Privacy & Cookie Policy

Test and Keep USA Privacy Policy

Effective from 11/30/2022

Leadscale Labs is committed to protecting your personal data and respecting your privacy.

This privacy policy ("Privacy Policy") explains the type of information that Leadscale Labs collects from its website www.testandkeepusa.com (the "Website"), how we will use it and the rights that you have in relation to this information.

By using this Website you accept the terms of this Privacy Policy.

1. ABOUT US

This Website is operated by Leadscale Labs Limited, a company registered in England and Wales (company reg: 04738797) (referred to in this Privacy Policy as "Leadscale Labs", "us" or "we"). Our registered office and main trading address is Unit 1, 6 Owen Street, London EC1V 7JX. Our VAT number is 187730083.

Except as otherwise described in this Privacy Policy, Leadscale Labs is the data controller of the personal information we collect about you from the Website for the purposes of the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and, with effect from 25 May 2018, the General Data Protection Regulation ("GDPR") and any other data protection laws which apply in the United Kingdom from time to time (together, "Data Protection Law").

For any enquiries relating to this Privacy Policy or how we use information collected from this Website, please contact us by writing to us at Unit 1, 6 Owen Street, London EC1V 7JX or by visiting our Help Desk.

2. THE INFORMATION WE COLLECT ABOUT YOU

This section explains how we collect personal information about you, the types of personal information we may collect, how we may use it, who we may share it with and how long we will keep it for:

Personal information you submit to us when you sign up to receive information about freebies, discounts and prizes:

• We will collect your contact details and some basic information about you:We will collect your first and last name, salutation, your email address, your postal address, your mobile phone number and your date of birth.
• We will use your personal information to contact you about the latest freebies, discounts, offers and prizes:When you enter your contact details for this reason and click "register free", you will be consenting to us contacting you by email and / or SMS about the latest freebies, discounts, offers and prizes that we make available on behalf of our partners through the Website. We will only be able to send you emails about the latest freebies, offers, discounts, and prizes if you have provided your consent.
• We will stop using your personal information for this purpose if you withdraw your consent at any time:If you subsequently decide that you do not want to hear from us about the latest freebies, discounts, offers and prizes, you are entitled at any time to withdraw your consent to receiving emails from us. To unsubscribe, please click the "Unsubscribe" link at the bottom of the Website or any email that we have sent to you, log in to your Test and Keep USA account or visit our Help Desk.
• We store personal information collected by us inside and outside the EEA, as may other parties that we may share your personal information with:The personal information that we collect from you may be stored at a destination outside the European Economic Area ("EEA") and may be processed by personnel (who work for us or one of our service providers) operating outside the EEA in countries that the European Commission has not decided offer adequate data protection in accordance with Data Protection Law. Where we pass your personal information to parties located outside of the EEA that do not offer adequate protection, if they are not subscribed to an approved data protection framework that permits us to transfer the personal data to them from the UK, we will enter into agreements which enable us to transfer that personal information to them and that enable you to exercise your rights in accordance with Data Protection Law. In particular:
  • We use email service providers that store the personal information collected by us about our registrants in the United States of America. To ensure that such personal information is provided adequate protection, we have put in place standard contractual clauses approved by the European Commission for transfers from data controllers in the EEA to data processors outside the EEA. A copy of these terms can be obtained by visiting our Help Desk.
  • Our personnel based in India may have access to personal information when they perform technical maintenance and support activities on our information technology systems. To ensure that such personal information is provided adequate protection, we have put in place standard contractual clauses approved by the European Commission for transfers from data controllers in the EEA to data processors outside the EEA. A copy of these terms can be obtained by visiting our Help Desk.
  • For further details about the locations in which our Affiliates may store your personal information, please visit the privacy policy available on their websites.
  • For further details about the locations in which any client of ours may store your personal information (which it will be using as a separate data controller for the purposes of Data Protection Law), please see the information that was provided to you in the data collection notice that you received at the time you registered for a promotion, competition or other service offered by that client, or contact that client directly.

