Your Privacy Policy Information

Last updated: 2 November 2026

1. Who we are

ClearLeads Consultancy ("we", "us", "our") is a sole trader trading as ClearLeads Consultancy.

We are the "controller" of the personal data described in this policy, meaning we decide how and why it is used.

• Contact for privacy matters: admin@clearleadsconsultancy.co.uk
• ICO registration number

2. What this policy covers

We provide business-to-business client acquisition services, including email and LinkedIn outreach, lead generation and appointment booking. This policy explains how we handle personal data when you:

• receive an email or LinkedIn message from us
• visit our website or contact us
• are a client of ours

3. The personal data we collect

If we contact you as a prospect (business contact)

• Name, job title, business email address, business phone number
• Company name and details about your business
• Your LinkedIn profile URL and publicly visible professional information
• Records of our messages and any replies you send

If you contact us or visit our website

• Name, email address and any details you include in an enquiry or booking
• Technical information such as IP address, browser type and pages viewed (see Cookies, section 11)

If you are our client

• Contact details, billing details and records of the services we provide
• Information you give us to carry out outreach on your behalf (see section 9)

We do not knowingly collect special category data (such as health or political opinions) or data about children.

4. Where we get your data

• From you directly, for example when you complete a form, email us or book a call
• From publicly available sources, such as Companies House, company websites, professional directories and your public LinkedIn profile
• From LinkedIn, where we view or connect with professional profiles in line with LinkedIn's terms
• From our clients, where they ask us to contact their own prospects or contacts (see section 9)

When we contact you using data we did not collect from you directly, we will tell you who we are, where we got your details and why, in our first message or by linking to this policy.

5. Why we use your data and our lawful basis

Purpose

Lawful basis (UK GDPR)

Contacting businesses about our services (B2B marketing by email and LinkedIn)

Legitimate interests – developing our business by offering relevant services to professionals. We have assessed this and balanced it against your rights

Responding to enquiries and booking calls

Legitimate interests, or steps taken at your request before entering a contract

Providing services to clients

Performance of a contract

Keeping accounts and meeting legal obligations

Legal obligation

Keeping a suppression list so we do not contact you again

Legal obligation and legitimate interests

Website analytics and improvement

Consent, where cookies require it; otherwise legitimate interests

Where we rely on legitimate interests, you have the right to object (see section 10).

6. Electronic marketing rules (PECR)

We send marketing emails only to corporate subscribers, such as limited companies and LLPs, or to individuals who have given us consent or where the rules otherwise allow. We screen our lists to exclude sole traders and ordinary partnerships, who are treated as individuals under the Privacy and Electronic Communications Regulations. Every marketing message identifies us clearly and includes a simple way to opt out. We act on opt-out requests promptly.

7. Who we share your data with

We do not sell your personal data. We share it only with service providers who help us run our business, acting on our instructions:

• Google (Gmail / Google Workspace) – to send and receive emails and store related records
• LinkedIn – to send connection requests and messages through the LinkedIn platform
• Website hosting, scheduling and analytics providers: [LIST, e.g. calendar booking tool, website host]
• Professional advisers such as accountants and lawyers, where needed
• Regulators, law enforcement or courts where we are legally required to

If we add further tools (for example a CRM or data provider), we will update this section.

8. International transfers

Google and LinkedIn are US-based companies and may process data outside the UK. Where this happens, we rely on appropriate safeguards, such as the UK Extension to the EU-US Data Privacy Framework, the UK International Data Transfer Agreement or Addendum, or standard contractual clauses, as provided by those companies. You can contact us for more information about these safeguards.

9. Our clients' data

When we run outreach on behalf of a client, we may handle contact details that the client provides or that we source for them. In that case, depending on the arrangement, we act either as a processor on the client's instructions or as a controller in our own right, and our contract with the client sets this out. If you have received a message sent by us on behalf of a client and want to exercise your rights, contact us at admin@clearleadsconsultancy.co.uk and we will deal with it or pass it to the client promptly.

10. Your rights

Under UK data protection law you have the right to:

1. Be informed about how we use your data (this policy)
2. Access the personal data we hold about you
3. Rectify inaccurate or incomplete data
4. Erase your data in certain circumstances
5. Restrict how we use your data in certain circumstances
6. Object to our use of your data, including at any time to direct marketing, which we will always honour
7. Data portability where it applies
8. Withdraw consent where we rely on it

To exercise a right, email admin@clearleadsconsultancy.co.uk. We will respond within one month. You will not usually pay a fee.

To opt out of marketing, reply to any message with "no thanks", or email admin@clearleadsconsultancy.co.uk. We will add you to our suppression list so we do not contact you again. We keep your minimal details (name and email) on that list for this purpose only.

11. Cookies

Our website uses only essential cookies. 

12. How long we keep your data

Data

Retention

Prospect contact data with no engagement

Up to [12] months from first contact, then deleted

Prospects who have replied or engaged

Up to [24] months from last interaction, then reviewed

Opt-out / suppression records

Kept indefinitely so we honour your request

Client and accounting records

[6] years, to meet legal and tax requirements

Website enquiries

[12] months

13. Security

We use appropriate technical and organisational measures to protect personal data, including secure accounts with strong passwords and two-factor authentication, restricted access and encrypted devices. No method of transmission or storage is completely secure, but we take reasonable steps to keep your data safe. If a breach is likely to put your rights at risk, we will report it to the ICO and tell affected individuals as the law requires.

14. Complaints

If you have a concern about how we use your data, please contact us first at admin@clearleadsconsultancy.co.uk so we can try to put it right. You also have the right to complain to the Information Commissioner's Office (ICO):

• Website: ico.org.uk
• Telephone: 0303 123 1113

15. Changes to this policy

We may update this policy from time to time. The latest version will always be on our website, with the date at the top.