Lead and Prospect Data Notice

This notice is for people whose business contact details appear in the prospect lists that Keenfunnel compiles and licenses to other businesses. If you are reading it because we or one of our clients contacted you, it explains where your details came from, what we do with them and how to stop it.

Who is responsible

Keenfunnel LLC, 418 Broadway STE 4000, Albany, NY 12207, United States ("Keenfunnel", "we", "us"), is the controller of the prospect data described here.

1. Contact: legal@keenfunnel.com
2. Representative in the European Union and the United Kingdom: Mario Bosquet, mario.bosquet@keenfunnel.com

What data we hold

We hold only your name and email address.

We do not hold sensitive data, such as information about health, religion or political opinions, and we do not compile data about children.

Where it comes from

You can ask us at any time where we obtained your details, and we will tell you.

Why we use it, and on what legal basis

We use your data to compile and update prospect lists and to license them to businesses that want to offer products or services relevant to your professional role.

In the European Union and the United Kingdom we rely on our legitimate interest, and that of our clients, in business-to-business marketing (Article 6(1)(f) of the GDPR and of the UK GDPR).

Who receives it

1. Clients who license our lists. Each client becomes responsible for its own use of your data and must follow our Lead Data License Terms, including honoring your objection.
2. Service providers, such as hosting and email providers, that store or process the data for us under contract.

We license your data only for business outreach. We never license it for decisions about credit, employment, insurance or housing.

International transfers

Keenfunnel is based in the United States and our clients are located around the world. When data about people in the EU, the UK or Switzerland goes to a country without an adequacy decision, we use the European Commission's standard contractual clauses, with the UK addendum or the Swiss adaptations where they apply. You can ask us for a copy.

How long we keep it

We keep each record only for as long as we need it to compile and license our lists, and then delete it. If you object, we keep only the minimum needed to make sure you are not added again (see "Your rights").

Your rights

You can ask us to:

1. confirm whether we hold your data and give you a copy;
2. correct it;
3. delete it;
4. restrict how we use it;
5. stop using it for marketing. You can object at any time, without giving a reason, and we will stop.

To exercise any of these rights, write to legal@keenfunnel.com. We reply within one month. We also tell every client who received your details to stop using them, unless that proves impossible.

To make your objection last, we keep your email address, or a one-way hash of it, on a suppression list that we and our clients check before any outreach.

Complaints

You can complain to us at legal@keenfunnel.com or to a data protection authority, for example the Agencia Española de Protección de Datos (AEPD) in Spain, the Information Commissioner's Office (ICO) in the UK, or the authority where you live or work.

If you live elsewhere

1. United States: where a state privacy law applies to us, you can opt out of the sale of your personal information by writing to legal@keenfunnel.com.
2. Canada: we and our clients send commercial emails only as Canada's Anti-Spam Legislation (CASL) allows, and every message has a working unsubscribe.
3. Australia: you can ask us to stop using your information for direct marketing and to tell you where we obtained it (Australian Privacy Principle 7).
4. New Zealand: this notice is how we tell you that we collected your information from other sources (information privacy principle 3A).
5. Anywhere else: we honor the rights your local law gives you. Write to legal@keenfunnel.com.

Changes

We show the date of every change at the top of this page. See also our Privacy Policy.