A Modern Company with Good Old Fashioned Values 
How do we source our data? 
Listbrokers business data is pooled from a variety of sources including directory information and Companies House data; together with desk, telephone and web research. Aggregating data from a number of sources creates a larger file, and also allows for greater verification. 
What Personal Information do we collect? 
As a business data provider, the amount of personal information we hold is limited to: 
Named contacts in corporate entities. 
Personal email addresses in corporate entities. 
Contact details, postal address and telephone numbers of sole traders and traditional partnerships which are treated as personal information under GDPR. 
The suppliers who contribute to our data pool also operate on legitimate interest, and our grounds for processing are based on the following impact assessment and any selections made from our partners files ensure that communications sent to end users are relevant to their industry and/or job function. 
Our suppliers make it clear with individuals why we/they need their data at the point of collection, and they have a reasonable expectation that the information that they provide to directory companies and similar entities will be used for direct marketing purposes. 
Business-to-business email communications fall into two categories as follows: 
Emails to the employees of corporate entities – limited companies, publically limited companies, limited liability partnerships and government departments (including schools and hospitals) can be emailed without consent. Individuals must be given a clear and easy meansof opting-out from future communications. 
Emails to sole traders and traditional partnerships are treated in the same way as consumer data, and opt-in consent must be gained for these contacts.In the light of the final point above, Thinking Data Limited only provides emails for corporate bodies. 
What restrictions are there on the use of any database for marketing? 
Tthe following broad principles apply: 
All communications must be relevant and proportionate. 
All communications should clearly identify the end-user of the data and must contain a clear opportunity to opt-out from future correspondence. 
Keep data up to data through frequent – but not intrusive – contact, and record any changes. 
All requests to opt out must be honoured. 
How is the data cleaned? 
The files are updated and cleaned on a monthly basis to ensure that maximum deliverability is maintained. Data is cleaned against standard industry suppression files, and telephone numbers are run against the Telephone Preference Service and the Corporate Telephone Preference file prior to supply. 
Listbroker respect the rights of individuals to have their details removed from our active file at any time. We remove any individuals who have indicated they no longer wish to receive direct marketing material. Where clients have taken data from us on a lease basis we will provide updates of those individuals who have requested removal in order for them to keep their files current. 
Data subject access and removal requests 
Subject access requests and requests for removal/suppression from the file should be addressed to the list owner to opt-out must be honoured 
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