1. Who are we?
   1. We are Prospect Global Ltd – trading as Sopro.io. We are a tech company providing digital marketing services to our global client base. Our processing is based primarily on the use of publicly available data to identify sales prospects for our clients. As such, your privacy is important to us, we take our responsibilities seriously and will always respond quickly and courteously to any request. You can contact us using the details below:
      By email to our Data Protection Officer: dpo@sopro.io
      By telephone on: +44 17 7221 7772
      
      or
      
      By post to: Sopro, 27-29 North Street, Brighton, BN1 1EB
      By telephone on: +44 207 030 3340
      
2. Our GDPR Policy
   1. We are committed to safeguarding the privacy and accuracy of the personal data of our website visitors, service users and email recipients.
   2. This policy applies where we are acting as a Controller with respect to the personal data of our website visitors, service users, email recipients and personal data collected from public sources; in other words, where we determine the purposes and means of the processing of that personal data.
   3. This policy also applies where we determine the purpose and means of the processing jointly with our clients and other companies, or where we are acting as a Processor, working on behalf of our clients to process data as required by them. In this policy, “We”, “Us” and “Our” refer to Prospect Global Ltd – trading as Sopro.
   4. Any reference to a Data Subject means a natural person whose personal data is processed by us as a Data Controller, Joint Controller or as a Data Processor, in other words, you.
   5. Any reference to the GDPR applies to both the UK GDPR and EU GDPR. Likewise, any reference to EU countries will also apply to the UK. This will remain the case so long as the UK is subject to an adequacy decision by the EU. Should there be a conflict between the two, the version that grants data subjects the greatest protection will apply.
3. How We use Your personal data

   We want to be clear with you about how we use your data, so in this section we talk about the general categories of personal data that we may process and, in the case of personal data that we did not obtain directly from you, we’ll tell you where we got your data and the purposes for which we may process your data; finally, and very importantly, we’ll explain the legal bases of the processing which applies to us and you.

   The General Categories of Personal Data That We May Process:

   1. Usage Data. We may process data about your use of our website and services (“Usage Data”). The Usage Data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the Usage Data is Google Analytics as well as our analytics tracking system. This Usage Data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services, and tailoring any communication with you. We, of course, use this data to help us run our business as well as we can.
   2. Account Data. We may process your Account Data (“Account Data”). The Account Data may include your name, email address, company information, and other contact and other related information we may collect about you. The source of the Account Data is generally you or your employer. The Account Data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us [or your employer] and/or taking steps, at your request, to enter into such a contract. In some cases, we may also rely on Legitimate Interest as our lawful basis where we use your data for marketing purposes or in order to operate our business and improve our services.
   3. Service Data. We may process your personal data that are provided in the course of the use of our services (“Service Data”). The Service Data may include name, email address, telephone number, and other related information. The source of the Service Data is you or your employer. The Service Data may be processed for the purposes of providing our services and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
   4. Enquiry Data. We may process information contained in any enquiry you submit to us regarding goods and/or services (“Enquiry Data”). The Enquiry Data may be processed for the purposes of us offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent, which may be withdrawn by you at any time by contacting us, or contract and/or legitimate interest where your requests represent an invitation to send you information about our services.
   5. Notification Data. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“Notification Data”). The Notification Data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent, which may be withdrawn by you at any time by contacting us.
   6. Correspondence Data. We may process information contained in or relating to any communication that you send to us (“Correspondence Data”). The Correspondence Data may include your name, email address and the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The Correspondence Data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, business and communications with users.
   7. Public Data. We may process information found on public social networking profiles and other from other publicly available sources (“Public Data”). This data may include name, employment information, career information. education details, job title, and other relevant information. Public Data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you and/or your employer. The legal basis for this processing is our legitimate interests, namely the administration of our business, to develop our business, and in order for us to make a profit.
   8. Legal Claims Data. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure (“Legal Claims Data”). The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
   9. Professional Use Data. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice (“Professional Use Data”). The legal basis for processing Professional Use Data is our legitimate interests, namely the proper protection of our business against risks.
   10. Third Party Data. We may process any of your personal data where we purchase this data from a third party. This includes name, address, email, phone number, other contact details, employment details etc.. Where we purchase data, we will ensure that the supplier has the appropriate lawful basis in place and is GDPR compliant. We will also ensure that we have appropriate evidence of consent where necessary, or have an alternative appropriate lawful basis and GDPR compliance processes in place to allow us to use your data.

