Privacy Policy

LDS SALES GUARATEES LIMITED (LDSSG) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how LDSSG and the LDSSG group of companies (we refer to these as “LDSSG”, “we”, “us”, or “our”) collect, use, and share your personal information in connection with the website and LDS BOOST or any other service or any product or service that links to this Privacy Policy provided by LDSSG (we call these our “Services”).

This Privacy Policy, however, does not apply to:

• The “content” that is distributed within our Services (including with respect to personal information included in such content), although this is addressed in our Information Content Privacy Policy; or
• Any website, application, product, software, service, or content that are offered by third parties or that link to their own privacy policy, privacy policy, or privacy notice.

Importantly, some laws (like UK GDPR) distinguish between a “controller” and a “processor” (or similar terms). We note that we are a “controller” for those Services where we make decisions on how personal information is used in connection with our Services, and we are a “processor” for those Services where we only use personal information as allowed by our customers.

Where we make decisions on how personal information is used in connection with our Services (where we are acting as a controller), we are responsible for the obligations of a “controller” under applicable laws in connection with the processing of personal information – for example, we use this Privacy Policy and other notices to provide you with information about our use of personal information, as required by law.

WHO WE ARE & HOW TO CONTACT US

LDSSG is a company incorporated in England and Wales with company number 09857980 with its registered office at Unit B Lynstock Way, Lostock, Bolton United Kingdom BL6 4SG. In addition, the LDSSG group of companies is made up of numerous legal entities all registered at Unit B Lynstock Way, Lostock, Bolton United Kingdom BL6 4SG.

Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to info@LDSyoursite.com or you can write us as follows:

To LDSSG’s Data Protection Officer:

Data Protection Officer LDS Sales Guarantees Limited
Unit B
Lostock Office Park
Bolton
BL6 4SG

You have a right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these 2

third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

INFORMATION WE COLLECT

The type of personal information we collect depends on how you are specifically interacting with us and which Services you are using. Generally, we collect the following categories of personal information:

• Contact Information, such as name, alias, address, phone number, social media user ID, email address, and similar contact data.
• Organisation and Contacts Information, such as your employer or organisations that you are a member of, information about your colleagues or those within your organisation, your status with an organisation, and similar data.
• Account Information, such as security-related information (including user names and passwords, authentication methods and roles).
• User Content, such as content of communications, suggestions, questions, comments, feedback, and other information you send to us, that you provide to us when you contact us, or that you post on our Services, and similar data.
• Device & Browser Information, such as network and connection information (including Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, user agent, language and time zone settings, and other technical information), advertising identifiers, cookie identifiers and information, and similar data.
• Usage Information and Browsing History, such as usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, backup information, API calls, and other logs), content interactions (including searches, views, downloads, prints, shares, streams, and display or playback details), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page response times, page interaction information (such as scrolling, clicks, and mouse-overs), and download errors), advertising interactions (including when and how you interact with marketing and advertising materials, click rates, next steps you may make after seeing an advertisement, and marketing preferences), and similar data.
• Location Data, such as the location of your device, your household, and similar location data.
• Demographic Information, such as country, preferred language, age and date of birth, marriage status, gender, physical characteristics, personal or household/familial financial status and metrics, military status, and similar data.
• Social Media and Online Content, such as information in social media and online profiles, online posts, and similar data.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to contract on an LDSSG Sales Guarantee). In this case, we may have to cancel a product you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We collect personal information about you either directly from you, through your interactions with our websites or the subscriber providing access to our Services or from other sources (such as publicly available sources) as follows:

You provide personal information to us when you:

• Search for or subscribe to our Services.
• Use our Services or otherwise interact with us.
• Create or maintain a profile or account with us.
• Use, or otherwise interact with content, products, or services from third party providers who have a relationship with us.
• Create, post, or submit user content on our Services.
• Register for or attend one of our events or locations.
• Request or sign up for information.
• Communicate with us by phone, email, chat, in person, or otherwise.
• Complete a questionnaire, survey, support ticket, or other information request form.
• When you express an interest in working with us or apply for a job or position with us.

We collect personal information automatically when you:

• Search for, visit, interact with, or use our Services (including through a device).
• Access or use content from us.
• Open emails or click on links in emails or advertisements from us.
• Otherwise interact or communicate with us (such as when you attend one of our events or locations, when you request support or send us information, or when you mention or post to our social media accounts).

