Privacy Policy

The Bespoke Leads Privacy Notice

What does this Privacy Policy Cover?
We at Bespoke leads are completely transparent in our services with you (consumers, our
clients and our network of publishers) and about how we collect and use your Personal
Data, including visitors to our website www.bespokeleads.com or for any other services
referring to this policy, privacy is very important and so is keeping personal information
confidential.
This information has been produced to help you understand everything you need to know about
the way Bespoke Leads collects, uses, and shares personal data, what your legal rights are and
how to exercise them.
We hope you’ll take some time to read this document; we’ve tried to keep it all as simple as
possible and to avoid jargon, and we’ll make our best efforts to keep you informed if there are
any changes to the way we process your personal data in the future.
Bespoke Leads takes its responsibility for protecting your data very seriously and we do advise
you get to know our practices. If there’s anything here you don’t understand, or if you want to
ask any questions, please feel free to contact us.

 • Who we are.
• What we do.
• Cookies.
• What are “Your Rights” over your Personal Data.
• What Personal Data we collect.
• How we use your Personal Data and why.
• Who we share your Personal Data with.
• How we keep your Personal Data secure.
• How long we store your Personal Data.
• Our policy on children.
• Changes to this policy.
• Third party Links.
• Contact Us.

EU-wide data protection legislation “General Data Protection Regulation” or “GDPR” ,
became active on the May 25th, 2018. This Website Privacy Policy is intended to comply
with our duties of Transparency under the GDPR and all other applicable privacy laws.
Any modifications to our Privacy Policy will be shown on this privacy page.
Who we are.

We are Bespoke Leads. Bespoke Leads is a registered trading name of Tower Bridge
Marketing LTD.
Registered address: 3rd Floor, 86-90 Paul Street, London, EC2A4NE
Registration number: 13629640

In this document Bespoke Leads may be referred to as “we”, “us”, or “our”.
We have appointed a “Data Protection Officer”, this is a person who is responsible for
overseeing and advising us in relation to our compliance with the GDPR and our compliance
with this Privacy Policy. If you want to contact our Data Protection Officer directly, you can
email: [email protected]
 
What we do.
Bespoke Leads are a data processor under the definitions of the GDPR.
We are a bespoke marketing agency that specialises in helping both clients, advertisers, and
publishers across many platforms of marketing for all lead generation / data acquisition
requirements.
Our offerings include campaign design and planning, buying, management, delivery,
optimisation, measurement and analytics for advertisers and agencies. We enable
publishers to use Bespoke Leads as a single point of industry contact to access multiple
campaigns.
 
Cookies.
We do not collect any data or information from your cookies whilst you browse the public
pages of our website or any other Bespoke Leads web property.
 
What are “Your Rights” over your Personal Data.

Under data protection law you have certain rights and access to information with regards to
how we process your data.
Any information requested received by Bespoke Leads will be provided within a month of
receipt of request.
To request any of the following rights, please email us at [email protected] or write
to us at the address provided at the bottom of this privacy page:
Your Individuals Rights as a Data Subject
A: Right to be informed – When we process data, the processing is fair and deemed
necessary in the fulfilment of a contract.  We have ensured our Privacy Policy is up to date
to detail our processing activities and your rights as a consumer.  We aim to help you with
any queries you may have, please use the contact us area to get in touch.
B: Right to access – You own the right to contact us in writing to request details of the data
we have about you. Bespoke Leads is a data processor, our visibility on your personal data
may be limited based on the processing activities we may have undertaken.  We do NOT
own your data, but we retain a digital footprint of the data controller whom we’ve
processed personal data on behalf and will be able to assist any consumer with your right to
access.

C: Right to Rectification – You have the right to ask us to rectify the information held on you
if it’s inaccurate or incorrect. Bespoke Leads will be able to assist in putting you in contact
with the data controllers whom we have processed your information on their behalf, or you
the publishers who holds an account with Bespoke Leads.
D: Right to Erasure – This is also known as “the right to be forgotten”. This gives you right to
request your information to be removed/erased verbally or in writing. We maintain a list of
the people who have asked not to be contacted and ensure that you get no further
marketing from our clients, we will also put you in touch with the originating data controller
to perform the same action.
E: Right to Restrict processing – Where certain conditions apply, you have the right to tell us
to stop processing your data but allowing us to keep enough information about you to
ensure that your wishes are repeated in the future.
F: Right of Portability – This gives you right to ask for your information to be transferred to
another business. It enables you to take advantage of applications and services which you
may wish to use.
G: Right to Object – You have the right to object to the processing of your information for
marketing purposes and profiling for marketing uses. You likewise hold the right to ask us to
cease processing based on a data controllers’ legitimate interest, where there is no
overriding justification for the processing of your information. Your rights and freedoms
override a data controllers’ interests.

