Privacy Policy

You have certain rights in relation to your data, including the right to object to processing based on legitimate interests, profiling (including the use of custom and lookalike/similar audiences), and direct marketing. At any time, you can exercise your rights by emailing us at compliance@hotleadslimited.co.uk. For further details about our processing and your rights, please see below.

DISCLAIMER

We maintain commercial relationships with our Service Providers. This means that we may receive payment when we share information that you provide to us via our webforms with our Service Provider(s) in order to allow them to offer you a quote or information for the product or service that you have requested.

CONTENTS

• About our site
• How our site works
• About us
• What we don’t do with your data
• What data we collect, and how
• How we use your data
• Cookies
• Transferring your data
• Storing your data
• Legal grounds
• Your rights
• Contacting us
• Changes to this notice

ABOUT OUR SITE

Our site enables people to request quotes or information for the product or service shown or selected on this site (the “Product”).

The service that our site provides is to connect people who are looking to purchase the Product with relevant providers of the Product (“Service Providers”).

HOW OUR SITE WORKS

If you would like to request and receive quotes or information for the Product (“Quotes”), please complete and submit our webform.

Once we’ve received your request, we’ll connect you with one or more relevant Service Providers. We’ll tell the Service Providers who you are, and your Product requirements, and they’ll then contact you directly with your requested Quotes.

For certain products, before connecting you with relevant Service Providers, we may call you to confirm your details or requirements.

You’ll see on our webform that we have a really clear consent statement. This statement sets out the Service Providers that will contact you.

You can choose which Service Provider to buy from. But you don’t have to buy from any of them. There is no obligation to purchase.

We do not work with any Service Providers until we have a legal contract in place. This is to ensure that they respect your data and rights by keeping your data secure and confidential, limiting their use of your data (i.e. to providing you with the requested Quotes), and not sharing your data with anyone else.

ABOUT US

Hot Leads & Compare Quotes Guru are brands of Hot Leads Limited (“hotleads”, “we”, “us”, “our”) is a company registered in England and Wales (company number: 10767448), whose registered office address is at Unit 34 Capital Business Centre, Carlton Road, South Croydon, England, CR2 0BS.

For the purposes of the General Data Protection Regulation (the “GDPR”), Pawel Laskowski is the controller in relation to your data. We are registered as a controller with the UK Information Commissioner’s Office (ICO) under registration number ZA252743. You can confirm our registration here: www.ico.org.uk

WHAT WE DON’T DO WITH YOUR DATA

Before confirming what data, we collect, and why, here is what we definitely don’t do with your data, unless clearly set out in this notice:

• We don’t share it with anyone else.
• We don’t use it for any purpose (including retargeting, commingling across multiple advertisers’ campaigns or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis, and only to assess the performance and effectiveness of our advertising campaigns.
• We don’t use it to build, append to, edit, influence or augment user profiles, including profiles associated with any mobile device identifier or other unique identifiers that identify any particular user, browser, computer or device.
• We don’t transfer it (including any anonymous, aggregate or derived data) to any advertising network, advert exchange, data broker, or other advertising or monetisation-related service.

WHAT DATA WE COLLECT, AND HOW

If you complete our webform in order to request Quotes, it will ask you for your contact details, such as your name, email address, telephone number, postal address, and/or postal code.

Our webform will also ask for information regarding your product requirements.

From time to time, we change our webforms, and so they may ask you for other information. It will always be clear from the webform what information we’re requesting, and we only request information that is relevant to your request, and the service that we’re providing.

We also store and share Internet Protocol (IP) addresses, as explained below. Every computer or device has an IP address – a unique number – which enables it to communicate with other computers and devices over the Internet.

We may monitor and/or record calls between you and us for the purposes of quality control and staff training. Also, occasionally, we may need to provide Service Providers with limited access to such recordings in order to resolve disputes.

When you visit our site, we will do our best to provide you with the information you are looking for. This will mean that, sometimes, we may ask you for your name and email address (via a pop-up box on our site) so that we are able to send you more information about the products or services that you have shown an interest in. You are not required to submit this information to us and, if you change your mind, you can opt-out at any time by clicking the unsubscribe link in the email.

If you choose to download and use our app, to enhance your experience we may collect some additional information. We do this by using a tracking tool that collects your online identifier, geolocation, device specification, Google advertising ID and other behavioural data relating to the use of our app.

Additionally, we might collect data about you if you:

• Contact us, or we contact you, by email, telephone or post.
• Post comments, material or other content on our site.

HOW WE USE YOUR DATA

We use your data (described above) in the following ways.

To connect you with relevant Service Providers

As explained above, if you submit our webform, we’ll pass your request to one or more relevant Service Providers (named on the consent statement). We will do this in a secure way. For example, using HTTP Secure (HTTPS), which means the data is encrypted. The Service Providers then contact you directly with your quotes. They may contact you by telephone, text/SMS or email.

Before we pass your request to any Service Providers, our service may involve an element of automated decision-making. Our technology platform may automatically assess your Product requirements and pass your request to such Service Providers that would like to receive requests for Quotes at the time your request is made.

We store IP addresses in order to stop unwanted traffic (i.e. spam) to our site. For example, if we become aware that spam is coming from a particular IP address (i.e. computer or location), we can block that IP address. From time to time, we also share IP addresses with Service Providers to enable Service Providers to verify that requests for Quotes have come from a particular country.

To call you to confirm your details or requirements

For certain products, before connecting you with relevant Service Providers, we may call you to confirm your details or requirements.

We may also call you to ask about your experience using our site and service, and dealing with the Service Providers with which we connected you.

To email you about similar products and services – But only if you have not opted out of such emails

If you use our quote request service, then, as an existing user, we would like to email you, or send you text/SMS messages, about similar products and services for which we think you might like quotes or information (“Other Products”).