We also collect personal information about you from third parties, such as:

• Others with whom you have a relationship that provide or publish personal information related to you, such as others when they create, post, or submit user content on our Services that may include your personal information.
• Professional or industry organisations and certification / licensure agencies that provide or publish personal information related to you.
• Third parties and affiliates who resell or integrate with our Services.
• Service providers and business partners who work with us in relation to our Services and that we may utilise to deliver certain content, products, or services or to enhance your experience.
• Marketing, sales generation, and recruiting business partners.
• Credit bureaus and other similar agencies.
• Government agencies and others who release or publish public records.
• Other publicly or generally available sources, such as social media sites, public and online websites, open databases, and data in the public domain.

HOW WE USE INFORMATION

This section includes details of the purposes for which we use personal information and the different legal reasons for processing that personal information.

Definitions:

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To Perform the Services. Where the processing is necessary for the performance of the Services.
• Legitimate Interests. Where the processing is necessary for legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information.
• Your Consent. Where you have given us consent to process your personal information for specified purposes, such as to provide our Service and other items requested by you.
• Comply with the Law. Where the processing is necessary for compliance with a legal obligation.

We process your personal information in connection with our Services and for other business purposes, including to:

• Provide, deliver, analyse, and administer our Services (including in connection with the performance of a contract).
• For internal research and development purposes for new content, products, and services, and to improve, test, and enhance the features and functions of our current Services.
• Process transactions related to our Services and administer accounts or profiles related to you or your organisation (including registrations, subscriptions, purchases, billing events, royalty calculations, and payments).
• Personalise and make recommendations related to our Services and other offerings.
• Contact and communicate with you in connection with our Services or other notifications, programs, events, or updates that you may have registered for.
• Send you offers, advertising, and marketing materials, including to provide personalised advertising to you.
• Conduct and communicate with you regarding recruiting and human resources administration.
• Comply with your instructions or to fulfil other, specified purposes for which you have given your consent.
• Detect and prevent fraud and abuse to ensure the security and protection of all customers and others, as well as to identify and authenticate your access to our Service or to identify and authenticate you before we provide you with certain information.
• Exercise our rights and to protect our and others’ rights and/or property, including to take action against those that seek to violate or abuse our Services.
• Comply with the law and our legal obligations, including to respond to a request or order from a court, regulator, or authority, as well as to fulfil our contractual obligations with our customers when they arrange access to our Services for you.
• Effectuate the sale, merger, acquisition, or other disposition of our business (including in connection with any bankruptcy or similar proceedings).

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

We have set out below, in a table format, examples of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate in these examples. Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you	(a) Identity (b) Contact	Performance of the Services
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of the Services (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of the Services (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

SUPPLEMENTAL PRIVACY POLICY FOR CONTENT DISTRIBUTED WITH LDSSG’S SERVICES

This policy supplements LDS Sales Guarantees Limited’s (“LDSSG”) Privacy Policy and further explains how LDSSG distributes and curates this informational content.

LDSSG publishes through its LDS BOOST platform various types of content, such as opinions, analysis, articles and many other types of information, that we believe have value for our subscribers.

LDSSG obtains informational content in a number of ways – sometimes we purchase or license the content from others, sometimes we commission the content ourselves, and sometimes the content is collected from a number of public sources, like public records, journalistic sources, and information in the public domain. Any personal information contained in informational content that is subsequently distributed by LDSSG originates from the original text of the informational content.

In addition to distributing the informational content LDSSG prepares and provides summaries, metadata, or other related information concerning the original content. For example articles might include a headnote, key cite, and other metadata, as well as the full-text article. In many cases, LDSSG prepares the curation of the content. Any personal information contained in the curation is derived from personal information included in the original information content supplied by the source of that content.

Except for clerical/typographical errors and format changes in compliance with editorial house styles and except as directed by source of the original information content, LDSSG does not edit or change the substance of the original information content in most cases.

In many cases, we are not the source of the information content and LDSSG is not obliged to change or delete the substance of the original content including any personal information unless we receive a verified request from the source of the information content, such as, for example, a court order from the court that issued the court case in the first place.

If you have any questions or concerns regarding the substance of any informational content or your personal information as contained in that information content, please contact the source of the informational content and work with them directly to resolve your questions or concerns.

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