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Terms & Conditions of Purchase for Bespoke Leads





We follow the ICO guidelines of the Data Protection Act 2018. We are ICO registered and only work with other companies that are ICO registered.




                  Do Not Call list (DNC):                               We maintain a DNC that is updated daily- you need to return all opt-out or suppression requests                                                                           from the data we supply within 48hrs of receipt of such a request.

                  Delivery of your Data:                                For every order, we will aim to make delivery by 2pm via our SFTP platform the next working day                                                                               following                   collection.

                  Voice records/Chain of Consent/          For every order, you can request support for up to 15 records free of charge within any one             Web Opt in                                                   calendar month. If you have a TPS, Consumer or ICO complaint, then we will provide as many as                                                                                           needed to satisfy the complaint however, we will require written evidence of the TPS or ICO                                                                                  complaint. Should you require more than 15 records from any order in any calendar month,                                                                                    a charge of £7 per record will be payable in advance.

                  Due Diligence and Other Forms:            Once under contract, we will provide you electronic copies of our completed Due Diligence                                                                                      forms on our SFTP platform. Every order also includes up to five (5) chain of consent or                                                                                                   subject access requests. If you require more, then there will be a charge of £7 per request.                                                                                As FGT act as a Data Processor, (as defined in GDPR and the Data Protection Act 2018) the client                                                                           must supply FGT a Controller/Processor data sharing agreement within 30 days of the effective                                                                                         date of this contract


A £75 charge will be payable for the following instances: Removing multiple postcodes / Adding additional Qualification              Questions


If we receive major change requests for a question, agent talk time is affected and collection becomes more difficult, so our costs may        rise as a result.



    • In these Terms and Conditions and the Order Confirmation, and save where the context otherwise requires, the words and phrases below shall have the following meaning


“Additional Responses”                   any Responses obtained by FGT which exceed the Order Quantity.


“Buyer”                                                the purchaser of the Data   and   the party to these Terms and Conditions and the Order confirmation.


“Core Questions”                               the lifestyle questions to be formulated by FGT and included in the Survey, details of which are available on request.


“Data”                                                   being the data contained in the Responses provided by FGT to the Buyer as ordered by the Buyer pursuant to an Order Confirmation or as otherwise provided in accordance with these Terms and Conditions.


“FGT”                                                                 Focus Global Trading Limited, Suite 10, High Oak Business Centre, Gentlemens Field, Ware, SG12 0EF, a company incorporated and existing under the laws of England and Wales with the company registration number 7344391, and ICO registration Z274514X.


“End Users”                                         being those persons specified on an Order Confirmation as “End Users” and to whom the Buyer may grant a sub-license to use the Data in accordance with clause 4


“Fee”                                                     the fee payable by the Buyer to FGT for the service and license to be provided by FGT   hereunder and calculated in accordance with clause 9 and the Order Confirmation.


“Responses”                                       being one data record to be provided by FGT to the Buyer containing a consumer’s response to the Product Questions together with the relevant consumer’s name, postal address and / or telephone number and/or other information as specified in the Order Confirmation as maintained by or on behalf of FGT.


“Order Confirmation”                       FGT’s Order Confirmation, electronically completed by the Buyer, to which these            conditions are annexed.


“Order Quantity”                                the number of Responses requested by the Buyer in the Order Confirmation.

“Product Questions”                         the question(s) to be included in the Survey in relation to the Buyer’s product category and or sub- category and or question criteria specified in the Order Confirmation.


“Survey”                                               the Survey to be compiled and executed by or in conjunction with FGT which will contain the Product Questions and the Core Questions.


“Support”                                            Voice recordings from Survey / Chain of Consent / Date, Time stamp, source URL and IP address records of registration



  • Each Order Confirmation agreed between the FGT and the Buyer shall be governed by these Terms and Conditions provided that in the event if there is any inconsistency between the terms set out in an Order Confirmation and these Terms and Conditions, the provisions as set out in the Order Confirmation shall prevail as between the


  • FGT reserves the right at any time prior to the delivery of the Data (or part thereof) to cancel any Order Confirmation without incurring any liability other than liability which may not by applicable law be excluded or limited, in which event no part of the Fee shall be payable by the


3.            USAGE

  • The Buyer acknowledges that FGT has the right in its sole discretion to amend the wording of the Core Questions, Product Question(s) and contents of the Survey at any


4.           LICENCE

  • In consideration for and subject to the payment of the Fee, FGT hereby grants to the Buyer a license to use the Data subject to these Terms and Conditions and the definition of “Direct Marketing” as a Legitimate Interest (as defined within Recital 47 of the GDPR and Data Protection Act 2018) as well as the provisions of this clause


  • The Buyer shall have the right to use, but not copy, alter, manipulate, adapt or license others to use, that part of the Data on one specific direct marketing campaign for a maximum period of sixty (60) days from the date of delivery of the Data to the Buyer or for such other period as may be stated from time to time in an Order


