Privacy Policy UK
Background
ProspectBase respects your privacy and understands that you care about how your personal data is used. This policy describes the personal data we collect, how we use it, and the rights you have to control and protect your own personal data.
1. About ProspectBase
Who we are: ProspectBase Ltd of Wessex House, Teign Road, Newton Abbot, Devon, TQ12 4AA, United Kingdom (reg. number: 15492457).
What we do: ProspectBase provides business-to-business (B2B) lead generation & content syndication services to companies looking to promote their products and services to other businesses. We achieve this using email promotion, multi-channel content syndication, and telemarketing services.
Why we do it: It’s our mission to enable businesses to promote their content more effectively to the right people in other businesses.
Contact Us: For any privacy or data protection queries, please email our team at privacy@prospectbase.com or write to us at: ProspectBase c/o Wessex House, Teign Road, Newton Abbot, Devon, TQ12 4AA, United Kingdom.
2. What Does This Notice Cover?
This Privacy Policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What Is Our Lawful Basis For Processing Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 as “any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier”.
Of the six lawful bases for processing Personal Data defined by the GDPR, the most appropriate lawful basis for the processing we do is legitimate interest. This is because:
- Our lead generation services are designed to enable our customers to promote their offerings more effectively to the right people at other businesses: we only perform B2B lead generation.
- The processing we do is highly unlikely to affect the fundamental rights and freedoms of the individuals whose data we process when we perform our lead generation services.
- We only process personal information that is business-specific (B2B) data, not personal (B2C) data.
- All of the information we collect, store and process is freely available in the public domain.
Other Lawful Bases that may apply:
- As our customer, we rely on our contractual relationship to process your personal data to provide goods and/or services to you.
- Should we rely on consent in any circumstances to process your personal data, you can easily withdraw your consent at any time by contacting us at privacy@prospectbase.com or by using any unsubscribe mechanism provided.
- Where ProspectBase identifies prospective business contacts using directory tools or third-party data sources, any matching of professional attributes is based on information self-declared by the data subject and is qualified through manual review by trained personnel before any marketing activity.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights:
- The right to be informed about our collection and use of your personal data.
- The right to access the personal data we hold about you.
- The right to have your personal data rectified if inaccurate or incomplete.
- The right to be forgotten.
- The right to restrict the processing of your personal data.
- The right to object to us using your personal data for a particular purpose.
- The right to withdraw consent.
- The right to data portability.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights, please contact us using the details provided in Part 1.
If you have any cause for complaint about our use of your personal data, please contact us first. You also have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect and How?
| Data Collected | Data Sources |
|---|---|
| Identity Information including first name and surname. | Publicly available sources including LinkedIn, Google Cache, company websites, networking sites, open forums, news sites, our own landing pages, and information provided by our client, customer or partner. |
| Contact information including business email address, phone number, DDI and/or mobile. | Publicly available sources including LinkedIn, Google Cache, company websites, open forums, news sites, our own landing pages, and information provided by our client, customer or partner. |
| Business information including business email address, employer, business address, industry, company size and IP address. | Publicly available sources including LinkedIn, Google Cache, company websites, open forums, news sites, our own landing pages, and information provided by our client, customer or partner. |
| Profile information including LinkedIn URL, marketing preferences, engagement statistics, website traffic information and cookie preferences. | Publicly available sources including LinkedIn, Google Cache, company websites, open forums, news sites, our own landing pages, and information provided by our client, customer or partner. |
| Data from third parties including identity, contact, business and profile information, firmographic, tech install and intent signal. | Supplied by the appropriate third party via contractual agreement. |
| Legally required information including DPAs, LIAs, NDAs, compliance details, insurance and regulatory details. | Supplied by the appropriate third party via contractual agreement or NDA, or supplied by a regulatory body under the legal lawful basis of processing. |
6. How Do You Use My Personal Data?
| What We Do | What Data We Use | Our Lawful Basis |
|---|---|---|
| Administering our business, including day-to-day operations, maintaining accurate data, keeping suppression lists, sending important notifications, enabling website interactions, improving user experience, and gathering analytics. | All data as defined in the table in Clause 5. | Legitimate Interest, Contractual & Legal. |
| Providing our services to clients and customers. | All data as defined in the table in Clause 5. | Legitimate Interests & Contractual. |
| Communicating with you directly via email, or indirectly via landing pages on our content library or via email domains that fall under our content library brand. | Contact Information; our website. | Legitimate Interests & Legal. |
7. Direct Marketing and Communication
Subject to your permission and in compliance with applicable laws, we may process your personal data for direct marketing purposes. This may include contacting you via email, telephone, or post with information, news, and offers pertaining to our products and services, as well as those of our clients and customers.
We are committed to upholding your rights and adhering to our obligations under the Data Protection Legislation and the Privacy and Electronic Communications Regulations 2003. You retain the right to withdraw your consent at any time.
8. Automated Decision-Making and Profiling
Our organisation does not employ automated systems for decision-making or profiling purposes. Any automated processes, including those involving artificial intelligence, that are used in the processing of information containing Personal Data or any data used in the provision of our Services, are subject to human oversight and intervention.
9. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary to fulfil the purposes for which we collected it. However, it is mission-critical for our business to use accurate data that enables us to deliver a high-quality service.
Therefore, we will retain your personal information for as long as it remains accurate and up to date, and we will remove your data if we confirm that it is no longer accurate, or you have requested to restrict us from processing your data.
10. How and Where Do You Store or Transfer My Personal Data?
We store some of your personal data in the UK, ensuring full protection under the Data Protection Legislation.
We will store some of your personal data within the European Economic Area. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
We use online storage for some or all of your personal data using only tier one third-party providers who offer adequate technical and organisational security measures.
The security of your personal data is essential to us, and to protect your data, we take a number of important technical and organisational measures, including:
- Data Minimisation
- Purpose Limitation
- Data Retention
- Data Resilience
- Data Security Measures including encryption, access controls, regular updates and security audits
- Data Subject Rights
- Contractual Obligations
- Staff Training
- Incident Response Plan
- Privacy by Design and Default
- Change Management
11. Do You Share My Personal Data?
We may share your personal data with other companies in our group in order to ensure data accuracy, apply suppression lists, and maintain excellent service standards. This includes any subsidiaries and affiliates, our holding company and its subsidiaries, and any shared-management partner business.
12. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for a copy of it. This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal address shown in Part 1.
We aim to respond to subject access requests within one month of receiving them. In some cases, if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
13. Changes to this Privacy Policy
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
14. California Consumer Privacy Act Compliance
Clauses 14 to 21 apply to California residents and supplement the information contained in the preceding clauses 1 to 13. They provide additional details about how we collect, use, and disclose personal information of California residents, as well as the rights afforded to them under the California Consumer Privacy Act.
15. Information We Collect
We have collected the following categories of consumers’ personal information from publicly available sources within the last twelve months:
- Identifiers such as name and email address
- Professional or employment-related information
- Internet or other electronic network activity information
- Commercial information
For details on the specific pieces of information collected and the sources of this information, please refer to Clause 5.
16. Use of Personal Information
We use the personal information we collect for the business purposes described in Clause 6 of this Privacy Policy. These purposes include:
- Providing and improving our B2B lead generation and content syndication services
- Communicating with you about our services
- Administering our business operations
17. Disclosure of Personal Information
In the preceding twelve months, we have disclosed personal information to third parties for business purposes as described in our Privacy Policy. The categories of third parties to whom we disclose personal information include:
- Our group companies, subsidiaries and affiliates
- Service providers and partners who help us deliver our services
- Our B2B clients who receive leads as part of our services, which may include personal information of California residents