• We will keep a record of the personal information that we receive from you in order to contact you about the latest freebies, discounts, offers and prizes.We will keep our copy of your personal information held for this purpose until 6 months following the last time you engaged with our emails or, if earlier, until you have contacted us to ask for the processing of your personal information for this purpose to be stopped (in which case we will retain a record of your request in order to ensure that we comply with your wishes).

PERSONAL INFORMATION YOU SUBMIT TO US WHEN YOU REGISTER TO ENTER A PRIZE DRAW:

• We will collect your contact details and some basic information about you:We will collect your first and last name, salutation, your email address, your postal address, your mobile phone number and your date of birth.

• We will use your personal information to enter you into the prize draw:When you submit your contact details to enter into the prize draw, we will use them to enter you into the prize draw and to contact you about the prize draw (for example, if you win a prize).

• We will use your personal information to contact you about the latest freebies, offers, discounts and prizes:When you submit your contact details to enter the prize draw, you will also be able to choose to consent to us contacting you by email or SMS about the latest freebies, offers, discounts, and prizes that we make available on behalf of our partners through the Website. We will only be able to send you emails about the latest freebies, offers, discounts, and prizes if you have provided your consent. We will seek your consent through the use of tick boxes or similar methods.

• We will stop using your personal information for this purpose if you withdraw your consent at any time:If you subsequently decide that you do not want to hear from us about the latest freebies, discounts and prizes, you are entitled at any time to withdraw your consent to receiving emails from us. To unsubscribe, please click the "Unsubscribe" link at the bottom of the Website or any email that we have sent to you, log in to your Test and Keep USA account or visit our Help Desk.

• We store personal information collected by us inside and outside the EEA, as may other parties that we may share your personal information with:The personal information that we collect from you may be stored at a destination outside the EEA and may be processed by personnel (who work for us or one of our service providers) operating outside the EEA in countries that the European Commission has not decided offer adequate data protection in accordance with Data Protection Law. Where we pass your personal information to parties located outside of the EEA that do not offer adequate protection, if they are not subscribed to an approved data protection framework, we will enter into agreements which enable us to transfer that personal information to them and that enable you to exercise your rights in accordance with Data Protection Law. In particular:
  • We use email service providers that store the personal information collected by us about our registrants in the United States of America. To ensure that such personal information is provided adequate protection, we have put in place standard contractual clauses approved by the European Commission for transfers from data controllers in the EEA to data processors outside the EEA. A copy of these terms can be obtained by visiting the Help Desk.

• Our personnel based in India may have access to personal information when they perform technical maintenance and support activities on our information technology systems. To ensure that such personal information is provided adequate protection, we have put in place standard contractual clauses approved by the European Commission for transfers from data controllers in the EEA to data processors outside the EEA. A copy of these terms can be obtained by visiting the Help Desk.

• For further details about the locations in which our Affiliates may store your personal information, please visit the privacy policy available on their websites.

• For further details about the locations in which any client of ours may store your personal information (which it will be using as a separate data controller for the purposes of Data Protection Law), please see the information that was provided to you in the data collection notice that you received at the time you registered for a promotion, competition or other service offered by that client, or contact that client directly.

• We will keep a record of the personal information that we receive from you in order to enter you into a prize draw.We will keep our copy of your personal information held for this purpose until we no longer require, following the last time we use your personal information for this purpose or, if earlier, until you have contacted us to ask for the processing of your personal information for this purpose to be stopped (in which case we will retain a record of your request in order to ensure that we comply with your wishes).

