Privacy policy

The purpose of this Privacy Policy is to inform users of the site (the “Site”) (regardless of where they access or visit the Site from) as to how we look after the personal information when they visit the Site and tell them about their privacy rights and how the law protects them.

Because we offer our services on a global basis we have chosen to use the European Union (GDPR) model, often considered as the strictest model for user transparency, as the format for this Privacy Policy.


Personal data:

Depending on where the users of our Site are located, and the privacy legislation that applies to the collection and processing of their personal information, personal data means any information relating to a household or an identified or identifiable natural person (hereinafter referred to as “data subject”); an “identifiable natural person” means a natural person who can be identified, directly or indirectly, in particular by reference to a identifier, such as a name, an identification number, data of location, an online identifier, or one or more elements specific to their physical, physiological, genetic identity, psychological, economic, cultural or social.


Any operation or set of operations performed or not using automated processes and applied to data or sets of personal data, such as collection, recording, the organization, structuring, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, broadcast or any other form of posting available, rapprochement or interconnection, limitation, erasure or destruction.


The French Law known as “Informatique et Libertés” n°78-17 of January 6, 1978.


The natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of processing.


The EU General Data Protection Regulation of April 27, 2016.


The natural or legal person, public authority, service or any other body which receives communication of personal data, whether or not it is a third party.


When using the Site, you must read this Privacy Policy and accept it by ticking the box provided for this purpose.
In the event that this Privacy Policy would be modified, you must read its updated version and check the box provided for this purpose during any new connection after the entry into force of the modified privacy policy. However, the personal data are processed in accordance with the Privacy Policy in force at the time of their collection.


Our Site is not intended for minors. No one under age 18 may provide any information to or on the Site. We do not knowingly collect personal information from minors. If you are under 18, do not use or provide any information on this Site or through any of its features, register on the Site, make any purchases through the Site, use any of the interactive or public comment features of this Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a minor, we will delete that information. If you believe we might have any information from or about a minor, please contact us using the form to that effect on the Contact page of our Site.


We have set out below, in a table format, a description of all the ways we plan to use your personal data, and, if you are based in the European Union or the UK, which of the legal bases we rely on to do so. Where we rely on legitimate interests as the legal basis we have also identified what those legitimate interests are where appropriate.





Creation and management of the personal online account

Email address and password

Performance of the contract/service

2 (two) years from the end of the subscription

Login to personal account

Email address and password,

Performance of the contract/service

2 (two) years from the end of the subscription

Carrying out an IQ test by the User

Name, first name, email address

Performance of the contract/service

2 (two) years from the end of the subscription

Management of subscription payment - invoicing Maintaining the accounting

Bank details Identity, postal address

Performance of the contract/service

13 (thirteen) months from the debit date or 15 (fifteen) months if payment is made with a debit card with a deferred payment date.

Invoicing Bookkeeping

Identity, postal address, means of payment used

Compliance with a legal obligation (to comply with applicable accounting laws)

The current financial year plus ten (10) years.

Prevention and fight against computer fraud

Usage and connection logs relating to user actions the User on the Site, technical logs recording the activity of software and hardware components used by the User, IP address

Legitimate interest

For logs: 6 (six) months from the last connection


For the IP address: 1 year from its registration

Managing requests to exercise rights with respect to personal data

Last name, first name, gender, email address, telephone number, content of the request, ID if necessary

Compliance with a legal obligation

5 (five) years from the request. Identity document: time necessary to verify the identity of the person

Use of cookies for statistical analysis purposes and improvement of the Site

IP Address


5 (five) years from the last connection.


Personal data is hosted by the company OVH SAS in France.


EU and UK residents

Because we are based in the United Kingdom, we will also process your personal data in the United Kingdom. This will involve transferring your information to the United Kingdom.

In addition, a number of our service providers are based outside the UK and European Economic Area so their processing of our users’ personal data in connection with the services they provide to them will also involve a transfer of information outside the UK and EEA.

If you are based in the UK or European Union, please note that whenever we transfer your personal information out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us using the form to that effect on the contact page of our Site, if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

Canadian residents

If you are based in Canada please note that when you connect to our Site or when we provide you with our services we will transfer your personal information outside of Canada for processing in accordance with this Privacy Policy.

