Adviser Lead Engine
Privacy Policy
Contents
- Who We Are
- What This Policy Covers
- What We Collect
- How We Use It
- Our Lawful Bases
- Who We Share It With
- International Transfers
- How Long We Keep It
- How We Protect It
- Your Rights
- Deleting Your Account
- Children
- Changes to This Policy
- Contact Us
1. Who We Are
Adviser Lead Engine (ALE) is a brand of Obsidian Software Limited, a company registered in the United Kingdom with company number 17256297, whose registered office is at Suite Ra01, 195-197 Wood Street, London, England, E17 3NU. In this policy, "we", "us" and "our" mean Obsidian Software Limited trading as Adviser Lead Engine.
For the account data of people who use the ALE app, we are the controller. For the leads we generate and manage for an adviser firm, we act on that firm's behalf as its processor, under our agreement with the firm, and the firm decides how those leads are used.
2. What This Policy Covers
This policy covers the ALE mobile app for iPhone and Android, which is available only to people invited by an adviser firm that works with us. It explains what personal data the app collects, why, and what you can do about it.
It does not cover the lead forms and adverts that people respond to before they become leads. Those carry their own privacy notices.
3. What We Collect
Your Account
| Data | Why |
|---|---|
| Full name | Entered when you register. Shown to you in the app and to our team. |
| Email address | The address your invite was sent to. Used to sign you in with a one time code and to link you to your firm. |
| One time sign in codes | Emailed to you each time you sign in. They expire after a short time. |
| Firm membership | Which firm you belong to, and whether your invite has been accepted. |
| Sign in and security records | Account creation and sign in times, and technical data such as IP address, kept by our authentication provider to keep accounts secure. |
Information You Work With in the App
| Data | Why |
|---|---|
| Leads | For each lead your firm receives: their full name, phone number, how they currently get leads (their answer on the form), when the lead arrived, its stage (Triage, Booked, Closed or Lost) and when it was first contacted. We may also hold an email address and postcode supplied with the lead, which the app does not show. |
| Notes | Notes you or your colleagues add to a lead. |
| To Do answers | Answers, links and confirmations you give for the onboarding items we need from your firm. |
| Files and links | Links you share with us, and documents and files we share with your firm. |
| Updates | Our progress updates to your firm, and which ones you have read. |
| Campaign figures | Advertising performance for your firm, such as spend, impressions, clicks and leads. These are business figures and do not identify anyone. |
On Your Device
- The app keeps you signed in by storing a secure session on your device, and remembers which firm you last viewed.
- When the app checks for updates, your device sends basic technical information, such as the platform, app version and IP address, to our app delivery provider.
What We Do Not Collect
- We do not use advertising, analytics or tracking tools in the app, and we do not track you across other companies' apps or websites.
- When you tap Call or WhatsApp Call, the app opens your phone or WhatsApp. We do not record calls or access your call history, contacts, messages, photos or location. WhatsApp's own privacy policy applies to anything you do in WhatsApp.
4. How We Use It
- To create and secure your account, sign you in, and give you access to your firm.
- To show your firm its leads, campaign results, updates, files and outstanding items, and to save the changes you make.
- To run our marketing and lead generation service for your firm, including understanding what we need from you.
- To deliver app updates and keep the app working and secure.
- To respond when you contact us, and to meet our legal obligations.
We do not sell personal data, and we do not use it for automated decisions that have legal or similarly significant effects on you.
5. Our Lawful Bases
Under UK data protection law (the UK GDPR and the Data Protection Act 2018) we rely on:
- Contract, to provide the service your firm has agreed with us, including your access to the app.
- Legitimate interests, to keep the app secure, prevent misuse, support you and improve the service, where those interests are not outweighed by your rights.
- Legal obligation, where the law requires us to keep or disclose information.
For lead data, we process it on your firm's instructions, and your firm is responsible for its own lawful basis.
6. Who We Share It With
- Your firm. Everyone your firm has invited sees the same leads, updates, files and To Do items. Our team sees your firm's information so that we can run the service.
- Service providers who process data for us under contract and only on our instructions, including Supabase (database and sign in), Cloudflare (file storage), Expo (app delivery and updates), our email delivery provider (sign in codes), and Apple and Google (app distribution).
- Legal and safety. Where the law requires it, or to protect our rights, our users or others.
- Business changes. If our business is sold or reorganised, personal data may transfer to the new owner under this policy.
7. International Transfers
Some of our service providers may store or process data outside the United Kingdom. Where they do, we make sure it is protected by an adequacy decision or by appropriate safeguards, such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.
8. How Long We Keep It
- Your account is kept while it is active. If you delete it, your account is removed straight away, and any copies in our backups are overwritten in the normal backup cycle.
- Lead data and your firm's information are kept for as long as your firm works with us, and then for any period set out in our agreement with your firm or required by law.
- Notes and To Do answers belong to your firm's record, so they stay with your firm if you delete your own account.
9. How We Protect It
Data is encrypted in transit and stored with providers that encrypt it at rest. Access is controlled per firm, so people only see their own firm's information, and our team's access is limited to what they need. The app holds no passwords: you sign in with a one time code sent to your email. No system is completely secure, so please tell us straight away if you think your account has been misused.
10. Your Rights
You have the right to:
- access the personal data we hold about you;
- have it corrected if it is wrong;
- have it deleted;
- restrict or object to how we use it;
- receive it in a portable format; and
- withdraw any consent you have given, without affecting what happened before.
To use any of these rights, email [email protected]. We will reply within one month. If your request is about lead data, we may pass it to the firm concerned, which decides how its leads are handled.
If you are unhappy with how we have handled your data, you can complain to the Information Commissioner's Office at ico.org.uk. We would appreciate the chance to put things right first.
11. Deleting Your Account
You can delete your account at any time in the app: tap your profile in the top right, open Settings, then Delete Account. This permanently removes your name, email and sign in, and ends your access to your firm. Your firm's leads, notes and files stay with your firm. You can also ask us to delete your account by emailing [email protected].
12. Children
The ALE app is a business tool for adviser firms and is not intended for anyone under 18. We do not knowingly collect data from children.
13. Changes to This Policy
We may update this policy from time to time. We will change the date at the top when we do, and tell you in the app or by email if the changes are significant.
14. Contact Us
Obsidian Software Limited, trading as Adviser Lead Engine
Company number 17256297, registered in the United Kingdom
Registered office: Suite Ra01, 195-197 Wood Street, London, England, E17 3NU
Email: [email protected]