Skip to main content

Privacy notice

This notice covers two different groups of people: providers who open an account with us, and customers whose enquiry we hold and sell. If you made an enquiry about getting work done and want to know what we have, section 4 is written for you and section 9 tells you how to have it corrected or deleted — no account required.

Version
Version — to be confirmed
Last updated
Effective date — to be confirmed
Controller
Bling Marketing
Data protection contact
[email protected]

1. Who is responsible for your data

The controller of the personal data described in this notice is the United States business trading as Bling Marketing, whose address and telephone are given below.

Business address: 456 Raintree Dr, Oswego, IL 60543, United States. Telephone: (318) 498-6750.

For anything to do with personal data — a question, a request, a complaint — write to [email protected]. That address is monitored by a named person and you do not need an account to use it. It is deliberately separate from our support queue, because most of the people whose data we hold have never signed up to anything of ours.

We have not appointed a statutory data protection officer. If that changes, this notice will name them.

2. The two groups of people this notice covers

Bling Marketing is a marketplace, so it holds personal data about two very different groups, and almost everything about the two is different: how we got the data, why we hold it, what legal basis applies, how long we keep it, and who else sees it.

  • Providers. Service businesses that open an account, buy credits and buy leads. They came to us, agreed to our terms, and can sign in and see everything we hold. Section 3 covers them.
  • Customers who made an enquiry. People who wanted a job done and left their details with us or with one of our sources. They have no account with us, and in most cases they have never seen our website. Their contact details are the thing providers pay to unlock. Section 4 covers them, and section 5 explains how their data reaches us and what we record about the permission to hold it.

If you are a customer and you want to know what we hold, have it corrected or have it deleted, go straight to section 9 — or just write to [email protected].

We also hold data about our own staff, and about people who write to us without being either of the above. Those are covered by the same rights and the same contact route, and the same retention rules apply where they are relevant.

3. If you are a provider with an account

This is everything we hold about an account holder, why we hold it, the legal basis we rely on, how long we keep it, and who outside our own systems sees it. “Our infrastructure” below means the hosting, database and file-storage providers named in the register in section 6.

Personal data we hold about providers, with purpose, lawful basis, retention and recipients
What we holdWhyLawful basisHow longWho else sees it
Your name, business name, email address, phone number and business profileTo create and run your account, sign you in, and contact you about the servicePerformance of our contract with youWhile your account is open, then 12 monthsOur infrastructure; our email provider when we email you
Your password, stored only as a one-way hashTo let you sign in without us knowing your passwordPerformance of our contract with youWith the accountOur infrastructure only
Sign-in and security events: what happened, when, from which IP address, a fingerprint of the browser, and whether it succeededTo protect your account, spot attacks and investigate incidentsOur legitimate interest in the security of the service12 monthsOur infrastructure only
Your active sessions and the devices they were created onTo keep you signed in and to let you end a session you do not recognisePerformance of our contract with you90 days after a session is endedOur infrastructure only
Orders, payments, payment-provider references and the provider’s raw responseTo take payment for a credit pack, grant the credits, and answer a payment disputePerformance of our contract with you; our legal obligation to keep tax and accounting records7 yearsOur payment provider; our infrastructure
Invoices and credit notes, including the billing name and address recorded on themTo issue an invoice and keep the statutory accounting recordOur legal obligation7 years — and kept in full even if you ask us to erase your data, because an invoice without the customer’s identity is not a valid accounting recordOur infrastructure; our accountants, and a tax authority where required
Your credit balance and every movement on itTo run the credits you bought and to reconcile our accountsPerformance of our contract with you; our legal obligation for the accounting record7 yearsOur infrastructure only
The leads you bought, your notes and statuses on them, and any credit-return claim with its evidenceTo deliver what you paid for, to decide a claim, and to keep the record of what we released to youPerformance of our contract with youThe purchase record 7 years; the customer’s contact data inside it is purged 24 months after the saleOur infrastructure only
Every email we sent you: recipient, subject, template, delivery status, the mail server’s response, and the exact bodyTo prove we sent it and that it was accepted, and to answer “I never received it”Performance of our contract with you; our legitimate interest in being able to evidence deliveryThe record 24 months; the stored body 90 daysOur email provider; our infrastructure
Your notification and email preferences, and every consent or withdrawal you have given us, with the time, method, IP address and the version of the notice you sawTo honour your choices and to be able to show what you agreed to and whenConsent, for marketing messages; our legal obligation to evidence consentConsent records: while the account is open, then 7 yearsOur infrastructure only
Correspondence with our support teamTo answer you and to keep a record of what was agreedPerformance of our contract with you; our legitimate interest in running a support serviceWhile needed for the matter, and no longer than the account plus 12 months unless it relates to a financial recordOur email provider; our infrastructure
An audit trail of actions taken on your account, including by our staffAccountability: to be able to say who did what, and whenOur legal obligation; our legitimate interest in the integrity of the platform7 years, and never deleted earlyOur infrastructure only

Where the data comes from

All of it comes from you, or is generated by your use of the service. We do not buy data about providers, and we do not enrich your profile from third-party sources.

