Last Updated: August, 2023

1. Introduction

In this policy, “We”, “Us” and “Our” refer to Levaro LTD, a company registered in England and Wales with Company Number: 15235673, operating under the brand Simply-B2B and the website https://simply-b2b.com .

This policy applies where we are acting as a Controller with respect to the personal data of our website visitors, service users, email recipients and personal data collected from public sources; in other words, where we determine the purposes and means of the processing of that personal data.

Where we are acting as a Processor, which means where we process personal data on behalf of our clients, which is when providing our services in line Simply-B2B’s Terms & Conditions, our collection and use of personal data is governed by our Simply-B2B Data Processing Addendum available at Data Processing Addendum

Any reference to a Data Subject means a natural person whose personal data is processed by us as a Data Controller or as a Data Processor, in other words, you.

Any reference to the GDPR applies to both the UK GDPR and EU GDPR. Likewise, any reference to EU countries will also apply to the UK. This will remain the case so long as the UK is subject to an adequacy decision by the EU. Should there be a conflict between the two, the version that grants data subjects the greatest protection will apply.

2. How We use Your personal data

We want to be clear with you about how we use your data, so in this section we talk about the general categories of personal data that we may process and, in the case of personal data that we did not obtain directly from you, we’ll tell you where we got your data and the purposes for which we may process your data; finally, and very importantly, we’ll explain the legal bases of the processing which applies to us and you.

The General Categories of Personal Data That We May Process:

1. Usage Data.We may process data about your use of our website and services (“Usage Data”). The Usage Data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the Usage Data is Google Analytics as well as our analytics tracking system. This Usage Data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services, and tailoring any communication with you. We, of course, use this data to help us run our business as well as we can.
2. Account Data. We may process your Account Data (“Account Data”). The Account Data may include your name, email address, company information, password and phone number, as well as, further data required for subscribing to our services including credit card details, country, city and physical address. The source of the Account Data is generally you or your employer. The Account Data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you (or your employer) and us, and/or taking steps, at your request, to enter into such a contract. In some cases, we may also rely on Legitimate Interest as our lawful basis where we use your data for marketing purposes or in order to operate our business and improve our services.
3. Service Data. We may process your personal data that are provided in the course of the use of our services (“Service Data”). The Service Data may include name, email address, telephone number, and other related information. The source of the Service Data is you or your employer. The Service Data may be processed for the purposes of providing our services and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
4. Enquiry Data. We may process information contained in any enquiry you submit through our website https://simply-b2b.comor other channels of communication, regarding goods and/or services (“Enquiry Data”). The Enquiry Data may be processed for the purposes of us offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent, which may be withdrawn by you at any time by unsubscribing from our marketing emails or contacting us, or contract and/or taking steps, at your request, to enter into such a contract.
5. Notification Data.We may process information that you provide to us, such as email address, name and company name (“Notification Data”). The Notification Data may be processed for the purpose of subscribing to our email newsletters and/or eBook and sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent, which may be withdrawn by you at any time by unsubscribing from our emails or contacting us.
6. Correspondence Data. We may process information contained in or relating to any communication that you send to us (“Correspondence Data”). The Correspondence Data may include your name, email address and the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The Correspondence Data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, business and communications with users.
7. Public Data.We may process information found on public social networking profiles and other from other publicly available sources (“Public Data”). This data may include name, employment information, career information. education details, job title, and other relevant information. Public Data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you and/or your employer. The legal basis for this processing is our legitimate interests, namely the administration of our business, to develop our business, and in order for us to make a profit.
8. Legal Claims Data.We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure (“Legal Claims Data”). The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
9. Professional Use Data.We may process any of your personal data identified in this policy where necessary for the purposes of managing risks or obtaining professional advice (“Professional Use Data”). The legal basis for processing Professional Use Data is our legitimate interests, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3. Source of your Personal Data

Primarily, we obtain your data from you, when you use our website features and/or when you subscribe to our services, or from other publicly available sources.

4. Data sharing

Simply-B2B is a prospecting and lead generation company, where our services comprise the collection and sharing of personal data to our clients, and on behalf of our clients. In respect of personal data that we process on behalf of our clients, please refer to our clients’ privacy policies for the information about sharing of data provided to them.

Where Simply-B2B processes personal data as a Controller (website visitors, service users, email recipients, etc.), we may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries, together known as “Group Companies”) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedures.

