Last updated: 26.05.2026 | Version 2.3
1. Data Controller
Le Leads SIA (“we”, “us”, “our”), is the data controller in respect of personal data collected through this website (the “Service”). Contact: hello@leleads.com.
2. Scope and Purpose
This Policy explains how we collect, use, share, and protect personal data of visitors and users who submit inquiries or request compensations through our Service. We operate as a lead generation intermediary — we do not sell flights or travel products directly.
3. Personal Data We Collect
3.1 Data you provide
- Identity & contact: full name, email address, phone number, country of residence.
- Travel preferences: origin and destination airports, travel dates, number of passengers, other optional information.
- Correspondence: any additional information you include in free-text fields or subsequent communications.
3.2 Data collected automatically
- Technical data: IP address, browser type and version, device type, operating system.
- Usage data: pages visited, time on site, referral URL, click-stream data.
- Cookies and similar technologies.
4. Legal Bases for Processing
We process your personal data on the following legal bases under Article 6 GDPR:
- to fulfil your request to be matched with service providers. Contract performance (Art. 6(1)(b)):
- fraud prevention, network security, analytics to improve the Service, and direct marketing of similar services (subject to your right to object at any time). Legitimate interests (Art. 6(1)(f)):
- where we obtain your consent for specific processing, such as receiving third-party promotional communications. You may withdraw consent at any time without affecting prior processing. Consent (Art. 6(1)(a)):
- where required by applicable law. Compliance with legal obligations (Art. 6(1)(c)):
5. How We Use Your Data
- Matching and referral: sharing your information with selected service providers who may fulfil your compensation request.
- Service communications: responding to enquiries and providing updates on your request.
- Service improvement: analysing usage patterns and user feedback to enhance functionality.
- Marketing: sending you information about related travel opportunities, subject to applicable marketing rules and your preferences.
- Legal compliance and protection: complying with regulatory requirements and protecting our rights.
6. Sharing of Personal Data and International Transfers
6.1 Third-party service providers
We engage third-party service providers who process personal data on our behalf or independently as controllers. These may include:
- Airlines, travel agencies, and brokers, collection services providers (recipients of your lead enquiry);
- IT infrastructure and cloud hosting providers;
- CRM, email marketing, and analytics platforms;
- Customer support tooling providers;
- Payment processors (if applicable);
- Legal, accounting, and compliance advisors and service providers.
Upon date transfer to third party service providers, the particular service providers may ask you to agree to their own privacy policy and terms of service.
6.2 International transfers
Some of our service providers are located outside the European Economic Area (“EEA”), including in countries that may not provide a level of data protection equivalent to that within the EU. Where we transfer personal data outside the EEA, we ensure an appropriate safeguard applies, which may include:
- An adequacy decision by the European Commission (Art. 45 GDPR);
- Standard Contractual Clauses approved by the European Commission (Art. 46(2)(c) GDPR); or
- Other lawful transfer mechanisms recognised under applicable law.
You may request a copy of the relevant transfer safeguards by contacting us at the address in Section 1.
6.3 Other disclosures
We may also disclose personal data to regulatory or law enforcement authorities where required by law, or to prospective acquirers in the context of a business sale or reorganisation, subject to appropriate confidentiality undertakings.
7. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable law. In general:
- Enquiry and lead data: retained for 36 months from the date of submission, unless a longer period is required for contractual or legal purposes.
- Marketing data: retained until you opt out or withdraw consent.
- Technical and log data: retained for up to 36 months.
Once data is no longer needed, it is securely deleted or anonymised.
8. Your Rights
Subject to applicable law, you have the following rights in respect of your personal data:
- Access (Art. 15): obtain confirmation of whether we process your data and receive a copy.
- Rectification (Art. 16): request correction of inaccurate or incomplete data.
- Erasure (Art. 17): request deletion of your data in certain circumstances (“right to be forgotten”).
- Restriction (Art. 18): request that we restrict processing pending resolution of a dispute.
- Portability (Art. 20): receive your data in a structured, machine-readable format and/or request transmission to another controller.
- Objection (Art. 21): object at any time to processing based on legitimate interests or for direct marketing purposes.
- Withdrawal of consent: withdraw previously given consent at any time without affecting prior lawful processing.
To exercise any right, contact us at hello@leleads.com. We will respond within one calendar month (extendable by a further two months for complex requests). You also have the right to lodge a complaint with your competent supervisory authority (e.g., your national data protection authority).
9. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction, including encryption in transit (TLS), access controls, and regular security assessments. However, no internet transmission is completely secure; we cannot guarantee absolute security.
10. Cookies
We use cookies and similar tracking technologies on our Service. For full details of the cookies we use, their purpose, and how to manage your preferences, please see our separate Cookie Policy.
11. Children’s Data
Our Service is not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If you have purposefully submitted personal data of your children on their behalf, they will be processed as any other data described in this Privacy policy. If you believe a child has submitted personal data through our Service and you, as a legal guardian, object to it, please contact us.
12. Changes to This Policy
We may update this Policy from time to time to reflect changes in our practices or applicable law. We will post the revised version with a new “Last updated” date. Where changes are material, we will provide more prominent notice (e.g., by email or a website banner). We encourage you to review this Policy periodically.
13. Contact Us
If you have any questions, concerns, or requests regarding this Policy or our privacy practices, please contact:
Email: hello@leleads.com
Le Leads SIA
Attention: Data Protection Officer