What we do not do

We do not sell your data. We do not advertise to you off-platform using your data, and we do not upload it to an advertising platform. We do not send you marketing without your consent — and service messages about money you have paid or a lead you have bought are not marketing, which is why they have no unsubscribe link and cannot be turned off.

4. If you are a customer whose enquiry we hold

You are reading the most important section of this notice. If you made an enquiry about getting work done and your details ended up with us, here is exactly what we hold and what happens to it.

We are a marketplace for enquiries. When you asked for quotes — on a form, on a comparison site, or through a partner who collects enquiries — your enquiry may have been passed to us so that providers who do that kind of work can respond to you. Our business model is that a provider pays us for the ability to contact you about that enquiry. We tell every provider, in our terms, that they may use your details for nothing else.

Personal data we hold about customers who made an enquiry, with purpose, lawful basis, retention and recipients
What we holdWhyLawful basisHow longWho else sees it
Your name, phone numbers, email address, full address and postcode, and — where the enquiry included them — precise coordinatesSo that a provider who buys the enquiry can get back to you about itYour consent, given where the enquiry was collected. Where we rely instead on our legitimate interest in matching an enquiry to a provider, we record the assessment that supports it for that batch of leadsNever sold: 90 days from the date you enquired, then deleted. Sold: 24 months from the sale, then the contact fields are erased in placeThe providers who bought the enquiry — up to the number of seats on it, normally at most 5; our infrastructure; our email provider; a contact-verification supplier
What you asked for: the service, the location, the budget range, the timeframe, your own description of the job, your answers to any questions, and any files you attachedTo describe and price the enquiry, and to give the provider enough to quoteThe same basis as your contact detailsThe same as your contact detailsThe same as your contact details. Before purchase, providers see only a summary with contact information stripped out, the town, the first half of the postcode and a budget band
Where the enquiry came from and the evidence of your permission: the source, the partner or supplier, the batch it arrived in, their reference for it, the form or page, when your permission was captured, and the IP address it came fromTo be able to show that we hold your data lawfully, and to trace an enquiry back to its origin if you ask us toOur legal obligation to demonstrate a lawful basis; our legitimate interest in being able to answer youFor as long as we hold the enquiry recordOur infrastructure only. This is shown to a provider who bought the lead, so they can see where it came from
One-way hashes (fingerprints) of your phone number and email addressTo spot the same enquiry arriving twice, and to make sure a deletion request keeps being honoured if the same details are offered to us againOur legitimate interest in inventory quality and in honouring your objectionWhile the fingerprint is needed for that purpose — a deletion fingerprint is kept indefinitely, because forgetting it would let the data back inOur infrastructure only
The result of technical checks on your phone number and email address — whether the line is live and whether the mailbox existsTo keep dead and mistyped contact details off the marketplaceOur legitimate interest in the quality of what we sell, which is also in your interest: it reduces the chance of a stranger being called about someone else’s enquiryWith the enquiry recordA contact-verification supplier; our infrastructure
A record of which provider was given your details, exactly what was released, and whenTo be able to tell you who has your data, to prove what was delivered, and to instruct a provider to delete itOur legal obligation to be able to answer a request from you; our legitimate interest in evidencing delivery7 years for the fact of the delivery; the copy of your details inside that record is erased at 24 months while the fingerprint and the timestamps remainOur infrastructure only

Things worth knowing

  • More than one provider may contact you. An enquiry has a limited number of seats and each is sold once. Normally at most 5 providers can buy the same enquiry, and some are sold to only one.
  • We never sell your details as a list. A provider buys one enquiry at a time and cannot bulk-export enquiries.
  • A provider’s access is time-boxed. We stop showing your details in the provider’s dashboard 90 days after they bought the enquiry. They will also have received a copy by email, which is their own record; our terms limit what they may do with it and require them to delete it when it is no longer needed.
  • We do not sell special category data. We do not ask for, and do not knowingly hold, information about health, ethnicity, beliefs, sex life, trade union membership or criminal records. If an enquiry you wrote contains something like that, it is because you put it in your own description; tell us and we will remove it.
  • We do not market to you. We will never email or text you to sell you something. The only messages you might get from us are a reply to a request you sent us.

