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Privacy Policy

Last updated: July 9, 2026
Controller: Oleksandr Riabtsev, private entrepreneur (Ukraine), reg. no. 29309570, 03187 Ukraine, Kyiv, Glushkova, 26, ap. 99
Contact: [email protected] · 03187 Ukraine, Kyiv, Glushkova, 26, ap. 99

1. Who we are

We provide B2B lead-generation services: we identify companies that may benefit from our clients' services and contact their business representatives.

2. What data we process and where it comes from

Business contact data (name, job title, business email, company, business phone, LinkedIn profile URL): obtained from licensed business-data providers, public professional sources (company websites, professional profiles), or directly from you. We record the source of every record.

Website data: basic analytics and any information you submit via forms or booking pages.

We do not process consumer/personal-life data, and we do not contact personal mailboxes.

3. Why and on what legal basis

PurposeLegal basis
Contacting you about services relevant to your business roleLegitimate interests (Art. 6(1)(f) GDPR) — B2B relevance assessed per campaign and documented
Responding to your inquiries; scheduling meetings you requestContract / pre-contract steps (Art. 6(1)(b))
Delivering agreed lead records to a client after your expressed interestLegitimate interests; you are told which client before any handover
Legal compliance, records, dispute defenseLegal obligation / legitimate interests

4. Your rights

You may at any time: opt out of all communication (one click in any email, or write to us — executed within 24 hours and permanent), request access to the data we hold about you, correction, erasure, restriction, or object to processing. EU/EEA residents may complain to their supervisory authority. We respond to requests within 72 hours (statutory maximum one month).

5. Sharing

Data processors we use (hosting, email delivery, CRM, scheduling), each under data-processing terms; our clients, only where §3 row 3 applies; authorities where legally required. We do not sell personal data.

6. International transfers

We operate from Ukraine and use processors in the EU/US. Ukraine is not covered by an EU adequacy decision for all categories of commercial data. Accordingly, for transfers of EU/EEA personal data to our servers in Ukraine and to any US-based processors, we rely on the European Commission's Standard Contractual Clauses (SCCs), supplemented by appropriate technical and organizational measures. A copy of the SCCs and details of the safeguards in place are available on request at [email protected].

7. Retention

Business contact data: deleted or anonymized 6 months after last interaction unless an active engagement exists. Opt-out records: kept permanently (suppression list) — this is how we guarantee we never contact you again. Financial records: 7 years (legal requirement).

8. Security

Encrypted storage and transit, access controls, append-only audit logging of processing actions.

9. Changes

We will post updates here with a new "last updated" date.