Privacy Policy

Last Updated 6 July 2022

We at THE LEAD ICON, Inc. (“we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we take it seriously and know how important it is to you to know how the information you provide to us is used and shared.  This Privacy Policy applies to the way we collect information from (i) www.theleadicon.com, (Our Website), and (ii) the information you provide to us without limitation, via phone, video conferencing, email, social media, and face-to-face.

Description of Users and Acceptance of Terms

This Privacy Policy applies to visitors to THE LEAD ICON Website, who view only publicly-available content (“Visitors”), and private members and customers who register with us and wish to purchase a package, program, product, or service through our website.

  • By visiting THE LEAD ICON website, Visitors are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use.  

  • By visiting, becoming a private member or customer with us, and purchasing a package, program, product or service through our Website, each visitor, private member, and customer is agreeing to the terms of this Privacy Policy, and the accompanying Terms of Use.

  • By providing us information offline, you are also agreeing to the terms of this Privacy Policy.

GDPR & Privacy

For THE LEAD ICON’s visitors, private members, and customers in the European Economic Area (“EEA”), we are committed to ensuring the protection of all personal information we hold and to provide and to protect all such data. We recognise our obligations in updating and expanding this program to meet the requirements of GDPR.

THE LEAD ICON is dedicated to safeguarding your personal information under our control and maintaining a system that meets our obligations under GDPR regulations. Our approach is summarised;

THE LEAD ICON already have a consistent level of data protection and security across our organisation, but we have introduced new measures to ensure data and privacy are safeguarded.

Information Audit — We carried out an audit of information previously held and ensured that it was compliant with the GDPR regulations.

Policies and Procedures — we have revised data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:

  • Data Protection - our main policy and procedure document for data protection has been revised to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy and the rights of individuals.

  • Data Retention and Erasure - we have updated our retention policy and schedule to ensure that we meet the "data minimisation" and "storage limitation" principles and that personal information is stored, archived and destroyed in accordance with our obligations. We have procedures in place to meet the new "Right to Erasure" obligation.

  • Data Breaches - our procedures ensure that we have safeguards in place to identify, assess, investigate and report any personal data breach as early as possible. Our procedures have been explained to the entire team.

  • International Data Transfers and Third-Party Disclosures - where THE LEAD ICON stores or transfers personal information outside the EU, we have robust procedures in place to secure the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as binding rules, or standard data protection clauses for those countries without.

 

  • Subject Access Request (SAR) - we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge.

Privacy Notice/Policy - we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.

Obtaining Consent - we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it, and giving clear, defined ways to consent to us processing their information

Direct Marketing - we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out, and providing unsubscribe features on all subsequent marketing materials.

Data Protection Impact Assessments (DPIA) - where we process personal information that is considered high risk, we have developed stringent procedures for carrying out impact assessments that comply fully with the GDPR's Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity, and implement mitigating measures to reduce the risk posed to the data subject(s).

Processor Agreements - where we use any third-party to process personal information on our behalf (ie Payment, Surveys, CRM, Analytics, Facebook Pixel, Payroll, Recruitment, Hosting, etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they meet and understand their/our GDPR obligations.

Data Subject Rights

We provide easy-to-access information via our website, email, during induction and so forth of an individual’s right to access any personal information that THE LEAD ICON processes about them and to request information about:

  • what personal data we hold about them

  • the purposes of the processing

  • the categories of personal data concerned

  • the recipients to whom the personal data has/will be disclosed

  • how long we intend to store your personal data for

  • if we did not collect the data directly from them, information about the source

  • the right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this

  • the right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use

  • the right to lodge a complaint or seek judicial remedy and who to contact in such instances.

Information Security and Technical and Organisational Measures

THE LEAD ICON takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction.

GDPR Roles and Employees

THE LEAD ICON have appointed a Data Protection Officer (DPO) to develop and implement our roadmap for complying with any data protection Regulation. The DPO is responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR compliance, identifying any gap areas, and implementing the new policies, procedures and measures.

THE LEAD ICON understands that continuous team awareness and understanding is vital to the continued compliance of the GDPR and involve our Team to ensure we protect data and privacy.

