| Version | 3.0 |
| Effective Date | 29 July 2026 |
| Data Controller | Lead Labs Group Ltd |
| ICO Registration | ZC191646 |
| Governing Laws | UK GDPR / Data Protection Act 2018 Australian Privacy Act 1988 (Cth) / APPs |
| Server Location / Company | United Kingdom Company No. 17051237 |
1. About This Privacy Policy
This Privacy Policy explains how Lead Labs Group Ltd (“we”, “us”, “our”), operating the website BusinessPrices.net, collects, uses, discloses and protects personal information about individuals (“you”, “your”) who submit an enquiry through our multi-step enquiry form.
Lead Labs Group Ltd is a company registered in England and Wales (company number 17051237) whose servers are located in the United Kingdom. Our primary market is Australia: we generate business energy enquiries from individuals and businesses in Australia, which we supply to contracted fulfilment partners who provide the comparison and switching service.
Because we carry on business in Australia and collect the personal information of individuals in Australia, we are subject to the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) under section 5B of that Act, notwithstanding that we are incorporated in the United Kingdom. This Policy is designed to comply with:
- The Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), administered by the Office of the Australian Information Commissioner (OAIC);
- The Spam Act 2003 (Cth) and the Telecommunications (Do Not Call Register) Act 2006 (Cth);
- The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, administered by the Information Commissioner’s Office (ICO), in respect of our UK-based processing.
By submitting an enquiry through BusinessPrices.net you acknowledge that you have read and understood this Policy.
2. Who We Are — Data Controller Details
Lead Labs Group Ltd — Data Controller
| Trading name | BusinessPrices.net |
| Registered office | 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ |
| Company number | 17051237 |
| ICO registration | ZC191646 |
| Privacy contact | management@leadlabs.co.uk |
| Website | https://www.businessprices.net |
For Australian privacy enquiries the same contact details apply. We do not maintain a separately registered Australian entity; as set out in Section 1, by carrying on business in Australia and collecting information from individuals in Australia we are nonetheless bound by the Australian Privacy Act 1988 (Cth) and the APPs.
3. Information We Collect
3.1 Information You Provide Through the Enquiry Form
Our enquiry form is a multi-step flow. Across its steps we collect the following personal information:
| Step / Category | What we collect |
|---|---|
| Business or home | Whether the enquiry relates to a business or home premises |
| Fuel type | Electricity, gas or both |
| Postcode | The postcode of the premises |
| Business name | The name of your business |
| Spend | Your approximate monthly energy spend (used to qualify the enquiry) |
| First name | Your first name |
| Email address | Your email address. A lead record is created in our database at this step. The consent statement (see Section 4.1) is displayed here. |
| Phone number | Your telephone number. The consent statement is displayed again at this step before you continue. |
We do not seek sensitive information (such as health, racial or ethnic origin, financial account or biometric data). Please do not submit such information through our form.
3.2 Information We Collect Automatically
When you visit BusinessPrices.net we automatically collect certain technical data, including:
| Category | Details |
|---|---|
| IP address | Collected by our web server and analytics tools; used for fraud prevention and geographic analytics |
| Device & browser identifiers | Browser type, operating system, screen resolution |
| Referring URL | The page or advertisement that brought you to our site |
| Google Click Identifier (GCLID) | Passed from Google Ads when you arrive via a paid search advertisement; used for conversion tracking and campaign optimisation |
| Cookie & tracking data | Set and read in accordance with Section 12 (Cookies). Includes analytics and, where you consent, advertising cookies |
We use cookies to collect this technical data. Where those cookies are non-essential (analytics or advertising), we collect this data only where you have given your consent via our cookie banner — see Section 12.
4. How and Why We Use Your Information
4.1 Consent Obtained During the Enquiry Form
Consent statement displayed at the email and phone-number steps of the enquiry form
“By continuing you agree to be contacted by us and your matched provider. See our Privacy Policy.”
This statement is presented as a clear notice immediately before each of the email-address and telephone-number steps. Continuing past either step constitutes your consent to:
(a) Lead Labs Group Ltd contacting you by email, telephone and SMS to progress your enquiry and to market related business services; and
(b) your matched fulfilment partner(s) contacting you with quotes and information relevant to your energy enquiry.
You may withdraw consent at any time — see Section 11.