  • Where explicitly stated in an Order Confirmation, the Buyer may grant a license to use the Data to such number of End Users as is expressly set out in an Order Confirmation as per these Terms and Conditions and provided that where the Buyer licenses the use of the Data to an End User the Buyer warrants to FGT that each relevant End User:


  • shall not copy, alter, manipulate or adapt the Data;
  • shall not license (or purport to) to third parties the use of such Data;
  • shall use the Data only in respect of one specific direct marketing campaign for a maximum period of sixty (60) days from the date of delivery of the Data to the Buyer or for such other period as may be stated from time to time in an Order
  • The Buyer confirms that no electronic communications (as defined under PECR 2003) will be sent to the individuals named in the data supplied at any time, without previously gaining the explicit consent of the individuals named within the data.


  • FGT shall have the right to analyse the Data and formulate conclusions from such analysis and extract information from the Data and shall be entitled to use such information (including information comprising such conclusions) at its sole discretion including, but not limited to, by way granting licenses to third parties and provided that nothing herein shall permit FGT to reveal to any third party the replies to any Product Questions that related exclusively to the business of the


  • The Buyer’s right to use that part of the Data which is derived from responses to the Product Questions shall be non-exclusive.


5.            FGT’S OBLIGATIONS

  • FGT will only deliver the Data to the Buyer in the format specified in the Order Confirmation via Secure File Transfer Protocol (SFTP), and will only accept Personally Identifiable Data such as Caller Line Identification (CLI) via the same method.


  • In the event that any delivery date or time shall be agreed between FGT and the Buyer in the Order Confirmation, the Buyer acknowledges that such date or time shall be indicative only and that FGT shall not be liable for any loss or damage suffered by the Buyer as a result of late delivery of the Data. Furthermore, FGT reserves the right to supply the Data in instalments on varying


  • FGT does not undertake the Surveys itself but warrants that it will use all reasonable endeavors to procure that the relevant service providers used by FGT to undertake the Surveys do so in accordance with all applicable laws and good industry


  • FGT shall use reasonable endeavors to keep confidential that part of the Data which consists of the Product



  • In the event of any complaints or disputes concerning the Data supplied, the Buyer may request the investigation procedure as set out in clause 6.2 be carried out provided the following conditions have been met:
    • the Buyer or relevant End User, must have made contact with 25% or more of the consumers named in relevant Responses making up the Data set;
    • the request for an investigation must have been submitted to FGT within 7 days of the date of delivery of the relevant Data set; and
    • the Buyer must submit a dialer report to FGT demonstrating that at least 25% of the data supplied from the total order which they have contacted is defective.


  • On the Buyer having requested an investigation (and having met the conditions set out in clause 6.1), FGT:
    • will randomly select a Response from the Data set;
    • will test that Response and the next 20 Responses following alphabetically (based on the consumers surname) within that Data
    • FGT will check the consumer’s name, address, the questions being asked word for word, the response from the consumer and will check if the voice file has been tampered with using “Cool Edit” or similar software;
    • Within 7 business days of the investigation having been validly requested, FGT will report to the Buyer on its findings and will provide a recording of (i) the opening survey question asked to the consumer (ii) the question asked before the particular question(s) being investigated, (iii) the question(s) being investigated and (iii) the question being asked after the question(s) being
    • If as a result of FGT’s investigation it is found that 20% or more of the Responses provided as part of the Data set contain an error, FGT will run the relevant Survey again and replace the relevant Data set that has been provided with new Responses at no extra cost (for the avoidance of doubt where the Data has been provided in instalments the investigation and replacement of Data shall apply only to the Data supplied in that instalment and not previous or subsequent instalments);
    • If an investigation of the replacement Data is triggered and it is found that again more than 20% of the relevant Responses contain an error, FGT will refund any monies already paid by the Buyer to FGT in respect of that Data
    • If an investigation is triggered but the findings show that 0% of the Responses contained an error, the Buyer agrees that it shall pay to FGT the sum of £125 plus



  • The Buyer shall and undertakes to procure that relevant End User shall use the Data:
    • solely for its internal business purposes;
    • as a source of reference for its circulation by mail or by live telephone call to some of or all of the individuals listed in the


  • The Buyer agrees with and warrants to FGT that any documents or other items mailed by or on behalf of the Buyer as a result of or following its use of Data will at all times comply with the current British Code of Advertising Practice, the British Code of Sales Promotion Practice and the ICSTIS Code and will contain nothing which infringes copyright or any other right of any third party or is defamatory, obscene, indecent or otherwise illegal or unlawful whether or not such a claim is justified or The Buyer further agrees and warrants that it will upon request by FGT forthwith supply to FGT copies of any such documents or other items.


