1. Who we are LEAD WOLF DIGITAL LTD (“Lead Wolf”, “we”, “us”, “our”), company number 12023161, registered at Salix House Waters Edge, Wansford, PE8 6LH, is a marketing agency. We build and host websites, run advertising campaigns, and provide the Lykos CRM to retailers — principally kitchen, bathroom and bedroom businesses.
This policy explains what we do with personal data. It covers two quite different situations, and which one applies changes both your rights and who you should contact. 2. The two roles we act in Where we are the controller. For our own website visitors, enquiries, clients and staff, we decide why and how personal data is used. Sections 3 to 5 and 7 cover this. Where we are a processor. Most personal data we handle belongs to our clients’ customers — people who enquired with a kitchen, bathroom or bedroom retailer. That retailer decides why and how the data is used; we act only on their instructions, under a written contract. Section 6 covers this. If you enquired with a retailer rather than with us, we are almost certainly acting as a processor, and your rights are exercised against that retailer. We will always pass a request on and tell you who to contact — see section 11. 3. Data we collect as controller When you use our website. If you complete a contact or enquiry form, we collect your name, email address, telephone number and anything else you choose to tell us, so that we can respond to you. When you become, or enquire about becoming, a client. Business contact details, correspondence, and the information needed to provide and bill for our services. Automatically when you visit. Device and browser information, IP address, and how you move through the site. Where this involves cookies or similar technologies we ask for your consent first, and you can change or withdraw that consent at any time. See our Cookie Policy. 4. Why we use it, and our lawful basis What we do Lawful basis Respond to your enquiry Legitimate interests — replying to someone who contacted us Provide our services and bill for them Performance of a contract Send marketing about our services Consent, or legitimate interests where you are an existing client Keep our website secure and working Legitimate interests Meet legal, accounting and tax obligations Legal obligation You can opt out of marketing at any time using the unsubscribe link in any email we send, or by emailing [email protected] 5. Who we share it with Suppliers who host our systems, send our email and provide our software — under contract, and only on our instructions. Our professional advisers: accountants, lawyers, insurers. Authorities, where the law requires it. We do not sell personal data, and we do not share it for anyone else’s marketing. Some suppliers process data outside the UK or European Economic Area. Where they do, we rely on UK adequacy regulations or the International Data Transfer Agreement, so that your data keeps an equivalent level of protection. 6. Data we process on behalf of our clients This section applies if you enquired with one of our clients rather than with us. 6.1 What we receive, and where it comes from When you make an enquiry with one of our clients, your details reach the Lykos CRM so that their sales team can respond. We receive them: from a form on the client’s website, which we may have built and may host; from an advertising platform’s own lead form — principally Meta (Facebook and Instagram) Instant Forms, where you submit your details inside the app without visiting a website. We retrieve those enquiries from Meta using their Lead Ads API and place them in the client’s CRM; by telephone or in person, where the client’s own staff record them. The data is typically your name, email address, telephone number, postcode, and whatever you told the client about what you are looking for. It also includes information about how you arrived — for example, which advertisement or campaign you responded to. 6.2 Who controls it The client is the data controller. We are their processor, acting only on documented instructions under a written contract. We do not use your details for our own purposes, do not sell them, and do not share them with our other clients. 6.3 Measuring which advertising works On our clients’ instructions, we tell advertising platforms — currently Meta and Google — when an enquiry went on to become a genuine appointment or sale. This allows the client to stop paying for advertising that produces poor-quality enquiries. Two things are worth being clear about: Identifiers are hashed before they are sent. Email addresses and telephone numbers are converted using a one-way cryptographic function (SHA-256), so the platform can match the record against its own data without ever receiving readable contact details. We do not send the content of your enquiry, and we do not send what you bought or discussed. We respect your cookie choices. Where your enquiry came from a website and you did not consent to advertising cookies, this measurement is not sent. Where your enquiry came from a Meta lead form, the basis is the one shown to you when you submitted your details inside Meta, under Meta’s own Lead Ads terms. You can object to this processing at any time — see section 11. 6.4 How long we keep it We keep client data for as long as the client instructs us to, and we delete or return it when our contract with them ends. Some limits apply regardless: Records of advertising measurement are kept for >>> RETENTION PERIOD — the CRM currently prunes conversion events at 24 months. Diagnostic records of enquiry deliveries contain identifiers only, never your contact details, and are deleted after 90 days. If you ask a client to erase your data, we erase it from the CRM and add a one-way fingerprint of your email address to a suppression list, so that the same details can never be uploaded to an advertising platform again. That fingerprint cannot be reversed to recover your address. 7. How long we keep data where we are the controller We keep personal data only for as long as we need it for the purpose we collected it, plus any period the law requires — for example six years for accounting records. Enquiries that do not become clients are deleted after RETENTION PERIOD For the detail on any particular category, email [email protected] 8. Where data is stored Our systems are hosted in the United Kingdom and the European Economic Area. Some suppliers, including the advertising platforms named above, process data in the United States and elsewhere. Where they do, we rely on UK adequacy regulations or the International Data Transfer Agreement so that protection travels with the data. 9. Security We use encryption in transit and at rest; access controls that limit staff to what their role requires; and separation between clients, so that one client’s data is never visible to another. Credentials for third-party platforms are encrypted, with the keys held separately from the data itself. No transmission over the internet is completely secure, and we cannot guarantee the security of data sent to us before it reaches our systems. 10. Automated decision-making We do not make decisions about you by automated means that produce legal effects concerning you, or that similarly significantly affect you. 11. Your rights You have the right to ask for a copy of your data; to have it corrected; to have it erased; to restrict or object to how it is used; to receive it in a portable format; and to withdraw your consent where consent is the basis we rely on. Where we are the controller — you contacted Lead Wolf directly — email [email protected] and we will respond within one month. Where we are a processor — you enquired with one of our clients — the request is properly made to that client. If you do not know who they are, or would rather come to us, email [email protected]. We will identify the client, pass your request on, and tell you who they are so that you can deal with them directly. You can also complain to the Information Commissioner’s Office at ico.org.uk, although we would rather you raised it with us first so we can put it right. 12. Cookies Our website uses cookies and similar technologies. Non-essential cookies are set only with your consent, which you can change or withdraw at any time. See our Cookie Policy for the detail. 13. Changes to this policy We may update this policy from time to time. The current version is always on this page, with the date it was last changed. Where a change materially affects how we use data we already hold, we will tell those affected. 14. Contact us LEAD WOLF Digital Ltd Salix House, Waters Ege, Wansford [email protected]
