Privacy Notice

Information pursuant to Articles 13 and 14 GDPR for persons whose business contact data we process

This notice covers our processing of business contact data. The privacy policy for visitors of the hiring-intelligence.io website is a separate document. The German version of this notice is the authoritative version; this English version is provided for convenience.

1. Who we are

Growthlynk Management FZCO, trading as "Hiring Intelligence", Dubai Digital Park, Dubai, United Arab Emirates.
Contact: [email protected]
EU representative pursuant to Art. 27 GDPR: Euverify Ltd (Ireland), Unit 3D, North Point House, North Point Business Park, New Mallow Road, Cork, T23 AT2P, Ireland — [email protected]. You may address our EU representative, in addition to or instead of us, on all matters related to our processing of your data.

2. What we do and why this notice concerns you

We analyse published job advertisements in order to show recruitment and staffing companies which employers are currently hiring or have been hiring within the past year. For those employers we process business-related contact data of professionals — typically managing directors, HR leaders and department heads.

You are receiving or reading this notice because your business contact data may be processed by us.

3. What data we process

• Identity and role data: name, job title, seniority, salutation
• Business contact data: business email address, phone number, business address, LinkedIn profile URL
• Employer data: company name, website, industry, size, location, published job advertisements
• Data quality metadata: verification status, source and timestamps

We do not intentionally process special categories of personal data (Art. 9 GDPR) and no data relating to your private life. We process phone numbers only insofar as our sources identify them as business contact data. Where a number is reported to us as private or incorrect, we suppress it without undue delay and permanently — tell us via our opt-out form (see section 9).

4. Where the data comes from (Art. 14(2)(f) GDPR)

• Publicly available sources: public job advertisements and job platforms, company websites (in particular imprint/legal notice and team pages), commercial registers, public professional profiles
• Licensed B2B data providers (contact enrichment and verification services, e.g. BetterContact)
• Verification services used to confirm deliverability of business email addresses

5. Purposes and legal basis

We process this data to provide B2B sales intelligence to recruitment and staffing companies — i.e. to enable them to contact employers with current or recurring hiring demand about recruitment services.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest). Our legitimate interest is the operation of a B2B business-information service; our customers' legitimate interest is B2B direct marketing to businesses with demonstrable or recurring hiring demand (cf. Recital 47 GDPR). We have documented the balancing of interests in a Legitimate Interest Assessment; its outcome: only professional, role-related data of business decision-makers is processed, which such persons can reasonably expect to be used for business-to-business communication.

We differentiate between contact channels: use of the business email address is what a person is most likely to anticipate, whereas a phone call intrudes further into the working day. We have therefore carried out a separate balancing for phone numbers. It comes out in favour of the processing, because we process only numbers identified as business contact data, deliver them only to commercial recipients, and permanently suppress numbers reported to us (section 3). Responsibility for the lawfulness of the call itself lies with the calling customer as an independent controller (section 6).

No automated decision-making, including profiling, within the meaning of Art. 22 GDPR takes place.

6. Who receives the data

• Our customers: recruitment and staffing companies in the DACH region and internationally. Upon delivery, each customer becomes an independent controller of the data it receives and is itself responsible for its use, including its own outreach.
• Our service providers (hosting, task execution, AI-assisted data processing, email verification, and the sending infrastructure through which we send our own outreach) under data processing agreements.
• Our opt-out form provider (Tally, Belgium/EU): when you use our opt-out form, the details you submit (name, business email, phone number) are processed by Tally on our behalf to receive and action your request.

7. International transfers

We are established in the UAE. Our primary database is hosted in the EU (Ireland). Our own access to this data from the UAE is governed directly by the GDPR, which applies to our processing under Art. 3(2) GDPR — we have appointed an EU representative for this reason (section 1). Where personal data is processed by third-country service providers (in particular US providers), we rely on the EU Standard Contractual Clauses and supplementary measures (EU data-at-rest hosting, encryption, access controls). You can obtain a copy of the Standard Contractual Clauses on request via the contact details in section 1.

8. How long we keep the data

We retain business contact records only while they serve the purpose. What matters is not the individual job advertisement but an employer's recurring hiring demand: recruitment cycles repeat, and an employer that has been hiring within the past year remains relevant to staffing providers. This gives the following periods:

• Records never passed on: where a record was never delivered to a customer and never used for any communication, we delete it 180 days after collection.
• Records delivered or used: we delete these once the employer has shown no hiring signal for 12 months, or we irreversibly minimise them — in which case only the reference to the company remains, without personal data. Merely updating or re-verifying a record does not extend this period — only a new hiring signal does.
• Raw contact-enrichment data: deleted 90 days after processing.
• Records of which customer received which record: retained for the term of the customer contract plus three years. We need them in order to notify you and the recipients of any rectification, erasure or objection (Art. 19 GDPR), to meet our accountability obligation (Art. 5(2) GDPR), and to defend legal claims within the applicable limitation periods.
• After an objection: we permanently retain only the minimum data required to honour it (suppression list).

9. Your rights

You have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), and objection (Art. 21 GDPR). You can object to the use of your data for direct marketing purposes at any time; we will then stop processing your data for such purposes.

You further have the right to lodge a complaint with a supervisory authority.

To exercise your rights, use our opt-out form (https://tally.so/r/Y5g1Jv — no account or login required) or the contact details in section 1. We answer within one month. We also forward your objection to customers who received your record and instruct them to stop using it.

10. Why we inform via this notice (Art. 14(5)(b) GDPR)

The data in our database is collected from public and licensed sources, not from you directly. Given the number of records concerned, individually notifying every person at the time of collection would involve disproportionate effort (Art. 14(5)(b) GDPR). We therefore make this information publicly available through this notice and protect your rights through additional measures: outreach sent through our systems refers to the hiring signal that prompted the contact — as a rule, the job advertisement; where one of our customers contacts you, that customer is an independent controller, itself responsible for informing you about its own processing, and contractually required — if you ask — to truthfully disclose us as the source of your data and to point you to our opt-out channels; records are deleted in accordance with the periods set out in section 8; and you can object at any time with immediate effect (section 9).