Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Act 1998 (the Act) and the EU General Data Protection Regulation (GDPR), the data controller is First Light Leads Ltd of 56 Leman Street, London, E1 8EU. Our ICO registration number is ZA087659.
Our nominated Data Protection Officer (DPO) is Adam Clark and you may contact our DPO to find out more about the way we treat and use personal data via email at firstname.lastname@example.org.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
IF YOU DO NOT PROVIDE PERSONAL DATA
If we need to process the data you provide us with about yourself to fulfil our service and you fail to provide that data when requested, we may not be able to perform the service, in which case, we may have to cancel a product or service you have with us. We will of course notify you if this is the case at the time.
WHAT INFORMATION DO WE USE?
We will collect and process the following data about you:
Information you give us about you.
This is information about you that you give us by filling in forms on our website that you may access directly or through another website, or by corresponding with us by e-mail or otherwise. It only includes basic personal data required for you to be able to use our site or when you report a problem with our website. The information you give us may include your full name, e-mail address and phone number.
Information we collect about you.
With regard to each of your visits to our website we will automatically collect the following information:
- Technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
Information we receive from other sources.
This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers and search information providers). We will notify you when we receive personal data about you from them and the purposes for which we intend to use that information.
HOW DO WE USE THIS INFORMATION?
We will only use personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data.
Information you give to us.
We will use this information:
- To provide you with the information and services that you request from us;
- To notify you about important changes to our service.
Information we collect about you.
We will use this information:
- To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our website to ensure that content is presented in the most effective manner for you and for your device;
- To allow you to participate in interactive features of our service, when you choose to do so;
- As part of our efforts to keep our website safe and secure.
Information we receive from other sources.
We may receive personal data about you from selected third parties that we work with or that provide us with a service (such as payment services for example) and public sources (such as Companies House for example).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your contact details and technical data that we collect about you, such as your IP address and the way you browse our website to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you requested a quote and in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at email@example.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
REMARKETING AND BEHAVIOURAL TARGETING
We use Google Adwords and Bing Ads to provide targeted adverts to consumers who may wish to use our services. The way it works is that, when you visit our website your web browser automatically sends certain information to Google. This includes the URL of our site and your IP address. Google may also set cookies on your browser or read cookies that are already there.
Google uses the information shared by our site to deliver its services, maintain and improve them, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, and personalise content and ads you see on Google.
To find out more about your options and how to opt out of interest-based advertising and behavioural targeting, you can visit the Network Advertising Initiative website here.
We will get your express opt-in consent before we share your personal data with any external company for marketing purposes.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email us at firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
HOW DO WE SHARE YOUR INFORMATION?
You acknowledge and agree that from time to time we have the right to share your personal information with:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- Selected third parties including:
- Layer 5 Solutions Ltd, (“Layer 5”) based in the UK, to host our website;
- Rocket Science Group, LLC for use of their service, Mailchimp (“Mailchimp”) based in the US, to send you our newsletter, if you consent; and ask you for feedback about our service.
- Google LLC. (“Google”) based in the US, for the storage of documents that include your personal data on Google Drive, to provide more personalised advertising to you as described above in conjunction with Google Adwords, and Google Analytics to monitor use and traffic to our site and find ways to improve it;
- Microsoft Inc. for use of their service, Bing Ads (“Bing”) based in the US, to provide more personalised advertising to you as described above;
- Inspectlet Inc., to record users’ sessions so we can see how you’re using and navigating our site and to improve it;
- Dropbox Inc. (“Dropbox”) based in the US, to store and share documents and digital files;
- Leadspedia Inc., (“Leadspedia”) based in the US, to manage our integration with clients.
- Codeberry Ltd, for the use of their service GetAddress (“Get Address”) based in the UK, to verify your postcode when you provide it to us;
- Data8 Ltd., (“Data8”) based in the UK to verify your telephone number when you provide it to us;
- Briteverify UK Ltd, (“Briteverify”) based in the UK to verify your email address when you provide it to us;
- Liquid New Media Limited for the use of their service Reviews.co.uk (“Reviews”), based in the UK, when you provide us with a review;
- Select business partners, suppliers and sub-contractors.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If First Light Leads Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred 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 Website Terms and Conditions and other agreements; or to protect the rights, property, or safety of First Light Leads Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
WHERE DO WE STORE YOUR INFORMATION?
All personal data we process is processed by our staff and contractors who are based both in the UK and outside the European Economic Area (EEA).
For the purposes of IT hosting and maintenance this information is located on servers within the European Economic Area.
Some of our external third parties such as Google, Rocket Science Group, Inspectlet, Dropbox and Leadspedia are based in US, outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. We also have developers who are based in India who may have access to your personal data as part of their activities for our business.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- If they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Once we have received your information, we have a Data Protection regime in place to oversee the effective and secure processing of your personal data and we will use strict procedures and security features to try to prevent unauthorised access.
However and 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 website at transmission stage; any transmission is at your own risk.
HOW LONG DO WE KEEP YOUR INFORMATION FOR?
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.
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.
We are required under UK tax law to keep basic personal data about our customers (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
In some circumstances you can ask us to delete your data. See below for further information.
WHAT ARE YOUR RIGHTS?
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
EXERCISING YOUR RIGHTS
If you wish to exercise any of your rights set out above, please email us at firstname.lastname@example.org.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.