PRIVACY_NOTICE.md

Rama main · réplica de lectura del repositorio original.

# Privacy Notice — OpenOutreach Contacts Store

_This notice explains how the central contacts store operated at `hub.openoutreach.app` collects, uses, and discloses personal data. It is published for the people whose work contact details may appear in the store and for the operators who contribute to and read from it._

## Who operates the store

The store is operated by the maintainer of the open-source project **OpenOutreach**. It holds two kinds of record pooled across the OpenOutreach operator network: **work email addresses**, so a contact one operator has already resolved can be served to another, lowering each operator's email-finder spend as coverage grows; and **professional profiles** returned by operators' prospect searches, so the pool of business contacts does not depend on any one data provider staying available.

Throughout this notice, an **operator** is a person running a self-hosted OpenOutreach instance that contributes to and reads from the store.

## What data is in the store

**Email records.** For a person whose work email an operator resolved, the store holds:

| Field | Example | Why it is kept |
| --- | --- | --- |
| Profile identifier | `https://…/in/jane-doe` | A stored profile URL — held as an opaque key, never fetched — used for contribution and resolution. |
| Country code | `in` | Drives the geographic exclusion below. |
| Work email address(es) | `jane@acme.com` | The contact detail the store exists to serve. |

**Profile records.** For a person who appeared in an operator's prospect search, the store holds:

| Field | Example | Why it is kept |
| --- | --- | --- |
| Profile identifier | `https://…/in/jane-doe` | The same opaque key as above. |
| Country code | `in` | The country the search targeted; drives the geographic exclusion below. |
| Professional fields | name, headline, job title, seniority, industry, state/region and country, employer name, domain and industry | What the data provider returned for the search, kept so a person can be judged against a business's ideal customer without searching the provider again. |

With a profile record the store also holds a **384-dimension numeric profile vector** (an "embedding"): a compact mathematical representation of the professional fields, **computed on the operator's own machine**, used to rank people by how closely they resemble a business's ideal customer. Email records sent by older versions of the software may carry one too. It records which operator token sent each record (provenance), which software build sent it, and when.

**What is _not_ collected:** no phone number, postal address, personal email, photo, or free-text description of the employer; no special-category data.

Only **professional, business-context (B2B)** contact data is in scope. Consumer contact details and any special-category data are out of scope and are not collected.

## Geographic exclusion (who is _not_ in the store)

Any person located in the **EU/EEA, the UK, or Switzerland** — or whose location cannot be determined — is **never written to the store**. This exclusion runs authoritatively on the server, at the point data enters the store, regardless of what a contributing client sends.

## How data is collected

Data reaches the store from OpenOutreach operators, at two moments:

- **Email records** arrive **after an operator's paid email-finder lookup returns a verified work email.**
- **Profile records** arrive **whenever an operator's prospect search returns a page of results.** The source of those results is the operator's own account with the B2B data provider **BetterContact** (its Lead Finder search), which compiles publicly available professional information.

The maintainer does **not** scrape any website, buy data, or run searches of its own to populate the store; it is filled only by operators' own searches and lookups, subject to the geographic exclusion above.

## How data is used and disclosed

- **Resolution (disclosure to operators).** An operator may query the store for a person's email before paying a finder service. A match is returned to that operator. This means **an email in the store may be disclosed to operators other than the one who contributed it**, so they can carry out business-to-business outreach. This is a disclosure of personal data to a third party — comparable to commercial B2B contact-data providers. The data is **not sold**.
- **Finding prospects (profile records).** Profile records are used to find people who match a business's description of its customers, for the maintainer's own lead-list service and for operators, without searching the data provider again. Profile records are **not** served to operators through any read endpoint today.
- **No consumer-facing purpose.** The store is not used for advertising to consumers or any consumer-facing purpose.

## Legal basis

Where data-protection law applies, the store relies on **legitimate interest** (Art. 6(1)(f) GDPR and equivalents) for **resolution** (serving a known work email) and for **finding prospects** (profile records): **facilitating business-to-business professional communication using professional contact data**, by disclosing existing professional contacts to operators who carry out their own outreach and by identifying professionals who match a business's customer profile. This does not involve profiling for the store's own marketing, automated decision-making with legal or similarly significant effects, or the **sending** of marketing email by the store — operators send from their own infrastructure and are responsible for their own sends and the anti-spam law that governs them.

A legitimate-interest assessment balances that interest against the rights of the people in the store. The safeguards that keep the balance reasonable are: the **geographic exclusion** (people located in the EU/EEA, UK, or Switzerland — or whose location cannot be determined — are never written to the store, so they are never in the searchable set); **data minimisation** (professional fields only — no phone, address or personal contact detail, and the provider's free-text employer description is dropped before it is sent); the **B2B-only, professional-context** scope, with no special-category and no consumer data; and the **objection and suppression** rights below, honoured across the whole store. Operators contributing or resolving data may be controllers or joint controllers and carry their own responsibilities.

## Your rights and how to exercise them

If your work email or professional profile is in the store, you may request **access, correction, or erasure**, and you may **object** to the processing. To exercise any of these, or to be excluded from the store entirely:

- **Suppression / opt-out:** a request submitted to `POST /api/v2/suppress/` (or via the contact route below) removes the record and **blocks the email and public identifier from re-entering** the store. Suppression is honoured across the whole store, including against future re-contribution.

Suppression is recorded immediately as a request; the suppressed identifiers are excluded from the data served to operators, and the underlying records are erased on the store's maintenance cycle.

## Retention

Email records persist while they remain useful for resolution and are refreshed when re-contributed. Profile records persist while they remain useful for finding prospects; each is dated, and a person who appears in a later search is stored again with that later date. A suppressed record is removed from served results immediately and erased from source on the maintenance cycle, and a suppressed profile identifier is refused at entry from then on.

## Contact

Questions, complaints, or data-subject requests: open an issue on the OpenOutreach repository or contact the maintainer at the address published there. If your country has a data-protection regulator (for example the AEPD in Spain, the ICO in the UK, or another EU/EEA supervisory authority), you may also lodge a complaint directly with that regulator.

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_This notice is published in good faith and may be updated as the store evolves; material changes will be reflected here._