We may also disclose your personal data to our suppliers, partners and other carefully managed third parties as required to operate our company and provide our services. Where this is the case, we will always ensure appropriate technical and administrative controls are in place.

As you would expect, in addition to the specific disclosures of personal data set out above, we may disclose your personal data where such disclosure is necessary for compliance with a binding legal obligation.

5. International transfers of your personal data

Simply-B2B processes your personal data primarily in the United Kingdom and United States. Transfer of personal data from the United Kingdom and United States to other countries is carried out only if it is necessary for the execution of contracts, complying with legal obligations and/or to achieve our legitimate interest.

Simply-B2B transfers personal data to countries which, according to EU, provide adequate level of personal data protection and based on signed agreements governing data processing.

When a country does not provide adequate level of personal data protection according to EU, personal data is then being transferred on basis of implementing appropriate safeguarding measures, such as European Standard Contractual Clauses, UK International Data Transfer Addendum and appropriate transfer risk assessments, or other safeguards in line with the GDPR

6. Retaining and deleting personal data

This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

We retain your data for as long as you have an account. When you close an account, we will delete its content. We may retain your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.

Data collected for the purposes of sending the relevant notifications and/or newsletters or offering, marketing and selling relevant goods and/or services is retained until you withdraw your consent or select unsubscribe link in the communication email received from us.

Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. External links

Our website contains links to external websites run by other organisations. This privacy policy applies only to our websites not those external websites that we link to, who will have their own privacy policies. We are not responsible for these external websites and their privacy policies and practices. In addition, if you linked to our website from an external site, we cannot be responsible for the privacy policies and practices of the owners and operators of that external website and recommend that you check the privacy policy of that external site.

8. Automated decision-making, including profiling

Our processes are not designed in a way to be automated, including profiling, and to make decisions which produce legal effects concerning you, or decisions which similarly significantly affect you.

9. The rights of data subjects

In this section we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

The Right to be Informed. This is the right of Data Subjects to know details regarding the processing of their data and how we acquired their data, this information is included in this Privacy Policy.

The Right to Access. You have the right to confirm as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data upon request and within one month of verification of your identity (we may extend the time within which we must provide the information by a further two months if the request is particularly complex, or if there are numerous requests and we will let you know if this is the case). The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

The Right to Rectification. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. If the request is accepted by us, the rectification will be completed within one month (may be extended by us by a further two months if complex). We will use all reasonable endeavours to notify any third party with whom we have shared the data of any rectifications made.

The Right to Erasure (also known as the “Right to be Forgotten”). In some circumstances you have the right to the erasure of your personal data without undue delay. However, there are exclusions to the right to erasure. We will use all reasonable endeavours to notify any third party with whom we have shared the data of any actioned erasure requests.

The Right to Restrict Processing. In some circumstances you have the right to restrict the processing of your personal data. Where processing has been restricted, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. We will use all reasonable endeavours to notify any third party with whom we have shared the data of any restriction placed on the processing of your data.

The Right to Object to Processing. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for certain tasks. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing is for the establishment, exercise or defence of legal claims.

The Right to Data Portability. To the extent that the legal basis for our processing of your personal data is:

1. Consent; or
2. That the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract; and
3. Such processing is carried out by automated means.

You have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

Right to Complain. If you consider that our processing of your personal information infringes data protection laws, you should first contact us. If you are dissatisfied with the outcome, you have a legal right to lodge a complaint with a Supervisory Authority responsible for data protection. You may do so in the UK (Information Commissioner’s Office) or EU member state of your habitual residence, your place of work or the place of the alleged infringement.

10. Contact us

If your query relates to this Privacy Policy, Simply-B2B Data Protection Addendum, or should you wish to exercise one of your data protection rights as a Data Subject, you can contact us in the following ways:

1. By email at: support@simply-b2b.com
2. By “Get in touch” contact form on our website: https://simply-b2b.com
3. By post to our registered office: 128 City Road, London EC1V 2NX, England, UK

If you remain unsatisfied by our response you may complain to the Information Commissioners offices at the following address:

1. Information Commissioner’s Office
   Wycliffe House, Water Lane
   Wilmslow, Cheshire
   SK9 5AF
   or
2. ico.org.uk.
3. Amendments to this policy

We may update this policy from time to time by publishing a new version on our website.

You should check this page occasionally to ensure you are happy with any changes to this policy.

We may notify you of changes to this policy by email.