If you have any questions about our GDPR compliance policies, please contact us at contact@theleadicon.com

 

The Information We Collect/or Receive; the Purpose of Collection and Use

In the course of operating our Website and/or interacting with you, we will collect (and/or receive) the following types of information.

1. Contact Information

When you become a customer, or sign up to become a private member, receive any of our news feeds, newsletters, respond to a survey, register for an educational program, purchase any package, resource, product or service, or sign up to become an affiliate or industry partner, you may be required to provide us with certain information about yourself, such as your name, address, e-mail address, social media information, phone number, PayPal account email address, Stripe account email address (private members, customers and visitors making purchases, and affiliate or industry partners) and (the “Contact Information”). The Contact Information is used to provide the requested program, package, product or service or information and to contact you for purposes of direct marketing of our current and future products and services.

If you land on one of our pages through an affiliate partner link and provide us Contact Information (e.g., to request information, purchase a product or service), we may share your name and e-mail address to such affiliate partner to let him/her know that you were referred and in case (s)he has offered you any bonuses or rewards for following their referral link. We have no control over how affiliate partners may use your information after it has been received and we are not responsible for fulfilling any bonuses that such affiliate partners may have offered you; where applicable, please check such affiliate partners’ privacy policies and terms of use for more information on how they may use your personal information.

The various purposes for which we process personal data:

  • Visitors to theleadicon.com

  • Platinum Tier Customers

  • Private Member Customers

  • Individuals whose personal data we obtain in connection with providing contributions to our customers

  • Business DNA Analysis

  • Contacts in our customer relationship management (CRM) systems

  • Participants of THE LEAD ICON’s online meetings, conferences, events and educational programs, masterclasses, and sessions

  • Individuals who use our applications

  • Individuals who visit our social media sites, social media plugins and tools

  • Individuals who correspond with THE LEAD ICON via email

  • Individuals who purchase our user paid content

  • Job applicants

  • Industry partners

If you have any questions regarding the processing of your personal data please contact THE LEAD ICON at contact@theleadicon.com who will direct your query to the appropriate person within the organisation.

2. Order Information

When you place an Order, you must provide us with certain information about the products and services you are seeking to purchase.  Such information is collectively called the “Order Information.”  The Order Information is used to fulfil your Order.

3. Billing Information

When you wish to purchase a package, program, product, or service, you will be required to provide certain information in addition to the Personal Information and Order Information noted above.  Such information may include a debit card number, credit card number, expiration date, billing address, activation codes, and similar information. Such information is collectively called the “Billing Information.” Billing Information is collected and processed by our third-party payment processor operating as our agent (see, Onward Transfers to Third Parties). We do not directly obtain or process any Billing Information.

4. Other Information

In addition to the information noted above, we may collect additional information (collectively, the “Other Information”).  Such Other Information may include:

From You.  Additional information about yourself that you voluntarily provide to us (e.g., via a survey), such as business revenue range, gender, product and service preferences, and other information that does not identify you personally.

From Your Activity.  Information that we automatically collect when you use our Website, including, without limitation:

  • IP addresses, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; date and time; amount of time spent on particular pages; what sections of the Website you visit; and similar data; and

  • Information about your device, including the type of device; universally unique ID (“UUID”); advertising identifier (“IDFA”); MAC address; operating system and version (e.g., iOS, Android or Windows); carrier and country location; hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled); network type (WiFi, 3G, 4G, 5G, LTE); and similar data. 

Purposes for which we process your personal data as a visitor to our site are:

  • To administer and manage our site, including to confirm and authenticate your identity, and prevent unauthorized access to restricted areas of our site

  • To personalise and enrich your browsing experience by displaying content (including targeted advertising) that is more likely to be relevant and of interest to you

  • To analyse the data of visitors to our site and site traffic information

  • To capture webmetrics about the journey of users within our site

  • To determine the company, organisation, institution, or agency that you work for or with which you are otherwise associated

  • To develop our business, services, and products

  • To provide you with marketing communications, THE LEAD ICON Thought Leadership materials, and online benchmarking tools

  • To conduct benchmarking and data analysis (for example, regarding usage of our site and demographic analyses of visitors of our site)

  • To understand how visitors use the features and functions of our site

  • To monitor and enforce compliance with applicable terms of use

  • To conduct quality and risk management reviews

  • To enable the better management of THE LEAD ICON events, educational programs, online and face-to-face experiences.

