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Privacy Policy

Last updated: date of publication

This English translation is provided for convenience only. In the event of any discrepancy, the German version is legally binding.

01Overview

In this privacy policy, we inform you in accordance with Art. 13 of the General Data Protection Regulation (GDPR) about which personal data we process on the Leadpartner website, for what purposes and on what legal basis, and what rights you have.

Leadpartner is a B2B website of L-P GmbH for traffic partnerships in the dating industry. It is aimed at businesses that want to buy or sell traffic.

At a glance

  • We do not use cookies or any analytics, tracking or advertising tools.
  • When you access the website, the technical access data required for this is processed.
  • If you use the partner inquiry form, we process your details to handle your inquiry and forward them to our team via the email service Resend (USA).

02Controller

The controller within the meaning of Art. 4(7) GDPR responsible for data processing on this website is:

Service provider
L-P GmbH
Ballindamm 27
20095 Hamburg
Germany
Represented by the managing director
Andrej Feldhinkel

If you have any questions about data protection or wish to exercise your rights, you can contact us at any time using the contact details above.

03Data protection officer

You can reach our data protection officer at: Add name or organization and contact details of the data protection officer—remove this section if none has been appointed

04Hosting and server log files

This website is hosted by the following provider: Add name and address of the hosting provider. Server location: Add server location; if outside the EU/EEA, state the legal basis for the third-country transfer.

Each time the website is accessed, technical access data is necessarily transmitted to the server, in particular:

  • IP address
  • date and time of access
  • requested URL
  • referrer URL (the previously visited page), if transmitted
  • browser type and version as well as operating system (user agent)

This data is processed to deliver the website and to ensure its secure and stable operation, for example to detect malfunctions and defend against attacks. The hosting provider may store it in server log files for these purposes. Retention period: Add retention period of the server log files.

The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in providing our website securely and reliably. The hosting provider acts as our processor (Art. 28 GDPR). Confirm that a data processing agreement has been concluded with the hosting provider

05Encrypted transmission (TLS)

This website is delivered via an encrypted HTTPS connection (TLS). Data you transmit to us—such as the details you enter in the inquiry form—is thus protected against access by unauthorized parties while in transit.

06Inquiries via the partner inquiry form

You can use the partner inquiry form to let us know whether you would like to buy or sell traffic. In doing so, we process the following information:

Required information

  • your intent (buy traffic or sell traffic)
  • if you buy traffic, the range of your monthly budget; if you sell traffic, the range of your monthly traffic volume
  • name
  • company
  • email address
  • country

Optional information

  • URL of your website or app
  • your Telegram username
  • target countries or countries your traffic comes from (“GEOs”)
  • if you buy traffic: preferred pricing models (e.g., SOI, DOI, CPA/PPS, RevShare, CPC/CPM)
  • if you sell traffic: traffic sources (e.g., SEO, social, push, email)
  • your message (free text)

Information added automatically

  • the language version of the website you used
  • date and time of submission

We process this data to handle your inquiry, to get in touch with you and to initiate or perform a business relationship. The legal basis is Art. 6(1)(b) GDPR (pre-contractual steps taken at your request or performance of a contract). As our services are aimed at businesses, we additionally base the processing on Art. 6(1)(f) GDPR where you act as a contact person for a company. Our legitimate interest lies in efficiently answering business inquiries and initiating business relationships.

If you contact us directly by email, we process the data you provide for the same purposes and on the same legal bases.

07Email delivery via Resend

To deliver your inquiry, we use the transactional email service Resend, provided by Plus Five Five, Inc., 2261 Market Street #5039, San Francisco, CA 94114, USA. After you submit the form, our server sends your details as an email via Resend to the internal team mailbox of L-P GmbH. Your email address is set as the reply-to address so that we can respond to you directly.

In doing so, Resend processes the content of the message and the metadata required for delivery and acts as our processor (Art. 28 GDPR). Resend provides a Data Processing Addendum for this purpose. Confirm that the data processing agreement with Resend has been concluded

As sending the email is part of handling your inquiry, the legal bases stated in the previous section apply (Art. 6(1)(b) and (f) GDPR); our legitimate interest also covers the reliable delivery of inquiries to our team.

Transfer to the USA

Resend is a provider based in the USA; according to Resend, its processing primarily takes place there. Resend states that it stores metadata and logs of sent emails in the USA regardless of the selected sending region. Sending region used by us: Add the sending region configured in Resend.

