Privacy Policy

Effective Date: May 7, 2025

This Privacy Policy explains how we collect, use, and protect personal data when you visit our website or interact with our services. Our company is located in Germany and operates in full compliance with the General Data Protection Regulation (GDPR), the California Online Privacy Protection Act (CalOPPA), and the California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA).

For California consumers, this Privacy Policy serves as our Notice at Collection under CCPA/CPRA.

Do Not Sell or Share My Personal Information

1. Who We Are

We are a German-based company offering data-driven lead generation services. Our website provides information about our services and allows visitors to contact us or opt into tracking consent where applicable.

2. What Data We Collect

• Contact Data: If you fill out our contact form, we collect your full name and email address.
• Scraped Data: We collect publicly available data of US-based businesses from publicly available online sources:
  • Name of business representatives (e.g., CEO, founder, marketing lead)
  • Business-related email addresses (e.g., john.doe@company.com)
  • Job titles, business phone numbers
  • Public business social media links
  • Website technology indicators (e.g., CMS, analytics tools)
  Website technology data is used solely to assess business relevance for our clients' marketing services.
• Website Usage Data: If you provide your consent, we may collect data on how you interact with our website, including page visits, clicks, session behavior, and technical information such as IP address. This data is only collected if you actively opt in to analytics cookies.
• Email/DM Outreach Data: If we contact you via email or direct message, and you provide consent, we may track email open rates, clicks, and post-click behavior.

We do not use automated decision-making that produces legal/significant effects, except for basic lead scoring based on public professional criteria.

3. Source of Data

We collect data from publicly available online sources only. These include official company websites, public directories, and other websites where business representatives have voluntarily published their contact information or business affiliation.

We do not use data from login-restricted areas or circumvent access restrictions in any way.

We verify data sources through:

• Domain registration checks for professional email addresses
• Cross-referencing multiple public directories
• Excluding any data behind paywalls or login requirements

Scraped data is retained for 24 months unless:

• A valid deletion request is received
• Data becomes outdated per our quarterly reviews

4. Legal Basis for Processing

We process personal data on the following legal bases:

• Art. 6(1)(a) GDPR - Consent: For the use of cookies, tracking technologies, and personalized analytics. And when you voluntarily submit your name and email address via our contact form.
• Art. 6(1)(f) GDPR - Legitimate Interest: When we process publicly available business contact data for the purpose of B2B lead generation, client outreach, and relationship building. Our legitimate interest is to offer relevant business services to decision-makers and professionals acting in a business capacity. We ensure that processing is proportionate, non-intrusive, and aligned with the expectations of the individuals whose data is publicly available, as permitted under Recital 47 of the GDPR.
• Contractual Necessity: To respond to inquiries or perform a contract.
• We do not process sensitive personal information as defined by CPRA §1798.140(av).

We've performed a balancing test confirming our processing:

• Doesn't override data subjects' fundamental rights
• Only processes professional contact data (no sensitive personal data)
• Enables legitimate B2B communications expected in commercial contexts

5. California-Specific Provisions

Shine the Light Law: We do not share personal data with third parties for direct marketing purposes without consent.

CPRA Correction Right: You may request correction of inaccurate data.

6. Use of Cookies and Tracking Technologies

We use cookies and similar technologies to measure the effectiveness of our communications and optimize our website. Upon your first visit, you will be asked to provide consent for the use of non-essential cookies (such as analytics cookies). No tracking or analytics will occur unless you have explicitly granted permission.

We do not pre-tick consent boxes or assume consent. You may manage or withdraw your consent at any time via the cookie banner or the settings link at the bottom of our website.

7. Analytics and Data Anonymization

By default, analytics are configured to anonymize your data so it cannot be traced back to you. If you consent to analytics cookies, we may collect additional information, such as your IP address and detailed user behavior, to improve our services.

8. Data Transfers

All scraped data is initially stored on secure servers located in Germany. We apply industry-standard security measures, including encryption, access controls, and regular security reviews to protect the integrity and confidentiality of the data.

In the course of our business activities, we may transfer personal data—such as publicly available business contact information—to our clients located outside the European Economic Area (EEA), particularly in the United States, for the purpose of enabling B2B outreach activities.

These transfers are carried out in accordance with Chapter V of the GDPR, ensuring an adequate level of protection. Where necessary, Standard Contractual Clauses (SCCs) approved by the European Commission are incorporated into our client contracts to safeguard the data during transfer.