  • In the event that any recipient of any documents or other items mailed by the Buyer objects to such mailing or requests that it ceases or asks for his or its name to be removed from any list the Buyer shall procure that such mailing ceases forthwith and shall inform FGT and provide FGT on a quarterly basis with particulars of any documents and other items mailed to that recipient and of the name and address to which they were


  • The Buyer hereby undertakes to FGT that it will deliver to FGT any notice or other communication in respect of the Data received from the Information Commissioner on its receipt


  • The Buyer undertakes to FGT that it will at all times comply with the provisions of the Data Protection Act 2018 and PECR 2003 in respect of its use and storage of the


  • The Buyer shall allow FGT to include in the Data a small percentage of seed and dummy data subject details for control


  • The Buyer and its employees and agents shall keep confidential all information concerning the business of FGT that it has obtained or received as a result of the performance of this


  • The Buyer must comply with the provisions of clause 6 above in relation to any complaints or disputes arising concerning Data


  • The Buyer undertakes to provide FGT with any notices it receives relating to any breach of the provisions of this clause 7 and the Buyer agrees to indemnify and hold FGT harmless in respect of any losses and costs (including reasonable legal costs) it might sustain as a result


  • In the case of regulated and or licensed market sectors, Buyer and each End User confirms that Buyer is covered by and adheres to regulations and licenses set out for said market sectors and therefore allows and covers FGT as a legal representative of Buyer to perform the duties as set out in Order Confirmation. In the case of any financial loss to FGT resulting from performing the duties as set out within the Order Confirmation in a regulated and or licensed market sector, Buyer agrees to fully indemnify and pay all such losses in full to
  • The Buyer agrees that FGT may change age groups given in the survey to fit the Buyer’s specific age groups where
  • The Buyer agrees that should the Buyer or End User receive any suppression or opt-out request made by a survey respondent, this will be passed to FGT within 48 hours.



  • The property and the copyright and database rights (and all other intellectual property rights) in the Data, the Survey, the Core Questions and the Product Questions shall at all times remain reserved or vested in FGT and FGT reserves the right to grant licenses in respect of the Data and supply the same to any other


  • In the event of the Buyer being aware of any unauthorised use of any part of the Data, Buyer must notify FGT in writing


9.           PAYMENT

  • The Fee payable in respect of each Order Confirmation shall be set out in the relevant Order


  • Payment of the fee(s) specified in this document and in our corresponding invoice, irrevocably indicates your understanding and acceptance of these terms and conditions upon behalf of your organisation.


  • Unless otherwise stated, the Fee quoted in the Order Confirmation is exclusive of VAT (which will be charged at the prevailing rate).


  • In the event that the Order Confirmation does not set out the relevant fee payable by the Buyer, the Fee will be calculated by reference to the quantity of Data supplied at the standard rates charged by


  • In the event that FGT agrees to supply the Data for the purpose of de-duplication against other data held by the Buyer and on the basis that the Buyer shall only pay a proportion of the price reflecting the net names actually used (“Net Names Agreement”) any claim for credit for the unused proportion of Data:
    • must be made within a period not exceeding 14 days from the date of delivery unless otherwise agreed in writing by FGT ; and
    • must be supported by a written de-duplication report or certificate from a recognised data processing bureau or other independent agency approved in writing by


  • In the event that FGT obtains Additional Responses:
    • FGT shall be entitled to deliver and charge the Buyer for such Additional Responses up to 10% above the Order FGT will not deliver any more that 20% as an oversupply and thus will not charge for any Response that     may be delivered over the 10% oversupply. By way of example, where the Order Quantity specified in an Order                          Confirmation is for 1000 Reponses and the calling team makes 1067 calls then 1067 Reponses will be delivered and   charged for.
    • FGT may offer Additional Reponses it has obtained beyond the 10% threshold outlined in above to the Buyer at     such fee as it shall
    • FGT reserves the right to offer any Additional Responses not acquired by the Buyer under clause or to         any of its customers on such terms as FGT may


  • FGT reserves the right to charge interest of any sum not paid on a due date for payment at the rate of 5% per month above the prevailing Barclays Bank Base Rate, such interest to accrue daily on the unpaid sum from the due date for payment until the date of actual payment (after as well as before judgment).



  • Nothing in these Terms and Conditions shall be construed as limiting FGT’s liability for death or personal injury caused by its negligence or liability arising as a result of fraud or fraudulent


  • The Buyer acknowledges with respect to the Data and related licenses to use such Data provided under these Terms and Conditions and any related Order Confirmation, that the Buyer’s sole recourse against FGT with respect to the supply and license and use of such Data shall be under the investigation and dispute resolution procedure set out in clause Otherwise, FGT shall not be liable for any losses, liabilities, costs or expenses suffered by the Buyer, any End User or any third party arising from the supply, license or use of such Data.


