GDPR Compliance Statement

At Just Leadz B.V., (“Just Leadz”, “we”, “us” or “our”), putting our clients and campaign recipients (“you” or “your”) first means exceeding global privacy and data protection standards in order to keep important contacts and sensitive data and communications private, safe and secure.

We set up our infrastructure, applications and tools in a way that enables you to strengthen and leverage your important relationships when they matter the most, without having to worry about data security or privacy concerns.

All service activities of Just Leadz have been officially assessed based on the requirements of the new European General Data Protection Regulation (GDPR) and the Telecommunications Act by an authorized data protection & compliance corporation in the Netherlands.

You can find full GDPR documentation in English here. Please complete a legitimate interest assessment here to explore whether your campaign will be internationally compliant.

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1. Understanding GDPR:

The GDPR forms a legal framework that lays down guidelines for the gathering, preservation, and processing of personal information of individuals residing in the European Union (EU), including the United Kingdom (UK) and the Netherlands.

Across the EU, various national data protection authorities such as the Information Commissioner's Office (ICO) in the UK and the Autoriteit Persoonsgegevens in the Netherlands enforce the Data Protection Act 2018, the General Data Protection Regulation, and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

These bodies operate as data protection guardians and it is crucial for us to perpetually adhere to their guidelines. Our unwavering commitment to realize 100% compliance with GDPR and Privacy and Electronic Communications Regulations (PECR) standards helps maintain this compliance.

Non-compliance with GDPR stipulations can invite severe punitive actions. It is, therefore, paramount to consider GDPR compliance as a critical aspect of business operations, thereby mitigating the risk of being subjected to an investigation or enforcement notice by any European data protection authority.

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2. Just Leadz and GDPR Compliance:

Just Leadz has sought the expertise of external third-party compliance professionals to conduct audits and provide counsel on industry best practices. An authorized data protection and compliance firm in the Netherlands has formally evaluated all service activities of Just Leadz, ensuring they meet the stipulations of the newly implemented European GDPR and the Telecommunications Act. This investment enables us to assure our clients that GDPR best practices are being observed to the fullest extent, always and everywhere.

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3. Just Leadz’s Relationship with Clients:

Under GDPR and respective national data protection authorities, we function as Joint Controllers. As service providers, we share responsibility with our clients for determining target demographics, the type of data to be collected, the processing and storage of data, and the creation and dissemination of messages. To facilitate this relationship, we have embedded a comprehensive Data Sharing Agreement within our Services Agreement.

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4. Compliance of Just Leadz’s Marketing Initiatives:

Just Leadz offers services exclusively designed to facilitate business-to-business (B2B) interactions. The PECR permits email marketing as long as the content is relevant and provides recipients with an opt-out option for future emails. With regard to this, Just Leadz is inherently compliant. Further, for GDPR, we have devised a system ensuring compliance in all aspects of data collection, storage, and processing.

To ensure that we are adhering to the highest compliance standards, we conduct a thorough assessment before initiating any new client activity. This includes a Legitimate Interest Assessment (LIA) for us and a standard LIA for each of our clients.

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5. Legitimate Interest:

Just Leadz will not endorse any prospecting activity if it fails to meet the Legitimate Interests criteria within the scope of GDPR or infringes upon other regulations, including PECR. In the context of our services, Legitimate Interest is identified as the relevant lawful basis for processing as per GDPR.

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6. Rights of Individuals:

Every dispatched message will include a link to a privacy policy detailing users' rights and the nature of data held about them. Just Leadz can provide a template privacy policy or review your existing one to ensure it meets the requisite standards.

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7. Opting Out & Exclusion Lists:

Recipients can opt out seamlessly to avoid receiving further email communications. All responses to prospecting emails are recorded, and the respondents are added to your campaign exclusion list within 24 hours. Just Leadz accepts the import of existing exclusion lists ahead of any campaign activity.

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8. Subject Access Requests & Right to be Forgotten:

Individuals have the right to request a copy of all data held about them and the right to have some or all of their data removed ('forgotten') at any time. To support this, data subjects can email any requests to Just Leadz, and we will respond with the requested data within 72 hours.

When an individual exercises their right to be forgotten, a delicate balance must be struck between removing their data while maintaining their email address on an exclusion list to prevent future mailings.

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9. PECR and Sending B2B Messages:

While the GDPR controls the storage and processing of personal data within the EU, including the UK and the Netherlands, the transmission of messages is regulated under the Privacy and Electronic Communications Regulations (PECR). The PECR establishes clear guidelines for business communication and recommends keeping a 'do not email or text' list of any businesses that object or opt out, screening new marketing lists against this list.

