Privacy and cookie policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use only the cookies that are strictly necessary for our website to work. If we add cookies that are not strictly necessary, such as analytics or advertising cookies, we will ask for your consent before they are set.

1.4 In this policy, “we”, “us” and “our” refer to iLeads Ltd. For more information about us, see Section 18.

2. The personal data that we collect

2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

2.2 We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, business name, email address, telephone number and website address. The source of the contact data is you.

2.3 We may process the information you give us when you request a campaign review or otherwise enquire about our services (“enquiry data”). The enquiry data may include your trade, how you currently advertise and anything you tell us about your business. The source of the enquiry data is you.

2.4 If you give us access to your Google Ads account, Local Services Ads profile or another advertising account, we may process the personal data held in that account (“account data”). The account data may include the names and email addresses of account users and records of enquiries, calls and messages. The source of the account data is you and the relevant platform. Where account data includes personal data about your own customers, we process it on your behalf, as your processor, under our agreement with you.

2.5 We may process your personal data that are provided in the course of the use of our services and generated by our services in the course of such use (“service data”). The source of the service data is you and/or our services.

2.6 We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer.

2.7 We may process information relating to transactions, including payments for our services, that you enter into with us (“transaction data”). The transaction data may include your contact details, invoice and payment details, and the transaction details.

2.8 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication content and metadata associated with the communication. Our website generates the metadata associated with communications made using the website contact form, including the page the form was sent from and the IP address it was sent from.

2.9 We may process data about your use of our website (“usage data”). The usage data may include your IP address, browser type and version, operating system, referral source and the pages you request. The source of the usage data is the logs kept by our website server. We do not currently use analytics tracking on our website.

2.10 When you use a form on our website, we use Google reCAPTCHA to check that it is being sent by a person and not by an automated program (“spam check data”). The spam check data may include your IP address, information about your browser and device, and how you interact with the page. It is sent to Google, which tells us how likely it is that the form was sent by a person, and we keep that result with your enquiry. The source of the spam check data is your browser and Google.

2.11 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Purposes of processing and legal basis

3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal basis of the processing.

3.2 Operations. We may process your personal data for the purposes of operating our website and providing our services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.

3.3 Enquiries and campaign reviews. We may process contact data, enquiry data, account data and communication data for the purposes of responding to your enquiry and carrying out any campaign review you ask for. The legal basis for this processing is taking steps, at your request, prior to entering into a contract, and our legitimate interests, namely responding to business enquiries.

3.4 Providing our services. If you become a client, we may process contact data, account data, service data and transaction data for the purposes of managing your advertising, reporting to you, invoicing and administering our agreement. The legal basis for this processing is the performance of a contract between you (or your employer) and us, and our legitimate interests, namely the proper administration of our business.

3.5 Relationships and communications. We may process contact data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.

3.6 Direct marketing. We may process contact data and/or customer relationship data for the purposes of sending direct marketing communications, but only where you have agreed to receive them, and you can opt out at any time. Sending us an enquiry does not add you to a marketing list. The legal basis for this processing is consent.

3.7 Research and analysis. We may process usage data and/or service data for the purposes of understanding how our website and services are used and improving them. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business.

3.8 Record keeping. We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

3.9 Security. We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity, including using spam check data to keep automated spam out of our website forms. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

3.10 Insurance and risk management. We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.11 Legal claims. We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.12 Legal compliance and vital interests. We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

4. Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2 Personal data held on our website is stored on the servers of our website hosting provider in the United Kingdom. Enquiries sent through our website are also stored in our customer relationship management system, provided by HighLevel Inc., and sent to our email inbox, provided by our email hosting provider. Spam check data is sent to Google, which provides the reCAPTCHA service (see Section 14).

4.3 If you are a client, personal data in your advertising accounts is also processed by Google under its own terms and privacy policy, as the provider of Google Ads and Local Services Ads.

4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area (EEA).

5.2 We are based in the United Kingdom, and the hosting facilities for our website are situated in the United Kingdom.

5.3 Some of our Sub Processors, including HighLevel Inc. and Google, are based in the United States and may store personal data there. Transfers to those countries are protected by appropriate safeguards required by UK data protection law, such as standard data protection clauses approved by the Information Commissioner, a copy of which can be obtained from ico.org.uk.

5.4 We may engage such other processors (“Sub Processors”) as we consider reasonably appropriate for the processing of your personal data in accordance with the terms of this policy (including but not limited to in connection with support, maintenance and development, staff augmentation and the use of third-party data centres). Any Sub Processors are listed below. By using our services, you are providing us with general written authorisation to add a Sub Processor and/or replace or remove a Sub Processor where we deem necessary, provided that we shall notify you of the appointment of a new Sub Processor and you may, on reasonable grounds, object to the appointment of a Sub Processor by notifying us in writing within 14 days of receipt of our notification (or other such timescale as may be specified on our notification), giving reasons for your objection. The parties shall work together to reach agreement on the engagement of Sub Processors, and, for the avoidance of doubt, we shall not share your personal data with any Sub Processor you have objected to in accordance with this policy. We shall ensure that all Sub Processors are bound by contract with us which includes appropriate data processing terms, and we shall remain liable for Sub Processors’ acts and omissions in connection with this policy.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