5. How an enquiry reaches us, and what we record about permission

Enquiries reach us in three ways: uploaded in bulk from a partner who collected them, fed to us automatically by a partner’s system, or entered by our own staff from an enquiry made directly to us.

Every enquiry must arrive with a record of where the permission to pass it on came from. This is not a preference of ours; our system rejects the enquiry outright if that record is missing. Specifically we require, and store immutably against the enquiry: the type of source, which partner or supplier it came from, which upload or feed it arrived in, their own reference for it, who at our end brought it in and when, a description of where and how the permission was captured, when it was captured, and where available a link to the evidence and the IP address the permission came from.

We contract with every supplier of enquiries on the basis that they warranted the capture was lawful and that they indemnify us if it was not, and we keep a register of them. A supplier cannot be switched on in our system without a recorded contract reference. If we find that a supplier’s enquiries were not lawfully collected, we withdraw them, tell the providers who bought them to delete them, and return those providers’ credits.

If you want to know exactly where your enquiry came from, ask us at [email protected] and we will tell you what that record says.

6. Who we share data with

We share personal data with four kinds of recipient, and no others.

  • Providers who buy an enquiry. They receive the customer’s contact details and the enquiry, and they become independently responsible for that data in their own right. This is a disclosure, not processing on our behalf, and it is the central purpose of the service. It is described in section 4.
  • Suppliers who process data on our behalf — our processors, listed in the register below. Each is bound by a written agreement that permits them to use the data only to provide the service to us, requires security measures, and forbids them from using it for their own purposes.
  • Professional advisers and authorities — our accountants, auditors, insurers and lawyers, and a tax authority, a regulator, a court or law enforcement where we are legally required or legally entitled to disclose.
  • A buyer of the business, if we are ever sold or reorganised. We would tell you, and the buyer would be bound by this notice.

We do not sell personal data to advertisers, data brokers or list builders, and we do not participate in advertising audiences or data co-operatives.

Our sub-processor register

We publish the full list rather than a vague category, because “trusted partners” tells you nothing. An entry marked to be confirmed is a supplier we have not yet appointed: no agreement is in place, and no data has been sent to it. We update this register before appointing anyone new.

Sub-processors that process personal data on our behalf
SupplierWhat they do for usWhere they process it
RailwayHosting the website, the database and our scheduled tasksUnited States (US West)
CloudflareFile storage (R2) for invoices, delivery evidence, email bodies, attachments and exportsTo be confirmed when the storage is created
ResendSending our emails. Receives the recipient address and the message body, which for a lead delivery contains the customer’s contact detailsUnited States
PayPalTaking payment for credit packs. PayPal is responsible for payer data in its own right, under its own privacy noticePayPal’s own infrastructure
Stripe, Square and Authorize.netTaking card payments, where a payment is made by card. Each is responsible for cardholder data in its own right; card details never reach our serversEach provider’s own infrastructure
Contact-verification supplierChecking whether a phone line is live and a mailbox exists. This supplier would see customer phone numbers and email addressesTo be confirmed — not yet appointed
GitHubStoring our source code and running our tests. No live personal data is ever presentUnited States
Support toolSupport ticketing, if we adopt one. Until then support runs on a shared mailbox with our email providerTo be confirmed

7. Where your data is processed

We are a United States business and the people whose data we hold are in the United States. Where each of our suppliers processes data is stated in the register above, supplier by supplier, rather than summarised here in a sentence that could not be checked against it.

The residency decision for the platform has not been finalised. It matters more than it sounds, because the jurisdiction of the file storage is fixed at the moment the storage is created and cannot be changed afterwards. We will update this notice with the outcome, and the register above always shows the current position rather than the intention.

We minimise what leaves our own systems: our email provider is asked to keep our message content for 15 days, because our own copy is the authoritative record and a longer window at their end buys nothing.

You can ask us at [email protected] where any supplier in the register processes data.

8. How long we keep things

We do not keep personal data “as long as necessary” and leave it at that. Each class has a term, and the terms are enforced by scheduled jobs with verification queries rather than by a policy document nobody runs. The table is the whole schedule.

