This written notice defines how & why Leedle.co (also referred to as “Leedle.co”, “Humana Group Limited (14135316)”, “we”, “our” & “us”) uses personal data about individual users of our website www.leedle.co (the “Website”) & those that access our services through APIs & through third-parties, including website users, buyers & or professionals (whether prospective, current or past) (together, “you”). Leedle may operate across multiple domains other than www.leedle.co for the purposes of delivering our services. This policy will be displayed on any relevant sites and form part of our global policy across multiple arenas.
Leedle adheres to the Data Protection Act 2018 and any other relevant laws and regulations in the UK.
You should read this written notice so that you understand what we are doing with your personal data.
Our responsibilities in relation to data protection
“Personal data” is information relating to an identifiable natural person. Name, address & contact details are examples of personal data if they identify an individual.
“process” is defined as activity relating to personal data, including collection, storage, transmission and other uses.
Whether you are a buyer, a professional or just a website user (or a combination of those) Leedle.co is a “controller” of your personal data. This means that we make decisions about how & why we process your personal data & are responsible for making sure it is used in accordance with data protection laws.
Where do we get personal data from, and what kinds of personal data do we collect?
If you are reviewing this, you are likely to fall into at least one of the below types of individuals about whom we collect and process personal data:
(a) prospective, current or past customers of Leedle.co who register an account & or place a buyer request (known as a “Leedle” or “Lead”) (“Buyers”);
(b) current or prior persons or businesses that register as a Professional on Leedle.co (or any other site belonging to Humana Group Ltd) to provide a service to Buyers or businesses whom we identify as being of interest to our Buyers & whom we may then contact with potential business opportunities relating to our Buyers (“Professionals”); &/or
(c) individuals that access our Website (“Website Users”).
Accordingly, we will collect & process different types of personal data about you depending on which of these categories are relevant to you. The different types of personal data that we collect & the sources we collect it from are summarised below.
Personal Data Categories
Dependent on the type of use of our Website & services, we will collect different types of personal data about you. For example, this might include your name, contact details, details about your business, our correspondence with you, records of your transactions with us, & how you use our services. We need these details to provide our services to you. We have set out more specific details on the categories of personal data we collect & process on Buyers, Professionals & Website Users here.
We obtain this personal data from a number of different sources. For example, this could be from you, our Website, your business website/s as well as third party sources such as social media. More details of the sources from which we obtain personal data about Buyers, Professionals & Website Users can be found here.
How do we use personal data & why?
We process your personal data for particular purposes, which are relevant to your relationship & engagement with us. We are required by law to always have a “lawful basis” for processing your personal data.
We use the personal data we collect for a number of different reasons, including to provide our services to you or with you, to communicate with you, to verify your identity, to make sure our website & services are functioning properly & provide the best services for you, to keep accurate records & for legal reasons.
We rely on a number of different lawful grounds or ‘bases’ in order to process your personal data. These include that we have your consent to the processing, we need to process your personal data to enter into or perform a contract with you, we need to process your personal data to comply with our legal obligations, & or the processing is necessary for our legitimate interests (or the legitimate interests of a third party).
More details on the purposes for which we process personal data on Buyers, Professionals & Website Users, & the lawful bases we rely on, can be found here.
We may also convert your personal data into statistical or aggregated form to better protect your privacy, or so that you are not identified or identifiable from it. Anonymised data cannot be linked back to you. We may use it to conduct research & analysis, including to produce statistical research & reports. For example, to help us understand & improve the use of our Website.
Who do we share your personal data with & why?
We may use certain trusted third party companies & individuals to help us provide, analyse, & improve our services (including but not limited to Buyer/Professional verification, data storage, maintenance services, database management, web analytics, payment processing, & improvement of our services). These third parties will process your personal data on our behalf (as our processor). We will disclose your personal data to these parties so that they can perform those necessary functions.
We may also share your information with third parties, who then use your personal data for their own purposes. For example, to process payments from you or where you choose to access our services through such an application. These organisations will also use your personal data for their own, separate purposes (also as a “controller”) – they will have their own privacy notices which you should read, & they have their own responsibilities to comply with applicable data protection laws.
In certain circumstances, where necessary for the purposes set out here, we will also disclose your personal data to:
(a) consultants & professional advisors including legal advisors, auditors & accountants;
(b) business partners & joint ventures;
(c) a prospective seller or buyer of our business & their advisors;
(e) courts, court-appointed persons/entities, receivers & liquidators;
(f) third parties where necessary to comply with a legal obligation, to enforce a contract or to protect the rights, property or safety of our employees, customers or others; &
(g) to governmental departments, local government, and statutory & regulatory bodies including (in the UK) the Information Commissioner’s Office, the police & Her Majesty’s Revenue & Customs.
