Privacy Policy

Effective Date: January 2026
Website: arrayleads.com

ArrayLeads (“we”, “us”, “our”) respects your privacy and is committed to protecting personal data. This Privacy Policy explains how personal data is collected, used, disclosed, and safeguarded when you visit arrayleads.com.

ArrayLeads is a content-based blog and podcast platform operated by Sveresa tmi (Finland).

This Privacy Policy should be read together with our Cookie Policy, Terms & Conditions, and Disclaimer.

1) Data controller & contact

Data Controller:
Sveresa tmi
Y-tunnus: 3592316-3
Finland

Contact:
info [@] arrayleads.com

No separate Data Protection Officer (DPO) has been appointed. All privacy-related enquiries are handled via the contact above.

2) Categories of personal data we process

We process only personal data necessary to operate a content website and a newsletter.

Contact data

name
email address

(collected when subscribing to the newsletter or requesting resources)

Technical data

IP address
device and browser type
operating system
basic diagnostics

Usage data

pages viewed
referring URLs
time spent on the site
basic interaction data

Analytics data

website usage data collected via Google Analytics (Google Tag)

ArrayLeads does not knowingly collect special categories of personal data and does not knowingly collect data from children under the age of 16.

3) Lawful bases for processing (GDPR)

Personal data is processed based on the following lawful grounds under the GDPR:

Consent — newsletter subscriptions and non-essential cookies
Legitimate interests — operating, securing, and improving the website; basic audience measurement via analytics
Legal obligation — where required to comply with applicable law

Where processing is based on consent, you may withdraw your consent at any time.

4) How we use personal data

Personal data is used only to:

operate and secure the website
deliver requested resources or newsletter communications
understand how content is used and improve site quality
respond to enquiries
comply with legal obligations

ArrayLeads does not use personal data for behavioural advertising or cross-site tracking.

5) Cookies & similar technologies

ArrayLeads uses:

strictly necessary cookies
analytics cookies (Google Analytics), where required, with consent

We do not use advertising or retargeting cookies.

You can manage cookies through your browser settings and, where applicable, on-site consent controls.
Further details are available in our Cookie Policy.

6) Third-party services & international transfers

We may share limited personal data with trusted service providers strictly as necessary, including:

Hosting and infrastructure providers
Email newsletter tools (for subscription management)
Analytics providers (Google Analytics)

Where data is transferred outside the EU/EEA, appropriate safeguards are used, such as Standard Contractual Clauses (SCCs) and provider-level security measures.

7) Data retention

Personal data is retained only as long as necessary:

Newsletter data — until you unsubscribe or withdraw consent
Analytics data — according to provider settings (typically up to 24–26 months)
Technical logs — retained for security and operational purposes for a limited period

8) Your rights (GDPR)

You have the right to:

access your personal data
request rectification or erasure
request restriction of processing
object to processing based on legitimate interests
receive your data in a portable format (where applicable)

To exercise your rights, contact info [@] arrayleads.com.

You also have the right to lodge a complaint with 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)

ArrayLeads does not sell personal information.

We do not engage in cross-context behavioural advertising and do not “share” personal information as defined under the CPRA.

If you are a California resident and have questions regarding your rights, you may contact us at info [@] arrayleads.com.

10) Security

We implement appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls, and reliance on reputable service providers.

No system is completely secure, and we cannot guarantee absolute security.

11) Third-party links & affiliates

ArrayLeads may contain links to third-party websites or affiliate resources.

We are not responsible for the privacy practices of third parties.
Affiliate tracking, where applicable, is handled by third-party platforms under their own policies.

See our Disclaimer and Cookie Policy for additional information.

12) Children’s data

ArrayLeads is not directed at children under 16, and we do not knowingly collect their personal data.

If you believe a child has provided personal data, please contact us so we can delete it.

13) Changes to this policy

We may update this Privacy Policy from time to time.
Changes take effect upon publication with a revised Effective Date.

14) Contact

Questions or requests regarding this Privacy Policy may be sent to:

info [@] arrayleads.com

(Email address is published in a non-clickable format to reduce spam.)