Privacy Policy

ArrayLeads (“we”, “us”, “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit arrayleads.com and use our services.

1) Data Controller & Contact

Controller: ArrayLeads (Finland)
Contact: info [@] arrayleads.com

EU Representative / DPO: Not appointed. Privacy enquiries are handled via the contact above.

2) Categories of Personal Data We Process

• Contact Data: name, email address, company, role (e.g., when subscribing or requesting resources).
• Technical Data: IP address, device and browser type, operating system, basic diagnostics.
• Usage Data: pages viewed, referring URLs, time on site, form interactions.
• Marketing & Tracking Data: cookies, pixels (e.g., Google Analytics, Meta Pixel), UTM parameters, affiliate tracking IDs.
• Transaction Data: order metadata (via third-party processors such as Payhip, Stripe, PayPal). We do not store full payment card numbers on our servers.

We do not knowingly collect data from children under 16.

3) Lawful Bases for Processing (GDPR)

• Consent — newsletters, non-essential cookies, and specific marketing.
• Contract — providing purchased products/services or free resources you requested.
• Legitimate Interests — site analytics, service improvement, fraud prevention, basic audience measurement, B2B communications.
• Legal Obligation — accounting, tax, compliance.

4) How We Use Personal Data

• To operate, secure, and improve the website and services.
• To deliver resources (free or paid) and provide customer support.
• To send relevant updates and marketing (with consent or where permitted by law).
• To measure campaign performance and attribute traffic, including via affiliate tracking.
• To comply with legal and financial obligations.

5) Cookies & Similar Technologies

We use essential, analytical, and marketing cookies. You can manage cookies via your browser settings and, where available, our on-site cookie controls. For details, see our
Cookie Policy.

6) Disclosures & International Transfers

We share data with trusted processors strictly as necessary, including:

• Hosting & Infrastructure (website/CDN, security, backups).
• Email & Marketing (e.g., Acumbamail for email automation).
• Analytics & Attribution (e.g., Google Analytics, Meta Pixel).
• Payments & Commerce (e.g., Payhip, Stripe, PayPal).
• Professional Services (legal, accounting, compliance tools).

Where data is transferred outside the EU/EEA, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses (SCCs) and provider-implemented security controls.

7) Data Retention

• Newsletter data is retained until you unsubscribe or withdraw your consent.
• Purchase records: kept per applicable law (typically up to 6–10 years for accounting).
• Analytics data: retained per provider defaults (commonly up to 26 months) unless aggregated/anonymised earlier.

8) Your Rights (GDPR)

You have the right to request access, rectification, erasure, restriction, portability, and to object to processing where applicable. Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

To exercise your rights, contact info [@] arrayleads.com. You also have the right to complain to your local supervisory authority. In Finland, this is the Office of the Data Protection Ombudsman.

9) U.S. State Privacy Notices (e.g., CCPA/CPRA)

We do not “sell” or “share” personal information as those terms are defined under the CPRA. California residents may request:

• Disclosure of the categories/sources of personal information collected and the purposes of use.
• Access to and deletion of personal information, subject to exceptions.
• Correction of inaccurate information.
• To limit specific uses of sensitive personal information (if any).

Submit requests via info [@] arrayleads.com. If we ever engage in activities considered “sharing” for cross-context behavioral advertising, you will be provided a mechanism to opt out.

10) Security

We implement technical and organisational measures appropriate to risk (e.g., encryption in transit, access controls, least-privilege, provider due diligence). No method of transmission or storage is 100% secure.

11) Third-Party Links & Affiliates

Our site may link to third-party sites or include affiliate offers. We are not responsible for their privacy practices. Affiliate links may use cookies or tracking IDs to attribute referrals; see our
Disclaimer
and
Cookie Policy
for more information.

12) Children’s Data

Our services are not directed to children under 16, and we do not knowingly collect their personal data. If you believe a child has provided us with data, please get in touch with us to request its deletion.

13) Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be posted on this page with a new Effective Date.

14) How to Contact Us

Questions or requests about this Privacy Policy can be sent to: info [@] arrayleads.com