Privacy Notice

UK GDPR Article 14 — Indirect Data Collection

Last updated: 22 April 2026  |  Version 1.3

01

Who we are

LinLex LTD is a United Kingdom limited company providing B2B IT consultancy services, specialising in cybersecurity, infrastructure management, and programme delivery.

Registered nameLinLex LTD
Company number08446365
VAT numberGB 159 242 891
Registered address3rd Floor, 86-90 Paul Street, London, EC2A 4NE
Data controllerLinLex LTD (for our own outreach activities)
Contact emailprivacy@linlexltd.co.uk

Where LinLex conducts outreach on behalf of a named client company, that client acts as the data controller and LinLex acts as a data processor under a written data processing agreement. In those cases, this notice is provided on behalf of the relevant controller.

02

What personal data we hold about you

We process a limited set of business contact information. We do not collect or process any special category data (e.g. health, ethnicity, political opinions).

Category Data elements
Identity Full name, job title, seniority level
Contact Business email address
Professional Company name, LinkedIn profile URL
Derived Contact score (engagement likelihood), inferred timezone from company location
Interaction Email delivery status (sent, bounced), opt-out/unsubscribe status
03

Where we obtained your data

We did not collect your personal data directly from you. Your business contact information was obtained from one or more of the following sources:

In every case, the data relates solely to your professional role and business contact details, not your private or domestic life.

04

Why we process your data

We process your personal data for the following specific purposes:

Purpose Description
B2B outreach Sending relevant business communications about IT consultancy services that may be of interest based on your professional role
Contact scoring Assessing the likely relevance of our services to your role, so we only contact people for whom our services are genuinely relevant
Email personalisation Using AI-assisted tools to tailor message content to your industry and role, improving relevance and reducing unwanted contact
Send-time optimisation Detecting your likely timezone from company location data so emails arrive during business hours
Compliance management Tracking email delivery (bounces), recording opt-out preferences, and maintaining suppression lists
05

Lawful basis for processing

We rely on legitimate interests as our lawful basis under UK GDPR Article 6(1)(f).

For electronic communications specifically, we rely on the business-to-business exemption under Regulation 21 of the Privacy and Electronic Communications Regulations 2003 (PECR), which permits unsolicited email to corporate subscribers where:

Important: You can opt out of all communications at any time by clicking the unsubscribe link included in every email we send, or by contacting us at privacy@linlexltd.co.uk. We honour every opt-out request immediately.

06

Legitimate interest assessment

We have conducted a Legitimate Interest Assessment (LIA) and concluded that:

Our legitimate interest

LinLex has a genuine business need to identify and contact potential clients whose organisations may benefit from our IT consultancy services. Direct B2B outreach is a standard and expected practice in the professional services sector.

Necessity

Processing business contact data is necessary to reach relevant decision-makers. There is no less intrusive means of introducing our services to potential clients who are not yet aware of LinLex.

Balancing test

We have balanced our interests against your rights and freedoms and concluded that processing is proportionate because:

07

Who we share your data with

We keep your data within a tightly controlled set of systems and do not sell, rent, or trade personal data.

Recipient Purpose Safeguards
Microsoft 365 Email delivery infrastructure (for clients whose mailboxes are hosted on Microsoft) UK/EEA data centres, DPA in place, ISO 27001 certified
Google Workspace Email delivery infrastructure (for clients whose mailboxes are hosted on Google) ISO 27001 / SOC 2 / ISO 27018 certified, data processing terms in place, accessed via scoped OAuth tokens only
LinLex CRM Contact management and campaign tracking UK-based infrastructure under LinLex control, encrypted at rest, TLS in transit, role-based access
Client companies Where LinLex operates outreach on behalf of a named client (e.g. as data processor) Data processing agreement, access limited to campaign results

We may also disclose your personal data where required to do so by law, regulation, or court order.

08

How long we keep your data

Category Retention period Rationale
Active contacts While a reasonable prospect of business engagement exists, reviewed at least annually Ongoing legitimate interest in relevant B2B communication
Bounced/invalid contacts Deleted within 3 months of confirmed bounce No ongoing purpose; data quality hygiene
Opted-out contacts Suppressed permanently (name and email retained on suppression list only) Required to ensure we never contact you again, per PECR requirements
09

Your rights under UK GDPR

You have the following rights in relation to your personal data. These rights are not absolute and may be subject to legal exemptions.

Right What it means
Access (Art. 15) Request a copy of the personal data we hold about you
Rectification (Art. 16) Ask us to correct inaccurate or incomplete data
Erasure (Art. 17) Ask us to delete your data where there is no compelling reason to continue processing
Restriction (Art. 18) Ask us to suspend processing in certain circumstances
Portability (Art. 20) Receive your data in a structured, machine-readable format (where processing is based on consent or contract)
Object (Art. 21) Object to processing based on legitimate interests. For direct marketing, this right is absolute — we will stop immediately.

