Privacy Policy
10 minutes read
This privacy policy explains how Leadlinks Pixel process personal data in our business as per the General Data Protection Regulation (GDPR) and other relevant data protection and privacy laws applicable to our business.
Your data protection rights
- Access and rectification: you may request a copy of the information we process about you and ask us to rectify any incorrect data.
- Erasure or restriction: in some circumstances, you may ask us to delete or restrict our processing of your data, but we cannot delete any data we are legally required to process.
- Object to processing: in some circumstances, you may ask us to stop processing your data.
- Data portability: in some circumstances, you may ask us to transfer your data to you or another organization.
- Also, if you're unhappy about how we process your data, you have a right to complain to a national data authority. We hope, however, that you will contact us first so that we can try to resolve the matter for you in a satisfactory way.
Please get in touch with us if you have any questions about how we handle your data or want to exercise one of your rights. You are entitled to a reply within 30 days.
How we get your personal data
We typically process personal data on potential or existing customers, website visitors and vendors and collaboration partners. We may process personal data when you:
- Contact/communicate with us online (email, video calls, social media, etc.) or on the phone
- Use our services/software (Leadlinks Pixel)
- Deliver products/services to or enter into a collaboration with us
It is voluntary to provide us with personal data, but we cannot provide you with our services if you choose not to. We do not rent, buy or sell personal data from or to others, use automated decisions or profiling in the processing of your personal data, or process any special category data as per the GDPR Article 9.
Purpose, lawful basis and retention periods
We only process your personal data when we have a purpose and a lawful basis for doing so. Under the GDPR, the lawful bases we rely on are:
- Your consent
- We have a contractual obligation (contract)
- We have a legal obligation
- We have a legitimate interest
As a rule, we do not process personal data for longer than necessary to fulfill the purpose for processing. To comply with this, we have regular internal GDPR audits where we formally assess our data protection and privacy work with the intention to amend, update and, if necessary, delete personal data. We will only retain data for as long as we are required to as per applicable legal obligations such as accounting, tax, labour laws or any other relevant rules and regulations.
Details on the processing of your personal data
This section describes when and how we process your data, for what purposes and our legal grounds to do so (lawful bases). We also specify the retention periods for the processing.
We process personal data when:
You communicate with us
Regardless of your relationship with us, as a potential or existing customer, vendor or other, we process your personal data whenever you communicate with us. This could be when you contact us through email, phone (call, text message) or social media. Depending on where and how you contact us, this may include your name, contact details, IP address and other information you choose to send to us. We use a customer support system to manage personal data on potential and existing customers.
The purpose is to be able to respond to your inquiries and, on some occasions, to keep records in case of complaints or legal claims. The lawful basis is f), where our legitimate interest is to respond to your inquiries and, on some occasions, keep records in case of complaints or legal claims.
We review this data at our regular GDPR audits and delete personal data as appropriate. We typically keep this type of personal data for up to two years or six years if we have a legal obligation in accordance with accounting and bookkeeping rules.
You sign up for a trial
To get access, you need to share your email address and billing address, set a password, select your preferred plan, and enter your payment card details. Your card will be charged at the end of your trial unless you have cancelled your account. We will send you a few emails during your trial. If you don't want to receive these emails, you can easily opt-out at any time by clicking the unsubscribe link in any email.
The purpose of this processing is to give you access to a trial of our service, and the lawful basis is b) contract. We review this data at our regular GDPR audits and delete personal data as appropriate; however, no later than two years after you signed up for the trial.
You become a customer
When you purchase a subscription, we already have the personal data you provided when signing up for a trial. We will also have your order/invoice history. You can add other personal data in your account dashboard, like address, company name and VAT number. If you choose to become an affiliate, we ask for your PayPal email address (note that we do not share any personal data about the referrals you've made). The purpose of this processing is to fulfill our obligation to deliver the services you have purchased and manage the customer relationship. The lawful bases are b) contract and c) legal obligation related to accounting, tax and other business laws we must abide by. We process the data for as long as you are a customer, and we have a legal obligation as per any applicable rules and regulations we are bound by. We are required by law to store business records, including personal data, for as long as someone is a customer and then for at least six years for accounting and bookkeeping purposes.
