Contents
- Controller and contact
- Scope and sources
- Information collected
- Purposes and legal bases
- Sensitive information
- Sponsored and team work
- Sharing and service providers
- International transfers
- Retention periods
- Security
- Website and cookies
- Your privacy rights
- Automated decisions and children
- Changes and contact
1. Controller and Privacy Contact
LeadRaw, registered with the Chamber of Commerce (KVK), The Hague,
The Netherlands, under number 42137690, is the controller
responsible for the processing described in this policy.
Privacy enquiries and rights requests can be sent to
legal@leadrawintl.com.
2. Scope and Sources of Information
This policy covers information obtained through the website,
introduction requests, email, telephone, messaging applications,
proposals, agreements, invoices, individual sessions, leadership
team sessions, employer-sponsored work, and related business
contact.
Information is usually received directly from the individual or
from an authorised representative of a client organisation. In a
sponsored engagement, limited contact or engagement information
may be provided by the sponsoring organisation.
3. Categories of Information We May Process
Depending on the engagement, LeadRaw may process names, job titles,
organisations, email addresses, telephone numbers, appointment
details, correspondence, proposals, agreements, invoices, payment
status, agreed objectives, attendance, session notes, feedback,
and information voluntarily shared during mentoring or advisory
work.
Technical information may include basic server or security logs,
device and browser information, approximate location derived from
an IP address, and records necessary to protect and operate the
website. LeadRaw does not seek to collect information unrelated to
its services.
4. Purposes and Legal Bases
LeadRaw processes information to respond to enquiries and arrange
introduction calls based on steps requested before entering a
contract and, where appropriate, legitimate interests in managing
professional enquiries.
Information used to prepare, administer, and deliver an engagement
is processed because it is necessary to perform a contract or to
take requested pre-contractual steps. Invoicing, tax records, and
legally required disclosures are processed to comply with legal
obligations.
Limited information may be used to protect systems, prevent misuse,
manage disputes, and improve service quality based on LeadRaw's
legitimate interests, balanced against the rights of affected
individuals. Consent is used where required, including for
testimonials, optional marketing, or certain sensitive
information. Consent may be withdrawn at any time without
affecting earlier lawful processing.
5. Sensitive and Special-Category Information
LeadRaw does not require clients to provide medical diagnoses,
health records, political opinions, religious beliefs, sexual-life
information, or other special-category information. Clients should
avoid sharing more sensitive information than is necessary.
Where sensitive information is voluntarily disclosed and relevant
to the requested service, LeadRaw will minimise what is recorded
and rely on explicit consent or another valid legal condition
where required. Consent to record such information can be
withdrawn, subject to information that must be retained for legal
claims or other legal obligations.
7. Sharing and Service Providers
LeadRaw does not sell personal information. Information is shared
only where necessary with safeguarded providers supporting website
hosting, email, scheduling, messaging, document storage,
electronic signatures, accounting, invoicing, payment processing,
or professional advice.
Providers receive only the information reasonably necessary for
their role and are required to protect it through contractual or
equivalent safeguards. Information may also be disclosed to
authorities, courts, advisers, or insurers where required by law or
reasonably necessary to establish, exercise, or defend legal
claims.
Website form submissions are processed by
Formspree
for delivery, spam filtering, and temporary submission history.
Formspree may process information in the United States or other
countries where it operates. Appropriate transfer safeguards are
used where required by applicable law.
8. International Transfers
Some service providers may process information outside the
European Economic Area. Where required, LeadRaw relies on a valid
transfer mechanism such as an adequacy decision, European
Commission standard contractual clauses, or another lawful
safeguard, together with supplementary measures where appropriate.
Further information about the safeguards relevant to a particular
transfer can be requested through the privacy contact.
9. Retention Periods
Enquiry and introduction-call information is normally retained for
up to 24 months after the last meaningful contact, unless an
engagement begins or earlier deletion is appropriate.
Under the current account settings, Formspree retains website form
submissions in its dashboard for up to 30 days. The resulting
correspondence may be retained by LeadRaw in accordance with the
enquiry period above.
Engagement agreements, essential correspondence, objectives, and
necessary session records are normally retained for the duration
of the engagement and up to 5 years afterwards to support
continuity, resolve disputes, and establish or defend claims.
LeadRaw may agree a shorter period for session notes.
Invoices, payment records, and information forming part of the
business administration are retained for at least 7 years where
required under Dutch tax and record-keeping law. Approved
testimonials are retained until consent is withdrawn or the
testimonial is no longer used. Website security logs are retained
only as long as reasonably necessary and normally no longer than
12 months unless an incident requires longer investigation.
Information may be retained longer where required by law, a legal
hold, or an active dispute. It is deleted or anonymised when no
longer necessary.
10. Security and Confidentiality
LeadRaw uses reasonable technical and organisational measures
appropriate to the nature of the information, including access
controls, confidentiality commitments, careful provider selection,
and secure account practices. No online or electronic system can
be guaranteed completely secure.
If a personal data breach creates a legally reportable risk,
LeadRaw will notify the competent supervisory authority and
affected individuals where required.
11. Website Analytics, Cookies, and External Links
The current website does not intentionally use non-essential
tracking cookies. Essential technical functions and hosting
security may still create limited technical records. If analytics,
advertising, or embedded services are introduced, appropriate
information and consent controls will be implemented before those
tools are activated.
External websites and communication services operate under their
own privacy practices. LeadRaw is not responsible for independent
third-party websites merely because a link is provided.
12. Your Privacy Rights
Subject to the GDPR and any applicable limitations, individuals
may request access, correction, deletion, restriction, data
portability, or object to processing based on legitimate interests.
Where processing is based on consent, consent may be withdrawn at
any time.
Requests should be sent to
legal@leadrawintl.com.
LeadRaw may request proportionate information to verify identity
and will normally respond within one month. Complex or repeated
requests may lawfully require an extension, in which case the
requester will be informed.
Individuals may lodge a complaint with the
Dutch Data Protection Authority
or another competent supervisory authority. LeadRaw welcomes the
opportunity to address concerns directly first.
13. Automated Decisions and Children
LeadRaw does not use personal information to make decisions based
solely on automated processing that produce legal or similarly
significant effects. LeadRaw services are intended for adults and
are not directed to children. If information about a child is
received unintentionally, it will be deleted unless there is a
lawful reason to retain it.
14. Changes, Questions, and Contact
This policy may be updated when services, providers, or legal
requirements change. Material updates will be identified through a
revised effective date and, where appropriate, brought directly to
the attention of affected individuals.
Questions, objections, and privacy requests can be sent to
legal@leadrawintl.com.