Privacy Policy
Last updated: 21 February 2026
1. Introduction
This Privacy Policy explains how Campley Holdings Ltd ("we", "us", "our") collects, uses, stores, and protects your personal data when you visit lefcoin.com (the "Site"). We are committed to protecting your privacy and handling your data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
By using the Site, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, please do not use the Site.
2. Data Controller
The data controller responsible for your personal data is:
- Company: Campley Holdings Ltd
- Registered in: England & Wales
- Contact email: admin@lefcoin.com
If you have any questions about this Privacy Policy or our data practices, please contact us using the email address above.
3. What Data We Collect
We collect and process the following categories of personal data:
3.1 Analytics Data (Google Analytics 4)
When you visit the Site and consent to analytics cookies, we collect data through Google Analytics 4 (Measurement ID: G-MZGQX190BV). This includes:
- IP address (anonymised by Google in the EEA/UK by default)
- Device type, operating system, and browser information
- Pages visited, time spent on pages, and navigation paths
- Referring website or search engine
- Approximate geographic location (derived from IP address)
- Screen resolution and viewport size
Legal basis: Consent. Analytics data is only collected after you accept analytics cookies via our cookie banner. You may withdraw consent at any time by clearing your cookies or using your browser settings.
3.2 Contribution Form Data (FormSubmit.co)
If you submit the contribution form on the Contribute page, we collect:
- Your name
- Your email address
- Proposal type (e.g., data source, subindex, methodology improvement)
- Description of your contribution or proposal
This data is submitted via FormSubmit.co, a third-party form processing service that forwards submissions to our email inbox. FormSubmit.co acts as a data processor on our behalf.
Legal basis: Legitimate interest (to process and respond to your contribution proposals) and consent (you actively choose to submit the form).
3.3 Data Collected by Third-Party Services
The Site loads resources from third-party services that may collect limited technical data:
| Service | Purpose | Data Collected |
|---|---|---|
| Google Fonts (fonts.googleapis.com) | Typography (Archivo Black, Space Grotesk) | IP address, HTTP referrer, user agent |
| Chart.js CDN (cdn.jsdelivr.net) | Chart rendering on the homepage | IP address, HTTP referrer |
| Base Mainnet RPC (mainnet.base.org) | Fetching on-chain LOVE Index data | IP address |
| Google Analytics (googletagmanager.com) | Website analytics (with consent) | See Section 3.1 above |
| FormSubmit.co | Form processing (Contribute page) | See Section 3.2 above |
These services have their own privacy policies. We encourage you to review them:
- Google Privacy Policy (covers Google Analytics and Google Fonts)
- jsDelivr Privacy Policy
- FormSubmit.co Privacy Policy
4. Cookies
Cookies are small text files stored on your device when you visit a website. We use the following cookies:
| Cookie Name | Provider | Purpose | Duration | Type |
|---|---|---|---|---|
| _ga | Google Analytics | Distinguishes unique visitors by assigning a randomly generated identifier | 2 years | Analytics |
| _ga_MZGQX190BV | Google Analytics | Maintains session state and persists session data across page loads | 2 years | Analytics |
| lefcoin_cookie_consent | lefcoin.com (first-party) | Stores your cookie consent preference so the banner is not shown again | 365 days | Strictly Necessary |
Analytics cookies (_ga, _ga_MZGQX190BV) are only set after you provide consent via the cookie banner. The consent cookie (lefcoin_cookie_consent) is classified as strictly necessary because it records your preference and does not track you.
You can manage or delete cookies at any time through your browser settings. Please note that disabling cookies may affect the functionality of the Site.
5. How We Use Your Data
We use the data we collect for the following purposes:
- Website analytics: To understand how visitors interact with the Site, identify popular content, and improve user experience.
- Processing contributions: To receive, review, and respond to contribution proposals submitted through the Contribute page.
- Site functionality: To display live on-chain data and render visual elements (charts, typography) on the Site.
- Legal compliance: To comply with applicable laws and regulations, and to establish, exercise, or defend legal claims.
