This section applies if we have contacted you at work about our services, for example by email, without you contacting us first. If so, this section explains how we use your information, and it applies instead of sections 1 to 3.

What we collect: your name, job title or role, business email address and business phone number, the company you work for, and public information about the business (such as its website, sector, size, location and recent news). We also record where we found your details and whether you replied or asked us not to contact you again.

Where we get it: company websites, Companies House, public business directories and LinkedIn company pages. We do not buy contact lists.

Why we use it: to contact businesses we think could benefit from our marketing services. That is usually one short email and no more than two follow-ups, and we stop as soon as you reply.

Our lawful basis: legitimate interests (UK GDPR Article 6(1)(f)). We have a genuine interest in telling relevant businesses about our services, and we have weighed that against your rights in a written legitimate interests assessment. Under the Privacy and Electronic Communications Regulations (PECR), we only send these emails to corporate subscribers such as limited companies and LLPs. We do not cold-email sole traders or ordinary partnerships unless they have given their consent.

Who helps us: Google (Google Workspace), which runs our email, and Instantly, the tool we use to send and manage these emails. Instantly is operated by Foo Monk LLC in the United States, and Google may also process data outside the UK, including in the United States. Where your data leaves the UK, it is protected by approved standard contractual clauses with the UK International Data Transfer Addendum (Instantly), and by Google’s standard contractual clauses or another recognised transfer mechanism such as the UK–US data bridge (Google). Our prospecting emails are plain text and do not contain tracking pixels. We never sell or share your details for anyone else’s marketing.

How long we keep it: if you don’t reply, we delete your details within 12 months of our last email. If you ask us not to contact you again, we keep your email address and company name on a suppression list indefinitely, only so that we never contact you again. If you reply but don’t go ahead, we keep our correspondence for up to 12 months after our last contact, then delete it, unless you’ve asked us not to contact you again (in which case we keep only the suppression-list details above). If you become a client, the rest of this policy applies.

Automated decision-making: we don’t use automated decision-making or profiling that has legal or similarly significant effects on you. We choose which businesses to contact by hand, using the public information above.

General company addresses: sometimes we write to a general company address such as info@. Where that address doesn’t identify a person, it isn’t personal data, but we treat opt-outs from it in the same way.

Your rights:

• You have an absolute right to object to direct marketing. Reply “no thanks” to any of our emails, or email [email protected], and we will stop straight away. We don’t need a reason and we will never ask for one.
• You can also ask us to restrict how we use your information while a concern is looked into. You can ask for a summary of our legitimate interests assessment, and we will send it to you free of charge.
• You can ask for a copy of the information we hold about you, or ask us to correct or delete it. If you ask us to delete it, we keep only the minimum needed on our suppression list so that we don’t contact you again.
• If you are unhappy with how we have handled your data, you can complain to the Information Commissioner’s Office (ICO) at ico.org.uk/make-a-complaint or on 0303 123 1113. We’d appreciate the chance to put things right first.

Who is responsible: the data controller is Neil Carroll, a sole trader trading as The On Demand CMO, Dunholme, Thornes Road, Wakefield WF2 8QN. Email [email protected] or call 07863 759167. Our prospecting emails are sent from [email protected].