Definitions

We are Live Leads Limited of Mill House, Mill Lane, Sissinghurst, Kent, TN17 2HX and "we", "us", "our" and "ours" refer to Live Leads Limited and all branch offices of Live Leads Limited . Live Leads Limited, for the purposes of this agreement, includes any subsidiary or associated company (as defined by s.736 Companies Act 1985) of Live Leads Limited.

Live Leads Limited seeks to establish trusting relationships based on respect for personal identity and information by promoting the use of fair information practices. This privacy statement covers the site www.etc.co.uk ("our Web site").

We are committed to protecting the privacy of individuals in accordance with the UK Data Protection Acts 1984 and 1998. We have notified and we are authorised by the Data Protection Commissioner to process personal data.

We are registered on the Public Register of Data Controllers (Data Controller Name - Live Leads Limited. Registration Number PZ8643293) and all the information held on the register is available to the public for inspection. We collect, use and disseminate the personal information provided to us by the data subject ("you") only in accordance with the policies and procedures outlined below.

We will provide the following up-to-date information on request:

1. What personally identifiable information www.etc.co.uk collects.

2. What personally identifiable information third parties collect through the Web site.

3. What organisation collects the information.

4. How Live Leads Limited uses the information.

5. With whom Live Leads Limited may share user information.

6. What choices are available to users regarding collection, use and distribution of the information.

7. What types of security procedures are in place to protect the loss, misuse or alteration of information under Live Leads Limited control.

8. How users can correct any inaccuracies in the information.

9. If users have questions or concerns regarding this statement, they should first contact Customer Care using any of the means of contact indicated on the 'Contact Us' page. Live Leads agree to notify users of:

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Information Collection and Use

Information Collection
Live Leads Limited is the sole owner of the information collected on www.etc.co.uk. Live Leads Limited collects information from our users at several different points on our Web site.

Information Use
Personal Data that you provide via our Web site will be used solely for the purpose of providing you with the services you have requested, to update and enhance our records so that our services can be improved and email addresses are collected by www.etc.co.uk in order to mail you alerts and bulletins (see Communications below). Your address may also be occasionally used to send you other information that you have previously indicated you would like to receive from Live Leads Limited. Your Personal Data will be retained for as long as the purpose for which the information was collected continues. It will then be destroyed unless its retention is required to satisfy legal, regulatory or accounting requirements or to protect our interests.

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Profile

We may store information that we collect through cookies, log files, clear gifs, and/or third parties to create a profile of our users. A profile is stored information that we keep on individual users that details their viewing preferences. Consequently, collected information is tied to the users' personally identifiable information to provide offers and improve the content of the site for the user. This profile is used to tailor a user's visit to our Web site, and to direct pertinent marketing promotions to them. We do not share your profile with other third parties.

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Cookies

A cookie is a piece of data stored on the user's computer tied to information about the user. Cookies are now used by www.etc.co.uk. When a user visits www.etc.co.uk a session is started, the system may then generate a random string of characters (sessionID) and stores that in a cookie (a session cookie). This cookie only tells us information like which advert or website you came from before visiting www.etc.co.uk (e.g. a search engine, a partner site or one of our own websites).

Importantly, we CANNOT identify individual users from this cookie - we simply gather information about where our users come from. Disabling cookies will not affect your use of www.etc.co.uk but it may make some processes slower.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies once we have given permission for them to set cookies for advertising.

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Third Party Advertising

Some of the ads appearing on this Web site are delivered to users by our Web advertising partners. Information about users' visit to this site, such as number of times they have viewed an ad (but not user name, address, or other personal information), is used to serve ads to users on this site. This privacy statement does not cover the use of cookies by any advertisers.

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Log Files

Like most standard Web site servers we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyse trends, administer the site, track user's movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information. We use a tracking utility called modlogan that uses log files to analyse user movement.

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Communications from the Site

Legal Disclaimer
Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our Web site.

Aggregate Information (non-personally identifiable)
We share aggregated demographic information with our partners and advertisers. This is not linked to any personally identifiable information. We do not share any information at this time. This Privacy Policy will be amended and user will be notified of the amendment if we do so.

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Business Transitions

In the event Live Leads Limited goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, users' personal information will, in most instances, be part of the assets transferred. Users will be notified via prominent notice on our Web site for 30 days prior to a change of ownership or control of their personal information. If as a result of the business transition, the users' personally identifiable information will be used in a manner different from that stated at the time of collection they will be given choice consistent with our notification of changes section.

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Choice/Opt-out

If we collect your email address, our users are given the opportunity to 'opt-out' of having their information used for purposes not directly related to our site at the point where we ask for information. You agree that you do not and will not consider that being contacted in the ways described in this Privacy Policy will breach any of your rights under The Privacy and Electronic Communications (EC Directive) Regulations 2003 unless you have opted out as described below.

Users who no longer wish to receive our newsletter or promotional communications may opt-out of receiving these communications by replying to unsubscribe in the subject line in the email or email us at "customer care at 4 x 4 x bye dot co dot uk". We also offer an opt-out mechanism on any newsletter and have a link on every page in the www.etc.co.uk site. Or the user may contact us using any of the methods indicated on the Contact Us page to opt-out.

Users of our site are always notified when their information is being collected by any outside parties. We do this so our users can make an informed choice as to whether or not they should proceed with services that require an outside party.

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Links

This Web site contains links to other sites. Please be aware that we, Live Leads Limited, are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information. This privacy statement applies solely to information collected by this Web site.

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Surveys & Contests

From time-to-time our site may request information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as post code). Contact information may be shared with the contest or survey sponsors and to notify the winners and award prizes. Anonymous Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site. Users' personally identifiable information is not shared with third parties unless we give prior notice and choice. Though we may use an intermediary to conduct these surveys or contests, they may not use users' personally identifiable information for any secondary purposes.

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Security

This Web site takes every precaution to protect our users' information. When users submit sensitive information via the Web site, their information is protected both online and off-line.

All of our users' information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to personally identifiable information. Our employees must use password-protected screen-savers when they leave their desk. When they return, they must re-enter their password to re-gain access to user information. Furthermore, ALL employees are kept up-to-date on our security and privacy practices. Every quarter, as well as any time new policies are added, our employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure our users' information is protected. Finally, the servers that store personally identifiable information are in a secure environment.

If users have any questions about the security at our Web site, users can send an email to customercare(at)etc(dot)co(dot)uk

Supplementation of Information
In order for this Web site to properly fulfil its obligation to users it is necessary for us to supplement the information we receive with information from 3rd party sources.

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Enhancement of Marketing Profile

We may purchase third party marketing data and add it to our existing user database to better target our advertising and provide pertinent offers we think our users would be interested in. We use this information to enhance or overlay the 'profile' of individual users. This aggregate marketing data is therefore tied to the users' personally identifiable information. See also the "Profile."

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Correcting/Updating/Deleting/Deactivating Personal Information

If a user's personally identifiable information changes (such as post code, phone, email or postal address), or if a user no longer desires our service, we provide a way to correct, update or delete/deactivate users' personally identifiable information. This can usually be done at the Contact Us page or by emailing our Customer Care at customercare(at)etc(dot)co(dot)uk. Or contact us by telephone or postal mail at the contact information listed below.

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Notification of Changes

If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected.

If, however, we are going to use users' personally identifiable information in a manner different from that stated at the time of collection we will notify users via email. Users will have a choice as to whether or not we use their information in this different manner. However, if users have opted out of all communication with the site, or deleted/deactivated their account, then they will not be contacted, nor will their personal information be used in this new manner. In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our Web site notifying users of the change. In some cases where we post a notice we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices.

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