Business outreach privacy notice

Last updated: 17 October 2026.

This notice covers KELYNTIS business prospecting, investor outreach and related correspondence. It does not describe the separate website file-audit service. Please do not send confidential datasets or personal records in response to an introductory email.

Who is responsible?

Nico Clerckx, responsible for the KELYNTIS project in Belgium, is the controller. Contact address: Dendermondsesteenweg 329, 9000 Gent, Belgium. Email: operations@kelyntis.com. Website: kelyntis.com. KELYNTIS is a project, not a separately registered company. SMART is not represented as our legal entity or processor.

Data and sources

We use organisation names, business domains, countries, business contact routes, publicly provided professional contact details, source references and assessments of commercial relevance. Sources include official company websites, public business directories and our existing correspondence. We record contact history, replies, delivery failures and objections to prevent unwanted or duplicate contact. Correspondence may contain a person's name or other information they choose to provide. Our server stores message identifiers and classification metadata; Gmail holds the messages.

Purpose and legal basis

Our purpose is to introduce relevant data-quality services or discuss suitable investment opportunities, answer enquiries and manage existing conversations. Where personal data is involved, narrowly targeted professional prospecting is assessed under legitimate interests (GDPR Article 6(1)(f)): developing relevant business relationships, balanced against the person's privacy and reasonable expectations. This is not blanket permission to email anyone. Electronic-marketing rules, recipient type, country, relevance and objections must also be checked. Where consent is required, contact remains blocked unless it is established. Requested pre-contractual steps may rely on Article 6(1)(b) where applicable; otherwise business correspondence is assessed under legitimate interests. We retain necessary suppression information to respect objections and prevent renewed contact.

Service providers and international processing

Hetzner hosts the outreach database and server backups. The current server reports availability zone nbg1-dc3 (Nuremberg, Germany). A Hetzner processing agreement was confirmed concluded on 17 October 2026. Google Gmail handles email and related processing. The controller confirmed acceptance of Google's Cloud Data Processing Addendum by operations@kelyntis.com on 16 October 2026. Authorised project administration may also involve local working copies.

Google and its subprocessors may process data outside the European Economic Area; we do not claim EU-only storage. Google's contractual transfer provisions describe the applicable safeguards, including standard contractual clauses where required. See the Google processing terms and Workspace subprocessor list. Details or copies of applicable safeguards can be requested through our contact address. Separate website audit providers are not part of this Gmail sending route.

Retention

• Never-contacted prospects: 12 months from collection.
• Prospects without a response: 12 months from the last contact.
• Commercial correspondence: 24 months from the last contact.
• Customer records: the applicable contractual and legal period.
• Objections and opt-outs: only the information necessary for as long as needed to prevent renewed contact.
• Outreach backups: a maximum of 30 days unless a documented legal obligation requires otherwise.

Scheduled cleanup currently covers expired, unreferenced prospect records and dedicated outreach backups. Records linked to correspondence require separate review to preserve objections and necessary history. Gmail deletion is handled separately and is not automatic. These are retention-policy periods, not a claim that every copy is automatically erased at the expiry instant. Legacy shared backups and linked records remain subject to review; the current automation does not delete other projects' data.

Your choices and rights

You may object to direct marketing at any time, without charge, by replying “unsubscribe” or contacting operations@kelyntis.com. You do not have to give a reason. We stop further marketing and retain necessary suppression information. You may request access, correction, deletion, restriction or, where applicable, portability. Consent may be withdrawn where it is the basis for processing. Providing information is voluntary; without contact details we may be unable to respond. You may complain to the Belgian Data Protection Authority or your competent supervisory authority.

Automation and security

Software can select prospects, prepare personalised drafts and check sending conditions. This is not a decision determining a person's legal rights or access to credit or employment. Missing evidence blocks release. The mailing process uses exclusions, sending limits and stop controls. The logo is embedded in the email rather than loaded from a tracking URL. This privacy page has no forms, analytics scripts or third-party images; network information is necessarily processed to serve the HTTPS request.

Nederlandstalige vragen, inzageverzoeken en afmeldingen zijn welkom via operations@kelyntis.com. Deze verklaring betreft zakelijke prospectie en correspondentie, niet de afzonderlijke bestandsauditdienst.