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Template — complete the marked gaps and have counsel read it. The commitments below match what the platform actually does, but the entity details, the representative, the retention periods and the hosting and sub-processor commitments depend on decisions that have not been made yet. Every one of those gaps is marked in the text. Do not publish this as a live notice with them still showing, and do not fill them with a guess — an invented registered address in an article 14 notice is worse than a visible blank, because nobody goes back to check it.
Article 14 notice

How we got your data

You never gave us your details, and an email arrived anyway. Here is exactly who holds what, where it came from, why we think we are allowed to, and every way you can make it stop.

Last updated
18 August 2026
Applies to
Anyone in our business contact database
Reading time
About six minutes

1.Why you are reading this

You did not give us your details. We built a record about your professional role from sources you will find listed further down, and one of our customers used it to email you. When that happens, Article 14 of the UK and EU GDPR says we owe you an explanation without you having to ask for it — who we are, what we hold, where it came from and how to make it stop. This page is that explanation.

Every message sent through the platform carries an unsubscribe link in its footer, and the page that link opens points straight here — that is the route from a cold email to this explanation. Reading it is not conditional on you being a customer, being in Europe, or replying to anything.

If you only want the email to stop, that is one field and no waiting. Use the opt-out form. It takes effect when you press the button and covers every company sending through Salvo, not just the one that wrote to you. Reading the rest of this page is optional.

2.Who is responsible for the data

One company holds the database and answers for it. The customer who emailed you chose to contact you and wrote the message, but the record itself is ours, and so is the duty to explain it.

Controller
Salvo GTM Ltd Placeholder, to be completed before launch: confirm the incorporated nameThe company that decides what happens to the data, and the one answerable to you for it.
Registered address
Placeholder, to be completed before launch: registered office addressArticle 14(1)(a) wants the real one, not a support desk.
Company number
Placeholder, to be completed before launch: company number
Data protection contact
privacy@salvo.exampleMonitored by a person. Every route on this page ends up here.
Data protection officer
Placeholder, to be completed before launch: appointed? name and contact, or the recorded reason one is not required
EU / UK representative
Placeholder, to be completed before launch: article 27 representative, or the recorded reason none is neededRequired if we hold data about people in a region where we are not established.

3.What we hold about you

Business-role data, and nothing about your private life. A complete record is short enough to list in full:

  • Your name, and the job title, seniority and department we have on file for you.
  • The company you work for, and its website, industry, size band and locations.
  • A work email address, and a direct business line where a public listing gave us one.
  • A link to a professional profile you published yourself, where we matched one.
  • The provenance trail: for every field, which category of source it came from and the date we saw it there.
  • If a customer has emailed you through us, the record of that — when, by whom, whether it was opened, and your reply if you sent one.

We do not hold special category data — nothing about health, beliefs, politics, ethnicity, sex life or trade union membership — and we do not knowingly hold home addresses, personal email accounts or personal mobile numbers. If you find any of that in a copy of your record, that is a defect and we want to hear about it.

4.Where we got it

This is the honest answer to the question most people arrive with. Each field in your record carries the category of source it came from, so a copy of your data tells you which of these rows applies to which field.

SourceWhat it gives usPublicly accessible?
Your employer’s own websiteName, role and department from team, about and contact pages; the company’s trading address and phone.Yes — published by the company itself.
Professional profilesEmployer, job title and seniority from a profile page the person published for professional purposes.Yes — public pages, read the way any visitor reads them.
Business registers and filingsCompany identity, registered address, and officers where the register publishes them.Yes — statutory public registers.
Public map and directory listingsTrading locations, opening hours and a switchboard number for a company’s premises.Yes — open listings for a place of business.
Licensed data partnersFirmographics, and occasionally a work email address, bought under a licence that obliges the supplier to have had a lawful basis for it.No — a commercial feed. We name the supplier in an access request.
A customer’s own listAn address a customer uploaded into their workspace, plus whatever they already knew about you.No — and here the customer is the controller, not us.

We do not buy consumer lists, we do not guess addresses by pattern-matching a company domain, and we do not take data from anyone who cannot say where they got it.

The last row works differently. When a customer uploads their own list, they decided to hold your details and we only process them on their instructions. We will tell you that, name the customer where we are allowed to, and pass your request to them — but they are the ones who have to answer it. Everything else on this page is about the records we compile ourselves.

5.What we use it for, and why we are allowed to

One purpose, one lawful basis. We rely on legitimate interests — Article 6(1)(f) — and not on consent, because claiming you consented to something you were never asked about would not be true.

PurposeLawful basisThe interest being pursued
Letting a customer reach the right person at a company with a business propositionLegitimate interestsOur customers’ interest in finding buyers, and ours in selling a tool that works. Recital 47 accepts direct marketing may qualify; it does not settle it for us.
Keeping the record accurate and removing dead onesLegitimate interestsA stale record means mail to the wrong person, which is worse for you than for us.
Honouring an opt-out so it cannot be undoneLegal obligation, and legitimate interestsOnce you have told us to stop we have to remember, or the next refresh quietly puts you back.
Sending marketing where local law requires consent insteadConsentIn those countries we do not send on legitimate interests at all. Campaigns are blocked at the point of sending, not left to the sender’s judgement.

