WHO WE ARE

Industry Lead Partners provides lead generation, Meta advertising management, sales funnels, CRM integration, AI assisted follow up, appointment booking and reporting services, principally to UK window and door businesses. Industry Lead Partners is operated by Matthew Poole, a sole trader trading as Industry Lead Partners.

In this policy, “we”, “us” and “our” refer to that sole trader. Website: www.industryleadpartners.com. Email for privacy enquiries and complaints: [email protected]. We are the controller for personal information we use to manage our own website, business enquiries, client relationships, billing and business administration. This policy explains our use of that information under UK data protection law, including the UK GDPR and Data Protection Act 2018, as amended. This policy provides information about our practices. Visiting our website or reading this policy does not, by itself, constitute consent to marketing, tracking or international transfers.

HOMEOWNER ENQUIRIES MANAGED FOR OUR CLIENTS

When we operate a campaign or enquiry system solely on the documented instructions of a named window and door business, that business is the controller and we act as its processor. Its privacy notice explains why your information is collected, how it is used and shared, the relevant lawful bases, retention and your rights. The form or landing page should identify that business and link to its notice. In that role, we may handle your name, telephone number, email, postcode or address, project requirements, enquiry answers, communication history, appointment information and contact preferences to deliver the instructed services. We use this information only as authorised under the client’s instructions and applicable law. We do not use processor-held leads for our own unrelated marketing or sell them to other installers. If your enquiry concerns a named installer, you can contact that installer directly about your data. You may also contact us and we will help route the request. Platforms such as Meta may have separate responsibilities for their own processing under their feature-specific terms and privacy notices. Where we determine a separate purpose for collecting or sharing homeowner information ourselves, we will provide additional privacy information identifying our role, purposes, lawful basis and intended recipients before that processing takes place.

INFORMATION WE COLLECT FOR OUR OWN BUSINESS

Depending on your interaction with us, we collect:

• Identity and business contact information, such as your name, business name, role, email, telephone number and business address.

• Enquiry and relationship information, such as service requirements, correspondence, meeting and booking details, proposals and support requests.

• Contract and administration information, such as billing details, invoices, payment status and necessary transaction records. Payment providers may handle payment details under their own arrangements.

• Technical information generated by our website and security systems, such as IP address, browser and device information, access times and relevant security logs.

• Website usage and advertising information collected through enabled analytics or advertising tools, subject to the tracking rules described below.

• Marketing preferences, consent records where applicable, and records of objections or withdrawals. Please do not provide sensitive health information, criminal offence information or other unnecessary personal details in enquiry fields.

WHERE INFORMATION COMES FROM

We receive information directly from you when you submit a form, book a call, communicate with us or purchase our services. We may receive business contact information from your organisation or an authorised representative and technical information from our website and service providers. Where we obtain personal information indirectly, we provide the required privacy information within the applicable legal timeframe, unless a lawful exception applies.

HOW WE USE INFORMATION AND OUR LAWFUL BASES

Handling business enquiries and arranging meetings: we rely on our legitimate interests in responding to people interested in our services. Where you personally request steps before entering a contract with us, contractual necessity may apply instead.

Delivering and administering services: where the contract is with you personally, we rely on contractual necessity for processing objectively needed to perform it. Where you represent a business client, we rely on our legitimate interests in communicating with that business and administering the relationship.

Accounting and required records: we rely on legal obligation where processing is necessary to meet tax, accounting or other statutory duties. Other necessary business administration relies on assessed legitimate interests.

Security, fraud prevention and legal claims: we rely on our legitimate interests in protecting our systems, people and business and establishing or defending legal claims, or legal obligation where a specific duty applies.

Marketing our services: we rely on consent where required, or assessed legitimate interests where legally permitted, together with the applicable electronic marketing rules. Legitimate interests do not override a requirement for consent under PECR.

Website analytics and advertising: we obtain consent for tracking that requires it. Any use of an applicable statutory exception must meet all its conditions, including information and objection requirements where relevant. When relying on legitimate interests, we consider necessity, reasonable expectations and the effect on your rights. You may object as explained below. You are not generally legally obliged to make an enquiry. We identify required form fields; without sufficient contact or service details we may be unable to respond or provide the requested service. Optional marketing choices are not a condition of making an enquiry.