For US transfers, we conduct Transfer Impact Assessments and implement supplementary measures including:

• End-to-end encryption during transmission
• Strict contractual prohibitions against re-identification
• Annual audits of recipient security practices

We ensure that all recipients process the data only for the intended business outreach purposes and are contractually obligated to comply with applicable data protection regulations.

Data may be shared with:

• B2B marketing/lead gen agencies
• CRM software providers
• Client companies in the same industry vertical

The information you provide by using our contact/application form stays with us and will not be shared with any third party and it will neither be transferred.

9. Your Rights (GDPR, CalOPPA, CCPA/CPRA)

You have the right to:

• Access, correct, or delete your personal data
• Withdraw consent at any time (where applicable)
• Know what data we have collected and why
• Opt out of the sale or sharing of personal data
• Request a copy of your data or request deletion (California residents)

To exercise these rights, please contact us at m62f4866ed450833f06cace65686e5084o1516238d36d7125d22b702c947881fb1cdda4c7dffbe603833808259b5599ed5e.695f3b1f63fa91bf97e372a877083087sec14a8faf8d87b2c367ec24e22fed5a1cec14a8faf8d87b2c367ec24e22fed5a1i695f3b1f63fa91bf97e372a877083087ndda4c7dffbe603833808259b5599ed5eo9d896fe06e10e20b0464d16ec08577f1l9d896fe06e10e20b0464d16ec08577f1b1516238d36d7125d22b702c947881fb1aec14a8faf8d87b2c367ec24e22fed5a1n1516238d36d7125d22b702c947881fb1 (ta) 62f4866ed450833f06cace65686e5084ydda4c7dffbe603833808259b5599ed5en62f4866ed450833f06cace65686e5084a9d896fe06e10e20b0464d16ec08577f1p695f3b1f63fa91bf97e372a877083087m1516238d36d7125d22b702c947881fb1o1516238d36d7125d22b702c947881fb1cdda4c7dffbe603833808259b5599ed5e.

We respond to GDPR requests within 30 days and CCPA requests within 45 days (with notice if extension needed).

We will not discriminate against you for exercising privacy rights, including denying services or charging different prices.

Your California Opt-Out Rights

You have the right to opt out of the sale or sharing of your personal information under the California Consumer Privacy Act (CCPA) as amended by the CPRA. By submitting this request, you direct us not to sell/share your data with third parties for monetary or other valuable consideration.

We will process your opt-out request within 15 business days and honor it for at least 12 months. You may submit requests through this web form, or via email at m1516238d36d7125d22b702c947881fb1o62f4866ed450833f06cace65686e5084cec14a8faf8d87b2c367ec24e22fed5a1.ec14a8faf8d87b2c367ec24e22fed5a1s695f3b1f63fa91bf97e372a877083087cec14a8faf8d87b2c367ec24e22fed5a1i9d896fe06e10e20b0464d16ec08577f1ndda4c7dffbe603833808259b5599ed5eoec14a8faf8d87b2c367ec24e22fed5a1lec14a8faf8d87b2c367ec24e22fed5a1bdda4c7dffbe603833808259b5599ed5ea9d896fe06e10e20b0464d16ec08577f1ndda4c7dffbe603833808259b5599ed5e (ta) ec14a8faf8d87b2c367ec24e22fed5a1yec14a8faf8d87b2c367ec24e22fed5a1nec14a8faf8d87b2c367ec24e22fed5a1a1516238d36d7125d22b702c947881fb1pdda4c7dffbe603833808259b5599ed5emdda4c7dffbe603833808259b5599ed5eo9d896fe06e10e20b0464d16ec08577f1c62f4866ed450833f06cace65686e5084.

You are not required to create an account to exercise this right, and we will not require identity verification unless necessary to prevent fraud. We will never retaliate against you for exercising your privacy rights.

10. Data Security

All data is stored on secure servers in Germany, with strong encryption and access controls in place. We regularly audit and update our security practices to protect your data against unauthorized access or disclosure.

11. Do Not Track (CalOPPA)

We honor “Do Not Track” signals. If your browser is configured to send such signals, we will not use any tracking technologies unless you provide explicit consent through our cookie banner.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The most current version will always be available on our website. We encourage you to review it regularly.

13. Links to other Websites

This website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to the third party's website. We strongly advise you to review the privacy policy of every website you visit.

We do not have control over or assume any responsibility for the content, privacy policies or practices of any third part websites or services.

14. Children's Privacy

Our website and our services are not intended for use by children under the age of 13 ("children").

We do not knowingly collect personally identifiable information from Children under 13. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

15. Contact