Privacy Policy
ProspectBase Privacy Policy
BACKGROUND:
ProspectBase respects your privacy and understands that you care about how your personal data is used. This policy also serves as our Privacy Notice and 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, 18 Church Street, Portlaoise, Co. Laois, R32 TP89, Ireland (Irish company registration number: 762727).
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 Ireland Ltd, 18 Church Street, Portlaoise, Co. Laois, R32 TP89, Ireland.
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 GDPR (Regulation (EU) 2016/679) and the Data Protection Act 2018 (Ireland) (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'.
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 (such as an unsubscribe link in an email).
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights:
a) 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.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) 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.
d) 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.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) 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.
h) 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.
i) 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.
If you have any cause for complaint about our use of your personal data, please contact us first. We would welcome the opportunity to resolve your concerns. Should you wish to, you have the right to lodge a complaint with the Data Protection Commission (DPC) (www.dataprotection.ie).
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:
|
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. | 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 (see https://gdpr-info.eu/recitals/no-47/ point 7). 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 ePrivacy Regulations 2011 (S.I. No. 336/2011), as amended. 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, which 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 (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.
10. How and Where Do You Store or Transfer My Personal Data?
We store your personal data in Ireland and within the European Economic Area (the "EEA"), ensuring full protection under the Data Protection Legislation. As Ireland is a member state of the European Union, transfers of personal data within the EEA do not require additional safeguards.
Where we transfer personal data outside the EEA (for example, to service providers in non-EEA countries), we ensure that appropriate safeguards are in place in accordance with the Data Protection Legislation, such as Standard Contractual Clauses approved by the European Commission. Further information is available by contacting us at privacy@prospectbase.com.
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.
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
- Purpose Limitation
- Data Retention
- Data Resilience
- Data Security Measures (including encryption, access controls, regular updates, 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 (CCPA) Compliance
Clauses 14–21 apply to California residents and supplement the information contained in the preceding clauses 1–13. 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 (CCPA).
15. Information We Collect
We have collected the following categories of consumers' (as defined under the CCPA) personal information from publicly available sources within the last twelve (12) months:
a) Identifiers (such as name, email address)
b) Professional or employment-related information
c) Internet or other electronic network activity information
d) Commercial information
For details on the specific pieces of information collected and the sources of this information, please refer to clause 5. "What Personal Data Do You Collect and How?".
16. Use of Personal Information
We use the personal information we collect for the business purposes described in clause 6. "How Do You Use My Personal Data?" of this Privacy Policy. These purposes include:
a) Providing and improving our B2B lead generation and content syndication services
b) Communicating with you about our services
c) Administering our business operations
17. Disclosure of Personal Information
In the preceding twelve (12) 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:
a) Our group companies, subsidiaries, and affiliates
b) Service providers and partners who help us deliver our services
c) Our B2B clients who receive leads as part of our services, which may include personal information of California residents
While we may sell personal information strictly related to business contact details and no sensitive personal information in the traditional sense, our disclosure of lead information to clients may be considered a "sale" under the broad definition in the CCPA.
18. Your Rights Under CCPA
As a California resident, you have the following rights under CCPA:
1. Right to Know: You have the right to request that we disclose certain information about our collection and use of your personal information over the past 12 months.
2. Right to Delete: You have the right to request that we delete any of your personal information that we have collected and retained, subject to certain exceptions.
3. Right to Opt-Out: As we do not sell personal information, there is no need to opt out of the sale of personal information.
4. Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.
19. Exercising Your Rights
To exercise your rights under CCPA, please submit a verifiable consumer request to us by:
- Emailing us at: privacy@prospectbase.com
- Writing to us at: ProspectBase Ireland Ltd, 18 Church Street, Portlaoise, Co. Laois, R32 TP89, Ireland
- Using the "Do Not Sell My Personal Information" form on our website
- Only you, or a person registered with the California Secretary of State that you authorise to act on your behalf, may make a verifiable consumer request related to your personal information.
-
You may only make a verifiable consumer request for access or data
portability twice within a 12-month period. The verifiable consumer request
must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorised representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Please note that while we offer a "Do Not Sell My Personal Information" form on our website, we currently do not have a way to verify if users of this form are genuinely California residents. We will process all requests received through this form in good faith.
We will generally respond to a verifiable consumer request within thirty (30) days of its receipt (but no later than 45 days). If we require more time, we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request.
We will deliver responses to access requests electronically, in a readily useable format that allows you to transmit the information from one entity to another without hindrance.
20. Deletion Requests and Exceptions
If you request deletion of your personal information, we will delete your personal information from our records and direct our service providers to do the same, subject to certain exceptions permitted by law.
Please note that we will retain certain information on a suppression file to ensure we can continue to restrict your details from future processing, in line with your preferences and applicable data protection laws.
21. Changes to this CCPA Section
We reserve the right to amend this CCPA section at our discretion and at any time. When we make changes to this CCPA section, we will post the updated section on our website and update the section's effective date.