Legitimate interests only holds if the balance genuinely falls our way, so we wrote the test down and published it rather than asserting the conclusion. It is in the compliance FAQ, in full, including the parts that count against us. If you disagree with it, you do not have to argue: an objection to direct marketing needs no reason and we have no right to refuse it.

6.Who else sees it

  • Our customers — the companies that search the database and run campaigns. A customer sees your record when it matches what they are looking for.
  • Our sub-processors — cloud hosting, a managed database, transactional email infrastructure, a language model provider Placeholder, to be completed before launch: confirm the zero-retention terms are signed, error monitoring, and a support desk. Each one is under a written contract and processes only on our instructions.
  • Nobody who wants it for advertising. We do not sell personal data, we run no ad networks and we place no third-party marketing pixels.
  • A court or regulator, where the law compels us — and we will tell you unless we are legally barred from doing so.

The categories are listed with their regions in the privacy policy, and the named entities are in the DPA annex, available on request. An access request tells you which of our customers has actually seen your record, not just which ones could have.

7.Where it goes

Primary hosting is in Placeholder, to be completed before launch: hosting region, once the infrastructure is fixed. Where data reaches a country without an adequacy decision — in practice the United States — we rely on the European Commission’s standard contractual clauses with the UK international data transfer addendum, encryption in transit and at rest, and Placeholder, to be completed before launch: a transfer risk assessment, to be completed and dated. Copies of the clauses are available from privacy@salvo.example on request, and you do not have to explain why you want them.

8.How long we keep it

WhatHow longWhy that long
Your business role recordKept while it still checks out. Revalidated every Placeholder, to be completed before launch: revalidation interval and dropped after two failed validations.A record we can no longer verify is a record that is probably wrong about you.
A record nobody has ever usedPlaceholder, to be completed before launch: maximum time on file before it is deleted unusedNeeds a number, not a habit. Set it before launch.
Campaign history — messages sent to you, opens, your repliesPlaceholder, to be completed before launch: retention period for outreach historyLong enough to prove what was sent and to honour a complaint; no longer.
Your opt-outKept indefinitely: the address on its own, with nothing else from the record.It is the only thing that stops a later refresh silently recreating the record you asked us to stop using. Deleting it would undo your own request.
Application and access logsPlaceholder, to be completed before launch: log retention periodLong enough to investigate abuse and a mis-send, and no longer.
Encrypted backupsPlaceholder, to be completed before launch: backup retention windowA record restored from backup is re-checked against the suppression list before anything can be sent to it.

A request to erase is recorded with the date it is due, and the suppression takes effect the moment it arrives. The periods above only mean something once something enforces them without being asked: Placeholder, to be completed before launch: automated retention sweep, to be running before launch.

9.Scoring, and email written by a model

The platform scores how closely a company matches what a customer is looking for, and a language model drafts the email and classifies your reply. That is profiling in the ordinary sense of the word, and we would rather say so than hide it. What comes out of it is a marketing email — not a decision about credit, employment, insurance or eligibility — so it is not the kind of automated decision Article 22 gives you a right to object to individually. You can still object to the whole thing under Article 21, which is a wider right and takes one click. Content sent to our model provider is covered by zero-retention terms and is not used to train public models.

10.What you can make us do

These are yours whether or not you are a customer and wherever you live. All of them are free, none of them need a reason, and we will not ask you for a passport to settle a question about a job title.

  • Object to marketing (Article 21(2)) — absolute. We stop, immediately, and we cannot weigh anything against it.
  • Object to the rest of the processing (Article 21(1)) — we stop unless we can show compelling grounds that override your rights, and the burden is on us.
  • Get a copy (Article 15) — everything we hold, where each field came from, and who has seen it.
  • Have it corrected (Article 16) — wrong employer, old title, a name spelt the way nobody spells it.
  • Have it erased (Article 17) — the record goes; the hashed opt-out stays so it cannot come back.
  • Restrict processing (Article 18) — pause everything while an accuracy dispute is resolved.
  • Portability (Article 20) — a machine-readable file, where it applies.
  • Complain to a regulator (Article 77) — see below, and you never need our permission.

Access, correction and erasure go through a confirmation email first, because we will not send somebody’s file to whoever typed their address into a form. Opting out does not: the right to stop marketing is unconditional, so we do not put a condition in front of it.

11.If you want to complain

Tell us first if you are willing to — we would rather fix it than read about it from a regulator — but you are under no obligation to, and complaining to us does not use up your right to complain to anyone else.

You can lodge a complaint with the data protection authority in the country where you live, where you work, or where the thing you are unhappy about happened. In the UK that is the Information Commissioner’s Office. In the EU it is your national authority; the European Data Protection Board publishes the list. Our own lead supervisory authority is Placeholder, to be completed before launch: lead supervisory authority, once the entity is registered.

Talk to a person

Every form on this site ends up in the same inbox, and so does a plain email. Write to privacy@salvo.example in whatever words you like — “take me off your list” is a valid legal request and we treat it as one. We acknowledge within a working day and answer within 30 days.

  • Salvo GTM Ltd, Placeholder, to be completed before launch: registered office address
  • Supervisory authority: Placeholder, to be completed before launch: lead authority, once registered
  • Longer version, covering customers and site visitors too: privacy policy · compliance FAQ