This website is owned and operated by LeadStream (Jersey) and is intended for use by consumers in the United Kingdom. We abide by the relevant rules of the General Data Protection Regulation (“GDPR”) and the Data Protection (Jersey) Law 2018.
In relation to regulated products only, and our service in relation to the same, we are an Appointed Representative of LeadStream (UK) Limited. You can view our Financial Conduct Authority (FCA) register entry at: https://register.fca.org.uk
We obtain and process personal data in different ways depending upon the purpose of the processing and way in which we obtained your personal data.
In most circumstances your data will only be processed within the UK or EEA. If for any reason we need to have your data processed elsewhere we will inform you of that, any privacy risks involved and what we have done to minimise those risks.
You can at any time ask us to tell you what personal data relating to you we hold.
You also have the right to ask us to rectify your data if it is inaccurate, erase it or restrict the processing of it, in particular in regards to your right to object to processing under legitimate interests of your data for profiling (including the use of custom, lookalike or similar audiences) and for direct marketing. In some circumstances you can ask us to provide it to you in a format which would allow you to transfer it digitally to another.
Where we have requested, and you have given us consent to process your data you may withdraw that consent at any time.
Were our business to be sold all your data would be transferred to the purchaser so that they could use it in the same way as we do now.
If you are at all concerned about our processing of your data, please let us know by contacting our Data Protection Officer at firstname.lastname@example.org. You may also complain about it to the Office of the Information Commissioner (“ICO”).
Our service enables people to request quotes or information about the products shown on this website. Our service is connecting people who are looking to purchase those products with relevant service providers of those products.
As a customer seeking a quote, we collect certain data from you, depending on the product you enquire about. We will collect this when you submit one of the forms on our website or contact us by telephone to request a quote. This data may include:
Where you ask us to provide you with a quote for your partner too, we will collect details regarding them from you too, including their:
We do not collect any personal information from children, or about children. Some of the information above may come from your spouse or another member of your family.
We also collect data about your visits to our website and the pages that you viewed.
From time to time, the information we request may change. If it does it will be clear what we are requesting, and we only request information relevant to the product you are enquiring about.
Additionally, we might collect data about you if you: Contact us, or we contact you, by email, telephone or post. Post comments, material or other content on our site.
We store IP addresses in order to stop unwanted traffic (i.e. spam) to our site. For example, if we become aware that spam is coming from a particular IP address (i.e. computer or location), we can block that IP address.
Once we receive your request, we will connect you with one or more of our relevant service providers in order to help you find a quote for the product you are looking for. Before we do this, we may call you to confirm your details and/or requirements. Once we pass you to a service provider, they will contact you directly with your quotes. They may contact you by telephone, text or email only about and directly in relation to your enquiry. In relation to equity release enquiries, one of the companies who may contact you are Key Retirement Solutions Limited t/a Key Equity Release, an FCA authorised equity release firm. You do not have to buy anything from any of our providers. There is no obligation to purchase.
We may also call you to ask about your experience using our site and service, and your experience in dealing with the service providers with which we connected you.
We may monitor and/or record these calls for the purposes of quality control and staff training, regulatory compliance, and to resolve disputes. We will never share these call recordings with any third parties.
If you request a quote using our service then as our customer, we would like to email you, or send you text messages, about similar related products and services for which we think you might like quotes or information. Under the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), we send such communications on the basis of the existing customer (soft opt-in) exemption. You will always be given an opportunity to opt out of such messages before we send them, and we will never send such messages if you have opted out: https://homesos.co.uk/unsubscribe/
Profiling, Custom & Lookalike/Similar Audiences
We work with Facebook, Google and other platforms to reach out to you with adverts for similar related products and services we think you might be interested in. We also like to use platforms to reach out to other people who might like to use our service.
We do this in two ways. In both cases, your data, along with other data, is used to create a custom audience and/or a lookalike/similar audience. Whenever an audience is shared with a platform, the data is first hashed and pseudonymised, meaning that any data within the audience that could identify a person is replaced with an artificial identifier, and the process of transferring the data is secure. We don’t share more data than we need to for the purpose of creating the audience.
Custom Audience - A custom audience is a list of existing users of our service. From time to time, we share this with these platforms. As explained above, the data is first hashed and pseudonymised. The platform uses this audience to show our existing users our adverts for our other products and services.
Lookalike/Similar Audience - A lookalike/similar audience is an audience created by the platform. From time to time, we share with platforms a list of existing users. The platform profiles this list to find and create lookalikes - i.e. other platform users who have similar characteristics to the existing users - to which it shows our adverts. Again, as explained above, the data is first hashed and pseudonymised.
If we transfer data to these platforms, we will only do so where the entity we contract with is based within the UK or EEA, and if the platform uses sub-processors, that their sub-processors are in countries that have a European Commission adequacy decision, which means they are considered to offer an adequate level of data protection (e.g. EU-USA Privacy Shield).
At any time, you may object to such activity by opting out:
You can also opt out on Facebook
Receiving Data from Service Providers
From time to time, service providers may return data to us. They may do this if they have a query regarding a request for quotes that we have sent to them in order to enable us to resolve the query. They may also return data to us, together with confirmation on whether or not a product has been purchased, in order to enable us to improve our marketing. We may also use such data to create custom and lookalike/similar audiences, as explained above.
All our digital data is stored and processed in the UK by Leadstream (UK) Ltd and off site by them at a secure “server farm” also in the UK. It may also be shared with other members of our group - Money Marketing Group Limited and Cover Direct Limited. Your data is also shared with those who dispatch direct marketing communications for us.
We have appropriate contracts in place with all suppliers to ensure the protection and confidentiality of data.
We don’t work with any service providers until we have a legal contract in place. This is to ensure that they respect your data and rights by keeping your data secure and confidential, limiting their use of your data (i.e. to providing you with the requested quotes), and not sharing your data with anyone else. If we pass your request onto one or more of our relevant service providers, we will do this in a secure way.
Automated Decision Making
Before we pass your request to any service providers, our service may involve an element of automated decision-making. Our technology platform may automatically assess your product requirements and pass your request to such service providers that would like to receive requests for quotes at the time your request is made.
Your data will be retained in our systems for up to ten years after we obtain it or ten years after we pass you through to a Service Provider, with the exception of call recordings will be kept for a maximum of one month.
We have a legitimate interest in processing your data in the following ways, because you have asked us to do it and it is also necessary to allow us to fulfil our contractual obligations to you.
You have the right to object to processing based on legitimate interests. In each case where we have identified legitimate interests as the legal basis for our processing, we have conducted a legitimate interests assessment.
We only need your consent to process information about your health. We will obtain that consent when you first provide us with that information. You can withdraw it at any time.
We collect information about your computer, including where available your IP address, operating system and browser type using a cookie filer. Cookies help us to improve our website and deliver a better and more personalised service to you. They enable us to personalise your experience on our website, speed up your searches and help us select services or materials for inclusion on the website which may be of interest to you. It also allows us to monitor general traffic patterns and usage of our website to help us to improve our website design and layout. Most browsers accept cookies automatically, but usually you can alter the settings of your browser to prevent automatic acceptance. If you choose not to receive cookies, you may not be able to use certain features of our website.
The information within these cookies is completely anonymous.
If you provide us with information about yourself by form filling on our website a session cookie collects that information and stores it during your browsing session so that if you wish to fill another of our forms, it will be automatically populated. Information stored in that cookie is deleted as soon as you terminate your browsing session.
Leadstream (UK) Ltd, St Andrews House,