PERSONAL INFORMATION YOU SUBMIT TO US WHEN YOU CHOOSE TO RECEIVE EMAILS OR TELEPHONE CALLS FROM ONE OF OUR PARTNERS:

• We will collect your contact details:We will collect your first and last name, salutation, your email address, your postal address, your mobile phone number and your date of birth.
• We will share your personal information with our sponsors and partners, with your consent:When you sign up to receive information about freebies, discounts and prizes or when you enter a prize draw, you can also choose to share your personal information with our partners in the following circumstances:
  • From time to time, the Website is sponsored by one of our partners. When you sign up, we will tell you which of our partners is then sponsoring the Website. If you wish to receive emails about products and services provided by the sponsor, you will need to give consent to us sharing your contact details with them.
  • You can choose to receive offers by email or telephone from companies that we believe will be of interest to you by selecting from a list.
  • We will seek your consent through the use of tick boxes or similar methods.
• The sponsors and partners will be responsible for their processing of the personal information that you agree to share:When we share your personal information in this way, the sponsors and/or partners will be responsible for their processing or your personal information and the processing will be subject to the sponsors' and/or partners' privacy policies. At the time we seek your consent, we will provide you a link to the applicable sponsor's or partner's privacy policy.
• We store personal information collected by us inside and outside the EEA, as may other parties that we may share your personal information with:The personal information that we collect from you may be stored at a destination outside the European Economic Area ("EEA") and may be processed by personnel (who work for us or one of our service providers) operating outside the EEA in countries that the European Commission has not decided offer adequate data protection in accordance with Data Protection Law. Where we pass your personal information to parties located outside of the EEA that do not offer adequate protection, if they are not subscribed to an approved data protection framework, we will enter into agreements which enable us to transfer that personal information to them and that enable you to exercise your rights in accordance with Data Protection Law. In particular:
  • Our personnel based in India may have access to personal information when they perform technical maintenance and support activities on our information technology systems. To ensure that such personal information is provided adequate protection, we have put in place standard contractual clauses approved by the European Commission for transfers from data controllers in the EEA to data processors outside the EEA. A copy of these terms can be obtained by visiting the Help Desk.
• We will keep a record of the personal information that we receive from you in order to contact you about the latest freebies, discounts and prizes.We will keep our copy of your personal information held for this purpose indefinitely or until you have contacted us to ask for the processing of your personal information for this purpose to be stopped (in which case we will retain a record of your request in order to ensure that we comply with your wishes).

PERSONAL INFORMATION YOU SUBMIT TO US USING THE HELP DESK:

• We will collect your contact details and any personal information contained in your message:We will collect your email address, the subject of your enquiry and any personal information contained in the message section of your enquiry.
• We will use your personal information to reply to your enquiry:We will read your enquiry and use your personal information to respond to it:
  • If you are contacting us to unsubscribe from receiving emails or texts about the latest freebies, offers, discounts, and prizes that we make available on behalf of our partners through the Website:We will use your personal information on a suppression list. If you update your preferences to receive emails and texts about the latest freebies, offers, discounts and prizes that we make available on behalf of our partners, you will be resubscribed.
  • If you are contacting us to inform us that you have attempted to unsubscribe from texts or emails through the methods explained in this privacy policy and on the website:We will use your personal information on a suppression list.
  • If you are contacting us to request deletion of your account:We will use your personal information to locate your account and delete it. We will keep a record of your request for deletion in order to prove that we have complied with your wish.
  • If you are contacting us to request to update your information:We will use your personal information to locate your information and append your new information to your account.
  • If you are contacting us to request access to your information:We will use your personal information to locate your information and provide it to you as requested.
  • If you are contacting us to not sell your data:We will use your personal information to locate your information and securely share it with any third parties that you consented to our sharing your data with.
  • If you are making any other type of enquiry:We will use your personal information to consider and respond to your enquiry because it is in our legitimate interests to use your personal information in order to determine how to answer your query. Depending on the subject of your enquiry, it may also be necessary for us to use your personal information to comply with a legal obligation relating to how we manage our business or our relationship with your business.

• We will use your personal information to confirm your identity:If we do not know you or your role at your business, we may also use your personal information to confirm your identity and the business that you work for, as well as your role at that business. We do this because it is in our legitimate interests to make sure that your enquiry is genuine and is not being made for fraudulent reasons or is spam. We may also do this because we may be subject to legal obligations which require us to confirm the details that you provide us with before entering into a relationship with you.

