Privacy Policy

Last updated: January 30th, 2025

Lead Studioz, Ltd (the “COMPANY”) is committed to safeguarding the privacy of all data subjects who interact with us. In this Privacy Policy, when we use the term ‘we’ or ‘us’, it means the Company, and its affiliates and other group companies. This Privacy Policy (together with our Terms of Use, Draw Rules and any other documents referred to in it or in the above documents) sets out how we collect, use and manage your personal information (“Personal Information”) through COMPANY’ website and services.

In this context, ‘PERSONAL INFORMATION’ is data which relates to you, and which personally identifies you either directly or indirectly. This Privacy Policy explains the basis on which any PERSONAL INFORMATION that the COMAPNY collects from you, or that you provide to us, will be processed and used by COMPANY. Please read this Privacy Policy carefully to understand our views and practices regarding your PERSONAL INFORMATION and how we will treat it. By visiting response-nation.co.uk (the “Website”), you are accepting and consenting to this Privacy Policy.

Changes to this Privacy Policy: We may amend this Privacy Policy from time to time to make sure it is up-to-date and accurate. Any changes will be posted on the Website. Please check back frequently to see any updates or changes to our Privacy Policy. We will assume that you agree to the Privacy Policy or revised versions of the Privacy Policy if you continue to use the Website and online services after the effective date shown at the top of the Privacy Policy.

Data Controller: For the purpose of the Data Protection Act 2018, General Data Protection Regulation 2018 and the Privacy and Electronic Communications Regulations (the “Legislation”), the data controller is the Company, Office No. 21, 9.17 Capital Tower, 91 Waterloo Road, London, United Kingdom, SE1 8RT.

Data Protection Officer: We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below:

Full name of legal entity: Ori Weissberg.

Email address: ori.w@response-nation.co.uk.

Postal address: Office No. 21, 9.17 Capital Tower, 91 Waterloo Road, London, United Kingdom, SE1 8RT.

Your right to complain: You have the right to complain at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk ). We would, however, appreciate the opportunity to respond to your concerns before you approach the ICO.

How do we obtain your PERSONAL INFORMATION?

We may collect and process the following data about you:

Information you give us. You may give us PERSONAL INFORMATION about you by filling in surveys and/or other online forms on the Website or by corresponding with us by phone, e-mail or otherwise, participate in discussions with us, enter a draw, or any other activity. The information you give us may include your name, address, e-mail address and phone number and/or other personal details.
Information we collect about you. We may automatically collect the following information:

Technical information, including your Internet protocol (“IP”) address, your login information, browser type and version, time zone, browser plug-in types and versions, operating system and platform;
Information about your visits, including the URL clickstream to, through and from the Website (including date and time); pages and other items you viewed or searched for; page response times, download errors, length of your visits to certain pages, page interaction information, and methods used to browse away from the page and any phone number used to call our user service number.

PERSONAL INFORMATION that we collect and receive from third parties

We may receive PERSONAL INFORMATION about you if you use any of the other websites we operate or which are linked from our Website. We are also working closely with third parties (including, without limitations, prize sponsors, suppliers, business partners, sub-contractors, technical and payment services, advertisers, etc. and may receive information about you from them.

Examples of information collected: You provide information to us when you:

Use any of our services (including joining any draws, surveys or other activities);
view or use the content on a device, or through any service or application on a device;
configure your settings on, provide data access permissions for, or interact with the Website; or
communicate with us by phone, e-mail, or otherwise.

Following the above actions, you may provide us with information such as: your name; address and phone number; email; age; location information; your IP address; addresses and device log files.

Automatic information: Examples of information we collect and analyse include:

Internet protocol (IP) address;
Login, e-mail address and password;
location of your device;
information about your internet service provider (ISP) or other content interaction information;
use history, which we sometimes aggregate with information from other users;
URL clickstream to, through and from the Website (including date and time);
Pages or content you viewed or searched for;
response times, length of visits to certain pages, page interaction information (such as scrolling and clicks).

How do we use your PERSONAL INFORMATION and on what basis do we process your PERSONAL INFORMATION?

We have set out below, in a table format, a description of all the ways we may use your PERSONAL INFORMATION, and which of the legal bases we rely on to do so. Where appropriate, we have also identified our legitimate interests in processing such information.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To enter you into a draw	(a) Identity (b) Contact (c) Profile	Performance of a contract with a user.
To confirm your identity and protect against money laundering activity.	(a) Identity (b) Contact (c) Profile	Performance of a contract with a user. Necessary for our legitimate interests of ensuring user activity and payments are not fraudulent.
To process and deliver your activity.	(a) Identity (b) Contact	Performance of a contract with a user.
To carry out fraud assessments and credit risks to allow third parties to process your PERSONAL INFORMATION in order to protect against and detect fraud and other criminal activity.	(a) Identity (b) Contact (c) Technical	Necessary for our legitimate interests of ensuring no fraud is involved.
To notify you in relation to our legal obligations and documents, including changes to our terms or Privacy Policy.	(a) Identity (b) Contact (c) Profile	Necessary for our legitimate interests of ensuring our users are updated on these changes. Necessary for a legal requirement.
To help us improve our offering to our users, including asking you to leave a review or take a survey, or provide user insights.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	Necessary for our legitimate interests (to study how users use the Website and services, to improve our offering to you, to develop new features and grow our business).
To enable you to partake in a prize draw.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	Performance of a contract with a user to run the prize draw. We may also subsequently use your entries for the legitimate interest of understanding our user base more effectively.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, maintenance, support, reporting and hosting).	(a) Identity (b) Contact (c) Profile (d) Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
To deliver relevant website content, advertisements and other marketing material to you from us and/or from our prize sponsors and other third parties as set forth herein (“Third Parties”) and measure or understand the effectiveness of the advertising we serve to you.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how users use our products/services, to develop them, to grow our business to inform our marketing strategy and to improve our offering to users).
To use data analytics to improve the Website, products/services, marketing, user relationships and experiences.	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of users for our products and services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to users about services that may be of interest to you.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	With users’ consent (to develop our services and grow our business, and to improve our offering to users).
To comply with our legal obligations.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary to adhere to a legal requirement.
To display interest-based Advertising.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	With users’ consent (to develop our services, grow our business, and improve our offering to users).

Cookies

The Website uses cookies to distinguish you from other users of the Website. This helps us to provide you with a good experience when you browse the Website and also allows us to improve the Website. For more information, please visit our Cookies Policy.

Interest-based Advertising

COMPANY may display interest-based advertisements on the Website and on other, unaffiliated websites which may be linked from our Website. Interest-based advertising is displayed to users based on information collected from their activities, including, without limitations, browsing or entering into draws, completing surveys or other activities, on or through the Website or on third party websites, or based on users’ responses to our marketing efforts (collectively, the "Services"). For instance, users may see an advertisement on a COMPANY or third party website for products or services, based on information indicating such users’ interest in similar products or services. We may also transfer your PERSONAL INFORMATION to our prizes sponsors and/or other business partners in order for them to send to you offers and advertisement, subject always to your consent preferences as they may be from time to time and in accordance with applicable law including any Legislation.

Information collected: Pursuant to this Privacy Policy, the information collected and used for interest-based advertising may contain the following, without limitation: age, gender, device unique identity or other device identifiers and applicable settings, information about users’ use of the Services or other websites, information about advertisements or our marketing emails viewed by users.
Third party technologies: Analytics tools and advertisements serving technologies may use server log files, web beacons, cookies, tracking pixels and other technologies to collect the above information. They may combine the information collected through our products and Services with: (a) information collected from third party websites, products and services and/or (b) with demographic, advertisement, market and other analytics data. In addition, some of these technologies can sync or connect users’ behaviour across different websites, mobile apps and devices. COMPANY makes its best efforts to provide users with: (a) the list of third parties whose advertisements serving technologies are used in its Services, (b) links to these third parties’ own privacy policies according to which their technologies and services are used, and (c) when available, a link to allow users to opt-out from these third parties’ services. Opting out does not mean users will not see any ads; but rather that the advertising users will see may be less relevant to their interests.
Custom content: We may, depending on users’ preferences, also combine their PERSONAL INFORMATION with the information they have independently provided to various third parties, in order to tailor advertisements for them on our Services and/or on third party websites.
Do not track: At this time, we adhere to the standards set out in this Privacy Policy.

As set forth above, depending on the consents that you set up at the time of registration and/or from time to time, and what personal data we hold about you, we may pass your PERSONAL INFORMATION to Third Parties who may contact you by post, email and telephone for direct marketing purposes. Email and Telephone data will only be released to third parties where you have given your positive consent (usually at the time of registration) allowing you to fully understand your registration preferences. Telephone data will only be released to carefully selected partners where it has been TPS’d (see ‘Opting Out’ below). Note: if you request a call from one of our sponsors or brands partners this will override the TPS.

Currently, the Third Parties with whom we share PERSONAL INFORMATION can be found HERE.

Uses made of information. We use information held about users in the following ways:

Information Users Give to Us

to carry out COMPANY’ obligations arising from any contracts entered into between COMPANY and you and to provide you with the information, products and services that you request from COMPANY;
to provide you with information about other goods and services COMPANY offers that are similar to those that you have already purchased or enquired about;
to provide you, or permit selected third parties to provide you as set forth above and subject to your consent preferences and applicable law, with information about goods or services that COMPANY or such third parties feel may interest you;
to notify you about changes to the Services or other relevant issues; and
to ensure that content from the Website is presented in the most effective manner.

Information COMPANY collects about you

to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve the Website to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of COMPANY’ services if and when you choose to do so; as part of COMPANY’ efforts to keep the Website safe and secure;
to measure or understand the effectiveness of advertising COMPANY serves to you and others, and to deliver relevant advertising to you; and
to make suggestions and recommendations to you and other users of the Website about goods or services that may interest you or them.

COMPANY does not collect any special categories of PERSONAL INFORMATION about you (this includes details about your race, your ethnicity, your religious or your philosophical beliefs, your sex life, your sexual orientation, your political opinions, your trade union membership, information about your health and genetic and biometric data). Nor does the COMPANY collect any information about criminal convictions and offences.

Where COMPANY needs to collect PERSONAL INFORMATION by law, or under the terms of a contract COMPANY has with you and you fail to provide that data when requested, COMPANY may not be able to perform the contract it has or is trying to enter into with you. In this case, COMPANY may have to cancel a service you subscribed to or ordered however, COMPANY will notify you if this is the case at the time.

Who we share your PERSONAL INFORMATION with. COMPANY may share your PERSONAL INFORMATION with any member of its group, which means its subsidiaries, its ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may also share your information with selected third parties including:

Business partners, prize sponsors, advertisers, suppliers and sub-contractors for the performance of any contract COMPANY enters into with them or you including without limitations to serve you offers, advertisements, etc.
Analytics and search engine providers that assist COMPANY in the improvement and optimisation of the Website.

We may also disclose your PERSONAL INFORMATION to third parties:

In the event that COMPANY sells or buys any business or assets, in which case COMPANY may disclose your PERSONAL INFORMATION to the prospective seller or buyer of such business or assets. If the transfer or sale goes ahead, the organisation receiving your PERSONAL INFORMATION can use your data in the same way as COMPANY.
If COMPANY or substantially all of its assets are acquired by a third party, in which case PERSONAL INFORMATION held by it about its users will be one of the transferred assets. If COMPANY is under a duty to disclose or share your PERSONAL INFORMATION in order to comply with any legal obligation, or in order to enforce or apply its terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of COMPANY, its users, or others. This includes exchanging information with other persons or companies for the purposes of fraud protection and credit risk reduction.

Cross-border transfers of your PERSONAL INFORMATION

Some COMPANY partners and/or suppliers are based outside the European Economic Area (EEA). The processing of your PERSONAL INFORMATION for the purposes of providing you with our services may involve a transfer of data outside the EEA or to countries deemed to provide an adequate level of protection for PERSONAL INFORMATION by the European Commission. COMPANY will only transfer your PERSONAL INFORMATION from the European Economic Area (EEA), United Kingdom or Switzerland to third countries, i.e. countries outside the EEA, on the basis of appropriate safeguards or if otherwise authorised by applicable law. In other cases, COMPANY provides the necessary safeguards, e.g. through the conclusion of data protection contracts with the recipients.

How long we keep your PERSONAL INFORMATION for

COMPANY keeps your PERSONAL INFORMATION in accordance with its internal retention procedures, which are determined by its legal, regulatory and professional obligations including applicable data protection laws and in accordance with good practice. The retention periods may differ depending upon the nature of the data COMPANY holds and the reasons why its is holding it and are subject to change. COMPANY only keeps your PERSONAL INFORMATION for as long as it needs to. When your information is no longer required, COMPANY will delete it securely.

How we protect your PERSONAL INFORMATION

COMPANY is committed to ensuring that your PERSONAL INFORMATION is kept secure. In order to protect your information from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss, COMPANY has put in place appropriate technical, physical and managerial procedures. All employees and any third parties we engage to process your information are obliged to respect the confidentiality of your PERSONAL INFORMATION.

The data that COMPANY collects from you may be transferred to and stored at, a destination inside the European Economic Area ("EEA"). It may also be processed by staff operating inside the EEA who work for COMPANY or for one of its suppliers.

All information you provide to COMPANY is stored on its secure servers.

Unfortunately, the transmission of information via the internet cannot be completely secure. Although COMPANY will always do its best to protect your PERSONAL INFORMATION, it cannot guarantee the security of your data transmitted to the Website; therefore, any transmission is at your own risk. Once COMPANY has received your information, it will use strict procedures and security features to try to prevent unauthorised access.

Your rights under applicable laws

Access to information. The Legislation gives you the right to access information held about you. Your right to access can be exercised in accordance with the Legislation.

You have the right to ask COMPANY not to process your PERSONAL INFORMATION for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data if applicable or by contacting us at: support@response-nation.co.uk

Under certain circumstances, you have rights under data protection laws in relation to your PERSONAL INFORMATION. Please read below to find out more about these rights.

Request access to your PERSONAL INFORMATION. This enables you to receive a copy of the PERSONAL INFORMATION we hold about you and to check that we are lawfully processing it.

Request correction of the PERSONAL INFORMATION that we hold about you. This enables you to have any incomplete or inaccurate data COMPANY holds about you corrected, though it may need to verify the accuracy of the new data you provide to COMPANY.

Request the erasure of your PERSONAL INFORMATION. This enables you to ask us to delete or remove PERSONAL INFORMATION where there is no good reason for COMPANY continuing to process it. You also have the right to ask COMPANY to delete or remove your PERSONAL INFORMATION where you have successfully exercised your right to object to processing (see below), where COMPANY may have processed your information unlawfully or where it is required to erase your PERSONAL INFORMATION to comply with local law. Please note however, that COMPANY may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your PERSONAL INFORMATION where COMPANY is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where COMPANY is processing your PERSONAL INFORMATION for direct marketing purposes. In some cases, COMPANY may demonstrate that it has have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your PERSONAL INFORMATION. This enables you to ask COMPANY to suspend the processing of your PERSONAL INFORMATION in the following scenarios: (a) if you want COMPANY to establish the data's accuracy; (b) where COMPANY’ use of the data is unlawful but you do not want COMPANY to erase it; (c) where you need COMPANY to hold the data even if it no longer requires it as you need it to establish, exercise or defend legal claims; or (d) you have objected to COMPANY’ use of your data but it needs to verify whether it has overriding legitimate grounds to use it.

Request the transfer of your PERSONAL INFORMATION to you or to a third party. COMPANY will provide to you, or a third party you have chosen, your PERSONAL INFORMATION in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for COMPANY to use or where COMPANY used the information to perform a contract with you.

Withdraw consent at any time where COMPANY is relying on consent to process your PERSONAL INFORMATION. However, this will not affect the lawfulness of any processing carried out before the consent was withdrawn. If you withdraw your consent, COMPANY may not be able to provide certain products or services to you. COMPANY will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at: support@response-nation.co.uk.

You will not have to pay a fee to access your PERSONAL INFORMATION (or to exercise any of the other rights). However, COMPANY may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, COMPANY may have legitimate grounds to refuse to comply with your request in these circumstances.

COMPANY may need to request specific information from you to confirm your identity and ensure your right to access your PERSONAL INFORMATION (or to exercise any of your other rights). This is a security measure to ensure that PERSONAL INFORMATION is not disclosed to any person who has no right to receive it. COMPANY may also contact you to ask you for further information in relation to your request to speed up our response.

COMPANY aims to respond to all legitimate requests within one month. Occasionally, it may take longer than a month if your request is particularly complex or you have made more than one request. In this case, COMPANY will notify you and keep you updated.

Contact

For any questions or other inquiries regarding this Privacy Policy and your rights under the Legislation, please contact us at: support@response-nation.co.uk.