LeadFilter™ — Data Subject Rights Procedure

Last Updated: November 18, 2025

Website: leadfilter.ca

Legal Entity: VIGO ONLINE GROUP (Sole Proprietorship, BIN: 1000520463)

Merchant of Record: VIGO ONLINE GROUP

Address: 2 Robert Speck Pkwy Suite 750, Mississauga, ON L4Z 1H8

1. Purpose of this Document

1.1. This Procedure defines the process by which VIGO ONLINE GROUP (“Company,” “we,” “us”) receives, identifies, processes, and fulfills requests from data subjects (“You,” “User,” “Lead”) regarding their personal data.

1.2. This Procedure ensures compliance with:

• GDPR (General Data Protection Regulation) — EU/EEA;
• PIPEDA (Personal Information Protection and Electronic Documents Act) — Canada;
• CCPA / CPRA (California Consumer Privacy Act) — USA;
• Other applicable data protection laws where VIGO operates as the Merchant of Record.

2. Who is Considered a “Data Subject”

For the purposes of this Procedure, a Data Subject is any natural person whose data is processed by the LeadFilter™ platform, specifically:

• Partners: Users who register an account to create Quizzes.
• Leads (Purchasers): End-users who purchase digital goods or complete Quizzes hosted on the platform.

3. Types of Requests

We accept and process the following requests:

3.1. Right of Access: Request a copy of all personal data we hold about you.

3.2. Right to Rectification: Request correction of inaccurate or incomplete data.

3.3. Right to Erasure (“Right to be Forgotten”): Request deletion of personal data (subject to tax/legal retention requirements).

3.4. Right to Restriction: Request to freeze data processing temporarily.

3.5. Right to Portability: Request to receive data in a structured, machine-readable format (JSON/CSV).

3.6. Right to Object: Object to processing based on legitimate interests.

3.7. CCPA Rights: Request to opt-out of the “sale” or “sharing” of personal information.

4. Channels for Submitting Requests

To initiate a request, the Data Subject must use one of the official channels:

Email: support@leadfilter.ca

Mail: VIGO ONLINE GROUP, 2 Robert Speck Pkwy Suite 750, Mississauga, ON L4Z 1H8

Note: Requests submitted via social media or third-party chats are not considered official and may not be processed.

5. Identity Verification Procedure

5.1. To prevent unauthorized data disclosure, we strictly verify the identity of the requestor.

5.2. Verification methods:

• For Partners: We will send a confirmation code to the registered email address of the account.
• For Leads: We may request the Transaction ID, the exact email used during the purchase, or the date of the transaction.
  5.3. If the requestor cannot prove they own the email address associated with the data, the request will be denied.

6. Request Processing Times

We strive to fulfill requests within the statutory timeframes:

• GDPR (EU/UK): 30 calendar days. (Can be extended by 60 days for complex requests).
• PIPEDA (Canada): 30 calendar days.
• CCPA (California): 45 calendar days.

7. Grounds for Refusal

VIGO ONLINE GROUP may refuse to fulfill a request (fully or partially) if:

7.1. Legal Obligation (Tax/MoR): We cannot delete transaction records (invoices, payments) required by tax authorities (CRA/IRS) for 7 years, even if a deletion request is submitted.

7.2. Processor Role: If the request concerns data where VIGO is only the Processor (e.g., specific answers inside a Quiz), we cannot delete it without the instruction of the Controller (the Partner).

7.3. Unfounded/Excessive: The request is repetitive or intended to disrupt operations.

7.4. Identity Failure: The requestor failed to verify their identity.

8. Handling Requests: VIGO vs. Partner

Since VIGO operates as a Merchant of Record but facilitates Partner content, the handling of data depends on the data type:

8.1. Billing & Account Data (VIGO = Controller).

If a user requests access/deletion of their account login or billing history, VIGO handles this request directly.

8.2. Quiz Answers & Content (Partner = Controller).

If a Lead requests access/deletion of the specific answers they gave in a Quiz:

• VIGO acts as the Data Processor.
• We will forward the request to the specific Partner (Creator) who owns that Quiz.
• The Partner is legally obligated to instruct VIGO on how to proceed (e.g., “Delete this lead”).
• VIGO will execute the technical deletion upon the Partner’s instruction.

9. Request Fulfillment Workflow

1. Receipt: The request is logged in our internal ticketing system.
2. Verification: Support team verifies the user’s identity via email.
3. Classification: We determine if the data belongs to VIGO (Billing) or a Partner (Quiz Content).
4. Action:

• Billing Data: We export/anonymize the data directly.
• Quiz Data: We notify the Partner and await instruction.

1. Completion: We notify the Data Subject that the request has been fulfilled (or explain why it cannot be).

10. Fees

10.1. Standard requests are processed free of charge.

10.2. We reserve the right to charge a reasonable administrative fee for requests that are manifestly unfounded, excessive, or repetitive.

11. Contact Information

To submit a Data Subject Request:

VIGO ONLINE GROUP

Data Protection Officer

Email: support@leadfilter.ca

Phone: +1 437 886 3152

Address: 2 Robert Speck Pkwy Suite 750, Mississauga, ON L4Z 1H8

12. Updates

This Procedure is effective from the date of its publication on leadfilter.ca and forms an integral part of our Privacy Policy.