   In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4. Our Legitimate Interest
   1. Our lawful bases for processing include our Legitimate Interest to process your data. In this regard, we have carefully considered your rights and expectations of privacy and our rights, alongside the rights of our clients, to run our business. We have considered the impact on your privacy as a result of our processing of your data and completed a balancing assessment to consider the impact on the data subjects involved and also completed a Data Protection Impact Assessment to ensure we take appropriate precautions with all data. These Legitimate Interest and Data Protection Impact Assessments helped us ensure that the rights of the data subjects are not unduly impacted and that processing of data in this way is acceptable.
5. Source of your Personal Data
   1. We use a range of sources to provide our services, including public domain and social media sources. Our approach is based on carefully targeting business contacts with offers that we believe they will be interested in. We carefully select representatives from businesses and then only send relevant offers. Where we source data from other third parties, we will ensure these companies are GDPR compliant and that your rights are at all times protected.
6. Data sharing
   1. We don’t routinely sell or share your data with other companies other than in order to provide our services to them and to meet our obligations as a company. Sopro is a prospecting and lead generation company, where we have collected your data in order to provide our service to our clients, we share your data only with that specific client. Where this is the case, we will respect your right to be informed and ensure that you are given the option to opt-out of marketing at first contact and in all subsequent communications. The privacy policy of our client will include their contact details to ensure you are able to exercise your rights at any time.
   2. In addition, we may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries, together known as “Group Companies”) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
   3. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedures.
   4. We may also disclose your personal data to our suppliers, partners and other carefully managed third parties as required to operate our company and provide our services. Where this is the case, we will always ensure appropriate technical and administrative controls are in place.
   5. As you would expect, in addition to the specific disclosures of personal data set out above, we may disclose your personal data where such disclosure is necessary for compliance with a binding legal obligation.
7. International transfers of your personal data
   1. In this section we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (“EEA”). We, and our other Group Companies, have offices and facilities in the Republic of North Macedonia where your personal data may be processed. Transfers to the Republic of North Macedonia will be protected by appropriate technical and administrative safeguards included in our Terms of Contract for data processing agreed between us and our Republic of North Macedonia counterparts, which of course includes the standard clauses required under GDPR.
   2. Remember that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
   3. Our website contains links to external websites run by other organisations. This privacy policy applies only to our websites not those external websites that we link to, who will have their own privacy policies. We are not responsible for these external websites and their privacy policies and practices. In addition, if you linked to our website from an external site, we cannot be responsible for the privacy policies and practices of the owners and operators of that external website and recommend that you check the privacy policy of that external site.
8. Retaining and deleting personal data
   1. This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
   2. Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
9. Cookies
   1. By using our website and agreeing to this policy, you consent to our use of cookies, in accordance with the terms of our cookie policy.
10. Automated Processing
    1. We may use automated processing and decision making to verify your contact details and to determine whether to contact you as part of a prospecting campaign on behalf of our clients. This decision making is simply used to determine whether the campaign is likely to be of interest to you and to verify your contact details.
11. The rights of data subjects
    1. In this section we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
    2. Your principal rights under data protection law are:
       1. The right to be informed
       2. The right to access
       3. The right to rectification
       4. The right to erasure
       5. The right to restrict processing
       6. The right to object to processing
       7. The right to data portability
       8. Rights related to automated decision-making including profiling
       9. The right to complain to a supervisory authority; and
       10. The right to withdraw consent.
    3. The Right to be Informed. This is the right of Data Subjects to know details regarding the processing of their data and how we acquired their data, this information is included in this Privacy Policy.
    4. The Right to Access. You have the right to confirm as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data upon request and within one month of verification of your identity (we may extend the time within which we must provide the information by a further two months if the request is particularly complex, or if there are numerous requests and we will let you know if this is the case). The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
    5. The Right to Rectification. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. If the request is accepted by us, the rectification will be completed within one month (may be extended by us by a further two months if complex). We will use all reasonable endeavours to notify any third party with whom we have shared the data of any rectifications made.
    6. The Right to Erasure (also known as the “Right to be Forgotten”). In some circumstances you have the right to the erasure of your personal data without undue delay. However, there are exclusions to the right to erasure. We will use all reasonable endeavours to notify any third party with whom we have shared the data of any actioned erasure requests.
    7. The Right to Restrict Processing. In some circumstances you have the right to restrict the processing of your personal data. Where processing has been restricted, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. We will use all reasonable endeavours to notify any third party with whom we have shared the data of any restriction placed on the processing of your data.
    8. The Right to Object to Processing. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for certain tasks. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing is for the establishment, exercise or defence of legal claims.
    9. The Right to Data Portability. To the extent that the legal basis for our processing of your personal data is:
       1. consent; or
       2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract; and
       3. such processing is carried out by automated means.