You receive marketing as an existing customer
If we have an existing customer relationship with you, we may send you emails containing a promotional element (this happens very infrequently). The personal data we process is your name and email address. The purpose is to provide you with news and offers related to your subscription. The lawful basis is f), where our legitimate interest is to offer our relevant products and services. The lawful basis could also be a), where you have given us your consent to such marketing.
You can opt-out of marketing emails at any time by clicking the unsubscribe link in any such email. We process the data for as long as we have a customer relationship with you or if the processing is based on your consent until you withdraw it. When you ask us not to send you any promotional materials, your account will be flagged as "unsubscribed from marketing" in our internal database, and you won't receive any further marketing emails from us. We are still required to process data for accountancy, tax and other business purposes if you are our customer.
You use our website
When you use our website, we briefly process your IP address and user agent, which are considered personal data under the GDPR. Following a significant DDoS (Distributed Denial of Service) attack, we were also forced to start keeping partial access logs. We don't keep track of which pages are viewed, only the time & total requests per IP. The purposes for this processing are a) to protect against cyberattacks such as the DDoS one and b) to analyze our website traffic to optimize and run our business effectively. The lawful basis is f), where our legitimate interests protect our business against cyberattacks and optimize and run our business effectively.
Whom we share your personal data with
To run our business efficiently and securely, we sometimes will have to share your personal data with other (trusted) parties such as:
- Data processors: providers of various services that process your personal data on our behalf
- IT support, when necessary
- Public authorities: when we are obliged to report to them
We require that all such recipients secure data in accordance with good information security and as per the requirements of this Privacy notice. We review and quality assure all vendors and data processors and enter into a data processing agreement/addendum whenever necessary.
We use data processors for:
- Email, calendar and digital meetings
- Accounting/bookkeeping
- This website, including online payments providers
- Transactional emails to customers
- Support ticket system
We don't publish further details (like names) of our data processors to protect our business. If you'd like to know more about our processing and with whom we share your personal data, please get in touch with us.
Information security
We take information security as seriously as privacy, and we will always do our utmost to safeguard your personal data in the best possible way. For example, we use strong passwords, data encryption, two-factor authentication and several other measures to secure our data and prevent unauthorized persons from accessing, altering, deleting, or in any way affecting the data we store, includingyour personal data.
We only allow others to access or process your personal data in accordance with our instructions and only when strictly necessary (e.g. in the unlikely event that we require IT support).
We have created and implemented a dedicated IT security policy for technical and organizational measures and a routine for managing data breaches. Suppose we experience a personal data breach, i.e. a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, and it poses a medium to high risk for the people affected. In that case, we will notify the national data authority within 72 hours. If the risk is deemed high for the people affected, we will inform them directly, if possible.
Our role as a data processor
When you use Leadlinks Pixel on your website, we process data from your website visitors on your behalf. In this case, you are the controller of such data, and we are a data processor of yours. We comply with the requirements as per GDPR, like:
- Only carry our processing on your behalf and as per your instructions
- Use sufficient technical and organizational security measures to protect the data we process on your behalf
- Require our employees to treat your data as confidential
- Govern this processing by a contract (a data processing addendum) [DPA being published publicly soon]
We process minimal personal data on your behalf
We have minimum of personal data being processed to only include the IP address and User-Agent (in line with one of the fundamental principles of the GDPR; Article 5(1)(c)). The IP address and User-Agent are considered personal data under the GDPR, and the lawful basis for processing is usually consent or legitimate interest. Since the IP address is provided by the internet service provider and not by the user's terminal equipment, we do not consider such information to constitute "information stored in the terminal equipment". IP addresses provided in that manner are therefore outside the scope of Article 5 (3), and the consent requirement will not apply under the ePrivacy Directive (Directive 2009/136/EC). In addition, User-Agent is not accessed from terminal equipment, it is sent to us by your browser, and it's impossible for us not to receive it. Note: This may change in the future as browsers move to remove user agent strings. As per the Schrems II ruling, we are currently working out how we process data in the EU. This will be available on our website shortly, and this privacy notice will then reflect this change.
Accessing and Correcting your Personal Data
You have a right to access your personal data and request a correction if you believe it is inaccurate. If you have submitted Personal Information and would like to have access to it, or if you would like to have it corrected, please get in touch with us using the contact information provided below.
How to Contact Us
If you have any questions regarding this Privacy Policy or to access your information, please use this form to get in touch.