ZendoLead and Our Commitment to the GDPR

Article 1: Introduction and Commitment

Intellixio (operating ZendoLead) is committed to complying with the General Data Protection Regulation ((EU) 2016/679) ("GDPR") and relevant UK and Swiss data protection laws. As a B2B lead intelligence platform, we understand that data privacy is paramount.

Article 2: Our Role - The "Controller" Distinction

Under GDPR, it is vital to define who controls the data. Our model is a Controller-to-Controller relationship.

• Intellixio is the Data Controller: We act as the Data Controller for the ZendoLead Database. We independently determine the means and purposes of collecting business contact information.
• You (The Customer) are an Independent Controller: When you purchase credits and "Unlock" a lead, a copy of that data is transferred to you. From that moment, you become an independent Data Controller.

Article 3: Lawful Basis for Processing

• Consent (Article 6(1)(a)): For leads collected via voluntary Website Form submissions.
• Legitimate Interest (Article 6(1)(f)): For data aggregated from public business sources. We conduct LIA to ensure we don't override fundamental rights.
• Contract (Article 6(1)(b)): To process your (Customer) account data.

Article 4: Transparency and Article 14

GDPR Article 14 requires controllers to notify individuals when data is collected indirectly. Given the scale of our database, notifying every professional individually would involve a disproportionate effort (Article 14(5)(b)). Instead, we maintain public transparency via our Privacy Policy and offer an easy opt-out mechanism.

Article 5: Data Minimization and Accuracy

• Minimization: We limit collection to professional business data (Name, Job Title, Business Email, Phone).
• Accuracy: We employ automated validation to check email/phone status and purge decayed data.

Article 6: International Data Transfers

We utilize the European Commission's Standard Contractual Clauses (SCCs) for transfers of data to third countries (like Bangladesh).

Article 7: Data Subject Rights

• Right to Object / Opt-Out: Any individual can request removal. We maintain a suppression list.
• Right to Access & Erasure: Individuals may request a copy or deletion of their data.

Article 8: Contact Our Data Protection Officer