Legal

Privacy Policy

Last Updated: April 18, 2026  ·  Applies to: leadvar.com and the Leadvar API service

What we collect
  • Name and email at account registration
  • API key identifier and request timestamps
  • Server logs (IP, page, referrer) — 30 days
  • Payment records for invoicing
What we never do
  • Store email addresses you enrich via API
  • Sell or share your data with advertisers
  • Use cookies or third-party analytics
  • Send marketing emails without opt-in
Your rights
  • Access, correct, or delete your data
  • Export your data (portability)
  • Object to processing based on legitimate interest
  • Lodge a complaint with your local DPA

Leadvar ("we", "us", "our") is operated by Daniil Shurko, an individual based in Belgium, trading as Leadvar. This Privacy Policy explains how we collect, use, store, and protect personal data when you use our Service at leadvar.com, and the choices available to you.

Short version: We collect only what's necessary to run the service. We do not store the email addresses you enrich. We do not sell your data. We do not run ads.

1. Information We Collect

A. Data You Provide Directly

B. Data Collected Automatically

We do not use cookies, tracking pixels, or third-party analytics tools on this website.

C. Data from Third-Party Processors

Importantly: raw email addresses you send to our API are forwarded to these processors to generate the enrichment response, then immediately discarded — we do not persist them in our database.

2. How We Use Your Data

We do NOT use your data for: unsolicited marketing emails (unless you opt in), third-party advertising, or sale to other companies.

The lead score returned via the API is informational only. It does not constitute solely automated decision-making with legal or similarly significant effects on individuals under GDPR Article 22.

3. Data Retention

Data TypeRetention Period
Account informationDuration of service + 30 days after deletion request
Email addresses enriched via APINot stored — deleted immediately after API response
API request logs30 days (for debugging and abuse detection)
API keysUntil account deletion
Invoices & payment records7 years (statutory tax requirement)
Contact form submissionsUntil resolved, then deleted within 90 days

4. Legal Basis for Processing (GDPR)

Under GDPR Article 6, we process personal data based on the following legal grounds:

We do not process special categories of personal data (race, health, religion, biometrics, etc.) under GDPR Article 9.

5. Who We Share Data With

Service Providers (Sub-processors)

ProcessorPurposeLocation
ZeroBounceEmail validationUnited States
ApolloPerson & company enrichmentUnited States
HetznerCloud hosting & storageGermany (EU)
StripePayment processingUnited States

All sub-processors are bound by their own Data Processing Agreements. Where data is transferred outside the EU (ZeroBounce, Apollo, Stripe), we rely on EU-US Data Privacy Framework (DPF) certification where applicable, and Standard Contractual Clauses (SCCs) under GDPR Art. 46(2)(c) as a fallback, supplemented by Transfer Impact Assessments where required. You can request confirmation of applicable transfer mechanisms at hello@leadvar.com.

Legal Requirements

We may disclose data if required by law, court order, or lawful government request. Where legally permitted, we will notify you of such a request before disclosing.

Business Transfer

If Leadvar is acquired by or merges with another company, your data may be transferred as part of that transaction. We will notify you via email prior to any such transfer.

6. Your Rights

Under GDPR (EU/EEA residents)

Right of AccessRequest a copy of all data we hold about you
Right to RectificationCorrect inaccurate or incomplete data
Right to ErasureDelete your account and personal data (except legally required records)
Right to RestrictionLimit how we use your data in certain circumstances
Right to PortabilityReceive your data in a machine-readable format
Right to ObjectOpt out of processing based on legitimate interest

Under CCPA (California residents)

To exercise any right: email hello@leadvar.com. We will respond within 30 days. For complex or numerous requests, we may extend this by a further two months and will notify you within the first month with the reason for the delay. If you are in the EU/EEA and unsatisfied with our response, you have the right to lodge a complaint with your local data protection authority (DPA).

7. Data Security

While we follow industry best practices, no system is 100% secure. In the event of a data breach affecting your personal data, we will notify you and the relevant supervisory authority within 72 hours, as required by GDPR Art. 33–34.

Where processing activities may trigger a Data Protection Impact Assessment (DPIA) under GDPR Art. 35, documentation of our processing activities is available upon written request to hello@leadvar.com.

8. Cookies & Tracking

This website does not use cookies, tracking pixels, fingerprinting, or third-party analytics. We do not collect any data through your browser beyond standard server logs (IP, timestamp, page path) which are retained for 30 days.

9. International Data Transfers

Our infrastructure is hosted in Germany (Hetzner, EU). However, some sub-processors (ZeroBounce, Apollo, Stripe) are based in the United States. For EU-to-US data transfers, we rely on one or more of the following mechanisms as applicable:

To request copies of applicable SCCs or DPF certifications, contact hello@leadvar.com.

10. Children's Privacy

Leadvar is not directed at individuals under 18 years of age. We do not knowingly collect personal information from minors. If we become aware that we have collected data from a child without verifiable parental consent, we will delete it promptly.

11. Your Responsibility as Data Controller

If you use Leadvar to enrich email lists for outreach, you are the data controller responsible for: ensuring recipients have consented or that a legitimate interest basis applies (GDPR); complying with CAN-SPAM (US), CASL (Canada), and other applicable laws; and maintaining records of your lawful basis for processing. Leadvar is solely the data processor providing the enrichment tool.

12. Changes to This Policy

We may update this Privacy Policy at any time. Non-material clarifications take effect upon posting, with the "Last Updated" date revised accordingly. For material changes — including changes to what data we collect, how we use it, or who we share it with — we will notify registered users via email at least 14 days before the change takes effect. Continued use of the Service after the effective date constitutes your acceptance of the updated policy.

13. Contact Us

For privacy questions, complaints, or to exercise your rights:

For EU residents: if you are unsatisfied with our response, you have the right to file a complaint with your national data protection authority. As Leadvar is based in Belgium, the lead supervisory authority is the Belgian Data Protection Authority (APD/GBA)dataprotectionauthority.be.