protected] specifying your name and the details of your request.

12. Retention of personal data

12.1.  We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements

12.2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

12.3. Details of retention periods for different aspects of your personal data are available upon request by contacting us on [email protected] 

13. Right to withdraw consent: Where you have provided your consent to the collection, processing and transfer of your personal data, you have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, please contact us at [email protected]  

14. Changes to our privacy policy. We reserve the right to update this privacy policy at any time, and any changes we make to our privacy policy will be posted on this page. We will notify you if there are any changes to this policy that materially affect how we collect, store or process your personal data. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent where required by applicable law or regulation.

15. Contact us: Our Data Protection Officer oversees our compliance with this privacy policy. If you have any questions, comments or requests regarding this policy or how we use your personal data please contact our Data Protection Officer at [email protected] . This is in addition to your right to contact the Information Commissioners Office if you are unsatisfied with our response to any issues you raise. The contact details for the ICO can be found here: ico.org

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