H: Rights related to automated decision-making including profiling – We do not use
automated decision-making processes which would cause a potentially damaging effect to
you.
I: Right to withdraw consent at any time – You have the right to withdraw your consent at
any time.  Bespoke Leads is not the generator/originator of any personal data, we are a data
processor, therefore we have no list to remove your consumer information from.  We will
however from our processing activities be able to assist you in contacting the data
controllers to execute your right to withdraw your consent. If you are a publisher, please
refer to the comments based on your rights to de-activate your account.  Please see below
ways in which we can help:
By Email – [email protected]
In Writing – The Compliance Manager/ Data Protection Officer, Bespoke Leads Limited, 3 rd
Floor, 86-90 Paul Street, London, EC2A 4NE.
You can also withdraw your consent for live or automated calls from anyone by registering
your telephone number on the Telephone Preference Service. Details can be found at
www.tpsonline.org.uk

J: Right to lodge a complaint – If we cannot deal with your complaint to your satisfaction,
you have the right to complain to a relevant supervisory authority which include;
 The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF. https://ico.org.uk/make-a-complaint/ Tel: 0303 123 1113
 What Personal Data we collect.
The Personal Data we collect from you is outlined in the table below.
Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR
definition of Personal Data. Essentially, it boils down to information about an individual,
from which that individual is either directly identified or can be identified.
It does not include ‘anonymous data’ (i.e., information where the identity of an individual
has been permanently removed).
However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information
which alone doesn’t identify an individual but, when combined with certain additional and
reasonably accessible information, could be attributed to a particular person).
 
Category of
Personal
Data

What this means How we collect it

collected

Account
Information

First name, last name, email
address, telephone number,
profile picture, passwords and
security protocols of users who
maintain an account for any of
Bespoke Leads services.  (both
publishers and advertisers)

Through your active submission
(either directly through the
platform or indirectly through
Bespoke Leads or your
organisation’s administrator) when
you create an account with
Bespoke Leads.

Consumer
Information

First name, last name, email
address, plus any additional
information you share

If/when you contact us with a
question using our online enquiry
form, we collect your name, email
address and any comments you
have. We use this information
(ONLY) to respond to and/or
resolve your query/question. We
will not share this with third parties
for marketing purposes.

 
How we use your Personal Data and why.
 
Advertisers & Publishers
Purpose Category(ies) of
Personal Data involved

Why do we do
this

Our legal basis for this
use of data

To provide you
with access to
the Bespoke
Leads platform
and tools

Account Information

Using this
data helps us
to provide you
with a
consistent
experience.

We have obtained your
consent in the creation
of a
publisher/advertiser
account with Bespoke
Leads, as well as those
of your organization.
We need to provide
you with access to
administer our
platforms and services
and fulfil our
contractual obligations
to your organisation as
a service provider.

To provide
reporting to
your
organization

Account Information;
Log Records

We use your
Account
Information
and Log
Records to
prepare
reports to
report on your
use of our
services.

Your consent and the
legitimate interests, as
well as those of your
organization. We need
to be able collect
information regarding
your usage of our
services to report back
to your organisation.

Troubleshooting Log Records

We use Log
Records to
track issues
that might be
occurring on
our systems.

Your consent and the
legitimate interests, as
well as those of your
organization. We need
to monitor and ensure
the proper operation of
our systems and
services to administer
our services and fulfil
our contractual
obligations to your
organisation.

To Contact you Account Information

We use your
Account
Information to
contact you
regarding
your account
or our
services,
including to
market our
services to
your
organization.

Your consent and the
legitimate interests, as
well as those of your
organization. We need
to contact your
organisation to
administer our
platform and services,
to fulfil our contractual
obligations, and to
keep your organisation
informed about
additional product and
service offerings.

 
Consumers
Purpose Category(ies) of
Personal Data involved

Why do we
do this

Our legal basis for this
use of data

We process
your data
between data
controllers to
fulfil a contract

Your personal
Information, this could
include, Name, Address,
Date of Birth, Email
address, Telephone
numbers and any other
non-sensitive
information you may
have shared with the
data controllers.

To fulfil a
contract

This could be either
explicit consent where
you have asked to be
contacted by an
advertiser whom
Bespoke Leads processes
data on their behalf or a
publisher whom relies on
legitimate interest about
certain products or
services whom wishes to
share your personal data
with an end advertisers
whom Bespoke Leads
process data on their
behalf.

Who we share your Personal Data with.
 
The table below describes who we share your Personal Data with, what we share and why
we share it.
We endeavour to ensure that people to whom we provide Personal Data hold it subject to
appropriate safeguards and controls. In addition, where relevant, when we share Personal
Data with third parties who are not directly subject to the GDPR, we make sure:
that party is either:
 based in a country that has laws and institutions in place; or
 part of a sector or participates in a framework (e.g., the EU-U.S. Privacy Shield),
 that the European Union considers ensures that your Personal Data will be
adequately protected; or
 adequate safeguards are in place to ensure your Personal Data will be protected in
line with the requirements of the GDPR.
Advertisers & Publishers
 
Recipients Category(ies) of
Personal Data we share.

