Privacy Policy
Version 2026-11-07-v0.2. Last updated 7 November 2026.
1. Who we are
Halo Strategic Ltd is the controller of the personal information described in this policy. We are registered in England and Wales (company number 17409402), registered office 71-75 Shelton Street, London WC2H 9JQ.
This policy covers halostrategic.com, including our homeowner enquiry pages and the Halo Lead Exchange at halostrategic.com/leads-exchange.
Contact us about privacy at [email protected]. We are not currently registered with the Information Commissioner’s Office (ICO); we are reviewing whether registration is required for this activity.
2. At a glance
- You make an enquiry on one of our homeowner pages.
- We check it is a genuine fit for the service you asked about.
- Without your separate consent to sharing, your enquiry stays with Halo.
- With it, a business sees only a redacted summary first.
- Full contact details are shared only after that business has paid us and we have verified the payment.
- You can withdraw consent, or ask us to delete your data, at any time (section 10).
3. Homeowner information
What we collect. When you ask for a quote on one of our homeowner pages, we collect what you type into the form:
| Category | Examples |
|---|---|
| Identity and contact | First and last name, email, mobile number, preferred contact method |
| Property | UK postcode, ownership status, property type |
| Your enquiry | What you are interested in, existing installation, timeframe |
| Your choices | Which consent boxes you ticked, consent wording version, time of submission |
| How you found us | Campaign and UTM source codes from the link you clicked, where available |
We may add notes from any follow-up call where we confirm your enquiry, labelled as confirmed, your estimate, or unknown.
Why, and our lawful basis.
| Purpose | Lawful basis |
|---|---|
| Contact you about your enquiry and check it is a genuine fit | Your consent (“happy for Halo Strategic to contact me”) and our legitimate interest in handling enquiries |
| Share your details with one suitable business | Your separate, specific consent to sharing. Not bundled with anything else |
| Keep a record of what you agreed to and when | Legitimate interest and legal obligation (to show consent was given) |
| Optional email tips and updates | Your separate marketing consent, only if you tick that box |
You can withdraw consent at any time (section 10). Withdrawing does not undo sharing that has already happened, but we will tell the business you have withdrawn.
4. Sharing homeowner information
We only share your details with a business if you ticked the sharing box and we judge your enquiry to be a genuine fit for that business’s services and area.
- Who receives it: a business (the “buyer”) who has applied to us, been reviewed and approved, and agreed to our Buyer Terms.
- What they see first: a summary with general location, property type and enquiry details. No name or contact details.
- What they receive: your full contact and enquiry details, only after they have paid us for the enquiry and we have verified the payment.
- How many: as agreed in that buyer’s individual commercial terms — typically one, unless the enquiry is marked as shared.
- What they may do with it: contact you about this enquiry and any work you agree. Our Buyer Terms forbid them from reselling or passing on your details, or adding you to unrelated marketing.
- Their responsibility: once they receive your details, the business is a separate controller responsible for how they use them. Any quote, survey, finance or contract is between you and them.
We are paid by buyers for qualified enquiries. You are never charged by us.
We may also share information where the law requires it, or with professional advisers under confidentiality.
5. Buyer and applicant information
When a business applies to buy enquiries, or contacts us through the Lead Exchange, we collect:
| Category | Examples |
|---|---|
| Business and contact | Company name, registration number, website, location, contact name, email, telephone |
| Capability and coverage | Services, insurance and qualifications, counties and postcodes covered, travel distance |
| Commercial and sales information | Lead capacity, price expectations, previous lead suppliers, response times, conversion rates, average job value |
| Agreements | Confirmations given, Buyer Terms and Replacement Policy versions accepted and when |
| Account records | Approval status, commercial terms, lead purchases, replacements |
| Admin records | An internal suitability score and notes, used only to help our review. It never approves or rejects anyone automatically |
| Contact messages | Name, email and message |
Lawful basis: taking steps to enter into, and performing, our contract with the buyer; our legitimate interest in vetting buyers to protect homeowners; and legal obligations for financial records.
These are business contacts, but sole traders and named contacts are individuals, so this policy applies to them.
6. Marketing
We only send marketing emails if you tick the optional marketing box. Homeowners can opt in to occasional home-improvement tips; buyers can opt in to occasional updates from Halo Strategic. Account and lead notifications to buyers are service messages, not marketing.
Every marketing email has an unsubscribe link. You can also email us to stop at any time. We do not sell your details to anyone for marketing, and we do not use advertising cookies or retargeting pixels.
7. Service providers and international transfers
We use these providers to run the site and the Lead Exchange. They act on our instructions.
| Provider | What they do | Where |
|---|---|---|
| Netlify | Website hosting, form submissions, Lead Exchange application and database | United States |
| Resend | Sends our automated emails (e.g. confirming a buyer application has been received) | United States |
| Fonts (loaded on every page), Google Analytics 4 via Tag Manager only if you accept analytics cookies, Google Workspace for our email, and Google Sheets, where we keep an internal operational copy of homeowner enquiry details (name, contact details, postcode, enquiry answers) to track and action them | United States | |
| Tide | Business banking and buyer payment links | United Kingdom |
Where a provider processes data outside the UK, we rely on the UK Extension to the EU-US Data Privacy Framework or the UK’s International Data Transfer Addendum, as appropriate to that provider.
8. How long we keep it
| Information | Kept for |
|---|---|
| Homeowner enquiry not shared with anyone | 6 months from submission, then deleted |
| Homeowner enquiry shared with a buyer | 2 years from sharing, so we can handle replacements, disputes and complaints |
| Record of your consents | As long as we hold the related data, plus 2 years |
| Declined buyer applications | 12 months from decision |
| Active buyer accounts | While the account is open, plus 2 years |
| Payment and transaction records | 6 years, as required for tax and accounting |
| Contact messages | 12 months |
| Analytics data | Google Analytics 4 retention setting of 14 months |
When the period ends we delete the data or anonymise it so it no longer identifies you. Buyers keep the data we shared under their own retention policies.
9. Security
- Data is sent over encrypted connections (HTTPS).
- Only Halo administrators can see buyer applications and enquiry details. Admin accounts have no public sign-up, use hashed passwords, and every admin action is checked on the server and written to an audit log.
- Buyers never see a homeowner’s contact details before payment is verified.
- Bots are filtered out of our forms, and form submissions are rate-limited.
No system is perfectly secure. If a breach is likely to put you at risk, we will tell you and the ICO as the law requires.
10. Your rights
Under UK data protection law you can ask us to:
- give you a copy of your information
- correct anything inaccurate
- delete your information
- restrict or object to how we use it, including stopping marketing at any time
- move your information to another provider
- withdraw any consent you gave
If you ask us to delete or stop sharing your details after they have gone to a buyer, we will pass your request on to them.
Email [email protected]. We will reply within one month. There is no charge.
If you are unhappy with how we handle your information, you can complain to the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113. We would appreciate the chance to sort it out first.