Online Lead Portal is software that reveals the identity of your anonymous website traffic and turns them into actionable leads within a business to business environment. As a leading provider of SaaS solutions, we are committed to providing a high calibre data led solution for all of our clients, as part of that we take data compliance extremely seriously and are pro-active in ensuring the compliance of both the SaaS solutions we provide to our customers as well as ensuring compliance as a business entity in our own right.
The purpose of this statement is to provide information regarding how and why Online Lead Portal collect, process and store data, as well as providing the appropriate contact information should you wish to request the information we hold about you, withdraw from processing or request deletion of any data we hold about you.
Under the EU General Data Protection Regulation (GDPR) there are six lawful basis for processing personal data. These are detailed as follows:
The individual has given clear consent for you to process their personal data for a specific purpose
The processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract
- Legal Obligation
The processing is necessary for you to comply with the law (not including contractual obligations)
- Vital Interests
The processing is necessary to protect someone’s life
- Public Task
The processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law
- Legitimate Interests
The processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
Further information regarding the lawful basis for processing personal data can be found at onlineleadportal.com
Online Lead Portal Marketing and Sales Data
As an organisation that processes business related data, Online Lead Portal has assessed all six grounds for lawful processing of personal data and has selected ‘Legitimate Interests’ as the most suitable lawful ground for the processing of data for the purposes of Online Lead Portal marketing and sales.
Online Lead Portal collects, processes and stores data relating to businesses and decision makers. We believe that the individuals that we process the data of, are likely to have an interest in the Online Lead Portal product. Deemed as ‘Legitimate Interest’ this is based upon specific criteria including the business industry sector, size of organisation as well as the individual’s job function within the organisation. Our typical segmentation includes those within marketing, sales, business development, MD and owner related job functions, although this list is not exhaustive and other variables may apply.
We will only ever collect, process, and store the essential information required for making contact with the data subjects within a business environment. The personal data we collect is limited to:
- First name
- Last name
- Email address
- Social profiles (limited to LinkedIn)
- as well as business IP address.
- Other business-related data may also be processed including business name, job function, turnover and business address, however we will never collect further personal data such as those classed under ‘Sensitive Personal Data’.
The data collected will be used to communicate marketing and sales messages relating to the Online Lead Portal product, based upon the job function held by the data subject. Online Lead Portal specifically only sends messages to those we believe are likely to be interested in the Online Lead Portal product based upon the organisation they are employed by and based upon their job function within that organisation. Messages from Online Lead Portal could be delivered via email, social media, via telephone or any other business to business (B2B) marketing methods that may be relevant.
When you send Online Lead Portal an enquiry or booking form via our website or one of our micro sites you will be asked to provide your contact details. We will use the data you provide to process your request and may use it to inform you by email, telephone or mail about other Online Lead Portal products and services that we feel may be of interest to you, it is deemed that as you have visited the Online Lead Portal website and provided us with your contact information that you are legitimately interested in our products and services. You have the right to object from any method of correspondence at any time, using the unsubscribe button on an email, by informing the telephone operator or by contacting us via any of the methods below.
Screening phone numbers against TPS/CTPS Lists
All phone numbers that are collected are checked against the TPS (Telephone Preference Service) and CTPS (Corporate Telephone Preference Service) lists daily. This will ensure that our team does not contact via telephone any individual or business that has registered their phone number on either of these lists.
How we Procure Data
At Online Lead Portal we procure data in a variety of ways, collected in line with the lawful basis of ‘Legitimate Interests’. If you have received correspondence from us, we will have procured your data in one of the following ways:
- You have requested information from Online Lead Portal on a previous occasion
- Someone has sent us your e-mail address requesting information about our articles and/or services be sent to you
- You or someone else has expressly shared your contact details with us for the purpose of receiving information now and/or in the future
- We have previously met at an event and your business card or contact details were handed to us willingly
- You or a business colleague has visited our website and we believe that there is a genuine legitimate interest in our services
- You have previously connected with a member of our team via LinkedIn and discussed our services
- A member of our team has found your business and your contact details online, believing that your business would genuinely be interested in the Online Lead Portal product, based upon your job function aligning with our typical customer profiles they have made contact to introduce you to our product
- Your data has been purchased by a registered third-party data supplier, which will have been segmented by industry, organisation size and job function based upon our typical customer profiles. (Due diligence checks around GDPR compliance will have been conducted accordingly)
Legitimate Interest Assessment (LIA)
Online Lead Portal has carried out a Legitimate Interest Assessment (LIA) as advised by the ICO. Based upon that assessment it is deemed that the rights and freedoms of the data subjects would not be overridden in our correspondence regarding Online Lead Portal and that in no way would a data subject be caused harm by our correspondence. Based upon our segmentation by organisation and by specific job function, coupled with our processing of personal data within the context of a business environment, we believe that any individual that receives correspondence from Online Lead Portal in a direct marketing or sales capacity, could be legitimately interested in the Online Lead Portal solution. It is also deemed that direct marketing and sales is necessary in the context of promoting Online Lead Portal to professionals in business in order to increase awareness of our SaaS solution in the marketplace.