Why we share this Personal Data

Advertisers &
Publishers

Account Information &
Personal Data

We share in order for decisions to be
made when forming partnerships.
Following the formation of a partnership,
we process personal data between data
controllers and further information related
to campaign performance, necessary to
calculate payments/commissions. This is
made in the form of Publisher ID to remain
anonymous.

Hosting
Provider

Account Information;
Log Records

Our services are hosted by third parties
sub processors. To facilitate our services,
we have to pass data we hold (including
your Personal Data) to our hosting
provider.

Affiliates Account Information;
Log Records

As a group of companies, we rely on
affiliates to provide certain services to us.
All affiliates are required to adhere to the
descriptions and specifications set out in
this Interest

An acquirer or
insolvency
practitioner

Account Information;
Log Records.

We may share Personal Data when we do
a business deal, or negotiate a business
deal, involving the sale or transfer of all or
a part of our business or assets. These
deals can include any merger, financing,
acquisition, or bankruptcy transaction or
proceeding. All counterparties will be
required to keep such information strictly
confidential.

Law
enforcement
agencies and
regulatory
authorities

Account Information;
Log Records.

We may share Personal Data as we believe
necessary or appropriate:
• to comply with applicable laws; and/or
• to comply with lawful requests and legal
process, including to respond to requests
from public and government authorities to
meet national security or law enforcement
requirements.

 
Consumers
Recipients Category(ies) of Why we share this Personal Data

Personal Data we share.

Advertisers

Your Personal
Information, this could
include, Name, Address,
Date of Birth, Email
address, Telephone
numbers and any other
non-sensitive
information you may
have shared with the
data controllers.

To fulfil a contract.  The processing of your
information could be done to either explicit
consent or legitimate interest to facilitate
the safe transfer between an advertiser
and/or publisher that uses the services of
Bespoke Leads Limited.

Third Party
Data
Providers

Your Personal
Information, this could
include your Postal
Address and Telephone
Number that you may
have shared with the
data controllers.

To fulfil a contract. We may share your
Personal Information with third party data
providers who may append additional
information about you or your postal
address to your Personal Information and
return to us for profiling and segmentation
purposes. Bespoke Leads Limited will, under
written instruction from an Advertiser that
uses the services of Bespoke Leads Limited,
profile and segment your Personal
Information which we will then share with
the Advertiser to enable them to determine
and tailor relevant marketing offers and
communications to you.

 
How we keep your Personal Data secure.
We have put in place appropriate security measures and use encryption through technology
to prevent your Personal Data from being accidentally lost, used, or accessed in an
unauthorised way, altered or disclosed.
We limit access to your Personal Data to those employees and other staff who have a
business need to have such access. All such people are subject to a contractual duty of
confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach.
In the event of any such breach, we have systems in place to work with applicable
regulators. In addition, in certain circumstances (e.g., where we are legally required to do
so) we may notify you of this breach.
We ask all advertisers and publishers to create unique passwords and usernames that only
they know. Never share your password and in the event of losing/forgetting these, please
contact your relevant Bespoke Leads contact to reset.

 
How long we store your Personal Data.
We will only retain your Personal Data for so long as we reasonably require it to use it for
the purposes set out above unless a longer retention period is required by law (for example
for regulatory purposes).
The table below shows our standard retention practices:
Category of Personal Data Retention period

Account Information on
Advertisers and Publisher

We keep Account Information for a maximum of
one (1) year from the date on which the
organization account holder closes the applicable
account or terminates its relationship with us.

Personal Information on
Consumers

We retain a copy of all Personal Data processed in
respect of each Customer Campaign for a period of
six months after such Customer Campaign has been
completed (“Retention Period”) to enable us to
respond to any enquiries in respect of such
Customer Campaign; we then delete any Personal
Data held related to any Customer Campaign on
expiry of the Retention Period.

 
Our policy on children.
Our websites, products and services are not intended for use by children under the age of
16. 
Changes to this Privacy Policy.
This Privacy Policy is kept under regular review and changes are published on this page. This
Privacy Policy was last updated on 9 th  August 2022.
 
Third Party Links.
Our website – www.bespokeleads.com or any other Bespoke Leads web property may
contain links to the websites of third parties. If you follow a link to any third-party website,
please note that these websites will have their own privacy policies which we would
encourage you read.

 
Contact Us.
If/when you contact us with a question using our online enquiry form, we collect your name,
email address and any comments you have. We use this information (ONLY) to respond to
and/or resolve your query/question. We will not share this with third parties for marketing
purposes.
Bespoke Leads Ltd, 3rd Floor, 86-90 Paul Street, London, EC2A