Privacy Policy

Read our privacy policy below to learn more about 521 products

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Updated on: 15th Sep 2025  |  Effective Date: 05th Sep 2025

Privacy Policy of 521 Products (trading as Smartlead and SmartProspect)

Our platforms collect some personal data from Clients who use our services, and we also collects data about Prospects which we sell to Clients as part of the SmartProspect service.

We are 521 Products Pty Ltd, an Australian registered business. We trade under the SmartLead and SmartProspect brands.

You can contact us at: support@smartlead.ai

  1. Individuals we collect from or about

We collect data about two groups of individuals: (A) Clients who buy our services; and (B) Prospects who are stored as contact details for B2B marketing, and that are sold to our Clients.

For Clients, we collect:

  • Contact and title information needed for us to provide our services to you including: your name, title, employer, email address and phone number;
  • Information we need to contract with you including: your credit card details, the services you’ve purchased or considered purchasing;
  • Transaction history using your services, including: the frequency and duration of your visits to our platform; and
  • Any data that you provide to us, including: feedback or comments, and any other information from time to time that is required to provide our services to you.

For Prospects, we collect:

  • Name, email address (which we may infer) and sometimes mobile number;
  • Current employer and employment history;
  • Current and previous job titles; and
  • Performance data (eg if emails sent to you bounced or a reply was received), and any other information from time to time that is required to provide the services to our Clients.
  1. Purpose of Collection

Personal data is collected to allow us to provide our service to our Clients, improve our Services, comply with our legal obligations, respond to enforcement requests, protect our rights and interests (or those of its Clients or third parties), detect any malicious or fraudulent activity, display content from external platforms, interact with external social networks and platforms, analytics, interactions with Clients, access to third-party accounts, heat mapping on platform usage, and Client session analytics and recording.

  1. Sources of data

We collect personal data from a variety of sources.  For Clients we collect data directly from you, such as when you fill out forms on or access our website or communicate with us via email or phone.

For Prospects we collect data from publicly available sources, such as company websites and social media platforms, and from third-party data providers, such as data brokers.

  1. Legal basis of processing

For Clients: we process your personal information so that we can provide the services to you under our contract with you. We need your data to perform our contractual services. 

For Prospects: processing of your data is necessary for the purposes of the legitimate interests pursued by us, and those interests are not outweighed by undue prejudice to you. 

  1. Protection of your data

We take appropriate technical and organisational security measures to prevent unauthorised access, disclosure, modification or unauthorised destruction of your personal data.
In addition to us, in some cases, your personal data may be accessible to third parties involved with the operation or hosting of our platform, appointed, if necessary, as data processors by us. The updated list of these parties may be requested from us at any time.

  1. Place

Your personal data is processed in our hosted service provider which is Amazon Web Services located in Sydney, Australia. Your data does not leave Australia except as necessary to provide services to Clients, or to our staff for technical support in India.
We take reasonable steps in accordance with Australian law to ensure that your data is protected by those we trust with access to your data. 

  1. Retention time

Personal data shall be processed and stored for as long as required by the purpose it has been collected for.

Therefore:

  • Client: personal data collected for purposes related to the performance of a contract between us and the Client shall be retained until such contract has been fully performed, and then after as required for billing and marketing purposes.
  • Prospects: personal data shall be retained for as long as it is relevant, up to date and accurate in accordance with our data retention policy.

Once the retention period expires, personal data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

  1. Detailed information on the processing of personal data

Personal data is collected for the following purposes and using the following services:

  • Access to third-party accounts
    • This type of service allows the Smartlead platform to access personal data from your account on a third-party service and perform actions with it.
      These services are not activated automatically, but require explicit authorization by you.
  • Stripe account access (Stripe Inc)
    • This service allows the platform to connect with your account on Stripe, provided by Stripe, Inc.
    • Personal data processed: various types of personal data as specified in the privacy policy of the service.
    • Place of processing: United States – Privacy Policy.
  • Analytics
    • Using analytics, we are able to monitor and analyse web traffic and can be used to keep track of user behaviour.
  • Google Analytics (Google LLC)
    • Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the personal data collected on an aggregated basis to track and examine the use of this platform, to prepare reports on its activities and share them with other Google services.
      Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
    • personal data processed: Cookies; Usage Data.
    • Place of processing: United States – Privacy Policy – Opt Out.
  • Contacting the your
    • Mailing list or newsletter
    • By registering on the mailing list or for the newsletter, your email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this platform. Your email address might also be added to this list as a result of signing up to the service or after making a purchase.
    • personal data processed: email address.
  • Displaying content from external platforms
    • This type of service allows you to view content hosted on external platforms directly from the pages of this platform and interact with them.
      This type of service might still collect web traffic data for the pages where the service is installed, even when you do not use it.
  • Google Fonts (Google LLC)
    • Google Fonts is a typeface visualization service provided by Google LLC that allows this platform to incorporate content of this kind on its pages.
    • personal data processed: ssage Data; various types of personal data as specified in the privacy policy of the service.
    • Place of processing: United States – Privacy Policy.
  • Heat mapping and session recording
    • Heat mapping services are used to display the areas of this platform that users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyse web traffic and keep track of user behaviour.
      Some of these services may record sessions and make them available for later visual playback.
  • Hotjar Heat Maps & Recordings (Hotjar Ltd.)
    • Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
      Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the your's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
    • personal data processed: Cookies; usage Data; various types of personal data as specified in the privacy policy of the service.
    • Place of processing: Malta – Privacy Policy – Opt Out.
  • Interaction with external social networks and platforms
    • This type of service allows interaction with social networks or other external platforms directly from the pages of this platform.
      The interaction and information obtained through this platform are always subject to the your privacy settings for each social network.
      This type of service might still collect traffic data for the pages where the service is installed, even when you do not use it.
      It is recommended to log out from the respective services in order to make sure that the processed data on this platform isn’t being connected back to your profile.
  • Facebook Like button and social widgets (Facebook, Inc.)
    • The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
    • personal data processed: Cookies; usage data.
    • Place of processing: United States – Privacy Policy.
  • Platform services and hosting
    • These services have the purpose of hosting and running key components of this platform, therefore allowing the provision of this platform from within a unified platform. Such platforms provide a wide range of tools to us – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of personal data.
      Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the personal data are stored.
  • Webflow (Webflow, Inc.)
    • Webflow is a platform provided by Webflow, Inc. that allows us to build, run and host this platform. Webflow is highly customizable and can host websites from simple blogs to complex e-commerce platforms.
    • personal data processed: various types of personal data as specified in the privacy policy of the service.
    • Place of processing: United States – Privacy Policy – Opt out.
  • We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement
  1. The rights of Clients and Prospects