Per the ICO guidance, Online Lead Portal can confirm:
- We have checked that legitimate interests is the most appropriate basis
- We understand our responsibility to protect the individual’s interests
- We have conducted a Legitimate Interests Assessment (LIA) and kept a record of it, to ensure that we can justify our decision
- We have identified the relevant legitimate interests
- We have checked that the processing is necessary and there is no less intrusive way to achieve the same result
- We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests
- We only use individuals’ data in ways they would reasonably expect
- We are not using people’s data in ways they would find intrusive or which could cause them harm
- We do not process the data of children
- We have considered safeguards to reduce the impact where possible
- We will always ensure there is an opt-out / ability to object
- Our LIA did not identify a significant privacy impact, and therefore we do not require a DPIA
- We keep our LIA under review every six months, and will repeat it if circumstances change
- We include information about our legitimate interests in our privacy notice
Online Lead Portal has an in-house data verification team, who are responsible for ensuring the validity and quality of the data contained within the Online Lead Portal CRM system ‘Cyclone’. The team continually cleanse the data held within the CRM system, completing a full cleanse cycle at least once every 12 months. Any records found to be out of date are placed into a deletion queue which is securely purged four times in a 12-month period.
Data Storage and Retention
The data held within the Online Lead Portal CRM system is processed and stored in the UK within a secure environment.
Online Lead Portal has a continual cycle of cleansing and refreshing data contained with our CRM system; all data is verified at least once in a 12-month cycle. Any invalid records are placed into a deletion queue, which is then securely purged four times in a 12-month period.
In the interest of our employees, customers, and prospective customers, all calls are recorded for training and monitoring purposes. Please see our Call Recording Policy for more information.
Your Rights as a Data Subject
Subject Access Request
If you wish to make a Subject Access Request in order to enact any of your below listed rights, you can do so by:
Or by writing to: Data Compliance, Online Lead Portal, A-23 Connaught Place, New Delhi-110001.
Or by calling: +91-9958455307 and ask to speak with the Data Compliance team. Further proof of identification may be requested in writing to verify your identity before personal data is disclosed.
We will process and respond to your request within 30 days; this service will be free of charge.
Right of access to data held
Under Article 15 of the GDPR, you have a right of access to the personal data we hold on you. If you believe that we are processing your personal data, you can make a Subject Access Request to request the following:
- The purposes of our processing
- The categories of personal data concerned
- The categories of recipient to whom the personal data have been or will be disclosed.
- The envisaged period for which the personal data will be stored.
- The existence of the right to request from the controller rectification or erasure of your personal data, or the restriction of processing of your personal data, or the objection to processing of your personal data.
- The right to lodge a complaint with a supervisory authority.
- Where the personal data was not collected directly from you, any available information as to the source of the data.
- The existence of automated decision-making, including profiling, and any meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
- Information on the appropriate safeguards that have been put in place in the instance that your personal data has been transferred to an international organisation or third country.
- A copy of the personal data that we process (as long as doing so does not adversely affect the rights and freedoms of others)
Right to rectification
Under Article 16 of the GDPR, Online Lead Portal has the obligation to rectify, without undue delay, any inaccurate personal data. If you believe that the personal data we hold on you is inaccurate or incomplete, you can make a Subject Access Request to inform us of this inaccuracy and provide us with the necessary data to correct/complete our data files.
Right to erasure (‘right to be forgotten’)
Under Article 17 of the GDPR, you have the ‘right to be forgotten’. In the event that you make a request for erasure, a minimal amount of your personal data will be kept in our suppression files. This enables Online Lead Portal to fulfil our legal obligation under Article 6(1)(c) of the GDPR to ensure that you are not contacted again.
If you are not added to our suppression file, there is a risk that your data may be processed again in the future if your details are re-added to our software by out data procurement team. Therefore, we will keep a minimal amount of data (where applicable, name, business phone number, business email and/or LinkedIn URL where applicable) in a suppression file with a note to say that you no longer wish to receive communication so that you are not contacted again in the future.
Right to restriction of processing
Under Article 18 of the GDPR you have the right to request that Online Lead Portal does not further process your personal data beyond storing it. This can be a useful alternative to requesting erasure. For example, you can make this request to ensure that your entire data record is kept in our suppression files but will not be processed for sales or marketing purposes.
Right to object
Under Article 21 of GDPR you have the right to object to the processing of your personal data for direct marketing purposes.
In all correspondence with you we will give you the right to object from receiving further correspondence from Online Lead Portal. On any emails you receive from Online Lead Portal there will be the option to ‘unsubscribe’ from receiving any further email correspondence. If you are contacted via LinkedIn, you can reply to the message to request no further correspondence. If you receive a telephone call from us, you have the right to verbally request not to receive any further calls. Online Lead Portal has a companywide CRM system, and your request to object will be logged to ensure that you do not receive any further calls or emails. If you wish to make an objection outside of the abovementioned methods, please make a Subject Access Request.
Your right to lodge a complaint to a supervisory authority
Under Article 77 of the GDPR you have the right to lodge a complaint with a supervisory authority if you believe the processing of your personal data infringes your rights. In the UK, the supervisory authority is the Information Commissioner’s Office (ICO).
Or by calling their helpline on: 0303 123 1113
This policy was last reviewed and updated on the 29th September 2020. Policies are periodically reviewed to ensure compliance with the current compliance environment.
For questions relating to this policy, please contact firstname.lastname@example.org