We process your personal information for the purposes set out below. The table identifies, for each purpose, the basis under the Australian Privacy Act (our primary framework) and the corresponding UK GDPR lawful basis for any processing carried out in the UK.
| Purpose | Basis (Australian Privacy Act / UK GDPR) |
|---|---|
| Passing your enquiry to one or more contracted fulfilment partners so they can contact you to provide a quote and, where you proceed, the switching service (“lead fulfilment”) | Australian Privacy Act: APP 6.1 — primary purpose of collection, reinforced by your express consent obtained at the email / phone steps. UK GDPR: Art. 6(1)(a) — consent; alternatively Art. 6(1)(b) (steps taken at your request). |
| Contacting you by email, SMS and telephone to progress your enquiry and to market related business services we operate or promote | Australian Privacy Act: APP 7 — direct marketing with consent obtained via the form; simple opt-out in every message. Spam Act 2003 (Cth). UK GDPR: Art. 6(1)(a) — consent; supported by Art. 6(1)(f) legitimate interests and PECR soft opt-in where applicable. |
| Administering our platform, processing enquiries, verifying lead quality and maintaining records | APP 6.1 — primary purpose of collection. UK GDPR Art. 6(1)(b). |
| Conversion tracking, campaign analytics and advertising audience-building (GCLID, cookies — see Section 6) | Australian Privacy Act: APP 6.2(a) — reasonably expected secondary purpose, with cookie consent obtained separately. UK GDPR: Art. 6(1)(a) — consent via cookie banner. |
| Complying with legal obligations (e.g. tax and financial records, regulatory requests) | APP 3 / APP 6.2(b) — required or authorised by law. UK GDPR Art. 6(1)(c). |
| Protecting our legal rights and preventing fraud | APP 6.2(a) — related secondary purpose. UK GDPR Art. 6(1)(f) legitimate interests. |
5. Legitimate Interests — Supplementary Basis
Although consent is our primary basis for lead fulfilment and direct marketing (Section 4.1), we additionally rely on legitimate interests as a supplementary lawful basis for UK-based processing, in case consent is later found to be technically deficient or is withdrawn in part. We have carried out a Legitimate Interests Assessment (LIA); a summary is set out below. The full LIA is available on request.
LIA Summary — Lead Fulfilment & Direct Marketing
| Purpose | To connect you with energy providers who can quote on and deliver the service you asked for, and to follow up on and cross-sell related business services. |
| Legitimate interest | BusinessPrices.net is a commercial comparison and lead-generation platform. Operating this marketplace and maintaining contact with leads is our core business activity. |
| Necessity | Passing enquiry data to matched partners, and making follow-up contact, are the minimum steps required to fulfil the purpose of the platform. |
| Why within expectations | You submit an enquiry on a site clearly described as a comparison/lead service. Being contacted by a matched provider is the outcome you request. The consent statement in the form reinforces that this is expected. |
| Safeguards | We disclose only to contracted partners; provide only the data needed; limit partners per enquiry; honour opt-outs immediately; and you may object at any time — see Section 11. |
| Balance | Your right to object to direct marketing is absolute and always honoured. |
6. Advertising and Audience-Building
We run paid advertising campaigns (principally Google Ads) to drive enquiries to BusinessPrices.net. This involves the collection and use of advertising identifiers and cookie data as described below.
6.1 Google Click Identifier (GCLID) and Conversion Tracking
When you arrive at BusinessPrices.net from a Google Ads advertisement, Google appends a unique Google Click Identifier (GCLID) to the landing page URL. We capture this identifier and associate it with your lead record in our database. We use the GCLID to:
- Report conversions back to Google Ads so we can measure the effectiveness of our advertising spend;
- Optimise our bidding strategy and keyword targeting within Google Ads;
- Attribute enquiries to specific campaigns, ad groups, and keywords.
The GCLID itself does not identify you personally, but when combined with your lead record it constitutes personal data. We process it on the basis of your consent, obtained through our cookie banner (for the analytics/advertising cookie that enables the GCLID to be read), and through your use of our enquiry form.
6.2 Google Customer Match and Lookalike / Similar Audiences
We may from time to time upload hashed contact details (email address and/or telephone number) to Google’s Customer Match service in order to:
- Suppress existing leads from our Google Ads campaigns (to avoid advertising to people already in our database);
- Build ‘Similar Audiences’ of new prospects who share characteristics with our existing leads.
Before any upload to Customer Match we hash your data (using SHA-256) so that Google receives only a one-way fingerprint, not your raw contact details. Google’s use of this data is governed by Google’s own privacy policy and terms. We rely on Art. 6(1)(f) UK GDPR (legitimate interests: suppression and prospecting) and the consent obtained via our enquiry form for this activity. You may opt out of your data being used in this way by contacting us — see Section 11.
6.3 Meta (Facebook / Instagram) Custom and Lookalike Audiences
We may use the Meta Pixel and/or the Meta Conversions API to:
- Report conversion events to Meta for campaign measurement;
- Build Custom Audiences from our website visitors or lead lists;
- Build Lookalike Audiences of new prospects.
Meta pixel cookies are non-essential and are only placed where you have consented via our cookie banner. Where we upload contact lists to Meta, we hash data before transmission in the same way as described for Google Customer Match above.