Retention schedule
WhatHow longCounting fromWhat happens at the end
A signup that was never verified14 daysCreationDeleted
An invitation never accepted30 daysSentDeleted
An enquiry that was never sold90 daysThe date of the enquiryDeleted
The contact details on an enquiry that was sold24 monthsThe saleErased in place: the fields are emptied and the record kept, so the purchase, the invoice and the delivery evidence still make sense
A provider’s dashboard view of a purchased customer’s contact details90 daysTheir purchaseHidden. The purchase, the credits, the invoice and the evidence remain
Attachments to an enquiryWith the contact detailsThe saleFile and record deleted
The stored body of an email we sent90 daysSendingDeleted; the fingerprint of it is kept so delivery can still be evidenced
The record that an email was sent, and its delivery events24 monthsSendingDeleted
Sign-in and security events12 monthsThe eventDeleted
A session record90 daysThe session endingDeleted
Active account detailsLife of the account, then 12 monthsClosureReduced to a tombstone: the personal fields are emptied and a pseudonymous reference is kept so financial and audit records still balance
Invoices, credit notes and tax records7 yearsThe issue dateDeleted. Kept in full before then even if you ask for erasure — the law requires it
Orders, payments, refunds and disputes7 yearsThe orderPseudonymised once the account has been closed for 12 months; deleted at the end of the term
The credit ledger7 yearsThe entryPseudonymised, then deleted
Delivery evidence7 yearsWhen it was generatedThe copy of the customer’s details inside it is erased at 24 months while the fingerprint, the field names, the timestamp and the signature remain, so the evidence still verifies. The artefact is deleted at the end of the term
The audit trail of staff and account actions7 yearsThe eventDeleted, and never earlier. The actor is replaced with a pseudonymous reference on erasure
Records of impersonation for support7 yearsThe session endingPseudonymised and retained
Consent recordsLife of the account, then 7 years—Kept. Deleting them would destroy the evidence for the processing they permitted
Email suppressions — the list that stops us mailing an address againWhile the suppression stands—Kept as a one-way hash, and it survives erasure, because that is how an objection keeps being honoured
A data pack you asked us to generate7 daysGenerationThe file is deleted; the record that you requested it is kept for 7 years as a security record
Application logs30 days live, 12 months archivedThe eventDeleted
Backups35 days rolling, plus 12 monthly snapshots kept for 12 monthsThe backupOverwritten. After any restore we re-apply every erasure that had already been done

9. Your rights, and how to use them

These rights belong to everybody in this notice — providers and customers alike. You do not need an account to use any of them, you do not have to give a reason, and it is free. Write to [email protected].

Your data protection rights and how to exercise each one
RightWhat it meansHow to use it
To be informedTo know who holds your data, why, on what basis and for how longThis notice. If something in it is unclear, ask us and we will explain it
AccessTo get a copy of the personal data we hold about you, and to be told the purposes, the recipients and the retentionProviders can do this immediately and without asking anyone: your data page in the dashboard builds a complete pack — your account record, orders, purchases, invoices, credit ledger, email history, consents and the audit events about you — and gives you a download link. Customers, and anyone else, write to us and we will answer within one month
RectificationTo have wrong data corrected and incomplete data completedProviders can edit their own profile. Otherwise write to us; we will also tell any provider who received a corrected enquiry
ErasureTo have your data deleted where we no longer have a good reason to hold itWrite to us. For a customer enquiry this is the strongest right and we act on it in full — see below
RestrictionTo have us stop using your data while a dispute about it is resolved, without deleting itWrite to us. We will mark the record and stop selling or acting on it
PortabilityTo receive the data you gave us in a machine-readable form, or have it sent to another providerThe provider data pack is JSON and CSV, which satisfies this. Customers can ask us for the same
To objectTo object to processing we base on our legitimate interests, and to object at any time to direct marketingWrite to us, or use the unsubscribe link in any marketing email — one click, no sign-in. An objection to marketing is absolute and we act on it immediately
About automated decisionsNot to be subject to a decision made solely by a machine that has a legal or similarly significant effect on you, and to ask for a human to look at itSee the note below. Write to us and a person will review any decision you are unhappy with

What happens when a customer asks us to erase an enquiry

This is worth spelling out, because it is the request we most expect and the one that takes the most work. When we have verified that the request is really from you, we:

  • withdraw the enquiry, so it can no longer be bought;
  • erase your contact details from our records in place, leaving the surrounding commercial record intact but empty of you;
  • redact the copy of your details inside every delivery record and every piece of delivery evidence, keeping only the fingerprint and the timestamps so the evidence still verifies;
  • notify every provider who bought the enquiry that the record has been withdrawn and must be deleted;
  • add a one-way fingerprint of your phone number and email address to a list that is screened on every future import, so the same details cannot be loaded again;
  • automatically return the credits of any provider who bought the enquiry recently, so nobody has a commercial reason to argue about your request.

We will do all of that within 30 days of verifying your request, and we will list anything we are legally required to keep — for example an invoice — rather than quietly keeping it.