       You have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

    10. Rights related to automated decision-making including profiling. We do not solely use automated decision making (including profiling) when processing your data, automated processing will be used to verify your contact details and determine if the campaign will be of interest to you. You have the right to object to decisions, should they be based purely on automated processing.
    11. Right to Complain. If you consider that our processing of your personal information infringes data protection laws, you should first contact us. If you are dissatisfied with the outcome, you have a legal right to lodge a complaint with a Supervisory Authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
12. Contacting us concerning the contents of this Privacy Policy
    1. If Your query relates to this Privacy Policy or should you wish to exercise one of Your Data Protection Rights as a Data Subject, you can contact us in the following ways:
       By post to Our registered office
       
       By email at: dpo@sopro.io
       
       By telephone on: +44 207 030 3340
       
       
    2. If you remain unsatisfied by our response you may complain to the Information Commissioners offices at the following address:
       Information Commissioner’s Office
       Wycliffe House
       Water Lane
       Wilmslow
       Cheshire
       SK9 5AF
       
       or
       www.ico.org.uk
       
13. Amendments to this policy
    1. We may update this policy from time to time by publishing a new version on our website.
    2. You should check this page occasionally to ensure you are happy with any changes to this policy.
    3. We may notify you of changes to this policy by email.

This policy was last updated on 1 March 2022

1. Introduction

   These terms and conditions apply between you, the User of this Website (including any sub-domains, unless expressly excluded by their own terms and conditions), and Prospect Global Ltd., the owner and operator of this Website. Please read these terms and conditions carefully, as they affect your legal rights. Your agreement to comply with and be bound by these terms and conditions is deemed to occur upon your first use of the Website. If you do not agree to be bound by these terms and conditions, you should stop using the Website immediately.

   In these terms and conditions, User or Users means any third party that accesses the Website and is not either (i) employed by Prospect Global Ltd. and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Prospect Global Ltd. and accessing the Website in connection with the provision of such services.

   You must be at least 18 years of age to use this Website. By using the Website and agreeing to these terms and conditions, you represent and warrant that you are at least 18 years of age.