6.4 Advertising Cookies and Cookie Banner
All non-essential advertising and analytics cookies (including those that enable GCLID capture, the Meta Pixel, and any similar third-party tags) are gated behind our cookie consent banner. You will be presented with the banner on your first visit. You may change your cookie preferences at any time via the “Cookie Settings” link in our website footer.
Where you decline advertising cookies, the relevant tags are not loaded, no advertising identifiers are captured, and your data is not uploaded to advertising platforms as a result of that session.
6.5 Preference Centre
Our website provides a cookie preference centre accessible at any time. Through it you can:
- Accept or decline strictly necessary cookies (strictly necessary cookies cannot be declined as the site cannot function without them);
- Accept or decline analytics cookies;
- Accept or decline advertising / targeting cookies;
- Withdraw or change any previously given cookie consent.
Your preferences are stored in a first-party cookie and respected on each subsequent visit.
7. Sharing Your Information
7.1 Contracted Fulfilment Partners
Your enquiry details are disclosed to one or more fulfilment partners matched to your enquiry, with whom we hold a written contract. These partners contact you directly to provide quotes and the switching service, and each acts as an independent data controller for the information they receive. Our contracts require partners to handle your information lawfully and only for the purpose of responding to and fulfilling your enquiry. We provide only the data necessary for that purpose and limit the number of partners contacted per enquiry.
7.2 Advertising Platforms
As described in Section 6, we share hashed contact data and event data with Google and Meta for advertising and campaign measurement purposes, subject to your consent and the safeguards described.
7.3 Service Providers (Processors)
We may share your data with third-party service providers who process it on our behalf under written agreements, including web hosting and cloud infrastructure, email/SMS and CRM platforms, lead-verification and fraud-prevention providers, and our professional advisers. They may use your data only on our instructions.
7.4 Legal and Regulatory Disclosure
We may disclose your information to law enforcement, regulators (including the OAIC or ICO) or courts where legally required or permitted, or where necessary to establish, exercise or defend legal claims.
7.5 Business Transfers
In a merger, acquisition, financing or sale of assets, your personal information may be disclosed to the prospective or actual acquirer and its advisers, subject to appropriate confidentiality and privacy protections.
7.6 How We Describe Our Lead Business
We operate a commercial lead-generation marketplace: we may receive payment from fulfilment partners for qualified leads. We are transparent that our business is funded in this way. We do not disclose your personal information to unrelated third parties for those third parties’ own independent marketing that is unconnected with your enquiry.
8. Cross-Border and Overseas Handling of Information
8.1 Australian Privacy Act Perspective (APP 8)
Although your information is collected in Australia, the data controller (us) and our servers and certain processors are located in the United Kingdom, and your information will be accessed and stored there.
By submitting an enquiry on BusinessPrices.net you are informed, and you consent, that your personal information will be disclosed to and handled by Lead Labs Group Ltd and its processors in the United Kingdom for the purposes set out in this Policy. In reliance on this notice and your consent under APP 8.2(b), APP 8 does not require us to take further steps in respect of those UK recipients; the United Kingdom maintains a comprehensive data-protection regime (UK GDPR and the Data Protection Act 2018) providing protection substantially similar to the APPs.
8.2 UK GDPR Perspective
For information processed in the UK and any onward disclosure to a fulfilment partner in Australia, transfers are governed by Chapter V UK GDPR. Where required we rely on a UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU SCCs, or on the contractual-necessity derogation in Article 49(1)(b) for the disclosure to a partner you have asked us to engage.
9. How Long We Keep Your Data
| Data category | Retention period |
|---|---|
| Enquiry / lead data (name, contact, enquiry details) | Up to 3 years from the date of enquiry or last engagement, or until you withdraw consent / object / unsubscribe, whichever is sooner |
| Consent records (form consent, cookie consent) | 6 years from date of consent, to demonstrate compliance |
| Marketing suppression list (opt-out records) | Indefinitely, to honour your opt-out |
| Advertising identifiers (GCLID, hashed data uploads) | In our systems: up to 3 years. On Google / Meta platforms: subject to their own retention policies |
| Analytics and cookie data | Up to 26 months (anonymised after 13 months) |
| Legal / financial records | 6 years (UK statutory minimum) / as required by Australian law |
After the relevant retention period, personal information is securely deleted or de-identified. You may request earlier deletion — see Section 11.
10. Security
We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, loss, destruction, alteration or disclosure, including encryption in transit (TLS/SSL), access controls, staff training, and incident-response procedures.
In the event of an eligible data breach likely to result in serious harm we will notify the OAIC and affected individuals as required under the Notifiable Data Breaches scheme (Privacy Act 1988 (Cth)), and, for UK processing, notify the ICO within 72 hours and affected individuals without undue delay where required under UK GDPR Articles 33–34.
11. Your Rights and Choices
11.1 Rights Under the Australian Privacy Act
- APP 12 — Access: request access to the personal information we hold about you.