1. contact data and enquiry data will be retained for a minimum period of 6 months following the date of the most recent contact between you and us, and for a maximum period of 12 months following that date;
2. account data will be accessed only while we manage the relevant account, and any account data we hold will be retained for a minimum period of 6 months following the end of our agreement, and for a maximum period of 12 months following that date;
3. customer relationship data will be retained for a minimum period of 6 months following the date of termination of the relevant customer relationship, and for a maximum period of 12 months following that date;
4. service data will be retained for a minimum period of 6 months following the date of termination of the relevant contract, and for a maximum period of 12 months following that date;
5. transaction data will be retained for a minimum period of 6 months following the date of the transaction, and for a maximum period of 12 months following that date, except where Section 6.4 applies;
6. communication data will be retained for a minimum period of 6 months following the date of the communication in question, and for a maximum period of 12 months following that date;
7. usage data in our website server logs will be retained for as long as our hosting provider keeps those logs for security and operational purposes, and then deleted.

6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, such as keeping accounting and tax records for the periods the law requires, or in order to protect your vital interests or the vital interests of another natural person.

7. Security of personal data

7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

7.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

7.3 Data relating to your enquiries that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

7.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

7.5 We will never ask you for the password to your Google Ads or other advertising accounts. Access is given through each platform’s own user management, and you can remove it at any time.

8. Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:

1. the right to access: you can ask for copies of your personal data;
2. the right to rectification: you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
3. the right to erasure: you can ask us to erase your personal data;
4. the right to restrict processing: you can ask us to restrict the processing of your personal data;
5. the right to object to processing: you can object to the processing of your personal data;
6. the right to data portability: you can ask that we transfer your personal data to another organisation or to you;
7. the right to complain to a supervisory authority: you can complain about our processing of your personal data;
8. the right to withdraw consent: to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is consent, or that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11 If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In the United Kingdom, that is the Information Commissioner’s Office (ico.org.uk, 0303 123 1113). If you live or work in the European Union, you may also complain to the supervisory authority in the member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13 You may exercise any of your rights in relation to your personal data by written notice to us, including by email to contact@ileads.co.uk.

9. Third party websites

9.1 Our website includes hyperlinks to, and details of, third party websites.

9.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. Personal data of children

10.1 Our website and services are targeted at persons over the age of 18.

10.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11. Updating information

11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

12. About cookies

12.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

12.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

12.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

13. Cookies that we use

13.1 We use cookies only for the following strictly necessary purposes:

1. form recovery: if one of our website forms cannot be sent, we use a session cookie (PHPSESSID) so that the details you typed can be shown to you again. It is deleted when you close your browser;
2. cookie consent: if we add optional cookies in future, we will store your cookie choices in your browser, so that we do not ask you again on every page.

14. Cookies used by our service providers

14.1 We do not currently use analytics or advertising services that set cookies on our website. Our fonts and images are served from our own server.

14.2 Our contact and campaign review pages use Google reCAPTCHA to protect their forms from spam. It loads only once you start filling in a form, and it may set or read cookies and similar storage belonging to Google, such as the _GRECAPTCHA cookie. We treat these as strictly necessary, because they protect the form you are using. Google’s privacy policy explains how Google uses this information.

14.3 If we start to use an analytics or advertising service, such as Google Analytics or Google Ads conversion tracking, we will list it in this Section 14 and ask for your consent before its cookies are set.

15. Managing cookies

15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

1. Chrome;
2. Firefox;
3. Opera;
4. Safari;
5. Edge.

15.2 Blocking all cookies will have a negative impact upon the usability of many websites.

15.3 If you block cookies on our website, it will still work, except that our website forms will not be able to show you your details again if they fail to send.

15.4 If your browser or an extension blocks Google reCAPTCHA, our website forms may not be able to send your enquiry. You can call or email us instead.

16. Cookie preferences

16.1 We do not currently set any optional cookies, so there are no preferences to manage. If we add optional cookies, a cookie banner will let you accept or refuse them before they are set, and you will be able to change your choice at any time.

17. Amendments

17.1 We may update this policy from time to time by publishing a new version on our website.

17.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

17.3 We may notify you of changes to this policy by email.

18. Our details

18.1 This website is owned and operated by iLeads Ltd.

18.2 We are registered in England & Wales under registration number 11106552, and our registered office is at 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.

18.3 You can contact us:

1. by post, to the postal address given above;
2. using our website contact form;
3. by telephone, on 020 3915 5915;
4. by email, to contact@ileads.co.uk.

19. Data protection registration

19.1 We are registered as a data controller with the UK Information Commissioner’s Office.

19.2 Our data protection registration number is ZA774850.

20. Data protection officer

20.1 Our data protection officer’s contact details are: Data Protection Officer, iLeads Ltd, 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.

Version 2.2, November 2026. Replaces version 2.1, October 2026.