  • To enable teams managing events to coordinate their email campaigns and event notifications more effectively

  • To allow for event and webinar sign-up

  • To allow for content download and lead capturing

  • To allow services and information to be delivered effectively to you

  • Any other purpose for which you provided information to THE LEAD ICON

Legal grounds for processing personal data of visitors of our site are:

  • Our legitimate interest in the effective delivery of information and services to you, and the effective and lawful operation of our businesses

  • Our legitimate interest in developing and improving our site, and your user experience

  • Explicit consent of the visitor

From Cookies.  Information that we collect using “cookie” technology.  Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit.  We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using our Website.  If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies.  For more information about our use of cookies, please refer to our cookie policy.

Third-Party Analytics.  We use third-party analytics services (such as Google Analytics) to evaluate your use of our Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and mobile and Internet usage.  These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using our Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. Please be advised that if you opt-out of any service, you may not be able to use the full functionality of our Website.

Below is a list of analytics providers that we use; however, such list may be subject to change based on how we wish to understand the user experience and we will endeavour to update it diligently. You may use the accompanying links to learn more about such providers and, if available, how to opt-out from their analytics collection.

For Google Analytics, please visit: https://www.google.com/analytics

For Wix, please visit: https://www.wix.com/about/privacy

From Other Sources. We also may collect or receive information from third parties, such as LinkedIn, Instagram, YouTube, and/or other third-party social media sites.

Security

We go to great lengths to ensure data protection for all our visitors and customers. THE LEAD ICON is purpose-built on the Wix platform which offers next-level website and data security.

Wix deploys and maintains a range of technical and organizational security measures to protect our customers’ data and assets. The Wix security team leads the facilitation and development of procedures, processes, and controls that govern the security and integrity of Wix and THE LEAD ICON visitors. For more information, see a detailed breakdown of Wix’s Security Measures. https://support.wix.com/en/article/wix-security-measures-overview 

Information Collected by or Through Third-Party Advertisers & Remarketers


We may share Other Information about you with third parties, including, but not limited to, advertising and remarketing providers, or other brand partners, for purposes of personalising or otherwise understanding how you engage with ads or other content. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), or other technologies to collect Other Information in furtherance of such purposes, including to tailor, target (i.e., behavioural, contextual, retargeting, and remarketing), analyse, report on, and/or manage advertising campaigns or other initiatives. In addition, we may receive Other Information from these third parties, including through their service providers, such as advertising identifiers, IP addresses, and post-conversion data.
Below is a list of advertising/remarketing providers that we use; however, such list may be subject to change based on the campaigns that we run and we will endeavour to update it diligently. You may use the accompanying links to learn more about such providers and, if available, how to opt-out from their targeted ads or other personalization features. Please note you will not necessarily be opted-out of advertising or content generally; you may still receive generic ads or content.
For LinkedIn, please visit: https://www.linkedin.com/legal/privacy-policy
For Facebook, please visit: http://www.facebook.com/about/privacy
For Twitter, please visit: https://twitter.com/en/privacy
For Google, please visit: https://support.google.com/ads/answer/2662922?hl=en

Information Collected Through Our Website that is Not Covered by this Privacy Policy


You may post and/or share information, including but not limited to, comments using forums and other similar features available through the Website. NONE of the information you provide using these features is protected by this Privacy Policy. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION) THAT YOU PROVIDE USING ANY SUCH FEATURES. ALL SUCH INFORMATION IS PUBLIC INFORMATION AND MAY BE SEEN, COLLECTED OR USED BY ANY USER Of OUR WEBSITE. Please note that if you post and/or share information on our Website through your social media accounts, such information will be subject to the individual social media’s privacy policy.

