As leadstations (“The Company”), the protection and security of your personal data are at paramount
important to us.
Therefore, we are constantly reviewing our data processing activities and revising our policies
in accordance with the applicable legislation in our present markets.
(“Websites”) are also reviewed in accordance with General Data Protection Regulation (“GDPR”)
and Californian Consumer Privacy Act (“CCPA”) applies to all Websites, apps, events and to any other
services owned and operated by the Company.
1. Data Processing Principles
a. Information Automatically Collected.
When you access our Websites, we and our possible third party partners automatically record information
from your device and its software, such as your IP address, browser type, Internet service provider,
platform type, the site from which you came and the site to which you are going when you leave our website,
date and time stamp and one or more cookies that may uniquely identify your browser or your account.
When you access our Services using a mobile device, we may also receive or collect identification
numbers associated with your device (such as a unique device ID, IDFA, Google AdID), device type,
model and manufacturer, mobile device operating system brand and model, phone number, email address,
and other apps that you have downloaded ("Technical Data").
b. Location Data.
We do not currently collect your precise geolocation or any latitude or longitude coordinates for you.
Some of the information we collect, for example an IP address, can sometimes be used to approximate a
device’s location. In some cases, we assign the latitude and longitude of the centre of a city or state
on record for you to your profile as a way to improve our analytics and offer best matches for you.
This is a general latitude and longitude and does not correspond to your real time or historical location
c. Information Provided by Others.
We may link or combine the personal data we collect about you and the information we collect automatically.
This allows us to provide you with a personalised experience regardless of how you interact with us.
We may anonymise and aggregate any of the personal data we collect (so that it does not directly identify you).
We may use anonymised information for our business purposes including testing our IT systems, research,
data analysis, improving our services and developing new products and features. We may also share
such anonymised information with others.
Where you do not provide the personal data, we may not be able to provide you the related services; as it may depend on this information.
2. How & What Personal Information We Collect and How We Use:
Personal Information We Collect:
We only collect and process the following categories of data about companies and business professionals;
How and Where We Collect:
- Full Name
- Business Email Address
- Job Title
- Business Phone Numbers (general and direct)
- Business Office Address
- Public Social Link
How and Why We Use:
- Public Information either publicized by you or by a 3rd party that you have authorized
- Directly and indirectly from user activity on our Website
We provide accurate business data to our customer to promote their goods and services using
direct marketing to the right people (decision makers, influencers, champions etc.);
Promoting your business in the web searches,
- Enabling you to interact with features or tools on our platform such as live chat;
- Providing you our existing and new services,
- Improving your user experience and our features;
We will not collect additional categories of personal information or use the personal information
we collected for materially different, unrelated, or incompatible purposes without providing prior
The main reason we use your information is to deliver what we offer and constantly improve our services.
Additionally, we use your information to help keep you safe and to provide you with advertising that
may be of interest to you.
Besides, in line with the aforementioned, we may also use your personal data in the following circumstances:
Where you have given consent for us to use your personal data, for the stated purposes like;
marketing, sales and any sort of informative reasons
Where it is necessary for our legitimate interests (or those of a third party) and your interests
and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligations.
When the public area of the website is used, the user’s automatically anonymised IP address is saved.
As a result of the anonymization, it is impossible to identify the anonymised user and tracking their
movement on the website does not allow for any conclusions to be drawn about a specific user.
3. Withdrawing your Consent or Request of Deletion
4. Marketing Purposes and Newsletter
From time to time we may contact you with relevant information about our services and products.
Most messages we send will be by email. For some messages, we may use personal data we collect about
you to help us determine the most relevant information to share with you.
We only contact you once you will provide us your name-surname and e-mail address, which will be
deemed as explicit consent to subscribe to our Newsletter.
We use the double opt-in process for our newsletter registration. This means that after your
registration we send an email to the email address specified by you; in this email we request
your confirmation that you desire to be sent the newsletter. If you do not confirm your registration
within 24 hours your data is automatically deleted. Furthermore, we also save your used IP addresses
and the times of your registration and confirmation. The purpose of this process is to verify your
registration and to possibly explain any mis-usage of your personal data.
If you do not want to receive Newsletters and other messages from us, you will be able to tell
us by selecting certain boxes on forms we use when we first collect your contact details. You can
change your marketing preferences by clicking on the unsubscribe link at the bottom of our emails
or sending an e-mail to us.