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10. Just Leadz Employees:

All Just Leadz employees receive training on GDPR, PECR, and general compliance, covering the implications and impacts of these regulations on our operations and those of our clients. The training also emphasizes the importance of consistently adhering to these strict standards and the severe penalties associated with non-compliance.

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11. Client Responsibility:

While Just Leadz takes comprehensive measures to ensure adherence to GDPR and PECR across all client activities, it is important to note that responsibility for compliance falls on all parties involved. Given the continuous evolution of regulatory frameworks across different countries, we advise our clients to familiarize themselves with their local regulatory landscape and ensure their business operations comply with relevant frameworks.

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In Conclusion:

Just Leadz has made significant efforts to build a compliant service and software platform that offers innovative marketing services and technology to our clients while respecting the rights of data subjects from whom we collect information. Compliance is ingrained in our operations, and ongoing due diligence is an integral part of how we function. Compliance is central to our identity as a business.

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Privacy Policy

1. Important Information

1.1. General Terms

At Just Leadz, (“Just Leadz”, “we”, “us” or “our”), putting our users (“you” or “your”) first means exceeding global privacy and data protection standards in order to keep important contacts and sensitive data and communications private, safe and secure.

We set up our infrastructure, applications and tools in a way that enables you to strengthen and leverage your important relationships when they matter the most, without having to worry about data security or privacy concerns.

Our Privacy Promise:

• No one will access, read, or delete your emails.
• When Just Leadz connects to your email server, we pull only the minimum amount of information required for our service to function.
• You own your data.
• Your personal data will be kept private according to this policy and to the greatest extent allowed by the law.

Additional questions? Don’t hesitate to send us an email at support@justleadz.com

Just Leadz is committed to maintaining the privacy and security of any of your personal information on the website or in our applications or information received in any other manner. This Privacy Policy (“Agreement” or “Policy”) defines how Just Leadz uses and protects any personal information that it collects and stores.

For the purpose of this Policy, “Personal Information” means information about an identifiable individual but does not include aggregated information that cannot be associated with a specific individual.

For the purpose of this Agreement, “Services” refers to the Company’s website which can be viewed or accessed at https://justleadz.com (“Website”), our applications or any other services that we may supply to you which are further described in our Terms of Service.

By accepting our Policy and our Terms of Service, you expressly consent to our collection, storage, processing, use and disclosure of your Personal information as described in this Policy.

In case your organization acts as a data controller under ‘General Data Protection Regulation (EU) 2016/679’ of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data you will need to sign or agree to an additional Data Processing Agreement with Just Leadz in order to process data in our Services.

Just Leadz complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. See the section entitled EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield, below, for further information.

1.2. Revision Of The Privacy Policy

Just Leadz reserves the right to revise, modify or update this Policy at any time. Your continued use of the Services after any such revisions, modifications or updates constitutes your acceptance of any such change.

If we make any material changes we will notify you by posting the revised Privacy Policy on our Website or conspicuously in the Services and, if you subscribe to our Subscription Service, providing notice through the in-app Notifications.

2. Use Of Our Services

2.1. Our Customers Use

You can use the Services to create communication campaigns in order to reach out to or nurture prospects with sales, marketing or customer success purposes.
Just Leadz does not control the content of campaigns (text, email or other communications templates) or the types of information that our customers may choose to collect or manage using the Services.
That information belongs to you and is used, disclosed and protected by them according to their privacy policies and is not subject to this Privacy Policy.

Just Leadz processes our customers’ information as they direct and in accordance with our agreements with our customers, and we store it on our service providers’ servers, but we do not have control over its collection or management.
Our agreements with you customers prohibit us from using that information, except as necessary to provide and improve the Services, as permitted by this Privacy Policy, and as required by law.

We have no direct relationship with individuals who provide Personal Information to our customers.

Just Leadz acknowledges that you have the right to access your Personal Information.
You control and are responsible for correcting, deleting or updating information they have collected from you using the Services.
If requested to remove data we will respond within a reasonable timeframe.
We may work with you to help them provide notice to their visitors about their data collection, processing and usage.
Our agreements with our customers prohibit usage of the Services to collect, manage, or process Sensitive Information.

We are not responsible for your customers’ use of information on the Services.
Just Leadz collects information under the direction of its customers, and has no direct relationship with the individuals whose Personal Information it processes.

If you are a customer of one of our customers and would no longer like to be contacted by one of our customers that use our Services, please contact the customer that you interact with directly or leave a request on our support@justleadz.com.
We may transfer Personal Information to companies that help us provide our Services. Transfers to subsequent third parties are covered by the processing agreements with our customers.

2.2. “Sensitive Information”

This refers to credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver’s license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.

3. Information We Collect

When you provide Just Leadz with your Personal Information you consent to our providing your information to any third parties that are necessary to offer, support and improve the Services.