2. Intellectual property and acceptable use
   • All Content included on the Website, unless uploaded by Users, is the property of Prospect Global Ltd., our affiliates or other relevant third parties. In these terms and conditions, Content means any text, graphics, images, audio, video, software, data compilations, page layout, underlying code and software and any other form of information capable of being stored in a computer that appears on or forms part of this Website, including any such content uploaded by Users. By continuing to use the Website you acknowledge that such Content is protected by copyright, trademarks, database rights and other intellectual property rights. Nothing on this site shall be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademark, logo or service mark displayed on the site without the owner’s prior written permission
   • You may, for your own personal, non-commercial use only, do the following:
     • retrieve, display and view the Content on a computer screen
     • print one copy of the Content
   • You must not otherwise reproduce, modify, copy, distribute or use for commercial purposes any Content without the written permission of Prospect Global Ltd..
3. Prohibited use
   • You may not use the Website for any of the following purposes:
     • in any way which causes, or may cause, damage to the Website or interferes with any other person’s use or enjoyment of the Website;
     • in any way which is harmful, unlawful, illegal, abusive, harassing, threatening or otherwise objectionable or in breach of any applicable law, regulation, governmental order;
     • making, transmitting or storing electronic copies of Content protected by copyright without the permission of the owner.
4. Links to other websites
   • This Website may contain links to other sites. Unless expressly stated, these sites are not under the control of Prospect Global Ltd. or that of our affiliates.
   • We assume no responsibility for the content of such Websites and disclaim liability for any and all forms of loss or damage arising out of the use of them.
   • The inclusion of a link to another site on this Website does not imply any endorsement of the sites themselves or of those in control of them.
5. Privacy Policy and Cookies Policy
   • Use of the Website is also governed by our Privacy Policy and Cookies Policy, which are incorporated into these terms and conditions by this reference. To view the Privacy Policy and Cookies Policy, please click on the following: https://sopro.io/legal/#privacy-policy and https://sopro.io/legal/#cookie-policy.
6. Availability of the Website and disclaimers
   • Any online facilities, tools, services or information that Prospect Global Ltd. makes available through the Website (the Service) is provided “as is” and on an “as available” basis. We give no warranty that the Service will be free of defects and/or faults. To the maximum extent permitted by the law, we provide no warranties (express or implied) of fitness for a particular purpose, accuracy of information, compatibility and satisfactory quality. Prospect Global Ltd. is under no obligation to update information on the Website.
   • Whilst Prospect Global Ltd. uses reasonable endeavours to ensure that the Website is secure and free of errors, viruses and other malware, we give no warranty or guaranty in that regard and all Users take responsibility for their own security, that of their personal details and their computers.
   • Prospect Global Ltd. accepts no liability for any disruption or non-availability of the Website.
   • Prospect Global Ltd. reserves the right to alter, suspend or discontinue any part (or the whole of) the Website including, but not limited to, any products and/or services available. These terms and conditions shall continue to apply to any modified version of the Website unless it is expressly stated otherwise.
7. Limitation of liability
   • Nothing in these terms and conditions will: (a) limit or exclude our or your liability for death or personal injury resulting from our or your negligence, as applicable; (b) limit or exclude our or your liability for fraud or fraudulent misrepresentation; or (c) limit or exclude any of our or your liabilities in any way that is not permitted under applicable law.
   • We will not be liable to you in respect of any losses arising out of events beyond our reasonable control.
   • To the maximum extent permitted by law, Prospect Global Ltd. accepts no liability for any of the following:
     • any business losses, such as loss of profits, income, revenue, anticipated savings, business, contracts, goodwill or commercial opportunities;
     • loss or corruption of any data, database or software;
     • any special, indirect or consequential loss or damage.
8. General
   • You may not transfer any of your rights under these terms and conditions to any other person. We may transfer our rights under these terms and conditions where we reasonably believe your rights will not be affected.
   • These terms and conditions may be varied by us from time to time. Such revised terms will apply to the Website from the date of publication. Users should check the terms and conditions regularly to ensure familiarity with the then current version.
   • These terms and conditions together with the Privacy Policy and Cookies Policy contain the whole agreement between the parties relating to its subject matter and supersede all prior discussions, arrangements or agreements that might have taken place in relation to the terms and conditions.
   • The Contracts (Rights of Third Parties) Act 1999 shall not apply to these terms and conditions and no third party will have any right to enforce or rely on any provision of these terms and conditions.
   • If any court or competent authority finds that any provision of these terms and conditions (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of these terms and conditions will not be affected.
   • Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
   • This Agreement shall be governed by and interpreted according to the law of England and Wales and all disputes arising under the Agreement (including non-contractual disputes or claims) shall be subject to the exclusive jurisdiction of the English and Welsh courts.
9. Prospect Global Ltd. details

   Prospect Global Ltd. is a company incorporated in England and Wales with registered number 09648733 whose registered address is 33 Wrotham Road,, Borough Green,, Borough Green, Sevenoaks,, Kent, TN15 8DD and it operates the website https://sopro.io/ . The registered VAT number is GB234026052.

You can contact Prospect Global Ltd. by email on ryan@sopro.io.

Sopro GDPR Compliance Statement

This statement sets out the operating procedures Sopro undertakes to ensure GDPR best practice is observed to the greatest extent possible, at all times.

1. What is GDPR?

   The General Data Protection Regulation (GDPR) is a legal framework that sets guidelines for the collection, storage, and processing of personal information from individuals who live in the European Union (EU).

   The Information Commissioner’s Office is the UK regulator dealing with the Data Protection Act 2018 and the General Data Protection Regulation and the Privacy and Electronic Communications (EC Directive) Regulations 2003 across the UK.

