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Privacy Policy

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ProspectBase Privacy Policy

BACKGROUND:

ProspectBase respects your privacy and 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: 14941038).

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.

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.

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 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. In simpler terms, it is any information about you that enables you to be identified. The personal data that we use is set out in Part 5, below.

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;

We help our customers promote their offerings more effectively to individuals in businesses who would reasonably have a legitimate business interest in receiving such communication.

It’s in the interest of individuals whose personal data we process for us to maintain healthy and accurate information so that businesses can better reach the most relevant business contacts.

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 (such as an unsubscribe link in an email).

4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  • The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 1.
  • The right to access the personal data we hold about you. Part 10 will tell you how to do this.
  • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 1 to find out more.
  • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 1 to find out more.
  • The right to restrict (i.e. prevent) the processing of your personal data.
  • The right to object to us using your personal data for a particular purpose or purposes.
  • The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  • The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  • 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 as outlined above, please contact us using the details provided in Part 1.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data please contact us first, using the details in Part 1. We would welcome the opportunity to resolve your concerns. Should you wish to, you have the right to lodge a complaint with the Information Commissioner’s Office.

5. What Personal Data Do You Collect and How?

We may collect and hold some or all of the personal and non-personal data set out in the table below, from the sources also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children.

Data Collected Data Sources
Identity Information including: First Name, Surname. Publicly Available Sources including but not limited to: LinkedIn, Google Cache, Company Websites, Networking Sites, Open Forums, News Sites, Our own Landing Pages, Information provided by our Client / Customer / Partner.
Contact information including: business email address, phone number (DDI and/or mobile). Publicly Available Sources including but not limited to: LinkedIn, Google Cache, Company Websites, Open Forums, News Sites, Our own Landing Pages, Information provided by our Client / Customer / Partner.
Business information including: business email address, Employer, Business Address, Industry, Company Size, IP Address. Publicly Available Sources including but not limited to: LinkedIn, Google Cache, Company Websites, Open Forums, News Sites, Our own Landing Pages, Information provided by our Client / Customer / Partner.
Profile information including: LinkedIn URL, marketing preferences, engagement statistics, website traffic information, cookie preferences. Publicly Available Sources including but not limited to: LinkedIn, Google Cache, Company Websites, Open Forums, News Sites, Our own Landing Pages, Information provided by our Client / Customer / Partner.
Data from third parties including: identity, contact, business, and profile information (as above), firmographic, tech install, intent signal. Supplied by the appropriate 3rd Party via Contractual Agreement.
Legally required Information including: DPAs, LIAs, NDAs, Compliance Details, Insurance, Regulatory details. Supplied by the appropriate 3rd 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?

The following table describes how we may use your personal data, and our lawful bases for doing so:

What we Do What Data we Use Our Lawful Basis
Administering our business. This includes day-to-day operations and outside of our primary purpose of providing Services it also includes:
  • Providing our customers with the confidence that we have access to accurate data that enables us to better promote their goods and services using direct marketing to the right people (decision makers, influencers, champions etc.) in other businesses;
  • Ensuring we can keep accurate suppression lists in accordance with the appropriate data protection laws;
  • Where applicable helping us keep you up to date with our services, changes in policies and other important notifications;
  • Enabling you to interact with features or tools on our website or landing pages;
  • Providing you with the services we have and offering new services;
  • Improving your user experience;
  • Gathering analytics on usage and other statistics to improve features and functionality.
 All data as defined in the table in Clause 5. Legitimate Interest, Contractual & Legal.
Providing our Services to clients / 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 (www.knowledge-cloud.com) or via email domains that fall under our content library brand such as: knowledge-cloud.com; newtechlibrary.com; newtechresources.com; smarttechresources.com (new sub-domains may be added in the future). Contact Information; our website. Legitimate Interests & Legal.

With your permission (i.e. if you opt in to receive content we offer to you), and where permitted by law, we may use your personal data for direct marketing purposes (see GDPR Recital 47 point 7), which may include contacting you by email and/or telephone and/or post with information, news, and offers on products and services of ours and our clients / customers. We will always work to protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), and you will always have the opportunity to opt-out.

We do not use automated systems for carrying out any decision-making or profiling. All automated processes, including any AI-related processes used in the processing of any information that involves Personal Data or data of any kind used in the performance of Services requires human supervision.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 1.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary; 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 (as best we can determine) 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.

8. How and Where Do You Store or Transfer My Personal Data?

We store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. 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 3rd party providers who offer adequate technical and organisational security measures including but not limited to: Dropbox, One Drive and Sharepoint whose servers may be in the USA. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

  • We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data.
  • Where appropriate we will use specific contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation.

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 the following:

  • Data Minimisation: Collect and process only the necessary amount of personal data required for providing services. Limit the scope to non-sensitive personal data obtained from publicly available sources.
  • Purpose Limitation: Clearly define and document the purposes for which personal data is processed, ensuring it aligns with the services provided, limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality.
  • Data Retention: Establish and adhere to retention periods based on the necessity to provide services. Regularly review and securely dispose of data when it is no longer needed.
  • Data Resilience: Ensure back-up and recovery measures mitigate the potential loss or corruption of data to enable the restoration and availability of access to personal data in a timely manner.
  • Data Security Measures:
    • Implement encryption and pseudonymisation techniques to protect personal data during transmission and storage.
    • Maintain strict access controls (identification, authentication, and authorisation) to limit access to personal data to authorised personnel only.
    • Regularly update and patch systems and software to mitigate security vulnerabilities.
    • Conduct regular security audits and risk assessments to identify and address potential security threats.
  • Data Subject Rights:
    • Provide mechanisms for data subjects to exercise their rights, including the right to access, rectification, erasure, and restriction of processing.
    • Designate an individual (or team) responsible for overseeing compliance with data subject rights and GDPR requirements.
  • Contractual Obligations: Ensure that contracts with clients and third-party vendors include GDPR-compliant clauses regarding data processing, security, and confidentiality.
  • Staff Training: Provide regular training to employees on data protection principles, GDPR requirements, information security, acceptable IT usage and the company's relevant policies and procedures for handling personal data and maintaining a secure environment.
  • Incident Response Plan: Develop and maintain a comprehensive incident response plan to promptly detect, respond to, and report data breaches in accordance with GDPR requirements.
  • Privacy by Design and Default: Integrate privacy considerations into the design and implementation of systems, processes, and services from the outset. Default settings should prioritize the highest level of privacy protection for personal data.
  • Change Management: Company manages changes to its corporate infrastructure, IT systems and applications using a change management program approved by senior leadership. Testing and business impact analysis occur where appropriate and all relevant software development adheres to the change management process and more broadly, to ensure the effectiveness of technical and organisational measures. Critical changes are approved and implemented by authorised personnel only.

9. Do You Share My Personal Data?

We may share your personal data with other companies in our group in order to ensure data accuracy, suppression lists are applied the services we provide maintain an excellent standard. This includes any subsidiaries and affiliates, our holding company and its subsidiaries, and any shared-management partner business.

10. 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 (where any such personal data is held). 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.

If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We aim to respond to subject access requests within one month of receiving it. 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.

11. 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.

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