Privacy Policy

VAULT 369 LTD ('Lead-Gene') is committed to protecting your personal data. This policy explains what data we collect, why, and how you can exercise your rights.

1. Data Controller

VAULT 369 LTD 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom Operational Office: Avenue Ritz 15, 1950 Sion, Switzerland DPO contact: contact@lead-gene.com

2. Data Collected

Via contact / booking forms: Name, professional email, phone (optional), company name, sector, message content. Via analytics cookies (with consent): Anonymised IP, pages visited, session duration, traffic source. Via email / commercial exchanges: Data voluntarily shared during the sales process.

3. Purposes & Legal Bases

Responding to enquiries: Contract performance / Legitimate interest Sending proposals: Legitimate interest (B2B prospects) Service improvement: Legitimate interest Audience measurement (GA4): Consent Invoicing & accounting: Legal obligation

4. Recipients

Sub-processors (GDPR-compliant DPA in place): Vercel (hosting, EU servers), Cloudflare (CDN), Stripe (payments), Cal.com (scheduling), OpenAI / Anthropic (anonymised AI scoring), Resend (transactional email). No data sold to third parties. No transfers outside the EU without appropriate safeguards.

5. Retention Periods

Prospects: 3 years from last contact | Active clients: contract duration + 5 years | Invoicing data: 10 years (legal) | Technical logs: 12 months | Marketing emails: until unsubscribe

6. Your Rights

Under GDPR (and UK GDPR): access, rectification, erasure, objection, restriction, portability. Exercise your rights: contact@lead-gene.com — response within 30 days. Supervisory authorities: ICO (UK) ico.org.uk | CNIL (France) cnil.fr | FDPIC (Switzerland) edoeb.admin.ch *Last updated: April 2026*