   The ICO are like the data protection police and we need to make sure we always keep on their good side. Our determination to be 100% GDPR and PECR compliance will do exactly that!

   It is important to take GDPR compliance very seriously, since the penalties for non-compliance are punitive and designed to be painful. You definitely don’t want to be on the receiving end of an ICO investigation or enforcement notice!

2. Sopro and GDPR compliance

   In addition to appointing a compliance officer to oversee our adherence to the rules, Sopro have engaged 3rd party compliance expertise to audit and advise on best practice. This investment enables us to assure clients that GDPR best practices are strictly observed wherever possible, at all times.

3. Sopro’s relationship with you

   To put this in the language of GDPR and the ICO:

   • We are Joint Controllers. Yes – Joint Controllers. Even though, as a service provider, we are essentially working for you, it is important to recognise that we are both responsible for deciding who to target, what data to collect, how the data is processed, what messages we send them and how their data will be collected, processed, and stored. This decision is pretty fundamental to how we operate so if you have any questions let’s talk!
   • Just to make all our lives easier we have incorporated a comprehensive Data Sharing Agreement within Sopro’s standard Terms of Service. This sets out how we work together as Joint Controllers and how we support each other if we ever receive a GDPR request.
4. Is Sopro’s marketing activity compliant?

   Let’s look at this carefully. Sopro’s services are designed and offered solely to help businesses promote to other businesses. I.e. B2B marketing only. In which case PECR allows email marketing provided material is relevant and we and allow the recipient to opt-out of future emails. In this respect Sopro is naturally compliant. Now for GDPR, GDPR always applies and actually applies to all aspects of collection, storage, and processing of data. Sopro has been designed to be compliant and has established technical and operational systems to make sure this is the case. For example, before launching new client activity, Sopro conducts an in-depth assessment to establish if the product or service, combined with the proposed targeting, meets the criteria for GDPR and PECR compliant business to business (B2B) marketing. A key part of this assessment is called the Legitimate Interest Assessment (LIA), we have completed a LIA for us and also a standard LIA for each of our clients. We have also created a standard Privacy Policy update for client use as needed, this includes all the relevant clauses you need plus references to Sopro to make everything clear to the data subject – just let us know if you need a copy of any of these.

   Want to know more about how Legitimate Interest applies?

   If Sopro determines that your planned B2B prospecting activity does not meet the criteria for Legitimate Interests within the scope of GDPR or if your approach would breach some other part of the regulations [including PECR] then we cannot support the activity within any regions subject to GDPR.

   In the context of our Services, Legitimate Interest is the relevant lawful basis for processing as defined in GDPR. GDPR sets out a number of permissible circumstances (or categories) under which Personally Identifiable Information (PII) can be stored and processed, the most appropriate category in the case of most B2B marketing is Legitimate Interests. This link explains the Legitimate Interests basis for storing and processing PII: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/legitimate-interests/ To ensure client activity falls into this category, prior to engaging, we will carry out a full Legitimate Interests Assessment (LIA) with each new client. Essentially the LIA is a questionnaire containing a series of questions about your scenario. There are 3 areas that need to be satisfied for Legitimate Interests to be used as a basis for processing PII:

   • Identify a legitimate interest – The legitimate interest can be your own interests or the interests of third parties. They can include commercial interests, individual interests or broader societal benefits. The data processing is generally in your interests – whether it be to increase market share, increase brand awareness, or engage business leaders.
   • Show that the processing is necessary to achieve it – Can the same result be achieved differently? Core to the Sopro service is the efficiency and constant drive to be the most cost-effective sales channel which we believe cannot be replicated using other methods.
   • Balance it against the individual’s interests, rights and freedoms – Would the individual expect their data to be used in this way? Would an individual who lists publicly their role within a company expect to be contacted about services that may help that company or their department within the company? No data processing may replace or infringe the individuals interests or cause unjustified harm
5. LIA Failures

   If Sopro determines that your planned B2B prospecting activity does not meet the criteria for Legitimate Interests within the scope of GDPR or if your approach would breach some other part of the regulations [including PECR] then we cannot support the activity within any regions subject to GDPR.