• We may share your personal information with others in order to confirm your identity and to respond to your enquiry:
  • We may check your personal information by searching for your name and that of your business in publicly available and private databases of businesses and individuals, which will use the details entered by us to provide us with the search results. For example, we may use databases such as those retained by LinkedIn or Companies House for this purpose.
  • If you are a making an enquiry about a promotion, competition or other service provided by a partner or about personal information they may have about you, we may pass your personal information on to them so that we or they can respond to your enquiry.
  • We may pass your personal information to one of our affiliates, Leadscale Engine Limited, Leadscale Limited, (our "Affiliates") so that they can respond to your enquiry if it relates to their business, in which case that Affiliate will be using it as a separate data controller for the purposes of Data Protection Law. For example, if you make an enquiry through the Website about a service offered by Leadscale Engine, we may pass your personal information to Leadscale Engine Limited so that they can provide you a response, in which case, Leadscale Engine Limited will be using it as a separate data controller for the purposes of Data Protection Law.

• We store personal information collected by us inside and outside the EEA, as may other parties that we may share your personal information with:The personal information that we collect from you may be stored at a destination outside the EEA and may be processed by personnel (who work for us or one of our service providers) operating outside the EEA in countries that the European Commission has not decided offer adequate data protection in accordance with Data Protection Law. Where we pass your personal information to parties located outside of the EEA that do not offer adequate protection, if they are not subscribed to an approved data protection framework, we will enter into agreements which enable us to transfer that personal information to them and that enable you to exercise your rights in accordance with Data Protection Law. In particular:
  • We use a customer relationship management solution that stores the personal information collected by us about our clients in the United States of America. To ensure that such personal information is provided adequate protection, transfers of personal information to this service provider are made in accordance with all applicable Data Protection Laws
  • Our personnel based in India may have access to personal information when they perform technical maintenance and support activities on our information technology systems. To ensure that such personal information is provided adequate protection, we have put in place standard contractual clauses approved by the European Commission for transfers from data controllers in the EEA to data processors outside the EEA. A copy of these terms can be obtained by visiting the Help Desk.
  • For further details about the locations in which our Affiliates may store your personal information, please visit the privacy policy available on their websites.
  • For further details about the locations in which any client of ours may store your personal information (which it will be using as a separate data controller for the purposes of Data Protection Law), please see the information that was provided to you in the data collection notice that you received at the time you registered for a promotion, competition or other service offered by that client, or contact that client directly.

PERSONAL INFORMATION WE COLLECT FROM YOUR BROWSER AND YOUR DEVICE:

• We will collect personal information about your interaction with our Website and your location:We will collect your device's IP address, traffic data, location data, weblogs and other communication data and the resources that you access when you visit the Website and your browser or other applications on your device interact with it.
• We will use your personal information to operate and improve the use of the Website:We will use your personal information to determine how you may be viewing and using our Website:
  • To ensure that content from the Website is presented in the most effective manner for you and your device and for other users and to make improvements to the Website;
  • To recognise you when you return to our Website. This enables us to record your use of our Website, to automatically personalise our Website content for you and remember your preferences. It also allows you to participate in interactive features on our Website, when you choose to do so;
  • To automatically make suggestions and recommendations to you and other users of our Website about services of ours that may be of interest to you or to them;
  • As part of our efforts to keep the Website secure;
  • To administer and maintain the Website by conducting testing and solving errors; and
  • To analyse your and other users' use of the Website in order to create anonymised and aggregated research or statistics from time to time. Once your personal information has been anonymised and aggregated with that of other users, we will no longer be able to identify you or anyone else from the combined information;
  • We will use your personal information in this way because it is in our legitimate interests to determine how you may be viewing and using our Website so that we can operate it and improve it.

• We will keep a record of the personal information that we receive from your browser and your device to operate and improve our Website:We will keep our copy of the personal information held for this purpose indefinitely from the end of our last update to the Website.