We will also transfer outside of Canada the personal information about you that we collect, that we receive from third parties or that you provide to us as described in this Privacy Policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Site improvement and optimization).

When we transfer your personal information in and to a foreign country, these countries have different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this Privacy Policy and applicable Canadian privacy legislation. For more information on our policies and practices with respect to the use of service providers located outside of Canada please contact us using the form to that effect on the contact page of our Site.

By submitting your personal information or engaging with the Site, you consent to this transfer, storage, or processing.


The Controller of the personal data is the company "ADS LEADS LTD" whose headquarters are located at:

Suite 5, 39-41 Chase Side, Southgate, London, N14 5BP, UNITED KINGDOM.

The recipients of the personal data are:

In any case, the User is hereby informed that no personal information concerning him is the subject of communication to advertising agencies or in general any company involved in the advertising field. No personal data is shared or communicated without the User's consent outside of the recipients listed above.

Notwithstanding the foregoing, we may disclose personal information that we collect or you provide as described in this privacy policy to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ADS LEADS LTD's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by ADS LEADS LTD about our Site users is among the assets transferred.

We may also disclose your personal information:


Data security and confidentiality

In accordance with its security obligation, ADS LEADS LTD undertakes to ensure the confidentiality and security of personal data by compliance with the requirements of the LIL and the GDPR. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.  

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.


Article 7.1. Right of access (article 15 of the GDPR)

You have the right to obtain confirmation that personal data concerning you are or are not processed. In the event that the data is processed, you have a right of access to this data and to following information:

  1. The purposes of the processing;
  2. The categories of personal data concerned;
  3.  The recipients or categories of recipients to whom the data have been communicated or will be communicated;
  4.  If possible, the planned retention period of the data or, when this is not possible, the criteria used to determine this period;
  5.  The existence of the right to request the rectification or erasure of data, or limitation of processing or the right to object to the processing;
  6.  If you are based in France, the right to lodge a complaint with the CNIL as a supervisory authority; or with your national supervisory authority for data protection matters if you are based in the UK or in another country of the EU;
  7.  When personal data is not collected from you directly, any information available regarding the source of the data;
  8.  The existence of automated decision-making, including profiling and, at least in such cases, useful information regarding the underlying logic, as well as the importance and intended consequences of this processing for you.

A copy of the data subject to the processing will be provided to you.

Payment of reasonable fees based on administrative costs for any additional copies you request may be required.

If you request a copy of the data digitally, this will be provided to you in commonly used digital form unless you asked for it to be otherwise.

Finally, the right to obtain a copy of personal data should not infringe the rights and freedoms of others.

Article 7.2. Right of rectification (article 16 of the GDPR)

You have the right to request the correction of your data which are inaccurate, without undue delay. You also have the ability to obtain that incomplete personal data about you are completed including by providing an additional declaration to that effect.

Article 7.3. Right of erasure (article 17 of the GDPR)

You have the right to request the erasure of your personal data within as soon as possible when one of the following reasons applies:

  1.  Personal data is no longer necessary for the purposes of purposes for which they were collected or processed another way ;
  2.  You withdraw your consent on the basis of which the processing is based and it there is no other legal basis for the processing concerned. The withdrawal of consent applies for the future;
  3.  You exercise your right to object and there is no other required legitimate reason for the processing;
  4. Personal data has been subject to unlawful processing;
  5.  Personal data must be erased to comply with a legal obligation.

You are informed that the right of erasure may not apply if the processing is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal rights.

Article 7.4. Right to restriction of processing (article 18 of the GDPR)

You have the right to request the limitation of the processing of your personal data when one of the following applies:

  1.  Verification of your data after a dispute from you on the accuracy of your personal data;
  2.  The processing is unlawful and you object to the erasure of your personal data and demand the limitation of their use;
  3.  "ADS LEADS LTD" no longer needs your personal data concerning for processing but the data is necessary for you for the establishment, exercise or defense of legal rights ;
  4.  You have objected to the processing and "ADS LEADS LTD" verifies whether the legitimate reasons pursued by "ADS LEADS LTD" take precedence over your legitimate reasons.