6. Rights of Individuals
   • Privacy Policy – All messages sent will contain a link to a privacy policy that explains to the user exactly what their rights are as well as the type of data that is held about them and by who. Sopro will provide a template privacy policy or review your existing one to ensure it meets the required standard. A link to our Privacy Policy which is based upon this template is here: https://sopro.io/privacy-policy/ This standard privacy link would typically be contained in the email signature of any outbound messaging, in the case of messaging as part of client campaign activity, the privacy link will be that of our client’s own privacy policy.
   • Opting Out & Exclusion Lists – All recipients are able to opt out easily to prevent further email communication being received. All replies to prospecting emails are logged and those prospects are added to your campaign exclusion list within 24 hours. Sopro allows import of existing exclusion lists in advance of campaign activity. Exclusions can be submitted in the form of individual email addresses or full domains and will prevent communications being issued to those email addresses or domains listed.
   • Subject Access Requests – All individuals have the right to request a copy of all data you hold on them. To support this data subjects can email any SAR requests to dpo@sopro.io and we will return this data within 72 hours.
   • Right to be Forgotten – All individuals have the right to have some or all of their data removed (to be ‘forgotten’) at any time.. A conflict does arise in removing or forgetting an email address whilst at the same time keeping this address on an exclusion list to prevent future mailings. Where we have removed data, we will move the email address to a separate exclusion list, encrypted using a one-way hashing algorithm (SHA1), ensuring we are able to prevent any future messages being sent to the customer whilst continuing to honour their right to be forgotten.
7. PECR and sending of B2B messages

   Whilst GDPR controls the storage and processing of personal data in the UK, sending messages is regulated under the Privacy and Electronic communications Regulations (PECR). This is very clear as to the requirements on business communication: “You can email or text any corporate body (a company, Scottish partnership, limited liability partnership or government body). However, it is good practice – and good business sense – to keep a ‘do not email or text’ list of any businesses that object or opt out and screen any new marketing lists against that.” https://ico.org.uk/for-organisations/guide-to-pecr/electronic-and-telephone-marketing/electronic-mail-marketing/

8. Sopro Employees

   All Sopro employees undergo GDPR, PECR and general compliance training, this covers the GDPR rule set in detail, the relevance and impact of those rules on Sopro and our clients, and the steps we take to ensure best practice is observed at all times. We also make clear the consequences (I.e. penalties) associated with failure to meet the strict GDPR standards.

9. Client responsibility

   Whilst Sopro continues to take extensive measures to ensure best practice with respect to GDPR and PECR across all client activity, clients should take note that responsibility for compliance vests (in different forms) with each party. Sopro cannot be abreast of the constantly evolving regulatory frameworks in all countries at all times, as such it is important that you, as the client, have knowledge of your local regulatory climate and ensure your business operates within the relevant regulatory frameworks.

10. In Summary:

    Sopro has worked hard to develop a compliant platform providing innovative marketing services and technology for our clients and at all times respecting the rights of the data subjects whose information we collect. Compliance is now part of what we do and ongoing due-diligence is just part of how we operate. Compliance is central to our identity as a business.

Sopro CAN-SPAM and CCPA compliance statement

This statement sets out the operating procedures Sopro undertakes to ensure CAN-SPAM and CCPA best practice is observed to the greatest extent possible, at all times.

1. What is CAN-SPAM?

   In place since 2003, the primary regulation governing B2B sales in the US is the Controlling the Assault of Non-Solicited Pornography And Marketing Act of 2003 (CAN-SPAM). As email marketing started to gain momentum in the early noughties, this act was introduced to keep things in check. Read the rules of CAN-SPAM.

2. What is CCPA?

   The California Consumer Privacy Act (CCPA) was introduced in 2020, and only applies if you’re sending sales emails to contacts within California. It gives Californians the right to know exactly what personal data companies are collecting about them.

   Under the CCPA, Californians are able to access – and request the deletion of – any personal data that companies have collected on them.

   The CCPA applies if you meet the following requirements:

   • Your company has a gross annual revenue of more than $25 million
   • Your company gets more than 50% of its annual revenue from California residents
   • Your company buys, sells, or receives personal information of more than 50,000 California residents

   Under CCPA, Californian recipients have the right to request:

   • What kinds of personal data your company has collected on them
   • If their personal information has been sold or shared – and who has it (this also means informing people of if you’ve had a breach involving their data)
   • That their personal information is not sold
   • The deletion of the personal information (AKA the right to be forgotten)
   • Not be discriminated against for exercising their rights under CCPA
3. Sopro and CAN-SPAM/CCPA compliance

   In addition to appointing a compliance officer to oversee our adherence to the rules, Sopro has engaged 3rd party compliance expertise to audit and advise on best practice. This investment enables us to assure clients that CAN-SPAM and CCPA best practices are strictly observed wherever possible, at all times.