You may exercise certain rights regarding their personal data processed by us.

In particular, Clients and Prospects have the right to do the following:

  • Do not sell / objection: if you follow the ‘Do not sell my data’ link on our platform, or email us at the email address above, then we will ensure that your data is never sold or transferred to our Clients by us.
  • Access your Data. You have the right to learn if personal data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the personal data undergoing processing.
  • Verify and seek rectification. You have the right to verify the accuracy of your personal data and ask for it to be updated or corrected.
  • Restrict the processing of your personal data. You have the right, under certain circumstances, to restrict the processing of your personal data. In this case, we will not process your personal data for any purpose other than storing it.
  • Have your personal data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your personal data by us.
  • Receive your Data and have it transferred to another controller. You have the right to receive you personal data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the personal data is processed by automated means.
  • Lodge a complaint. You have the right to bring a claim before your competent data protection authority. You should first contact us to give us an opportunity to resolve your complaint before it is escalated to a regulator. 

How to exercise these rights

Any requests to exercise your rights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.  We will ask you to verify your identity before exercising your rights to ensure that you are the correct person. 

  1. Cookie Policy

Our platform uses trackers. To learn more, you may consult the Cookie Policy.

  1. Additional information about Data collection and processing
    1. Legal action

Your personal data may be used for legal purposes by us in Court or in the stages leading to possible legal action arising from improper use of this platform or the related services.
You accept that you are aware that we may be required to reveal personal data upon request of public authorities.

  1. Additional information about your personal data

In addition to the information contained in this privacy policy, this platform may provide you with additional and contextual information concerning particular services or the collection and processing of personal data upon request.

  1. System logs and maintenance

For operation and maintenance purposes, this platform and any third-party services may collect files that record interaction with this platform (System logs) use other personal data (such as the IP Address) for this purpose.

  1. Information not contained in this policy

More details concerning the collection or processing of personal data may be requested from us at any time. Please see the contact information at the end of this policy.

  1. How “Do Not Track” requests are handled

This platform does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

  1. Changes to this privacy policy

We reserve the right to make changes to this privacy policy at any time by notifying you on this page and possibly within this platform and/or - as far as technically and legally feasible - sending a notice to you via any contact information available to us. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

  1. Definitions and legal references
  2. Personal Data

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

  1. Usage Data

Information collected automatically through this platform (or third-party services employed in this platform), which can include: the IP addresses or domain names of the computers utilized by the yours who use this platform, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the your, the various time details per visit (e.g., the time spent on each page within the platform) and the details about the path followed within the platform with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the your IT environment.

  1. You – who could either by a Client or a Prospect

The individual using this platform who, unless otherwise specified, coincides with the Data Subject.

  1. Data Subject

The natural person to whom the personal data refers.

  1. Data processor

The natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller, as described in this privacy policy.

  1. Data controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, including the security measures concerning the operation and use of this platform. The Data Controller, unless otherwise specified, is we of this platform.

  1. This platform

The SmartLead or SmartProspect web service.

  1. Service

The service provided by this platform as described in the relative terms (if available) and on this site/application.

  1. European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

  1. Cookie

Cookies are Trackers consisting of small sets of data stored in the your browser.

  1. Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of you, for example by accessing or storing information on the your device.

  1. Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this platform, if not stated otherwise within this document.

  • Contact email: [insert contact details]
  • UK and EU Representative: if you are a resident of the UK or the EU then you may choose to contact our local representative prighter.com to exercise your rights at law and under this privacy policy.  
  • Date of Policy: 13 August 2025