Article 7.5. Right to data portability (article 20 of the GDPR)

You have the option to receive your personal data in a format that is structured, commonly used and machine readable when:

  1. Processing is based on consent or performance of a contract;
  2.  And the processing is carried out using automated processes.

The personal data concerned are those provided/entered by the user.

As part of the exercise of this right, you have the right to obtain that your personal data is transmitted directly to another data controller when technically possible.

The right to portability must not infringe the rights and freedoms of third parties.

Article 7.6. Right to object (article 21 of the GDPR)

In application of the right of opposition, you have the right to oppose at any time, for reasons relating to your particular situation, the processing of personal data based on the legitimate interests of “ADS LEADS LTD”.

Personal data will no longer be processed unless it is demonstrated that legitimate and compelling grounds for the processing exist and prevail over your interests and your rights and freedoms or for the establishment, exercise or defense of legal rights.

Article 7.7. Fate of post-mortem personal data

In application of the law, you have the right to define your guidelines for retention, erasure and communication of your personal data in the event of death.

You can communicate your instructions to us, or register them with a certified digital trusted third party. You can therefore designate the person of your choice who will be responsible for carrying out your instructions. Otherwise, it will be your heirs.

"ADS LEADS LTD" will naturally respect your guidelines and undertakes to destroy personal data after their communication to the designated person, if applicable, except in the event that "ADS LEADS LTD" should still keep these personal data due to a legal obligation or for evidentiary purposes.

U.S Residents: Your State Privacy Rights

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

The exact scope of these rights may vary by state. To exercise any of these rights please contact us via the form to that effect on the Contact page of our Site. To appeal a decision regarding a consumer rights request please contact us using the email:


Article 8.1. Procedure to exercise rights

For all requests concerning personal data processed by "ADS LEADS LTD", you can send your requests in the following form or to the following addresses:

“ADS LEADS LTD” may ask you for a copy of your document identity card in case of doubt about your identity.

Article 8.2. Response time

“ADS LEADS LTD” has a period of one (1) month upon receipt to respond to your request. This delay can be extended to two months given the complexity and number of requests. “ADS LEADS LTD” will inform the person concerned within a month from their request.

In the event that you exercise your right of deletion or your right to erasure, you are informed that "ADS LEADS LTD" may be required to archive your personal data before deleting it.

You also have the right to lodge a complaint with the CNIL, the French supervisory authority ( if you reside in France, or before the supervisory authority of your country of residence if you live abroad.


Some cookies require your consent so that they can be installed and others only require information.

Third-party cookies may be installed on the Site

Article 9.1. Third-party cookies

Third-party cookies are installed on the Site during your navigation, These are Google analytics® and Google Tag Manager® cookies.

These cookies aim to measure the audience in order to generate attendance statistics and to improve the site, in particular via the creation and placement of tracking tags. The cookie website banner on our Site allows the User to accept, refuse or configure these cookies.

Article 9.2. Managing cookies

Cookie management on the Site

During the first visit to the Site, a banner cookie will appear, allowing you to:

Concerning cookies for which consent is required, the User is informed that they can modify their choices when they choose so.

Management of cookies offered by your browser software

You have the ability to configure your navigation software in order to:

If you have accepted in your navigation software of each terminal the recording of Cookies on each terminal, the Cookies integrated into the pages and content you have viewed may be stored temporarily – without being able to exceed thirteen (13) months – in a space dedicated to your terminal. They will be readable only by their issuer.

If you withdraw your consent, please note that a cookie will be installed to deactivate the storage of other cookies on your terminal.

In order to configure your navigation software, you must refer to your browser's help menu.

Configuring your smartphone

To find out about the cookie management policy on your smartphone, you can consult the following pages:



You are informed that depending on the settings you activate, you may no longer be able to use all or some of the functionalities of the Site.


While we take all reasonable steps to protect the privacy of our Site visitors, we cannot promise that the current limitations of our online applications programming will address every browser setting or honor every personal browser preference. In particular, we have not implemented the necessary program changes to honor “Do Not Track” or “DNT” browser signals. As our online applications programming is refined, we will take all reasonable steps to honor such requests in the future. Please return to this Privacy Policy for further updates on this topic.

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