Privacy Notice

1. Who is responsible for your information

This notice explains how Lavery Leads collects, uses, shares and protects personal information when someone visits our website, requests a quote, becomes a client, communicates with us or raises a complaint.

The controller for the processing described in this notice is Joe Lavery, a sole trader trading as Lavery Leads, operating in Northern Ireland. Email joe@laveryleads.co.uk, telephone +44 7375 033886.

“Personal information” means information relating to an identified or identifiable person.

2. When this notice applies

This notice applies when Lavery Leads decides why and how personal information is used for its own purposes, including:

• Website visitors
• People who request information or a quote
• Clients and their staff or representatives
• Suppliers and professional contacts
• People who receive permitted business marketing
• People who raise service, privacy or accessibility complaints

When we process a Client’s lead or customer data only on that Client’s instructions, the Client is normally the controller and Lavery Leads is a processor. Section 10 explains that separate role.

3. Information we may collect

Depending on your relationship with us, we may collect:

Contact and identity information

• Name
• Business or trading name
• Job title or role
• Business address
• Email address
• Telephone number
• Social-media or professional profile

Enquiry and commercial information

• Services requested
• Project requirements, budget and timing
• Quote, proposal and package selections
• Contract and acceptance records
• Billing details, invoices and payment status
• VAT or company information where relevant

Our payment provider processes card or bank details. We normally receive transaction identifiers, payment status, card type and limited card information rather than the full card number.

Project and account information

• Website content, brand assets and photographs
• Domain, hosting and platform details
• Account identifiers and permissions
• Support and revision requests
• Approval and handover records
• Advertising budgets, campaign data and reports

Please do not send passwords through ordinary email or contact forms. Use the secure access method we specify.

Communications

• Emails, messages and call notes
• Meeting notes
• Feedback, complaints and outcomes
• Marketing preferences and objections

We will tell you if a call is recorded. We do not record calls by default.

Website and device information

• IP address
• Browser, device and operating-system information
• Pages visited and referring page
• Date, time and approximate location derived from an IP address
• Security logs
• Cookie and consent choices

More detail appears in our Cookie Policy.

Public professional information

Where we conduct proportionate business outreach, we may use business contact information published on a company website, business directory, Companies House, professional platform or social-media business page.

Client lead data

If a service involves handling enquiries or leads for a Client, the data may include a prospect’s name, contact details, requested service, area and message. We process that data under the Client’s instructions and Data Processing Agreement.

Special-category and sensitive information

Our services do not normally require health, biometric, racial or ethnic-origin, political, religious, trade-union, sexual-life, sexual-orientation or criminal-offence data. Do not provide it unless we have specifically agreed a lawful and secure need.

4. Where information comes from

We collect information:

• Directly from you
• From the business or Client you represent
• Through our website and forms
• Through email, telephone, WhatsApp or social media
• From payment and service providers
• From analytics and security tools where permitted
• From public business sources used for proportionate B2B research
• From referrals or professional contacts

If information is obtained from another source, we will provide required privacy information within the applicable period unless an exception applies.

5. Why we use information and our lawful bases

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Where we rely on legitimate interests, we consider the need for the processing, its impact on people and whether a less intrusive method is available. You can object in the circumstances described in section 12.

Where we rely on consent, you may withdraw it at any time. Withdrawal does not make earlier lawful processing unlawful.

6. If you do not provide information

Some information is needed to prepare a quote, enter into a contract, provide the service, verify instructions or meet legal obligations.

If required information is not provided, we may be unable to quote, begin work, take payment, provide support or investigate a request. Optional information and marketing consent are clearly identified as optional.

7. Who we share information with

We share personal information only where reasonably necessary, lawful and proportionate. Recipients may include:

• Website hosting, domain and security providers
• Email, communications and cloud-storage providers
• Customer relationship, project-management and form providers
• Payment processors, banks and accounting providers
• Meta, Google and other advertising or analytics platforms where selected and permitted
• Contractors supporting us under confidentiality and data-protection obligations
• Accountants, insurers, solicitors and other professional advisers
• Regulators, courts, law enforcement or public bodies where required or permitted by law
• A purchaser or successor in a genuine sale or reorganisation of the business, subject to appropriate protection

We do not sell personal information.