5. Disclosure of Your Information to Other Third Parties only if necessary
We may have to share your personal data with the parties in the needed situations as set out below;
6. International Transfers
The personal data we collect may be transferred to, and processed and stored in, countries outside
of your local jurisdiction. If you are located in the European Union ("EU"), your personal data may
be processed outside of the EU, including, for example, in US or in Turkey; these international
transfers of your personal data are made:
Disclosure to Protect Abuse Victims. We reserve the right, but have no obligation, to disclose
any information that you submit to the Websites, if in our sole opinion, we suspect or have
reason to suspect, that the information involves a party who may be the victim of abuse in any
form. Abuse may include, without limitation, elder abuse, child abuse, spousal abuse, neglect,
or domestic violence. Information may be disclosed to authorities that we, in our sole discretion,
deem appropriate to handle such disclosure. Appropriate authorities may include, without limitation,
law enforcement agencies, child protection agencies, or court officials. You hereby acknowledge
and agree that we are permitted to make such disclosure.
Technology Services Providers, including infrastructure partners (such as AWS), customer support
service providers, analytics service providers, cybersecurity partners, fraud analytics companies,
payment providers, chargeback representation services and similar partners.
- Advertising networks and technology companies that measure advertising performance and attribution.
Third parties, including consultants, who we engage to provide services on our behalf or to
jointly provide services to you, including but not limited to contests and sweepstakes, marketing
outreach and analytics, customer support, safety checks, and payment services (such as Cyber Source).
Social Networks, such as Facebook, where you have given permission to do so or where you have
used your social network account to log-in to the pages of the Company. If you have chosen to
To, in our discretion, (i) satisfy any applicable law, regulation, subpoena/court order, legal
process or other government request, (ii) enforce our Terms of Service, including the investigation
of potential violations thereof, (iii) investigate and defend ourselves against any third party claims
or allegations, (iv) protect against harm to the rights, property or safety of the Company, its
employees or the public as required or permitted by law and (v) detect, prevent or otherwise
address criminal (including fraud or stalking), security or technical issues.
In connection with any company transaction, such as a merger, sale of assets or shares, reorganization,
financing, change of control or acquisition of all or a portion of our business by another company
or third party or in the event of bankruptcy, dissolution, divestiture or any related or similar
We require all third parties to respect the security and privacy of your personal data and to treat
it in accordance with the law. However, we are not responsible for those third parties
to a country or territory ensuring an adequate level of protection for the rights and freedoms
of data subjects in relation to the processing of personal data as determined by the European
pursuant to appropriate safeguards, such as the Standard Contractual Clauses and Corporate Binding Rules,
approved by European Commission Decision C(2010)593 or any subsequent version thereof released
by the European Commission
If you wish to enquire further about these safeguards used, please contact us using the details set
7. Data Security
We have extensive security measures in place to protect the loss, misuse and alteration of the
information stored in our database. These measures include the use of Secure Socket Layer (SSL)
and administrative access to site data as well as other proprietary security measures which are
applied to all repositories and transfers of user information. We will exercise reasonable care in
providing secure transmission of information between your computer and our servers, but given that
no information transmitted over the Internet can be guaranteed 100% secure, we cannot ensure or
warrant the security of any information transmitted to us over the Internet and hence accept no
liability for any unintentional disclosure.
8. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected
it for (as set out above), including for the purpose of satisfying and legal, accounting, or reporting
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.
9. Your Rights under GDPR and under CCPA
You may have certain rights under GDPR in relation to your personal data. You have the rights to:
Request access to your personal data (commonly known as a “data subject access request”).
This enables you to receive a copy of the personal data we hold about you and to check that we
are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may need to verify the
accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove 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 information unlawfully or
where we are required to erase your personal data to comply with local law. 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, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest
(or those of a third party) 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. You also have the right to object where we are processing your personal
data for direct marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend
the processing of your personal data in the following scenarios: (a) if you want us to establish
the accuracy of the personal data; (b) where our use of the data is unlawful but you do not want
us to erase it; (c) where we no longer need the personal data for the purposes set out above,
but we are required by you for the establishment, exercise or defence of legal claims; or (d)
you have objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you,
or a third party you have chosen, your personal data in a structured, commonly used, machine-readable
format. Note that this right only applies to automated information which you initially provided
consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw
your consent. If you withdraw your consent, we may not be able to provide certain features of
the services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of these rights, you can contact us from our Websites.
Your Rights Under CCPA;
The CCPA provides California residents the following specific rights regarding processing their personal information;
Access to Specific Information and Data Portability Rights
As a Californian resident; you have the right to request the following;
Deletion Request Rights:
- The categories of personal information we collected about you
- The categories of sources for the personal information we collected
- Our business or commercial purpose for collecting or selling that personal information,
- The categories of third parties with whom we share that personal information,
- The specific pieces of personal information we collected about you (also called a data portability request).
You have the right to request us to delete any of your personal data that we process have with some exceptions.
Once we receive your valid request, we will delete (and ask from our service providers and customers
to delete as well) your personal information from our systems, unless an exception applies.
We may resist to delete your personal data in the following cases though;
1.Complete the transaction for which we collected the personal information, provide a good or
service that a consumer requested, take actions reasonably anticipated within the context of our
ongoing business relationship with that consumer, or otherwise perform our contract with that consumer.