Where is your personal data transferred to?
When we share personal data about you, as set out above, this may include a transfer of your personal data to recipients outside the UK. If any disclosures of personal data mean that your personal data will be transferred outside the European Economic Area, we will only make that transfer in accordance with our obligations under applicable data protection laws.
How long do we keep your personal data for?
We will only retain personal data for a limited period of time & for no longer than reasonably needed for the purposes for which we are processing it for (including as necessary to comply with our legal or regulatory obligations, resolve disputes, & enforce our agreements).
What are your rights in relation to your personal data & how can you exercise them?
You have certain legal rights in relation to any personal data about you that we hold. If you have any concerns or queries about this notice or how we process your personal data please contact us using the details below. Each of these is subject to certain conditions.
More details on your rights can be found here. (Table 4)
We may update this notice from time to time to reflect changes to the type of personal data that we process & or the way in which it is processed. We also encourage you to check this notice on a regular basis.
If you want more information about any of the subjects covered in this privacy notice or if you would like to discuss any issues or concerns with us, you can contact us at firstname.lastname@example.org.
|Types of Personal Data
|Basic contact information & identity information
|Communications we may have with you or other information which you may voluntarily provide, including images, videos or documents you may upload as part of a request
|Your contact/marketing preferences
|Profile and Details
|User names, passwords & other login information
|Activity history & referral data
|Analysis we may undertake on account usage from time to time
|Billing details, including card details & billing address
|Your enquiries and any responses received
|Feedback on your use of Leedle, comments & ratings of Professional/Sellers
|Information about your device, which may include the device's IP address, browser type, browsing history, preferences, identification numbers, your mobile carrier, date & time stamps & other interactions with the service
|Questions raised with us
|Information you provide us when you use our Website
|Your device &/ or the information you give us might tell us your approximate geographical location
|Information to monitor & analyse the use of our services, for example for our service's technical administration, to increase our service's functionality & user-friendliness & to verify users have the authorisation needed to process their requests
|Details about the service(s) you or your employer provide
|Payment records & bank account details
|Analysis we may undertake from time to time
|Account details & activity history
|User names, passwords & other login information
Table 4 - Rights as they pertain to an individual
|What does it mean?
|Limitations and conditions of your right
|Right of Access
|Subject to certain conditions, you are entitled to have access to your personal data (this is more commonly known as submitting a "data subject access request")
|If possible, you should specify the type of information you would like to see to ensure that our is meeting your expectations. We must be able to verify your identity. Your request may not impact the rights & freedoms of other people, e.g. privacy & confidentiality rights of other staff, Buyers, Professionals.
|Right to data portability
|Subject to certain conditions, you are entitled to receive the personal data which you have provided to us & which is processed by us by automated means, in a structured, commonly used machine-readable format.
|If you exercise this right, you should specify the type of information you would like to receive (& where we should send it) where possible to ensure that our disclosure is meeting your expectations. This right only applies if the processing is based on your consent or on our contract with you & when the processing is carried out by automated means. It covers only the personal data that has been provided to us by you.
|Rights in relation to inaccurate personal or incomplete data
|You may challenge the accuracy or completeness of your personal data & have it corrected or completed, as applicable. You have a responsibility to help us to keep your personal information accurate & up to date. We encourage you to notify us of any changes regarding your personal data as soon as they occur, including changes to your contact details.
|Please always check first whether there are any available self-help tools within your profile on our website to correct the personal data we process about you. This right only applies to your own personal data. When exercising this right, please be as specific as possible.
|Right to object to or restrict our data processing
|Subject to certain conditions, you have the right to object to or ask us to restrict the processing of your personal data.
|This right applies where our processing of your personal data is necessary for our legitimate interests. You can also object to our processing of your personal data for direct marketing purposes.
|Right to erasure
|Subject to certain conditions, you are entitled to have your personal data erased (also known as the "right to be forgotten"), e.g. where your personal data is no longer needed for the purposes it was collected for, or where the relevant processing is unlawful.
|We may not be in a position to erase your personal data, if, for example, we may need it to (i) comply with a legal obligation, or (ii) exercise or defend legal claims.
|Right to withdrawal of consent
|As stated above where our processing of your personal data is based on your consent you have the right to withdraw your consent at any time.
|If you withdraw your consent, this will only take effect for future processing.
If you wish to speak to us regarding the enforcement of your rights please speak to us by emailing email@example.com in the first instance. You can also write to us at our registered office.
Our registered office is First Floor, 8 Priory Place, Doncaster DN1 1BL.
You also have the right to lodge a complaint with the Information Commissioner's Office, which is the UK data protection regulator.
More information can be found on the Information Commissioner's Office website at ico.org.uk