Plus Five Five, Inc. is certified under the EU-U.S. Data Privacy Framework (DPF) (entry in the DPF list). The transfer is therefore based on the European Commission’s adequacy decision for the DPF (Art. 45 GDPR). In addition, Resend’s Data Processing Addendum incorporates the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR).

For more information, please see Resend’s privacy policy.

08Protection against spam and abuse

To protect the inquiry form against automated submissions (spam) and abuse, we use the following measures:

  • a form field that is invisible to visitors (“honeypot”) and is usually only filled in by automated programs
  • a plausibility check of the time taken to fill in the form
  • a limit on the number of inquiries per IP address within a certain period (rate limit)

For the rate limit, your IP address is processed only briefly in the server’s working memory. It is not stored in a database, not included in the email containing your inquiry, and is automatically discarded after a short time window—at the latest after one hour.

The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in protecting our website and our inquiry process against spam and abuse.

09Cookies, tracking and external content

This website does not set any cookies. We do not use any analytics, tracking or advertising tools or social media plugins, and we do not embed any external content.

You choose the language version via the page address (/de, /en). Only if you open the start page without a language in the address is your browser’s language setting (Accept-Language header) evaluated once in order to redirect you to the appropriate language version. No cookie is stored for this.

Fonts are loaded from this website’s own server; no connection to Google or other font providers is established.

10Recipients of personal data

Your data is received—in each case only to the extent necessary for the purposes stated—by the following recipients or categories of recipients:

  • our hosting provider as a processor (see “Hosting and server log files”)
  • Resend (Plus Five Five, Inc., USA) as a processor for sending inquiry emails (see “Email delivery via Resend”)
  • the provider of our team mailbox or CRM system in which inquiries are received: Add provider with address, data processing agreement and server location

Beyond this, we only disclose data if we are legally obliged to do so or another legal basis permits it.

11Retention period

We store personal data only for as long as necessary for the respective purpose and delete it afterwards, unless statutory retention obligations prevent this. In detail:

  • Inquiries that do not lead to a business relationship: Add specific deletion period, e.g., number of months after the inquiry has been fully processed
  • Inquiries that lead to business correspondence or a contract: retention for the periods required under German commercial and tax law (in particular Section 257 of the German Commercial Code (HGB) and Section 147 of the German Fiscal Code (AO))
  • Delivery data at Resend: Add retention period at Resend
  • Server log files: see “Hosting and server log files”
  • IP addresses for the rate limit: kept in working memory only and discarded automatically after one hour at the latest

12Your rights

Subject to the statutory requirements, you have the following rights:

  • right of access (Art. 15 GDPR)
  • right to rectification (Art. 16 GDPR)
  • right to erasure (Art. 17 GDPR)
  • right to restriction of processing (Art. 18 GDPR)
  • right to data portability (Art. 20 GDPR)
  • right to object (Art. 21 GDPR, see below)

Where processing is based on your consent, you can withdraw your consent at any time with effect for the future (Art. 7(3) GDPR). None of the processing described in this privacy policy is currently based on consent.

To exercise your rights, an informal message to the contact details given under “Controller” is sufficient.

Right to object under Art. 21 GDPR

Where we process your data on the basis of legitimate interests (Art. 6(1)(f) GDPR), you have the right to object to this processing at any time on grounds relating to your particular situation. We will then no longer process the data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims.

13Right to lodge a complaint with a supervisory authority

If you consider that the processing of your personal data infringes the GDPR, you have the right, without prejudice to any other remedy, to lodge a complaint with a supervisory authority (Art. 77 GDPR), in particular in the member state of your habitual residence, your place of work or the place of the alleged infringement.

Supervisory authority responsible for L-P GmbH: Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit (Hamburg Commissioner for Data Protection and Freedom of Information, HmbBfDI), Ludwig-Erhard-Str. 22, 20459 Hamburg, Germany, datenschutz-hamburg.de

14Provision of your data

The provision of personal data is neither a statutory nor a contractual requirement. Using the inquiry form is voluntary; however, we cannot process your inquiry without the required information. Processing the access data is technically necessary to display the website to you.

15No automated decision-making

No automated decision-making, including profiling, within the meaning of Art. 22 GDPR takes place.

16Changes to this privacy policy

We will update this privacy policy when our website or the legal requirements change. The current version is always available on this page.