6. Legal Bases for Processing
Under the UK GDPR, we must have a lawful basis for processing your personal data. We rely on the following legal bases:
| Processing Activity | Legal Basis | UK GDPR Article |
|---|---|---|
| Google Analytics data collection | Consent (via cookie banner) | Article 6(1)(a) |
| Contribution form submissions | Legitimate interest / Consent | Article 6(1)(a) and 6(1)(f) |
| Cookie consent preference storage | Legitimate interest (strictly necessary) | Article 6(1)(f) |
| Third-party resource loading (fonts, CDN, RPC) | Legitimate interest (Site functionality) | Article 6(1)(f) |
Where we rely on legitimate interest, we have conducted a Legitimate Interest Assessment to ensure that your rights and freedoms are not overridden. You have the right to object to processing based on legitimate interest at any time (see Section 9).
7. Data Sharing and Transfers
We do not sell, rent, or trade your personal data to any third party. We share data only with the following categories of recipients, strictly as necessary:
- Google LLC (as data processor for Google Analytics 4) — Analytics data is processed on Google's servers. Google may transfer data outside the UK. Google relies on Standard Contractual Clauses and other safeguards approved by the UK Information Commissioner. See Google's Data Processing Terms.
- FormSubmit.co (as data processor for form submissions) — Contribution form data is routed through FormSubmit.co and delivered to our email inbox.
- CDN providers (jsDelivr, Google Fonts) — These services receive your IP address and referrer information as part of delivering resources to your browser. This is a technical necessity, not a deliberate data sharing arrangement.
Where personal data is transferred outside the United Kingdom, we ensure that appropriate safeguards are in place in accordance with UK GDPR Article 46, including Standard Contractual Clauses or adequacy decisions.
8. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected:
| Data Type | Retention Period | Notes |
|---|---|---|
| Google Analytics data | 14 months | Retained per Google Analytics default settings. Automatically deleted after expiry. |
| Contribution form submissions | Indefinite (in email inbox) | Retained until manually deleted or until you request erasure. |
| Cookie consent preference | 365 days | Stored locally in your browser. Automatically expires. |
9. Your Rights Under UK GDPR
Under the UK GDPR, you have the following rights in relation to your personal data:
- Right of access (Article 15) — You have the right to request a copy of the personal data we hold about you.
- Right to rectification (Article 16) — You have the right to request correction of inaccurate or incomplete personal data.
- Right to erasure (Article 17) — You have the right to request deletion of your personal data where there is no compelling reason for its continued processing.
- Right to restriction of processing (Article 18) — You have the right to request that we restrict the processing of your personal data in certain circumstances.
- Right to data portability (Article 20) — You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
- Right to object (Article 21) — You have the right to object to processing based on legitimate interest or for direct marketing purposes.
- Right to withdraw consent — Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, please contact us at admin@lefcoin.com. We will respond to your request within one month, as required by law. In certain circumstances, we may extend this period by a further two months, in which case we will inform you of the extension and the reasons for it.
10. Data Security
We take appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:
- The Site is served over HTTPS (TLS encryption) to protect data in transit.
- Access to email inboxes containing form submission data is restricted to authorised personnel.
- We use reputable third-party services (Google, Cloudflare) that maintain industry-standard security practices.
- We regularly review our data processing activities and security measures.
While we strive to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security.
11. Automated Decision-Making and Profiling
We do not use your personal data for automated decision-making or profiling as defined under UK GDPR Article 22. No decisions with legal or similarly significant effects are made about you based solely on automated processing.
12. Children's Privacy
The Site is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at admin@lefcoin.com and we will take steps to delete such data promptly.
13. Links to Third-Party Websites
The Site may contain links to third-party websites, including BaseScan, GitHub, and other services within the Campley Holdings ecosystem. We are not responsible for the privacy practices of these third-party websites. We encourage you to read the privacy policy of any website you visit.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or the services we use. When we make material changes, we will update the "Last updated" date at the top of this page. We encourage you to review this page periodically.
Continued use of the Site after changes are posted constitutes your acknowledgement of the revised Privacy Policy.
15. Complaints
If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the UK supervisory authority:
- Information Commissioner's Office (ICO)
- Website: ico.org.uk
- Telephone: 0303 123 1113
- Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
We would appreciate the opportunity to address your concerns before you contact the ICO. Please reach out to us first at admin@lefcoin.com.
16. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal data, please contact us:
- Email: admin@lefcoin.com
- Data Controller: Campley Holdings Ltd, registered in England & Wales