We must maintain an accurate internal list of the actual providers used. A Client Data Processing Agreement will identify relevant subprocessors for Client-controlled data.

8. International transfers

Some providers may store or access information outside the United Kingdom.

Where a restricted transfer occurs, we will use an available lawful mechanism, such as:

• UK adequacy regulations
• The UK International Data Transfer Agreement
• The UK Addendum to approved EU Standard Contractual Clauses
• Another safeguard permitted by UK data-protection law

We will also carry out any required transfer assessment and apply additional measures where appropriate. You can contact joe@laveryleads.co.uk for more information about relevant safeguards.

9. How long we keep information

We keep information only for as long as reasonably needed for the stated purpose, legal duties, disputes and security.

Our intended retention periods are:

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We may keep a record longer where reasonably necessary for an active complaint, legal claim, fraud or security investigation. We may delete or anonymise it earlier where it is no longer needed.

10. When we act as a processor

For some lead-generation, website-form or advertising work, Lavery Leads processes personal information on behalf of a Client.

In that situation:

• The Client decides the purpose and lawful basis
• The Client provides privacy information to its prospects and customers
• We act only on documented instructions, subject to legal exceptions
• A Data Processing Agreement governs confidentiality, security, subprocessors, assistance, breaches, audits, international transfers and deletion or return
• Rights requests about Client-controlled data should normally be directed to the Client

If we receive a request relating to Client-controlled data, we will pass it to the relevant Client unless prohibited by law.

11. Security

We use proportionate technical and organisational measures intended to protect information, such as access controls, account permissions, secure providers, backups, software maintenance and multi-factor authentication where available.

No internet, email, cloud or storage system can be guaranteed completely secure. If we become aware of a personal-data breach, we will assess it and notify affected Clients, individuals or the Information Commissioner’s Office where required.

12. Your rights

Depending on the circumstances, you may have rights to:

• Be informed about processing
• Ask for access to your personal information
• Correct inaccurate or incomplete information
• Ask for deletion
• Restrict processing
• Receive certain information in a portable format
• Object to processing based on legitimate interests
• Object at any time to direct marketing
• Withdraw consent
• Ask for safeguards relating to significant solely automated decisions
• Make a data-protection complaint to us
• Complain to the Information Commissioner’s Office

These rights are not absolute and exemptions may apply.

To exercise a right, email joe@laveryleads.co.uk. We may ask for proportionate information to verify identity and authority. We normally respond within one month, subject to lawful extensions.

To stop marketing, use the unsubscribe method in the message or contact us. We will act on direct-marketing objections and retain only the minimum suppression information needed to avoid contacting you again.

13. Data-protection complaints

If you believe we have not handled your personal information properly, you can submit a data-protection complaint:

• Through the complaint form
• By emailing joe@laveryleads.co.uk
• By telephone on +44 7375 033886

Please identify it as a “data protection complaint” and explain what happened, the information concerned and what outcome you seek.

We will:

• Provide a clear and accessible way to complain
• Acknowledge receipt within 30 days
• Take appropriate steps to investigate without undue delay
• Keep you informed where the investigation remains open
• Tell you the outcome without undue delay

You may complain to the Information Commissioner’s Office at any time, although it normally recommends giving the organisation an opportunity to resolve the matter first:

14. Cookies

Our Cookie Policy explains the storage and access technologies used on https://laveryleads.co.uk, their purposes and how to manage choices.

You can change your choices at any time using the “Privacy choices” control in the footer of every page.

15. Children

Our services are intended for business clients and not directed at children. We do not knowingly collect personal information from children through this website. Contact us if you believe a child has provided information inappropriately.

16. Changes to this notice

We may update this notice to reflect changes in our services, providers or law. The current version and date will be published here.

Where a change materially affects how we use existing information, we will provide additional notice where required.

17. Contact