3. CONSENT TO USE YOUR PERSONAL INFORMATION WE COLLECT FROM COOKIES PLACED ON YOUR DEVICE: THE SECTIONS BELOW EXPLAIN THE COOKIES THAT WE WILL PLACE ON YOUR DEVICE WHEN YOU VISIT OUR WEBSITE. BY CONTINUING TO BROWSE THE WEBSITE, YOU AGREE TO OUR USE OF COOKIES EXPLAINED BELOW.

• We will collect personal information about your interaction with our Website, other websites you visit and your location:We will collect your device's IP address, location data, details of webpages, weblogs and other communication data and the resources that you access when you visit our Website our other websites when your device interact with it.
• We will use your personal information to operate and improve the use of the Website and to offer you goods and services:We will use your personal information to determine how you may be viewing and using our Website:
  • To ensure that content from the Website is presented in the most effective manner for you and your device and for other users and to make improvements to it;
  • To recognise you when you return to our Website. This enables us to record your use of our Website, to automatically personalise our Website content for you and remember your preferences. It also allows you to participate in interactive features on our Website, when you choose to do so;
  • To record your visit to our Website and other websites, the pages you have visited and the links you have followed so that we can automatically make suggestions and recommendations to you and other users about services of ours and those of our clients that may be of interest to you or to them on websites that you and other users may visit;
  • To contact you by email or text message to offer you goods and services where we have recognised that you have returned to our Website and you have previously agreed to receive marketing communications from us;
  • As part of our efforts to keep the Website secure;
  • To administer and maintain the Website by conducting testing and solving errors; and;
  • To analyse your and other users' use of the Website in order to create anonymised and aggregated research or statistics from time to time. Once your personal information has been anonymised and aggregated with that of other users, we will no longer be able to identify you or anyone else from the combined information;

• We will use your personal information to confirm your identity and to improve our products and services and those of our Affiliates:We will use your personal information that we collect from you and/or cookies placed on your device to confirm that your device and the information provided by you is genuine. We do this by checking it against existing information that may already exist about you on a system operated by Leadscale Engine Limited. To the extent that this information collected from cookies placed on your device or provided by you is not contained on the system operated by Leadscale Engine Limited or the information contained on the system operated by Leadscale Engine Limited is incorrect or incomplete, then Leadscale Engine Limited will use the information provided to correct or add to the existing information held on the Leadscale Engine system to improve it. Where personal information is checked against or added to the Leadscale Engine system for this purpose, Leadscale Engine Limited will be using it as a separate data controller for the purposes of Data Protection Law.

• We store personal information about you using cookies placed on your device when you visit our Website inside the UK and outside the EEA, as may other parties that we may pass your personal information:The personal information that we collect from you may be stored at a destination outside the EEA and may be processed by personnel (who work for us or one of our service providers) operating outside the EEA, in countries that do not offer adequate data protection in accordance with Data Protection Law. Where we pass your personal information to parties located outside of the EEA in countries that the European Commission has not determined offer adequate data protection, if they are not subscribed to an approved data protection framework we will enter into agreements which enable us to transfer that personal information to them and that enable you to exercise your rights in accordance with Data Protection Law. In particular:

• Our personnel based in India may have access to personal information when they perform technical support activities on our information technology systems. To ensure that such personal information is provided adequate protection, we have put in place standard contractual clauses approved by the European Commission for transfers from data controllers in the EEA to data processors outside the EEA. A copy of these terms can be obtained by visiting the Help Desk
• Other parties that we may pass your personal information to may be located or store your personal information in countries which are not in the European Economic Area and do not offer adequate data protection in accordance with Data Protection Law. For further details about the locations in which Google may store your personal information, please click here.

• We will keep a record of the personal information that we receive from your browser and your device to operate and improve our Website:We will keep our copy of the personal information held for this purpose indefinitely.

