Privacy policy
Last updated 12 October 2026. TraceLead is operated by Henry Kubik-Jones trading as TraceLead ("we").
1. Two kinds of people, two roles
TraceLead is run by one person, its operator; "we" on this page means that person. We process personal data in two different roles:
- As a controller for people who use the TraceLead dashboard (members of a customer organisation, including anyone invited to one).
- As a processor on behalf of our customers for visitors to the customers' websites, where the TraceLead snippet is installed. The customer is the controller of that data and decides the legal basis and the consent flow. Our processing terms set out what we do as their processor.
2. Dashboard users (we are the controller)
We hold your name, email address, password hash, optional two-factor and passkey credentials, organisation membership and role, billing status and the audit trail of settings changes. Payment details are collected and held by Stripe; we store only Stripe identifiers and subscription state.
Legal basis: performance of the contract with you, and our legitimate interest in securing and improving the service.
When you delete your account, your user record is deleted at once. An organisation you alone own is closed at the same time, its sites stop being served, and its collected visitor data is deleted 90 days later. 90 days after closure the organisation itself is deleted, with its sites, settings, members' access and audit trail. Invoices and payment records stay in our Stripe account for as long as tax law requires us to keep them.
3. Website visitors (we are the processor)
The snippet runs on our customers' websites. Only after the customer's consent mechanism signals consent does it:
- keep the first touch (UTM parameters, which advertising click identifier was present, the referrer hostname, the landing path with sensitive parameters removed, the time) in a first-party cookie or local storage on the visitor's device for the lifetime the customer configured (90 days by default);
- mint a random visitor identifier and a random session identifier, and send pseudonymous session and lead events (page paths, the form's id, the attribution above) to TraceLead;
- where the customer turns on contact clicks, send which kind of contact link was clicked (phone, email, SMS or WhatsApp), once per kind per visit, with the page path and the attribution above. The number, address or message in the link is never read or sent;
- where the customer turns on engagement counters, keep a count of visits and the time of the last visit beside the first touch, and send two numbers with each lead: the number of visits before it and the whole days since the first touch. No list of pages or visit times leaves the device.
We never receive or store names, email addresses, phone numbers, any form field values, full URLs, IP addresses (used transiently for rate limiting only) or user agents (inspected transiently to drop crawlers). The attribution written into the customer's form goes to the customer's own systems, not to us. Where a customer maps it, the customer's own Google Analytics client identifier (from their _ga cookie) is copied into their form for their CRM; it is never sent to TraceLead. Customers can forward each lead's attribution to their own systems through webhooks they configure, and read their aggregates through an API; neither carries visitor or session identifiers.
Collected data is deleted after the retention period the customer sets per site (30 days to two years, 395 days by default), and 90 days after the customer closes their account. Visitors can withdraw consent through the customer's consent mechanism, which deletes the identifiers on their device. Requests about data held by a customer should be made to that customer; if one reaches us, we pass it on to them.
4. Sub-processors
- DigitalOcean, LLC (London, UK region) — application and database hosting.
- Stripe Payments Europe Ltd — subscription billing.
- Postmark (ActiveCampaign, LLC, USA) — account emails.
Customers are told about a new sub-processor at least 30 days before it starts processing visitor data, as set out in the processing terms.
5. International transfers
Where a sub-processor handles personal data outside the UK, we rely on UK adequacy regulations or, where none applies, the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. You can ask us for a copy of the safeguards that apply.
6. Your rights
Under UK GDPR you can ask for access to, correction or erasure of your data, object to or restrict processing, and ask for portability. Dashboard users can delete their account from Settings. Contact henry@kubikjonesdigital.com. We answer within one month, extended by up to two further months for complex requests, in which case we tell you within the first month. Requests are free unless they are clearly unfounded or excessive. You can also complain to the Information Commissioner's Office.
7. Security
Data is encrypted in transit and passwords are stored only as salted hashes. TraceLead's operator is the only person with access to production systems; anyone we engage in future will be bound to confidentiality and given access only on a need-to-know basis. Public site identifiers in the snippet are not secrets and grant no access to any data. No system is perfectly secure.
8. Personal data breaches
If a breach affects dashboard users' data, we will tell the Information Commissioner's Office within 72 hours where the law requires it, and tell affected users without undue delay where the risk to them is high. If a breach affects visitor data we process for a customer, we will tell that customer without undue delay so they can meet their own duties.
9. Children
TraceLead is a business service for people aged 18 or over. We do not knowingly hold dashboard data about anyone younger; if we learn that we do, we delete it.
10. Changes
We will post changes here with a new date at the top and, for material changes affecting dashboard users, notify account owners by email before they take effect.