1. About us
2. Scope of this Policy
3. Personal Data We Process.
4. How long we store your personal data for
5. Your Rights
6. Cookie Notice
8. Personal Data may be processed outside the European Union
9. Use of site by children
10. Security of personal data
12. Contact details
1. About us
ANG Leads Ltd (a company registered in England and Wales; Company Number 12822756). Our registered office address is 42 Lytton Road, Barnet, United Kingdom, EN5 5BY.
For the purposes of the General Data Protection Regulation (the “GDPR”), ANG Leads Limited is the controller in relation to your personal data. We are registered as a controller with the UK Information Commissioner’s Office (ICO) under reference number ZA782287, organisation name ANG Leads Ltd. Start Date: 24th August 2020, End Date: 23rd August 2021.
2. Scope of this Policy
Our policy complies with the Data Protection Act 2018 and the EU General Data Protection Regulation (GDPR). The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.
3. Personal Data We Process
We may collect, use, store and transfer different kinds of personal data about you. In this policy "personal data" means information that (either in isolation or in combination with other information held by us) enables you to be identified as an individual or recognised directly or indirectly.
The different types of data we may collect are referred to below. We use these terms elsewhere in this policy to cover the type of personal data referred to:
Identity Data includes information such as first name, last name, title, gender and other identifiers that you may have provided.
Contact Data includes information such as your email address, contact numbers, company name, postcode and any other information you have given to us.
Employment Data includes details of your job, your position or job title and where you work (including any self-employed status).
Contractual Data includes details of the existence of (and the terms and conditions applicable to) any contract we have with you.
Technical Data includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website, as well as information about how you use our website, information about which website pages have been viewed or searched, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the website page.
Marketing Data includes your preferences in receiving marketing communications from us.
We may also aggregate Anonymous Data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity, therefore this data falls outside of the scope of this policy.
4. How long we store your personal data 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.
In some circumstances, you can ask us to delete your data. Please see section 9 regarding ‘Your Rights’ for further information.
5. Your Rights
You have the rights set out below with respect to the personal data that we hold about you. To exercise any of these rights, you should contact us by using the contact details set out at the bottom of this policy.
You will not normally have to pay a fee to exercise any of these 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.
We may need to request specific information from you to help us confirm your identity when you seek to exercise any of your rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to help clarify the scope of your request.
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.
Your right to access the personal data we hold about you
You have the right to ask us whether or not we process your personal data and to request information on the purposes of data processing as well as confirmation on whether we use your personal data for these purposes only.
In some circumstances, we may not be able to give you access to the personal data we hold about you (for example, we may not be able to give you access if it would unreasonably affect someone else's privacy or if giving you access poses a serious threat to someone's life, health or safety).
You also have the right to be informed of the third parties to which we transfer your personal data within the scope of this policy.
Your right to have your personal data corrected
You can contact us to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
Your right to erasure of your personal data
You can ask us to delete or remove your personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law.
Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, after you make your request.
Your right to request restriction of the processing of your personal data
You may ask us to suspend the processing of your personal data:
if you want us to establish the accuracy of the personal data;
where our use of the personal data is unlawful but you do not want us to erase it;
where you need us to hold the personal data even if we no longer require it, as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
We will inform you when you decide to lift any such restriction on processing.
Your right to object to us processing your personal data
You have the right to ask us to stop processing your personal data:
for direct marketing;
where the processing is based on legitimate interests and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. We will comply with your right to object in these circumstances, unless:
we can demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms; or
the processing is for the establishment, exercise or defence of legal claims.
Where you no longer wish to be contacted for direct marketing purposes, you can easily unsubscribe from our marketing communications at any time by following the instructions included in those marketing communications.
If you have consented to receive offers or marketing communications directly from any third parties, please note that those third parties (not us) are responsible for taking account of your rights, including your right to opt-out of receiving offers or marketing communications from them.
Where we are relying on your consent to process your personal data, you may withdraw consent at any time, but this will not affect the lawfulness of any processing carried out before you withdraw your consent.
You may withdraw your consent by emailing firstname.lastname@example.org. However, if you do so, you may not be able to use our website or our services further.
Your right to object to automated decision making
You have the right not to be subject to a decision which is based exclusively on automated processing and produces a legal effect or a similarly significant effect on you. In these circumstances, you are entitled to obtain human intervention, express your point of view and obtain an explanation of the decision and challenge it. However, this right does not apply if the automated decision is necessary for entering into or performance of a contract between you and us, is authorised by law or is based on your explicit consent.
Your right to have your personal data transmitted to another organisation
Where we process personal data about you which:
has been provided by you directly to us; and
is processed by automated means; and
is processed with your consent or for the performance of a contract with you,
you have the right to ask us to provide you with the personal data we hold about you in a structured, commonly used and machine-readable format or, where technically feasible, to transmit that data to another organisation.
Making a complaint
You have the right to lodge a complaint to the Information Commissioner's Office, the UK supervisory authority for data protection issues (www.ico.org.uk), if you believe that we have not complied with applicable data protection laws. Information on making a complaint to the ICO can be found at: https://ico.org.uk/make-a-complaint/. You also have a right to claim damages if processing of your personal data violates applicable data protection law.
We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO, so please tell us in the first instance by contacting email@example.com
7. Cookie Notice
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
9. Personal Data may be processed outside the European Union
Usually your personal data will be stored in the United Kingdom. However, some of our external third-party service providers (such as our website and email hosting company) are based outside the European Economic Area (EEA), so your personal data may be transferred to a destination outside of the EEA. This means it may also be stored and processed at a destination outside of the EEA, including by staff operating outside the EEA who work for one of our service providers.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it than applies within the EEA, by ensuring that certain minimum legal safeguards are met or implemented. We take all steps that are mandatory or reasonably necessary to ensure that your personal data is treated securely and in accordance with applicable data protection laws.
Please contact us if you want further information about the circumstances in which we transfer your personal data out of the EEA or the safeguards we use.
10. Use of site by children
We do not sell products or provide services for purchase by anyone under the age of 18. If you are under 18, you must not use our website.
11. Security of personal data
We use administrative, technical, and physical measures to safeguard personal data against loss, theft and unauthorised uses, access or modifications. For example, we use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any personal data you give us. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
Our staff and our third-party service providers are under a duty to process your personal data only in accordance with our instructions and they are subject to a duty of confidentiality regarding your personal data.
Certain areas of our website may be password protected. Where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. We ask you not to share your password(s) with anyone.
We have put in place procedures to deal with any suspected personal data breach. We will notify you and any applicable regulator of any breach where we are legally required to do so.
12. Queries and Complaints
As mentioned above (see section 6), you have a right to lodge a complaint with the Information Commissioner's Office (ICO), but we would appreciate the opportunity to deal with your concerns before you approach the ICO.
Last Updated: 29th October 2020
14. Contact details
If you have any questions about this policy, or if you wish to exercise your rights as referred to in this policy, please contact us by:
writing to our Data Protection Manager:
ANG Leads Limited
42 Lytton Road
emailing our Data Protection Manager at: firstname.lastname@example.org