2.Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity,
or prosecute those responsible for such activities.
3.Debug products to identify and repair errors that impair existing intended functionality.
4.Exercise free speech, ensure the right of another consumer to exercise their free speech rights,
or exercise another right provided for by law.
5.Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6.Engage in public or peer-reviewed scientific, historical, or statistical research in the public
interest that adheres to all other applicable ethics and privacy laws, when the information's deletion
may likely render impossible or seriously impair the research's achievement, if a consumer previously
provided informed consent.
7.Enable solely internal uses that are reasonably aligned with consumer expectations based on a
consumer’s relationship with us.
8.Comply with a legal obligation.
9.Make other internal and lawful uses of that information that are compatible with the context in
which a consumer provided it.
Right to Opt-Out of Sale or Sharing of Personal Information:
According to CCPA, you have the following rights to exercise anytime you wish and therefore we
pledge to comply with the following accordingly;
(a) to direct a business that sells or shares personal information about the consumer to third
parties not to sell or share the consumer’s personal information. This right may be referred to
as the right to opt-out of sale or sharing.
(b) A business that sells consumers’ personal information to, or shares it with, third parties
shall provide notice to consumers, pursuant to subdivision (a) of Section 1798.135, that this
information may be sold or shared and that consumers have the “right to opt-out” of the sale or
sharing of their personal information.
(c) Notwithstanding subdivision (a), a business shall not sell or share the personal information
of consumers if the business has actual knowledge that the consumer is less than 16 years of age,
unless the consumer, in the case of consumers at least 13 years of age and less than 16 years of
age, or the consumer’s parent or guardian, in the case of consumers who are less than 13 years of
age, has affirmatively authorized the sale or sharing of the consumer’s personal information.
A business that willfully disregards the consumer’s age shall be deemed to have had actual
knowledge of the consumer’s age.
(d) A business that has received direction from a consumer not to sell or share the consumer’s
personal information or, in the case of a minor consumer’s personal information has not received
consent to sell or share the minor consumer’s personal information, shall be prohibited, pursuant
to paragraph (4) of subdivision (c) of Section 1798.135, from selling or sharing the consumer’s
personal information after its receipt of the consumer’s direction, unless the consumer subsequently
provides consent, for the sale or sharing of the consumer’s personal information.
10. Cookies and Similar Tracking Technics
11. Links to Third Party Sites
This helps us to provide you with a good experience when you browse the Websites and also
allows us to improve.
A cookie is a small data file that we transfer to your device's hard disk (such as your
computer or smartphone) for record-keeping purposes.
We use the following types of cookies:
Strictly necessary cookies.
These are cookies that are required for the essential operation of the Website such as
These are used to recognise you when you return to the Website. This enables us to
personalise our content for you, greet you by name and remember your preferences
(for example, your choice of language or region).
These cookies record your visit to our website, the pages you have visited and the
links you have followed. We will use this information to make our website and the
advertising displayed on it, and the marketing messages we send to you more relevant
to your interests. We may also share this information with third parties who provide
a service to us for this purpose.
Third party cookies.
Please be aware that advertisers and other third parties may use their own cookies
tags when you click on an advertisement or link on our website. These third parties
are responsible for setting out their own cookie and privacy policies.
The cookies we use are designed to help you get the most from the Service but if you do not
wish to receive cookies, most browsers allow you to change your cookie settings. Please note
Service. These settings will typically be found in the “options” or “preferences” menu of your
browser. In order to understand these settings, the following links may be helpful, otherwise
you should use the “Help” option in your browser for more details.
If you only want to limit third party advertising cookies, you can turn such cookies off by
visiting the following links (please bear in mind that there are many more companies listed
on these sites than those that drop cookies via our website):
- Your Online Choices (http://www.youronlinechoices.com/)
- Network Advertising Initiative (http://www.networkadvertising.org/)
- Digital Advertising Alliance (http://www.aboutads.info/consumers)
If you would like to find out more about cookies and other similar technologies,
please visit www.allaboutcookies.org or the Network Advertising Initiative's online
sources at www.networkadvertising.org.
The Website may, from time to time, contain links to and from third party services. If you follow
a link to any of these services, please note that these services have their own privacy policies
and that we do not accept any responsibility or liability for their policies. Please check the
individual policies before you submit any information to those services.
12. Our Policy Towards Children
The Website is not directed at persons under 18 and we do not knowingly collect personal data
from persons under 18 or from any change that can be deemed as child in your jurisdiction.
13. Changes to This Policy
We evaluate our privacy policies and procedures to implement improvements and refinements from
are posted on this page.
If we need to provide you with information about something, whether for legal, marketing or other
business related purposes, we will select what we believe is the best way to get in contact with
you. We will usually do this through email or by placing a notice on the communication. The fact
that we may send notices to you will not stop you from being able to opt out of certain types of
15. Contact Details