You will always be given an opportunity to opt-out of such messages before we send them, and we will not send such messages if you have opted out.

To create custom and lookalike/similar audiences

We like to work with Facebook, Google, and other platforms (“Platforms”) to reach out to you with adverts for Other Products. We also like to use Platforms to reach out to other people who might like to use our quote request service.

We do this in two ways. In both cases, your data, along with other data, is used to create a custom audience and/or a lookalike/similar audience. Whenever an audience is shared with a Platform, the data is first hashed and pseudonymised, meaning that any data within the audience that could identify a person is replaced with an artificial identifier. So, the process is secure. Also, we don’t share more data than we need to for the purpose of creating the audience.

• Custom audience – A custom audience is a list of existing users of our service (“Existing Users”). From time to time, we share this with Platforms. As explained above, the data is first hashed and pseudonymised. The Platform uses this audience to show our Existing Users our adverts for Other Products.
• Lookalike/similar audience – A lookalike/similar audience is an audience created by the Platform. From time to time, we share with Platforms a list of Existing Users. The Platform uses this list to find and create lookalikes – i.e. other Platform users who have similar characteristics to the Existing Users – to which it shows our adverts. Again, as explained above, the data is first hashed and pseudonymised.

As we explain below, at any time, you may object to such activity by emailing us at compliance@hotleadslimited.co.uk

Receiving data from Service Providers

From time to time, Service Providers may return data to us. They may do this if they have a query regarding a request for Quotes that we have sent to them in order to enable us to resolve the query. They may also return data to us, together with confirmation on whether a product has been purchased, in order to enable us to improve our marketing. We may also use such data to create custom and lookalike/similar audiences, as explained above.

Working with suppliers

We work with several suppliers, who process data on our behalf. These include cloud storage providers, email service providers, and cloud telephony providers. We have appropriate contracts in place with such suppliers to ensure the protection and confidentiality of data.

COOKIES

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. At the bottom of this policy, we have included a table, setting out what cookies we use, and the purposes for which we use them.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

TRANSFERRING YOUR DATA

Depending on the countries in which you’re looking for Service Providers, we may transfer your data outside the European Economic Area (the “EEA”). For example, if you’re looking for Service Providers in the USA, we may need to transfer your data to the USA.

Some of those countries (e.g. Canada, New Zealand, USA) have a European Commission adequacy decision, which means they are considered to offer an adequate level of data protection.

Other countries do not have the same level of legal protection as countries in the EEA, or with an adequacy decision. If we do transfer your data in this way, we will take steps to ensure that it is protected to the same levels that apply in the EEA. This may include, for example, ensuring that the organisation receiving the data is registered with the EU-US Privacy Shield (in the case of transfers to the USA), or that we use the EU’s model contract clauses.

STORING YOUR DATA

We have a data retention policy, which clearly sets out how long we keep data for, and for what reasons.

We will keep your data only for as long as is necessary to fulfill the purpose/s for which it was collected in the first place, i.e. as set out in this notice.

For example:

• We will keep your request for Quotes for 6 months after you make the request to enable us to resolve any queries from Service Providers, should they arise.
• If you haven’t opted out of receiving marketing from us, we will keep your details, and send you emails, until such time as you don’t engage with our emails for a period of 6 consecutive months.

Following the periods set out above, we will not use the data, save that we will hash/anonymise the same, and retain it for a further 3 years for compliance purposes.

LEGAL GROUNDS

This notice sets out (above) how we use your data. Under the GDPR, controllers must have a valid lawful basis for each processing activity that they undertake. This section sets out our lawful basis for each activity.

*Under the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), we send such emails on the basis of the existing customer (soft opt-in) exemption.

In each case where we have identified legitimate interests as the legal basis for our processing, we have conducted a legitimate interests assessment.

YOUR RIGHTS

If you are located in certain countries, including the European Economic Area and the United Kingdom, you have certain rights under GDPR in relation to your personal data. In relation to our site, and the service that we provide, those rights are set out in the table above. We further explain these rights, and your other rights, below.

Right of access – You have the right at any time to ask us for a copy of the personal information that we hold about you, and to check that we are lawfully processing it.

Right of rectification – If personal information that we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed.

Right of erasure – In certain circumstances, you have the right to request that personal information we hold about you is erased (e.g. if the information is no longer necessary for the purposes for which it was collected or processed).

Right to object to or restrict processing – In certain circumstances, you have the right to object to our processing of your personal information. For example, if we are processing your information on the basis of our legitimate interests, and there are no compelling legitimate grounds for our processing which override your rights and interests.

Right of data portability – In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.

Right to withdraw consent – In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. You can exercise this right by accessing our Preference Centre.

Exercising your rights

As explained above, you can exercise your right to withdraw consent by accessing our preference centre https://preferences.safe-click.net/.

If you wish to exercise any of your other rights under the GDPR, please email us at compliance@hotleadslimited.co.uk. Alternatively, you can write to us at the address set out above, or inform us if you speak with us on the phone.

Our lead supervisory authority for the processing set out in this notice is the UK Information Commissioner’s Office (ICO). If you are unhappy with how we have processed your data, you have the right to make a complaint to the ICO.

If you are based outside of the UK, or you have a complaint concerning our activities outside of the UK, you may prefer to lodge a complaint with a different Supervisory Authority. A list of relevant authorities can be accessed here.

CONTACTING US

If you have any questions regarding this notice, or any questions relating to data protection or privacy, you can contact us at compliance@hotleadslimited.co.uk.

Alternatively, you can write to us at the address set out above.

CHANGES TO THIS NOTICE

From time to time, we may update this notice.