- APP 13 — Correction: request correction of inaccurate or out-of-date information.
- APP 7 — Direct-marketing opt-out: opt out of direct marketing at any time using the unsubscribe link in any email, by replying STOP to an SMS, or by contacting us. We action requests promptly and at no cost, and you may ask us to identify the source of information used to market to you.
- Withdraw consent: where we rely on your consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.
- Complain: complain to us and, if unsatisfied, to the OAIC at www.oaic.gov.au.
11.2 Rights Under UK GDPR (UK-based Processing)
| Right | What it means |
|---|---|
| Access (Art. 15) | Request a copy of the personal data we hold about you. |
| Rectification (Art. 16) | Request correction of inaccurate or incomplete data. |
| Erasure (Art. 17) | Request deletion where we no longer have a lawful basis to hold your data. |
| Restriction (Art. 18) | Ask us to pause processing in certain circumstances. |
| Portability (Art. 20) | Receive your data in a structured, machine-readable format. |
| Objection (Art. 21) | Object to processing based on legitimate interests, including direct marketing. Objection to direct marketing is absolute and always honoured. |
| Withdraw consent (Art. 7(3)) | Withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal. |
11.3 How to Exercise Your Rights
Contact our privacy team
Email: management@leadlabs.co.uk
Post: Privacy Officer, Lead Labs Group Ltd,
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ
Response time: Within 30 days. We may need to verify your identity.
No charge in most circumstances.
12. Cookies and Tracking Technologies
BusinessPrices.net uses cookies and similar technologies. We describe them below by category:
| Cookie category | Description and legal basis |
| Strictly necessary | Essential for the website and enquiry form to function (e.g. session management, CSRF protection, cookie-preference storage). No consent required — UK GDPR Art. 6(1)(f) / PECR Reg. 6(4) exemption. |
| Analytics | Used to understand how visitors use our site (e.g. Google Analytics). Collected only with your consent via our cookie banner. UK GDPR Art. 6(1)(a). |
| Advertising / targeting | Used for conversion tracking (including GCLID capture via Google Ads tags), remarketing, and advertising audience-building (Google, Meta). Collected only with your consent via our cookie banner. UK GDPR Art. 6(1)(a). |
A cookie banner is presented on your first visit. Non-essential cookies are not loaded until you provide consent. You may update your preferences at any time through the “Cookie Settings” link in the footer of every page.
Full details of the specific cookies we set, their duration, and the third parties involved are set out in our Cookie Policy, available at https://www.businessprices.net/cookie-policy/.
13. Children’s Privacy
BusinessPrices.net is a business-to-business comparison platform and is not directed at children under 18. We do not knowingly collect personal information from children. If you believe we have inadvertently received a child’s information, please contact us and we will delete it.
14. Additional Information for Australian Users
14.1 Collection Notice (APP 5)
At or before the time we collect your personal information we make the following matters known to you:
- The entity collecting your information is Lead Labs Group Ltd, trading as BusinessPrices.net, a UK company carrying on business in Australia; contact details are in Sections 2 and 16.
- We collect your information to connect you with contracted energy providers who can quote on and fulfil your enquiry, and for our own follow-up and marketing of related business services. Your consent to this is obtained via the consent statement displayed at the email-address and telephone-number steps of the enquiry form.
- Your information will be disclosed to: (a) matched fulfilment partners (typically in Australia); (b) our UK-based operations, service providers and processors; (c) advertising platforms (Google, Meta) where you have separately consented via our cookie banner; and (d) regulators or courts where required by law.
- Your information is likely to be disclosed to overseas recipients, principally in the United Kingdom. See Section 8.
- You are not obliged to provide your information, but if you do not we may be unable to respond to your enquiry or connect you with providers.
- You may access and correct your information and complain about our handling of it — see Section 11.
14.2 Spam Act 2003 (Cth) Compliance
All commercial electronic messages we send to Australian recipients will identify Lead Labs Group Ltd / BusinessPrices.net as the sender, include our contact details, and include a functional unsubscribe facility that stays active for at least 30 days. We will not message an address after an unsubscribe request, which we action within 5 business days.
We rely on the express consent obtained through the enquiry form consent statement as the basis for sending commercial electronic messages, in compliance with the Spam Act 2003 (Cth) — see Section 4.1.
14.3 Do Not Call Register
Where we or our partners undertake telephone marketing, calls comply with the Telecommunications (Do Not Call Register) Act 2006 (Cth).
15. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology or legal requirements. The current version is published at https://www.businessprices.net/privacy-policy/ with the effective date shown at the top. Where changes are material we will take reasonable steps to notify you.
16. Contact Us
| Email: | management@leadlabs.co.uk |
| Post: | Privacy Officer, Lead Labs Group Ltd, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ |
| Website: | https://www.businessprices.net |