COMMMUNICATIONS AND MARKETING CHOICES

We distinguish responses to your request, appointment arrangements and necessary service communications from ongoing promotional marketing. Requesting information or a quotation does not automatically authorise every type of future marketing. For unsolicited marketing emails or texts to individual subscribers, including sole traders and certain partnerships, we obtain consent unless a legally available exception applies and all its requirements are met. Different rules can apply to corporate subscribers, but we still identify ourselves, provide an opt out and respect objections. You can unsubscribe through the method provided in a message or contact [email protected]. We retain only the information needed to respect your objection and avoid adding you back to marketing lists inadvertently. When we communicate for an installer, its identity, your requested purpose and applicable permissions govern the communication. Marketing preferences are not treated as transferable permission for unrelated businesses.

AI AND AUTOMATED FOLLOW UP

Where enabled, automated workflows or AI assistants may help acknowledge enquiries, organise information, arrange appointments or route messages to a person. For client campaigns, these functions operate under the client’s documented instructions and approved contact rules. You can request human assistance by contacting [email protected]. We do not authorise client lead information to be used to train general AI models for unrelated purposes; provider terms and settings must support this restriction.

COOKIES AND SIMILAR TECHNOLOGIES

Our website may use cookies, pixels, scripts, local storage and similar technologies. Necessary technologies can support functions you request. Advertising tracking, including a Meta Pixel if installed, requires prior consent. Other technologies are assessed against applicable rules and exceptions. Optional tracking requiring consent must remain disabled until you choose to enable it. You can reject optional tracking or change your choices. Browser controls are an additional option, not a substitute for our consent controls.

WHO RECIEVES INFORMATION

We share necessary information with service providers supporting the relevant activity, including website hosting, CRM, email and messaging, booking, automation and AI, payment processing and accounting services. Providers acting as processors must operate under appropriate contractual obligations. We may also disclose information to professional advisers, insurers and public authorities where necessary and lawful. If our business is transferred, limited relevant information may be disclosed to advisers and a prospective or actual successor under suitable safeguards; we will provide required information about any change in controller or use. We do not sell personal information covered by our own business notice or share it with unrelated organisations for their marketing. Any separate intended sharing arrangement requires an appropriate lawful basis and clear information before it occurs.

SECURITY

We use appropriate technical and organisational safeguards proportionate to the information and risks, including restricting access to authorised people and selecting providers with suitable protections. Specific controls must reflect our actual systems and responsibilities. No online system is entirely risk free; this does not remove our legal security obligations.

YOUR DATA PROTECTION RIGHTS

Depending on the processing and applicable conditions, you can request access to your information, correction, erasure, restriction or portability. You may object to processing based on legitimate interests. You have a right to object to direct marketing at any time. Where we rely on consent, you may withdraw it without affecting the lawfulness of earlier processing. Rights are subject to their statutory conditions; deletion is not unconditional. Contact [email protected] to exercise your rights. We may request proportionate information to verify identity. We normally respond within one month, subject to any lawful extension or other applicable timing rules, and explain any refusal or restriction. Requests are normally free; charges or refusal apply only where legally permitted. If we hold your information as an installer’s processor, we forward the request to the relevant controller and assist it as required.

COMPLAINTS

You can complain about our handling of personal information by emailing [email protected]. Explain your concern and the outcome you seek. We will acknowledge your complaint within 30 days, investigate appropriately, keep you informed and communicate the outcome without undue delay. You may also complain to the Information Commissioner’s Office, the UK supervisory authority. Guidance and complaint routes are available at https://ico.org.uk/make-a-complaint/.

CHILDREN

Our agency services are intended for business customers and our homeowner campaigns are intended for adults. We do not intentionally seek children’s personal information. If you believe a child has provided information, contact us so we can assess it and take appropriate action, including involving the relevant installer where applicable.

EXTERNAL WEBSITES AND UPDATES

External websites and platforms have their own privacy notices. Review those notices when using their services. Linking to them does not remove our responsibilities for information we disclose. We may update this policy to reflect changes in our services, processing or legal obligations. The current version will appear on our website with its update date. Where required, we will notify affected people directly and obtain any necessary new consent before making the relevant change. Updating this policy does not itself authorise a new use of information.