Information Collected Through Social Media


You may post and/or share information through our Social Media Channels. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION) THAT YOU PROVIDE USING SOCIAL MEDIA COMMUNITY CHANNELS. USE OF ANY SOCIAL MEDIA COMMUNITY CHANNELS IS GOVERNED BY THE INDIVIDUAL PRIVACY POLICY OF THE SOCIAL MEDIA COMPANY. ALL SUCH INFORMATION IS PUBLIC INFORMATION AND MAY BE SEEN, COLLECTED OR USED BY ANY USER OF OUR SOCIAL MEDIA COMMUNITY CHANNELS.

Aggregate Data


In an ongoing effort to better understand our visitors, private members, customers, and our products and services, we may analyse the Order Information and Other Information in aggregate form in order to operate, maintain, manage, and improve our Website and/or our products and services.  This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.

Additional Uses


We also use information collected pursuant to this Privacy Policy to provide our services; to process Orders; to administer our rewards and promotional programs; to maintain and improve our Website and services to you; to solicit your feedback; and to inform you about our products and services and those of our third-party marketing partners.  

 

Sharing with Third Parties


Like many businesses, we contract with other companies to perform certain business-related services. We may disclose your information, including personal information in some cases, to certain types of third-party companies, but only to the extent needed to enable them to provide such services, including, without limitation, technical assistance, order fulfilment, customer service, marketing assistance, payment processing, survey collection, promotional and marketing assistance, and business operations. These other companies will have access to your information, including personal information in some cases, only as necessary to perform their functions and to the extent permitted by law. We may also disclose your information, including any personal information, to any of our parent companies, subsidiaries, affiliates, joint ventures, or other companies under common control with us in order to support delivery of our products and services.

Business Transfer


In the event of a merger, dissolution, or similar corporate event or the sale of all or substantially all of our assets, we expect that the Information that we have collected and/or received, including personal information, would be transferred to the surviving entity in a merger or to the acquiring entity.  All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy.

Disclosures to Public Authorities


In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

Opt-Out for Direct Marketing


You may opt out at any time from the use of your personal information for direct marketing purposes by e-mailing the instructions to this email address: contact@theleadicon.com.  Please allow us a reasonable time to process your request.

Accessing and Modifying Personal Information and Communication Preferences


Upon request to contact@theleadicon.com, we will provide you with confirmation as to whether we are processing your personal information, and have the data communicated to you within a reasonable time. You have the right to correct, amend, or delete your personal information where it is inaccurate or has been processed in violation of this Privacy Policy. We may require payment of a non-excessive fee to defray our expenses in this regard.  Please allow us a reasonable time to respond to your inquiries and requests.
In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any THE LEAD ICON marketing email.  Customers cannot opt out of receiving transactional e-mails related to their account or their Orders. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.  

Information You Share on Public Forums


We feature or may in the future feature public forums such as message boards or web logs, webinars, classes, telephone conferences, coaching calls, user comments, chat rooms, and similar activities (collectively, “Public Forums”). You may voluntarily post and share information through such Public Forums. NONE of the information you provide through the Public Forums or through the use of these features is protected by this Privacy Policy including any personal information. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION) THAT YOU PROVIDE USING ANY SUCH FEATURES. ALL SUCH INFORMATION IS PUBLIC INFORMATION AND MAY BE VIEWED, COLLECTED, USED, MODIFIED, AND/OR DISCLOSED FOR ANY PURPOSE BY US, ANY USER OF THE PUBLIC FORUM, AND THE PUBLIC.
You should think carefully before disclosing any information in any Public Forum.

How We Protect the Information


We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in processing and the nature of such data, and in compliance with applicable laws and regulations.  Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from Our Website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.  

Retention of Personal Information


We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, subsequently authorized, or as allowed under applicable law.

Important Notice 


It is important to note that the Website and their servers are operated in the United States and Europe.  If you are located outside of the U.S., please be aware that any information provided to or collected by us, including personal information, will be transferred from your country of origin to the U.S.  

Under 16 years of Age


We do not knowingly collect personal information from minors under the age of 16 through our Website.  If you are under 16, please do not give us any personal information. We encourage parents and legal guardians to monitor their young ones Internet usage and to help enforce our Privacy Policy by instructing their young ones to never provide personal information through our Website without their permission.  If you have reason to believe that a minor under the age of 16 has provided personal information to us, please contact us, and we will endeavour to delete that information from our databases.

