1. Who We Are
This Privacy Policy explains how Smart City OÜ ("we", "us", "our"), a company incorporated under the laws of Estonia (registration number: 12245557, address: Laeva 2, Tallinn 10111, Estonia), collects, uses, and protects personal data when you visit or use our website cpa.leadgid.com.
We act as the data controller for personal data processed through this website, unless stated otherwise.
Contact: info@leadgid.com
2. What Data We Collect and Why
We collect personal data in the following cases:
2.1 Publisher (Affiliate) Registration
Data collected:
- First name
- Last name
- Email address
- Phone number
- Company name (if applicable)
Purpose: identification of the user in the personal account at my.leadgid.com; communication regarding offers and services; conclusion of contracts.
Legal basis: performance of a contract (Art. 6(1)(b) GDPR); consent (Art. 6(1)(a) GDPR) for marketing communications.
Retention period: for the duration of the contract and 3 years after its termination, unless a longer period is required by applicable law.
2.2 Advertiser Registration
Data collected:
- Company name
- First name
- Last name
- Email address
- Phone number
Purpose: negotiation and conclusion of advertising agreements.
Legal basis: performance of a contract (Art. 6(1)(b) GDPR).
Retention period: for the duration of the contract and 3 years after its termination.
2.3 Contact Form (Site Visitors)
Data collected:
- First name
- Last name
- Email address
- Company name
- Phone number
Purpose: responding to enquiries submitted through the contact page.
Legal basis: legitimate interest (Art. 6(1)(f) GDPR) — handling incoming requests from potential clients and partners.
Retention period: 1 year from the date of the last communication, unless a longer period is necessary.
3. Cookies and Tracking Technologies
We use cookies and similar technologies on our website. For full details on the types of cookies we use, their purposes, and how to manage your preferences, please refer to our Cookie Policy available at cpa.leadgid.com/cookie-policy.
4. Recipients and Third Parties
We may share your personal data with the following categories of recipients:
- Advertisers — for the purpose of fulfilling the services described in the relevant agreement;
- IT service providers and hosting companies — acting as data processors under data processing agreements;
- Analytics and marketing platforms (Google, Facebook/Meta) — for website analytics and advertising performance. These providers process data under their own privacy policies and, where applicable, standard contractual clauses;
- Competent authorities — where required by applicable law or court order.
We do not sell personal data to third parties.
5. International Data Transfers
Some of our third-party service providers may be located outside the European Economic Area (EEA). Where data is transferred to countries not covered by an adequacy decision of the European Commission, we ensure appropriate safeguards are in place, including the use of Standard Contractual Clauses (SCCs) approved by the European Commission under Art. 46 GDPR.
You may request a copy of the relevant safeguards by contacting us at info@leadgid.com.
6. Your Rights
Under the General Data Protection Regulation (GDPR), you have the following rights in relation to your personal data:
- Right of access (Art. 15) — you may request a copy of the personal data we hold about you;
- Right to rectification (Art. 16) — you may ask us to correct inaccurate or incomplete data;
- Right to erasure (Art. 17) — you may request deletion of your data where there is no overriding legal basis for continued processing;
- Right to restriction of processing (Art. 18) — you may ask us to restrict how we use your data in certain circumstances;
- Right to data portability (Art. 20) — you may request to receive your data in a structured, machine-readable format;
- Right to object (Art. 21) — you may object to processing based on legitimate interests or for direct marketing purposes;
- Right to withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at info@leadgid.com. We will respond within 30 days.
You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon): www.aki.ee.
7. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. These include SSL/TLS encryption (2048-bit), two-factor authentication, Web Application Firewall (WAF), firewalls, and access controls with role-based permissions and operation logging.
8. Changes to This Policy
We may update this Privacy Policy from time to time. Any material changes will be communicated via the website or by email where appropriate. The date of the latest version is indicated at the top of this document.
9. Contact
Smart City OÜ
Laeva 2, Tallinn 10111, Estonia
Email: info@leadgid.com
