Privacy policy
Last updated: [date]
1. Who we are
Leadwin is provided by [Company Name AS], org. no. [000 000 000], [address]. Contact: [personvern@dittfirma.no].
2. Roles: data controller and data processor
When you, as a customer, use Leadwin to collect information from your visitors (for example name, email, and phone number), you, as the customer, are the data controller for that personal data. Leadwin is the data processor and processes the data only on your behalf and according to your instructions.
The relationship is governed by a data processing agreement in accordance with GDPR Article 28. [Describe how the agreement is entered into, for example by accepting the terms or as a separate appendix.]
3. What is your responsibility as a customer
- Having a legal basis for the collection, normally consent.
- Giving visitors clear information about purpose and use, and having a separate privacy policy.
- Handling access, rectification, and erasure requests from data subjects.
- Wording the consent text in the campaign.
4. What Leadwin processes
| Category | Examples | Purpose |
|---|---|---|
| Participant data | Name, email, phone, consent, game result | Deliver the campaign and give the customer leads |
| Anti-cheat | Device identifier, [IP address] | Prevent multiple plays per person |
| Customer account | Name, email, billing information | Manage subscription |
5. Subprocessors and storage
[List of subprocessors, storage location, and any transfers outside the EEA.]
6. Retention period
Participant data is stored for as long as the customer has the campaign, or until the customer deletes it. [Adjust.]
7. Security
[Describe technical and organizational measures.]
8. Rights
As a data subject, you have the right to access, rectification, erasure, restriction, data portability, and to withdraw consent. Participants should contact the business running the campaign. You can also file a complaint with the Norwegian Data Protection Authority (Datatilsynet).
9. Cookies
[Describe the use of cookies and local storage.]
10. Visitor statistics (analytics)
When you visit our website, we record page views, referring site, campaign parameters (UTM), browser, operating system, screen size, language, time zone, and approximate location (country and city) derived from your IP address. We use no cookies and store nothing on your device. The IP address is stored only for administrators in connection with security and statistics, and is automatically anonymized after 90 days; other statistics are deleted after 24 months at the latest. We respect "Do Not Track" and "Global Privacy Control": in that case, we don't record the visit. The legal basis is legitimate interest (Art. 6(1)(f)) in understanding and improving the service. [Adapt to your actual use and providers.]
Game visits via QR code or an embedded game are logged the same way (without content from the participant's form).
11. Contact
Privacy questions: [personvern@dittfirma.no].