California Consumer Privacy Act (CCPA)


THE LEAD ICON does not monitor, recognise or honour any behavioural advertising opt-out or does not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
California residents should review their specific rights under the Californian Consumer Privacy Act (CCPA). 

External Websites


Our Website may contain links to third-party websites.  We have no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links.  As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.


Changes to This Privacy Policy


This Privacy Policy is effective as of the date stated at the top of this Privacy Policy.  We may change this Privacy Policy from time to time. By accessing Our Website and/or using our services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes.  Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.


How to Contact Us


If you have questions about this Privacy Policy, please contact us contact@theleadicon.com 

 

Cookie Policy

Our Use of Cookies

When you visit THE LEAD ICON website, we will use cookies to give you the best experience on our website (and to keep it free!). Cookies are small text files stored on your device. The information collected does not usually directly identify you; oftentimes, the information is tied to a cookie ID, advertising ID, IP address, or similar online/device identifier.

The specific types of cookies served through our website and the purposes they perform are described below.

 

Strictly Necessary Cookies

These cookies are necessary for our site to function or to enable our affiliate program, and cannot be switched off in our system. They do not store any personally identifiable information.

These cookies are set in response to actions made by you which amount to a request for services (e.g., submitting a URL into your browser, clicking an affiliate link to one of our marketing landing pages).

They ensure the proper technical functioning of such service (e.g., carrying out necessary transmissions over the internet, ensuring proper attribution to affiliates who have referred you, showing a website version that has a broadband-related data quantity corresponding to that of your Internet connection, changing from http to https as appropriate, etc.).

More Information on Affiliate Program Cookies: Where you have landed on one of our pages due to a link provided by our trusted affiliates, a cookie is set by our referral marketing provider as necessary for the affiliate to get credit for referring you and for you to get any bonuses or rewards that the affiliate may have offered you for following their referral link. These cookies are what are called ‘third-party’ cookies since they are set by our affiliate marketing platform. They are listed in the following table.

If you do not allow these cookies (e.g., through browser settings or our cookie privacy manager), some parts of the site will not work. For a full list of cookies refer to;  https://support.wix.com/en/article/cookies-and-your-wix-site

 

Targeting Cookies

Targeting cookies are a primary way that websites are kept free. These cookies may be set through our site by our advertising partners, who may be separate controllers of the data obtained. The cookies work primarily through uniquely identifying your device (e.g., advertising ID, IP address, geolocation), and used to build a profile of your interests and show you relevant adverts on our sites and other sites. If you do not allow these cookies, you will experience less targeted advertising. https://support.wix.com/en/article/cookies-and-your-wix-site

 

Social Media Cookies

These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit.    If you do not allow these cookies you may not be able to use or see these sharing tools. https://support.wix.com/en/article/cookies-and-your-wix-site

How can I control cookies?

As your data controller, we respect your right to privacy and allow you to choose which types of cookies you would prefer to use (unless such cookies are considered “strictly necessary”). You can control cookies by using our cookie preference manager by clicking the button below. Click on the different category headings to find out more and change our default settings. Keep in mind that blocking some types of cookies may impact your experience of our sites and the services we are able to offer. The cookie settings that you choose will be remembered whenever you visit any of MFI’s sites and you may change your settings at any time.

Of course, we will need to use a cookie to remember the settings that you have chosen within this cookie privacy manager. This will have a couple of consequences:

If you delete all your cookies, you will have to update your settings with us again.

If you use a different device or browser, you will have to tell us your settings again.

Alternatively, you can control cookies directly from your web browser. Most browsers allow you to control cookies as part of their settings and preferences. Please refer to your specific browser for instructions on how to disable, limit and delete cookies.

The following links are provided for your convenience. Click on the relevant link below to access detailed information regarding cookie settings. Should your browser not be listed here, you should review the help pages for your specific browser to see what features are offered for adjusting your cookie settings:

  • Microsoft Internet Explorer

  • Google Chrome

  • Safari

  • Firefox

Where can I find more information about cookies?

You can learn more about cookies at the following third-party websites: