PRIVACY STATEMENT
LeadLabel takes your privacy very seriously and handles all your personal information with the utmost care. This document sets out LeadLabel’s privacy policy regarding the processing of (personal) data of homeowners and property owners in the Netherlands. When processing personal data, LeadLabel seeks to strike an appropriate balance between the organisation’s objectives on the one hand and the protection of privacy on the other. LeadLabel always acts in accordance with the General Data Protection Regulation (“GDPR”). In this privacy statement, you can find information about:
- the categories of personal data that LeadLabel processes about you;
- the legal grounds on which LeadLabel processes personal data;
- the purposes for which LeadLabel processes your personal data;
- whether LeadLabel shares your personal data with third parties;
- how long LeadLabel retains your personal data;
- the way in which LeadLabel secures your personal data; and
- your privacy rights.
1. About LeadLabel
The party responsible for the processing of personal data is LeadLabel B.V., with offices at and established in (3521 AZ) Utrecht, Stadsplateau 29, registered with the Dutch Chamber of Commerce under number 70789290.
LeadLabel produces address-level predictions (street, postcode, house number, addition) regarding the moving process for as many Dutch addresses as possible. LeadLabel analyses such information for the benefit of companies that provide services tied to residential locations, such as energy suppliers. In short, LeadLabel can predict when a property will be, or has been, sold. LeadLabel can also predict the value of a property. In addition to the address itself, LeadLabel does not possess any information about the owners/residents currently or previously living at that address.
Any questions regarding LeadLabel’s processing of personal data may be directed to contact @ leadlabel.com.
2. To whom does this privacy statement apply?
This privacy statement applies to all homeowners and property owners in the Netherlands whose address data is processed by LeadLabel.
3. What personal data does LeadLabel process, for what reason, and on what legal basis?
Below you will find an overview of the purposes for which LeadLabel processes personal data about you. For each purpose, it is indicated which data LeadLabel uses for that specific purpose, the legal basis for processing that data, and how long the data is retained by LeadLabel. To keep things clear, we have grouped everything by type of data flow.
3.1 What data does LeadLabel process?
LeadLabel analyses Dutch residential addresses for the benefit of its clients. In combination with the current value of the property, the type of property, and all other property-related aspects that are publicly known, LeadLabel provides information to its clients consisting of various address-level moments in the moving journey, including:
- this address will be sold in x weeks (prediction)
- this address will be rented out in x weeks (prediction)
In addition, other data about the addresses may also be provided (property type, surface area, year of construction).
LeadLabel makes predictions about the property itself and has no information about the residents concerned.
3.2 For what purposes does LeadLabel process personal data?
LeadLabel analyses the address and, on that basis, generates the above data/predictions for the benefit of its clients for the following purposes:
- Address-level predictions: after LeadLabel has provided the addresses together with the corresponding predictions, the client may compare those addresses with the address data of its own customers. The client may then decide to:
- send customers marketing messages about its own products or services
- inform the customer of the need to report a change of address
- make these customers an offer to remain a customer
What does this mean for you? If you appear in the client’s address database (for example because you are a customer of a particular energy supplier that is also a client of LeadLabel), the client may be able to identify you and contact you. At no point does LeadLabel obtain any additional data from its client. LeadLabel makes predictions solely on the basis of the publicly available address.
- Move-timing predictions for customer acquisition: in that case, based on addresses and the associated predictions, the client may decide to approach certain addresses that are likely to undergo a move in the near future, for example by means of a flyer, in order to inform them about offers and services.
What does this mean for you? In this situation, you may be approached shortly before or after a move with an offer from a LeadLabel client inviting you to become a customer. LeadLabel does not know whether, or if so which, addresses the client chooses to approach.
- Move-timing predictions for address validation: in this situation, the client uses the addresses and related predictions to verify whether the addresses of current customers in the client’s database are still accurate. Under the GDPR, clients are required to ensure that personal data is accurate and, where necessary, kept up to date (Article 5(1)(d) GDPR). In this way, among other things:
- sending mail containing privacy-sensitive information to incorrect addresses can be prevented
- fraud can be prevented, for example in relation to car insurance where someone has intentionally failed to report a change of address
- customer loss can be analysed
What does this mean for you? If you are a customer of the relevant LeadLabel client, the client may use the information obtained to verify whether the address it has on file for you is still up to date.
3.3 On what legal basis does LeadLabel process personal data?
LeadLabel has a legitimate business interest in analysing address data, making predictions, and selling this information to clients. In addition, this does not result in a significant infringement of your privacy, nor does it otherwise have any undesirable consequences for your interests and rights. Publicly available property data is used exclusively to make predictions about the sale of properties. In addition to the address, LeadLabel uses only publicly accessible (non-sensitive) information about the housing market and properties, and no other personal data. LeadLabel also does not obtain any additional data from the client on the basis of which it could further identify data subjects (method of processing). The resulting information is then used by LeadLabel’s clients for address validation, customer retention, and marketing purposes. If you would like more information about the balancing test carried out by LeadLabel, you may send an email to contact @ leadlabel.com.
3.4 How long does LeadLabel retain address data and related predictions?
Your personal data is retained in accordance with applicable laws and regulations and for as long as necessary for the purposes for which the data was collected, with a maximum retention period of 18 months.
4. Which sources does LeadLabel consult?
LeadLabel collects data from various public sources, such as certain individual real estate agency websites, Statistics Netherlands (CBS), and open data portals.
5. In which cases does LeadLabel disclose personal data to third parties?
LeadLabel shares the collected addresses and the analyses and predictions performed on them with its clients, such as energy suppliers, telecom providers, moving companies, (health) insurers, banks, and pension funds.
LeadLabel also uses an external hosting provider to store data on LeadLabel’s behalf. This service provider processes personal data solely on behalf of LeadLabel. A so-called data processing agreement applies to processing by service providers, under which LeadLabel has ensured that the service provider will only process personal data on LeadLabel’s instructions.
6. Transfer outside the European Economic Area (EEA)?
The personal data collected and processed by LeadLabel is stored in the Netherlands and is not transferred to parties outside the EEA.
7. What are your rights?
Under the GDPR, you have a number of rights in relation to your data and its processing. Because LeadLabel only processes addresses and other public information relating to a property, LeadLabel is, in principle, not able to identify you if you wish to exercise one of your rights. For this reason, LeadLabel is not required to comply with these rights (Article 11 GDPR). For the sake of completeness, they are listed below:
- Access: You have the right to obtain access to your personal data and to additional information about the processing of your personal data.
- Rectification: You have the right to request the rectification of inaccurate or incomplete personal data.
- Right to be forgotten: In some cases, you have the right to request that LeadLabel delete your personal data (the right to be forgotten).
- Right to restriction: In some cases, you have the right to obtain restriction of the processing of your personal data, for example where you contest the accuracy of your personal data.
- Right to object: You have the right to object to the processing of personal data based on LeadLabel’s legitimate interests. LeadLabel will then cease processing the personal data unless LeadLabel demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, or which relate to the establishment, exercise, or substantiation of a legal claim.
- Right to data portability: At your request, you have the right to receive the personal data you have provided to LeadLabel in a structured, commonly used, and machine-readable format, and you have the right to transmit that data to another controller.
8. How does LeadLabel protect your personal information?
LeadLabel takes appropriate technical and organisational measures to protect your (personal) data against loss or any form of unlawful processing.
9. Can this privacy statement be amended?
This privacy statement may be amended. Any such amendments will be brought to your attention through the website.
10. Where can I file a complaint?
If you believe that data protection legislation has been violated and the matter cannot be resolved through consultation between you and LeadLabel, you have the right to lodge a complaint with a supervisory authority. In the Netherlands, this is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