  • FGT shall not be liable whether in tort (including for negligence or breach of statutory duty) contract, misrepresentation or otherwise for any loss of profits, loss of business, depletion in goodwill, loss of anticipated savings, loss of contract, loss of use, loss or corruption of data or information in each case whether direct or indirect or for any special, indirect, consequential or pure economic loss, costs, damages charges of expenses of the Buyer or any End


  • In any event, FGT’s total aggregate liability arising out of or in connection with the performance or contemplated performance of its obligations under these Terms and Conditions and any Order Confirmation shall be limited in respect of all claims to the amount of Fees actually received by FGT from the Buyer in the previous 12 month


  • The Buyer agrees to indemnify and hold FGT harmless from and against any and all liabilities, claims, costs, assessments, fees or expenses of any kind, including without limitation defence costs and legal fees arising from any claims made by an End User in connection with the Data and license thereof or otherwise relating to the performance by FGT of its obligations under these Terms and Conditions or any Order


  • The Buyer acknowledges:
    • that FGT has no responsibility for and gives no warranty or representation as to the performance of the Data or the rate at which it converts into actual or eventual sales or payment activity; and
    • any data description including the words “first”, “second” or “third” etc. usage data relates to the number of times FGT or our supplier has sold the data. It cannot denote the preclusion of any other or prior distribution of the same or similar data by the data subject itself over which FGT has and can have no
    • FGT does not warrant that the Data is accurate or complete or that any information contained therein is accurate or complete;
    • the employees and agents of FGT are not authorised to make oral or written representations concerning any Data Order
    • An electronic signature box is provided in this Order Form. Your completion and signature on the Order Form (which contains an express acknowledgment you have had opportunity to read this agreement) shall constitute acceptance of this agreement.
    • The prices we provide can be amended by a reasonable amount if:

our costs rise;

you amend your instructions after we start work; or

you ask for expedited delivery.


  • The Buyer shall not institute proceedings for damages for breach of these Terms and Conditions or arising from any Order Confirmation after the expiration of one year from the date on which the Buyer became aware of the same or the date on which it ought reasonably to have become aware of the



  • FGT may terminate any and all Order Confirmations forthwith on giving written notice to the Buyer if:
    • the Buyer commits a serious breach of these Terms and Conditions and in the event of the breach being capable of being remedied shall have failed to remedy the breach within fourteen days after the receipt of a request in writing from FGT to do so; or
    • if the Buyer is unable to pay its debts (within the meaning of section 123 of the Insolvency Act 1986), or becomes insolvent, or is subject to an order or a resolution for its liquidation, administration, winding-up or dissolution, or has an administrative or other receiver, manager, trustee, liquidator, administrator or similar officer appointed over all or any substantial part of its assets, or enters into or proposes any composition or arrangement with its creditors generally, or is subject to any analogous event or proceeding in any


  • In the event of any termination of any Order Confirmation (irrespective of the reasons) the Buyer shall forthwith return any Data already delivered (including all copies) together with all other information which the Buyer or any End User might hold on or have received from FGT and confirm in writing that it has done Termination of an Order Confirmation shall not affect the accrued rights or liabilities of either party.



  • Each execution within a series will be treated as a separate order for execution in respect of


  • Requests for cancellation of any Order Confirmation by the Buyer must be made in writing stating all reasons for cancellation and must be received by FGT at least 1 month prior to the date on which FGT is due to begin the execution of the relevant FGT may refuse any request for cancellation of an Order Confirmation which does meet these criteria. FGT may refuse any cancellation of Order Confirmation where such confirmation forms part of a series of orders which have been agreed between FGT and the Buyer.



  • The Buyer may not assign its rights under any Order Confirmation or these Terms and Conditions without the consent of
  • FGT shall have the right to sub-contract any of its duties and obligations under these Terms and Conditions and any Order
  • In the event that FGT has sub-contracted any of its duties and obligations such as data supply or Survey services, the Buyer shall not be liable for a refund or resupply of data prior to FGT receiving the same from the


14.       WAIVER

The rights of FGT shall not be prejudiced or restricted by any indulgence or forbearance extended by FGT to the Buyer and no waiver by FGT in respect of any breach shall operate as a waiver in respect of any subsequent breach.


15.        NOTICES

Any notices given under the Agreement shall be in writing and shall be sent by registered post or recorded delivery service addressed in the case of a notice to FGT to FGT’s Registered Office and in the case of a notice to the Buyer to the address of the Buyer or its representative or agent shown in Order Confirmation. Notices may also be served by email or facsimile provided proof of sending is given. Any Notice that is given shall be deemed served if by post forty eight hours after posting and if by email or facsimile when dispatched.



These Terms and Conditions shall be governed by and construed in all respects in accordance with English law and the Courts of England and Wales shall be the sole courts of jurisdiction


Nothing else follows.

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