Just Leadz also collects Personal Information from you when you place an order including your name, physical address, email address. Just Leadz only uses this data for the purpose of fulfilling orders or communicating with you and Just Leadz’s partners regarding the Services.

3.1. When You Visit Our Website

You are free to explore our Website without providing any Personal Information about yourself. Just Leadz collects your Personal Information when you register and open an account with Just Leadz to help us operate and support the Services and to contact you in connection with your use of the Services. Also we collect navigational Information.

3.2. “Personal Information”

This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business.

Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.

3.3. “Navigational Information”

This refers to information about your computer and your visits to and use of the Services such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed.

We use this information for the above purposes and to monitor and analyze use of the Services, for the Services’ technical administration, to increase our Services’ functionality and user-friendliness, to verify users have the authorization needed for the Services to process their requests, and for advertising purposes.
For more details please see the “Navigation Information” section below.

3.4. Payment Information

We collect and process payment information from you when you subscribe to the Service, including credit cards numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect Sensitive Information from you.

3.5. Information About Children

The Websites and our Services are not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us at support@justleadz.com, so that we may delete the information.

3.6. Information You Provide

You may also provide us information that you post to the Services. Your questions, answers, and other contributions on the Services, and metadata about them (such as when you posted them), are publicly viewable on the Services. This information may be found by search engines and be published elsewhere on the web in accordance with our Terms of Service and this Policy.

3.7 Google User Data

If you choose to connect a Gmail account, we will, after we have confirmed your permission, securely access information obtained from your account. In particular, we may need to access your inbox folder in order to detect replies to emails, that have been sent via Just Leadz; this is necessary in order to make work the core functionality of our Services work as intended.

Our servers store all emails you have sent via Just Leadz and any responses you received to those emails, so we can detect replies, classify them and you can have access to them from the Services.

Also, we may store your authentication token and account email address. This data will be securely stored in order to be used by Just Leadz to provide you with the Services (including but not limited to logging in to your account, sending emails via the Just Leadz platform, accessing emails you sent and viewing replies you received). Under no circumstances will this data be voluntarily shared with any third parties; Just Leadz would only provide this information to legal authorities upon their rightful request or in the case of an emergency. Should you choose to disconnect your Gmail account or choose to close your account, any information from Google stored on our servers will be deleted permanently.

3.8 Web Beacons

We may also collect information using web beacons (also known as “tracking pixels”).

4. Use Of Information We Collect

4.1. We Do Not Sell Personal Information

We do not sell your Personal Information to any third party.

4.2 Navigational Data, Cookies And Web Beacons.

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Just Leadz uses cookies to identify and track visitors, and your website access preferences.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Just Leadz Services.

Web beacons are electronic images (also called “gifs”) that may be used in the Just Leadz Services or in emails that help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

You can decline to show gifs or pictures in your email clients to avoid being tracked by email web beacons.

Also we use Navigational Information to operate and improve the Services.

4.3 Use Of Personal Information

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:
(a) improve your browsing experience by personalizing and improving the Services;
(b) send information to you which we think may be of interest to you by post, email, or other means;
(c) send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, and
(d) provide other companies with aggregated and Non-Personal Information about our users — but this information will not be used to identify any individual user,

We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your unique Personal Information to the third party.

In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. If you do not want us to share your personal information with these companies, contact us at support@justleadz.com.

We use the information collected/stored via our Services by our customers for the following purposes:
(a) to provide the Services (which may include the detection, prevention and resolution of security and technical issues);
(b) to respond to customer support requests;
(c) otherwise to fulfill the obligations under the Just Leadz Terms of Service.

4.5. Customer Testimonials And Comments

We post customer testimonials and comments in our Services, which may contain Personal Information. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.

4.6. Use Of Credit Card Information

If you give us credit card information, we use it solely to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.

4.7. Service Providers

We employ other companies and people to provide services to the visitors and users of the Services and we may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive or invalid information from prospect lists, analyzing data, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service. In all cases where we share your information with such third parties, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.

4.8. Confidentiality And Security Of Personal Information

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.

All the Personal Information we have where Just Leadz acts as a processor for a customers data (e.g., use of the Just Leadz Services) is encrypted via database encryption. All connections to our Website or Services are protected via the use of encrypted connections, such as the Secure Socket Layer (SSL) protocol.

Additionally every account with access to our encrypted database is secured with 2-Factor Authentication and passwords are stored in a 2-Factor Authentication extra secured password manager.

If you have any questions about the security of your Personal Information, you can contact us at support@justleadz.com.

4.9. Social Media

Our Websites can include Social Media Features, such as the Facebook Like button and Widgets, such as the Share This button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

4.10. External Websites

Our Websites provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

4.12. Retention Of Personal Information

We retain Personal Information that you provide us as long as we consider it potentially useful in contacting you about the Service or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements, and then we securely delete the information.

We will delete this information from the servers at an earlier date if you so request, as described in “Opting Out and Unsubscribing” below.

If you provide information to our customers as part of their use of the Just Leadz Service, our customers decide how long to retain the personal information they collect from you. If a customer terminates its use of the Service, then we will provide customer with access to all information stored for the customer by the Service, including any Personal Information provided by you, for export by the customer according to our agreement with our customer. After termination, we may, unless legally prohibited, delete all customer information, including your Personal Information, from the Just Leadz Service.

4.13. International Transfer Of Information

If you are located outside the United States, the information that we collect from you may be transferred to, and stored and processed at, a destination in the United States or in the European Union. By submitting information, you agree to this transfer, storing or processing. We will take all steps necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

All our employees and contractors related to working with personal data as part of their duties are signed agreements that covers Just Leadz and their responsibility regarding transfer of data to remote working locations other than United States.

This Privacy Policy shall apply even if we transfer Personal Information to other countries. To get more details about transfer from EU or Switzerland to US please see section ‘EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield’.

4.14. Sharing With Third Party Applications

Certain aspects of the Just Leadz Service allow or require you to connect with third party applications or services. In connection with your use of any such third party applications or services, such third parties may receive information about you including your username and any Content you choose to use in connection with those applications and services, and such third parties may contact you directly as necessary.

The Just Leadz Service may automatically collect and upload certain data from such applications via direct integrations or proxy services.

This Privacy Policy does not apply to your use of such third party applications and services, and we are not responsible for how those third parties collect, use and disclose your information and Content. We encourage you to review the privacy policies of those third parties before connecting to or using their applications or services to learn more about their information and privacy practices.

4.15. Compelled Disclosure

Just Leadz reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud and security breaches , or comply with a law, court order, or legal process.

4.16. Data Retention

After Just Leadz account cancellation all the data within this account are due to be deleted in 60 days period time.
At the same time personal data of customers could be retained longer as it needed for providing legal and financial trace of past operations up to the time required by US law.

5. EU-U.S. Privacy Shield And Swiss-U.S. Privacy Shield

5.1. Commitment To EU-U.S Privacy Shield

Just Leadz complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Resource, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov

Our participation in the Privacy Shield applies to all personal data that is subject to the this Privacy Policy and which is received from the European Union, European Economic Area, and Switzerland. We will comply with the Privacy Shield Principles in respect of such personal data.

Our accountability for personal data that we receive under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if third-party agents that we engage to process the personal data on our behalf do so in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

We encourage European individuals (including Swiss individuals) to contact us should you have a Privacy Shield-related (or general privacy-related) complaint at support@justleadz.com.

5.2 Independent Recourse Mechanism

We have further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles or the Swiss-U.S. Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. Just Leadz is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

6. Opting Out And Unsubscribing

6.1. Reviewing, Correcting And Removing Your Personal Information

Upon request Just Leadz will provide you with information about whether we hold any of your Personal Information. If you provide us with your Personal Information, you have the following rights with respect to that information:

• To review the user information that you have supplied to us
• To request that we correct any errors, outdated information, or omissions in user information that you have supplied to us
• To request that your user information not be used to contact you
• To request that your user information be removed from any solicitation list that we use
• To request that your user information be deleted from our records
• To opt out of being solicited by Just Leadz or third parties
• To exercise any of these rights, please contact us at support@justleadz.com. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

6.2. Anti-Spam Policy

We at Just Leadz committed to provide customers with tools and expertise to curate highly targeted and relevant communications via our platform. We monitor and prohibits use of the Just Leadz Service to send unsolicited commercial email in violation of applicable laws as stated in our Terms of service, and requires the inclusion in every email sent using the Service of an “opt-out” mechanism and other required information.

We require all of our customers to agree to adhere to the Terms of Service Policy at all times, and any violations of the Terms of Service Policy by a customer can result in suspension or termination of the Just Leadz Service.

We also provide customers with the tools to manage their sending reputation and customer success team work closely to monitor all customer metrics and best-practices to ensure high quality and targeted campaigns.

6.3. To Unsubscribe From Our Communications

You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, or by sending us email us at support@justleadz.com. Customers cannot opt out of receiving transactional emails or notifications related to their account with us or the Just Leadz Service.

6.4. To Unsubscribe From Our Customers’ Communications

Our customers are solely responsible for their own sales or marketing emails and other communications;
We make sure that all emails sent using Just Leadz service has proper unsubscribe mechanics (links or text + AI sorting + Auto opt out).
You can unsubscribe from our customers’ communications by clicking on the “unsubscribe” link located on the bottom of their emails, responding to unsubscribe via email or by contacting them directly.