Automated decisions

We do not make decisions about you by wholly automated means that have a legal or similarly significant effect. Two things come close, and both are explained here rather than buried:

  • A credit-return claim can be approved automatically where our own data already verifies it — for example when we can see you bought the same contact before. That decision can only go in the provider’s favour; a refusal is always made by a person.
  • Our fair-use controls can automatically route a provider’s claims to manual review. That is a decision to involve a human, not to replace one.

How we verify a request

We have to be sure a request is genuine, because handing someone else’s data to the wrong person is itself a breach. We will ask you to confirm the request from the email address or phone number on the record, or to give us enough detail about the enquiry for us to match it with confidence. We will not ask you for identity documents unless we genuinely cannot verify you any other way, and we will explain why if we do.

Timescales, and the self-service route

We answer within one month. For a genuinely complex request we may take up to two months longer, and we will tell you inside the first month if that applies and why. We track every request against its deadline.

A provider’s own data pack is built on demand from the data page in the dashboard. The download link is signed and expires after 15 minutes; you can re-issue it as often as you like while the pack itself lives. You can request a new pack once every 30 days. The pack deliberately does not include the contact details of the customers whose enquiries you bought, because those are somebody else’s personal data and the right to a copy of your own data does not extend to theirs; the commercial facts of every purchase are all there.

10. Cookies

We set one cookie, and it exists to keep you signed in. We set no analytics, advertising or tracking cookies, and we store nothing else in your browser. That is why you have not been asked to accept anything.

The full detail — the cookie’s name, what is in it, how long it lasts and how to remove it — is in our cookie notice.

11. How we protect your data

What follows is what we actually do, not a list of adjectives. We hold no security certification — we are not ISO 27001 certified and we have no SOC 2 report — and we would rather say so than imply one.

  • In transit, everything travels over TLS. The site instructs browsers never to connect to it insecurely, and it runs a strict content-security policy that blocks injected scripts.
  • Passwords are stored using Argon2id, a memory-hard hashing function built for this job. We cannot recover your password, only replace it.
  • Session tokens are stored as one-way digests, so a copy of our database does not yield a usable session. So are the browser fingerprints on security events.
  • Customer contact details are physically separated from the information providers browse. They live in a different table, reached through a single piece of code, behind database rules that return no rows at all to a connection that has not proved it is entitled to them — including a connection from an administrative console.
  • Phone numbers and email addresses used for matching are held as one-way fingerprints rather than as searchable text, so duplicate detection and deletion screening work without a searchable index of contact details.
  • Access is by capability, not by job title. Every read and every write asks whether this actor holds this specific permission. Some staff roles are structurally blocked from customer contact details; a finance role can see the money and not the people.
  • Every reveal of a customer’s contact details by our staff is recorded individually, one record at a time, and bulk reveal is not possible through the interface.
  • The audit trail cannot be rewritten. Its records are append-only and chained together, so an alteration is detectable. The database refuses an update or a delete even from its owner.
  • Providers cannot bulk-export enquiries, and a provider’s view of a purchased customer’s details ends automatically after the period in section 8.
  • At rest, our database and our file storage are encrypted by the providers that operate them, and we require that of every provider we appoint. Backups are encrypted, and restoring one re-applies every erasure that had already been carried out, so a restore cannot quietly bring deleted data back.
  • Every supplier is contracted before it processes anything, and we keep the register in section 6 current.

If something does go wrong, we investigate immediately. Where a breach is likely to put you at risk we tell the people affected without undue delay, and we make whatever notifications the law requires of us.

12. Complaints

Please tell us first, at [email protected]. We would rather fix it. Say what happened and what you would like us to do, and we will reply.

Nothing in this notice takes away any right you have to complain to a regulator or other authority, or to go to court. Which authority that is depends on where you live and on which privacy laws cover you, so we do not name one here rather than send you to the wrong place — but if you ask us at [email protected] we will tell you what we know about how your data was handled, which is the part we can answer for.

13. Changes to this notice

This notice carries a version and an effective date at the top of the page, and we record which version was in force when you gave us a consent, so we can always show you what you were told at the time.

When we make a material change — a new purpose, a new lawful basis, a new category of recipient — we will tell account holders by email before it takes effect, and we will publish the change here. Where a change needs your consent, we will ask for it rather than assume it.

14. How to contact us

Anything about personal data: [email protected]. No account needed. This is the route to use if you are a customer whose enquiry we hold.

Anything about an account, an order or a lead: [email protected].

By post: 456 Raintree Dr, Oswego, IL 60543, United States.

By telephone: (318) 498-6750.