Privacy notice for business outreach

1. Who we are (Art. 14(1)(a))

Fröba Sales Solutions UG (haftungsbeschränkt), Johann-Nikolaus-Zitter-Straße 31, 96317 Kronach, Germany. Registered at Amtsgericht Coburg, HRB 7638. Managing Director: Kevin Fröba.
Email: hello@motionspec.dev · Phone: +49 151 61045255

2. Data protection officer (Art. 14(1)(b))

We are not required to appoint a data protection officer and have not appointed one. For any data protection matter, contact us at hello@motionspec.dev.

3. Why we process your data, and on what legal basis (Art. 14(1)(c))

Purpose: to contact you with a business proposal relating to motion and accessibility characteristics we measured on your company’s public website, and to follow up at most three times.
Legal basis: Article 6(1)(f) GDPR — our legitimate interests.

4. Our legitimate interests (Art. 14(2)(b))

Acquiring business customers through targeted, relevant direct contact, and the continued commercial viability of a small company. We assessed these interests against your rights and freedoms before contacting you, and we limited what we do accordingly: we contact you at a business address only, we send at most four messages, we do not build a profile about you, and we stop the moment you tell us to.

5. What data we hold (Art. 14(1)(d))

Business contact details (name, role, business email address), your employer’s name, domain and website address, the country or state in which the company operates, the company’s type and sector, publicly available professional profile information, the technology detected on the company’s website, and the results of our automated analysis of that website.

We do not process special categories of data (Article 9 GDPR). We do not process data about your private life.

6. Where we got it (Art. 14(2)(f))

From publicly accessible sources: your company’s website, its legal notice or imprint, its contact page, or a public professional profile. We record the specific source for every record we hold, and we will tell you exactly which one applies to you if you ask. We do not buy contact lists, and we do not use data from profiles whose visibility is restricted.

7. Who receives your data (Art. 14(1)(e))

Our email delivery provider, Foo Monk, LLC dba Instantly.ai, 30 N. Gould St., Ste. R, Sheridan, Wyoming 82801, USA, acting as our processor under a data processing agreement. We do not sell your data, share it for anyone else’s purposes, or enrich it through third parties.

8. International transfers (Art. 14(1)(f))

Your data is transferred to the United States. There is no adequacy decision covering this transfer: our provider is not certified under the EU-US Data Privacy Framework. The transfer is therefore based on the Standard Contractual Clauses adopted by the European Commission (Implementing Decision (EU) 2021/914, Module Two), together with additional safeguards including data minimisation — we transfer only what is needed to deliver the message. We have carried out and documented a transfer impact assessment.

You may request a copy of the Standard Contractual Clauses by emailing hello@motionspec.dev.

9. How long we keep it (Art. 14(2)(a))

12 months from the date we collected it, after which we delete it.

One exception: if you unsubscribe or object, we keep your email address on a suppression list indefinitely. We do this for one reason only — so that we never contact you again. That list is used for nothing else, is never sold or transferred, and contains only what is needed to recognise and block your address.

10. Your rights (Art. 14(2)(c), (e))

You have the right to:

• object to this processing at any time — this right is absolute for direct marketing under Article 21(2) GDPR. You do not need to give a reason, and we must stop immediately;
• request access to the personal data we hold about you (Article 15);
• have inaccurate data corrected (Article 16);
• have your data erased (Article 17);
• have processing restricted (Article 18);
• receive your data in a portable format (Article 20);
• lodge a complaint with a supervisory authority (Article 77).

The fastest way to object is the unsubscribe link in our email. You can also email hello@motionspec.dev — either works, and both take effect within 24 hours.

Our lead supervisory authority is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 18, 91522 Ansbach, Germany. If you are in the United Kingdom, you may also complain to the Information Commissioner’s Office (ICO).

11. Automated decision-making (Art. 14(2)(g))

Our analysis is automated, but it examines your company’s website, not you. We do not make automated decisions producing legal effects concerning you or similarly significantly affecting you within the meaning of Article 22 GDPR. No profile is built about you as an individual.

12. Is this required?

Providing data is not a statutory or contractual requirement, and you are under no obligation to respond. Not responding has no consequences for you.

A German translation of this notice is available at motionspec.dev/de/privacy-outreach.