Privacy Policy

Opto Agency Limited is a performance marketing and lead generation agency based in the United Kingdom. We provide lead generation, appointment setting, content, Meta advertising, landing pages, CRM automation and related marketing services to aesthetics training academies and clinics.

Email: info@optoagency.com

This policy may apply when you:

• visit or contact Opto Agency directly;
• submit an enquiry through a landing page, form or campaign that we operate for one of our client businesses;
• receive a call, text message, email or other follow-up in connection with an enquiry you have submitted;
• book or attend an appointment generated through a campaign we manage; or
• otherwise communicate with us in connection with our services.

Where we operate a campaign for a client business, that client will usually decide why the lead information is being collected and how it will be used in connection with its products or services. In those circumstances, the client business will usually be the Controller and we will process the information on its behalf.

We may also act as a Controller for personal information we use for our own legitimate business purposes, for example managing our own enquiries, administering our business, protecting our legal rights and, where applicable, carrying out quality assurance. The relevant campaign or landing page should identify the client business connected with your enquiry.

Depending on the campaign, service or interaction, we may collect or process:

• your name;
• telephone number;
• email address;
• address, postcode or geographical area;
• information about the product, treatment or course you are interested in;
• project details, preferences and requirements;
• budget or pricing information;
• enquiry and appointment information;
• communications between you, Opto Agency and the relevant client business;
• information you provide during telephone calls, messages or other communications;
• technical and system information generated through the platforms used to manage enquiries and campaigns; and
• any other information you choose to provide in connection with your enquiry.

The exact information collected will depend on the client business and campaign. We do not intentionally ask you to provide special category personal data unless it is genuinely required for a specific purpose. Please avoid providing sensitive information unless it is necessary.

We may receive personal information:

• directly from you when you complete an enquiry form or landing page;
• when you contact us or a client business by telephone, email, text message or another communication channel;
• during lead qualification or appointment-setting conversations;
• from the client business for whom we are providing services;
• through advertising, CRM, appointment-setting, communication and reporting platforms used to deliver the services; and
• from information generated as part of managing your enquiry or appointment.

Personal information may be used to:

• receive and manage your enquiry;
• contact you about the enquiry you submitted;
• understand the product, treatment or course you are interested in;
• qualify your enquiry against criteria agreed with the relevant client business;
• arrange, confirm, rearrange or follow up appointments;
• send service-related confirmations, reminders and follow-up communications;
• pass your enquiry to the client business whose product or service you enquired about;
• manage and improve campaign and lead-handling performance;
• operate CRM, reporting, call-tracking and communication systems;
• investigate complaints, disputes, suspected misuse or security incidents;
• comply with legal and regulatory obligations; and
• establish, exercise or defend legal claims.

Data protection law requires a lawful basis for each use of personal information. The lawful basis will depend on the circumstances and on whether we are acting as a Controller or processing information on behalf of a client.

Legitimate interests

Where appropriate, we may rely on legitimate interests to manage enquiries, operate and improve our services, carry out proportionate quality assurance, prevent misuse, protect our systems and legal rights, and administer our business. Where we rely on legitimate interests, we consider whether those interests are proportionate and whether your rights and interests override them.

Contract

We may process personal information where this is necessary to take steps at your request before entering into a contract with us, or to perform a contract to which you are a party. A contract between Opto Agency and a client business does not, by itself, make contract the lawful basis for processing your personal information.

Consent

Where consent is required for a particular activity, we will ask for it in an appropriate way. You may withdraw your consent at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.

Legal obligation

We may process personal information where necessary to comply with a legal or regulatory obligation.

We use technology to help manage enquiries and communications. This may include automated text messages, email follow-ups, CRM workflows and software that supports automated conversations.

Automated conversation software may be used to respond to enquiries and request basic information, such as a lead’s name and postcode, as part of the enquiry and appointment-setting process. The software is used to assist with communications and does not make solely automated decisions which have a legal or similarly significant effect on individuals.

Submitting an enquiry allows us and the relevant client business to contact you about that enquiry. This does not automatically mean that you have agreed to receive unrelated or future direct marketing.

Where electronic marketing rules apply, marketing emails, text messages or other electronic marketing will only be sent where the sender has an appropriate basis under applicable data protection law and the Privacy and Electronic Communications Regulations (PECR). Where consent is required, it must be obtained separately and you can withdraw it at any time.

You can ask not to receive direct marketing at any time by using the unsubscribe or opt-out method provided in the communication or by contacting the organisation responsible for the marketing.

Depending on the circumstances, personal information may be shared with:

• the client business whose products or services you enquired about;
• authorised Opto Agency team members who work on the relevant client account and require access to provide the services;
• freelancers, contractors and service providers used to support delivery of the services;
• CRM, appointment-setting, communication, automation, advertising, reporting and other technology providers;
• professional advisers, insurers or other advisers where reasonably necessary;
• regulators, law enforcement bodies, courts or other authorities where required by law; and
• a purchaser, investor or successor organisation where our business or relevant assets are sold or reorganised, subject to appropriate safeguards.

We do not sell personal information to third parties.

We use third-party technology and service providers to operate campaigns and manage enquiries. Some providers may process personal information outside the United Kingdom.

Where personal information is transferred internationally and UK data protection law requires safeguards, the relevant Controller will ensure that an appropriate transfer mechanism or other lawful safeguard is in place.

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including to manage enquiries, provide services, resolve complaints or disputes, meet legal or regulatory requirements and establish or defend legal claims.

Lead and enquiry information will normally be retained for no longer than 12 months from the date of the enquiry and may be deleted earlier where it is no longer required. We do not use lead information for ongoing lead generation or contact after 12 months. Information may be retained for longer where this is reasonably necessary to deal with a complaint or dispute, comply with a legal or regulatory requirement, or establish, exercise or defend a legal claim.

We take appropriate technical and organisational measures designed to protect personal information against unauthorised or unlawful access, use, alteration, disclosure, loss or destruction. Access to lead and enquiry information is restricted to authorised team members who work on the relevant client account and require access to provide the services.

No internet-based system can be guaranteed to be completely secure. Where we become aware of a personal data breach, we will deal with it in accordance with applicable data protection law.

Depending on the circumstances, you may have the right to:

• request access to personal information held about you;
• ask for inaccurate or incomplete information to be corrected;
• request deletion of your personal information in certain circumstances;
• request restriction of processing in certain circumstances;
• object to processing based on legitimate interests, including an absolute right to object to direct marketing;
• request transfer of certain information to you or another organisation where the right to data portability applies;
• withdraw consent where processing is based on consent; and
• raise concerns about solely automated decision-making where applicable.

These rights are not absolute and may depend on the circumstances and the lawful basis for processing.

If your request relates to a particular client business or an enquiry submitted through that client’s campaign, the client business may be the Controller responsible for dealing with your request. You can contact the client business directly or contact us and we will assist or direct the request as appropriate.

You can contact Opto Agency at: info@optoagency.com

We may need to ask for information to verify your identity before responding to a request.

If you have concerns about how your personal information has been handled, please contact us or, where relevant, the client business connected with your enquiry.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection. The ICO can be contacted through its website at ico.org.uk or by telephone on 0303 123 1113.

We may update this Privacy Policy from time to time to reflect changes to our services, technology, legal requirements or the way personal information is used. The current version should be made available wherever this policy is published or linked.

Opto Agency Limited

Email: info@optoagency.com