4. Sopro’s relationship with you

   When it comes to CAN-SPAM and the CCPA, we’re joint controllers. Even though we’re working for you as a service provider, it’s important to recognise that we’re both responsible for: deciding who to target, what data to collect, and how that data is collected, processed, and stored.

   We’ve also incorporated a comprehensive Data Sharing Agreement within Sopro’s standard Terms of Service - just to make everything easier. This agreement sets out how we work together as Joint Controllers and how we support each other if we ever receive a data request.

   This decision is fundamental to how we operate, so please ask if you have any questions!

5. Is Sopro’s marketing activity compliant?

   Of course! Compliance is built into everything we do at Sopro - our business wouldn’t be able to operate without it.

   Sopro’s services are designed and offered solely to help businesses promote to other businesses (i.e. B2B marketing only). We ensure that the email marketing provided material is relevant and allow the recipient to opt out of future emails. Sopro has also established technical and operational systems to ensure all aspects of data collection, storage, and processing are compliant.

   Before launching new client activity, we conduct an in-depth assessment to establish if the product or service, combined with the proposed targeting, meets the criteria for compliant business to business (B2B) marketing. A key part of this assessment is called the Legitimate Interest Assessment (LIA). We also have a standard privacy policy update for clients to use as needed, which includes all the relevant clauses plus references to Sopro to make everything clear to the data subject. Just let us know if you need a copy of any of these.

6. Rights of individuals

   Privacy Policy – All messages sent will contain a link to a privacy policy that explains to the user exactly what their rights are as well as the type of data that is held about them and by who. Sopro will provide a template privacy policy or review your existing one to ensure it meets the required standard. Here’s a link to our privacy policy: https://sopro.io/privacy-policy/. This standard privacy link would typically be contained in the email signature of any outbound messaging, in the case of messaging as part of client campaign activity, the privacy link will be that of our client’s own privacy policy.

   Opting out and exclusion lists – All recipients are able to opt out easily to prevent further email communication being received. All replies to prospecting emails are logged and those prospects are added to your campaign exclusion list within 24 hours. Sopro allows import of existing exclusion lists in advance of campaign activity. Exclusions can be submitted in the form of individual email addresses or full domains and will prevent communications being issued to those email addresses or domains listed.

   Subject access requests (SAR) – All individuals have the right to request a copy of all data you hold on them. To support this data subjects can email any SAR requests to dpo@sopro.io and we will return this data within 72 hours.

   Right to be forgotten – All individuals have the right to have some or all of their data removed (to be ‘forgotten’) at any time. A conflict does arise in removing or forgetting an email address whilst at the same time keeping this address on an exclusion list to prevent future mailings. Where we have removed data, we will move the email address to a separate exclusion list, encrypted using a one-way hashing algorithm (SHA1), ensuring we are able to prevent any future messages being sent to the customer whilst continuing to honour their right to be forgotten.

7. Sopro employees

   All Sopro employees undergo both general and region-specific compliance training, this covers the CAN-SPAM and CCPA rule set in detail, the relevance and impact of those rules on Sopro and our clients, and the steps we take to ensure best practice is observed at all times. We also make clear the consequences (i.e. penalties) associated with failure to meet the strict standards.

8. Your responsibility

   Whilst Sopro continues to take extensive measures to ensure best practice with respect to CAN-SPAM and CCPA across all client activity, clients should take note that responsibility for compliance rests (in different forms) with each party. Sopro cannot be abreast of the constantly evolving regulatory frameworks in all countries at all times, as such it is important that you, as the client, have knowledge of your local regulatory climate and ensure your business operates within the relevant regulatory frameworks.

9. In summary

   Sopro has worked hard to develop a compliant platform providing innovative marketing services and technology for our clients and at all times respecting the rights of the data subjects whose information we collect. Compliance is part of what we do and ongoing due diligence is core to how we operate.