4. DATA RETENTION

• We will only store your data in accordance with our Data Retention Policy. To read our Policy, click here

5. OUR EMAIL POLICY

• We comply with the federal CAN-SPAM Act. You can always opt-out of receipt of further email correspondence from us or our affiliates.

6. COOKIES

• This Website uses cookies to collect information. Cookies are small data files which are placed on your browser and the hard drive of your computer, mobile or other handheld device as you browse the Website. The cookies we use store information about your visit to this Website and distinguish you from other users. Some cookies are essential to the effective operation of our Website. They help us to provide you with a good experience when you browse our Website and also allows us to improve our Website.

The cookies set from our Website:

The following table sets out the types of cookie used on our Website and provides detail about what they are used for. When you use the Website for the first time, cookies which are essential to make our Website operate (see those identified as "essential cookies" below) will have been set but the other cookies will not have been set unless you agreed to those cookies being set at the time. If you have agreed to accept cookies then our Website will remember this and continue to set cookies each time you visit. If you do not want a cookie to be stored, then you may turn off certain cookies listed below individually or you can select the appropriate options on your web browser to delete some or all cookies. Please note, however, that if you block some or all cookies (including essential cookies) you may not be able to use or access all or parts of our Website, such as being able to log on to member specific areas.

How to disable the cookies

If you want to disable cookies you need to change your website browser settings to reject cookies. However, if you use your browser settings to block all cookies (including those essential for the operation of the Website) you may not be able to access parts of our Website. How to do this will depend on the browser you use. We have provided instructions below on how to disable cookies for the most popular browsers:

1. For Microsoft Internet Explorer:
   Choose the menu “tools” then “Internet Options”;
   Click on the “privacy” tab; and
   Select the setting the appropriate setting.
2. For Mozilla firefox:
   Choose the menu “tools” then “Options”;
   Click on the icon “privacy”; and
   Find the menu “cookie” and select the relevant options.

7. PROTECTION OF PERSONAL INFORMATION

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take appropriate measures to protect your personal information, we cannot guarantee the security of the personal information you provide to the Website and any transmission by you of it to us is at your own risk.

8. CHANGES TO THIS POLICY

We may make changes to this Privacy Policy at any time without notice to you. Any changes we make to this Privacy Policy in the future will be posted on this page and will be immediately effective upon the posting of the updated Privacy Policy, unless we indicate a particular date on which it will be effective. However, where we change our Privacy Policy to reflect a new way we may use personal information which we have not told you about before, we will not use your personal information collected before that change unless we notify you in advance.

9. YOUR RIGHTS

CALIFORNIAN CONSUMER RIGHTS

As a Californian resident, under the Californian Consumer Privacy Act, you are entitled to:

Right to Access

You may review certain information that we hold about you by signing into your account on our Website. To obtain a full copy of all information we maintain about you, you may send us a request using the contact information at the end of this Notice. After receiving the request, we will tell you when we expect to provide you with the information. We offer this service for free unless your request is excessive or manifestly unfound.

Right to Opt-Out

If you wish us to opt you out of receiving direct marketing from us or our partners, you may click the unsubscribe button at the bottom of the email, or by visiting the Help Desk.

Right to Erasure

If you wish us to remove or change personal data you have provided us with, you may contact us by visiting the Help Desk

Right to Equal Services and Price

The “right to equal service and price” refers to the Californian Consumer Privacy Act (2018)’s prohibition against discriminating against consumers who exercise their rights under the CCPA. Where a consumer exercises a right, a business is prohibited from denying goods or services, charging a different price, imposing penalties, providing a different level or quality of service, or suggesting the consumer will receive a different price or rate or different level or quality of goods or services.

When we receive any request to access, edit or delete personal data, we will first take reasonable steps to verify your identity.

For non-Californian residents, for any opt-out or deletion requests, please visit our Help Desk.

10. CONTACT

For any enquiries relating to this Privacy Policy or how we use information collected from this Website or contact the Data Protection Officer, please contact us by writing to us at Unit 1, 6 Owen Street, London EC1V 7JX or by visiting the Help Desk.