To exercise any of these rights, email privacy@linlexltd.co.uk with the subject line "Data Rights Request". We will respond within one calendar month as required by law. We may ask you to verify your identity before processing your request.

Data subject access requests (DSARs) are handled via our automated export tool, which can produce a full record of the data we hold about you.

10

Automated decision-making and profiling

We use limited automated processing in the following ways:

None of these processes produce legal effects or similarly significant effects on you. No automated decisions are made about whether to do business with you, and no data is used to make decisions about access to services, pricing, or similar outcomes. The scoring exists solely to improve the relevance and timing of business communications.

11

Google API Services User Data

Where a LinLex client uses a Google Workspace mailbox for outreach, the LinLex Outreach Platform connects to that mailbox using Google's OAuth 2.0 authorisation flow. The client (as the authenticated Google user) grants scoped access; they can revoke it at any time.

Scopes we request and why

ScopePurpose
openid, userinfo.email, userinfo.profile Identify the authenticated user so we can link the connected mailbox to the correct client record in our CRM.
gmail.send Send outbound B2B campaign emails from the authenticated user's own mailbox, one-to-one with personalised content. No bulk broadcast.
gmail.metadata Detect replies to outbound campaign emails by reading message headers (In-Reply-To, References, From, Subject) and message snippets only. Full message bodies are never fetched under this scope.
calendar.readonly Read the authenticated user's primary-calendar busy/free status within a sliding two-week window, to propose available meeting slots when a prospect responds. Event titles, descriptions, attendees and meeting links are not read.

How we store and use Google user data

Limited Use — what we never do with Google user data

LinLex Outreach Platform's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Specifically, we do not:

  • Use Google user data for serving advertisements, including retargeting, personalised or interest-based advertising
  • Sell Google user data to any third party
  • Transfer Google user data to third parties, except as necessary to provide or improve user-facing features that are prominent in the LinLex Outreach Platform's user interface, and with the user's consent; or to comply with applicable law; or as part of a merger, acquisition or sale of assets
  • Use Google user data to train, improve or develop generalised AI/ML models
  • Allow humans to read Google user data, except (a) with the user's affirmative agreement for specific messages; (b) as necessary for security purposes such as investigating abuse; (c) to comply with applicable law; or (d) for internal operations where the data has been aggregated and anonymised

Disconnecting your Google account

You can revoke the LinLex Outreach Platform's access to your Google account at any time by either of the following methods:

  1. Visit myaccount.google.com/permissions, locate LinLex Outreach Platform, and click Remove access.
  2. Visit our disconnect page at linlexltd.co.uk/disconnect for step-by-step guidance and a direct revocation link.

Upon revocation, the access and refresh tokens held by LinLex are invalidated immediately and no further Google API calls can be made on your behalf. We will delete the stored OAuth record within 30 days of detected revocation, subject to any regulatory retention obligations.

Questions or concerns

For any question specifically about our handling of Google user data, contact privacy@linlexltd.co.uk with the subject line Google Data Request.

12

International data transfers

Our CRM system operates on UK-based infrastructure under LinLex control. Email delivery infrastructure varies by client: Microsoft 365 clients' outbound email transits Microsoft's UK and EEA data centres; Google Workspace clients' outbound email transits the regions configured by that client's Google Workspace tenancy, which may include the United States.

Outbound B2B email is, by its nature, sent to recipients wherever their business is located. Where we contact a business recipient outside the UK or EEA, the message necessarily traverses the recipient's own email infrastructure in their jurisdiction, and any reply or engagement signals we receive return by the same route. Beyond this necessary delivery and reply-tracking, LinLex does not transfer personal data to third parties outside the UK or the European Economic Area.

Where a LinLex client's email infrastructure is provided by a US-based operator — for example Microsoft Corporation for Microsoft 365, or Google LLC for Google Workspace — the associated data processing may involve transfer to the United States. Such transfers are safeguarded by the UK Extension to the EU-US Data Privacy Framework or the UK International Data Transfer Agreement, as applicable, and by the provider's own certifications (including ISO 27001, ISO 27018, SOC 2).

13

Complaints

If you are unhappy with how we have handled your personal data, we encourage you to contact us first at privacy@linlexltd.co.uk so we can attempt to resolve the matter.

You also have the right to lodge a complaint with the UK supervisory authority:

Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Website: ico.org.uk/make-a-complaint

14

Contact us

If you have any questions about this privacy notice or how we handle your personal data, please get in touch.

LinLex LTD — Privacy Enquiries

Email: privacy@linlexltd.co.uk

Post: 3rd Floor, 86-90 Paul Street, London, EC2A 4NE

Web: www.linlexltd.co.uk