Legal

Privacy notice for business outreach

You received an email from me without having heard of me first. That means you did not give me your details yourself – so I have to tell you, unprompted, where they came from and what I do with them. That is what Article 14 GDPR requires. This page is exactly that, kept short.

1. Who processes your data

KONO Digital · Louis Konopatzki
Avenida Pádua 3, 2A 1B, 1800-294 Lisbon, Portugal
Tax number (NIF) 329332449
Email: louis@kono-digital.de

KONO Digital is a sole proprietorship. There is no data protection officer, because the statutory thresholds for appointing one are not met. I am responsible myself, at the address above.

2. What data I process

• the company's name and address, its legal form and registration number
• the general business email address and the website
• where the company publishes it itself, the name of a person authorised to represent it
• my own notes on your website – measurements such as load time, mobile rendering or encryption
• whether, when and with what content I wrote to you, and whether you replied or objected

I do not process special categories of personal data within the meaning of Article 9 GDPR.

3. Where the data came from

Exclusively from publicly accessible sources, in this order:

• from your own website – contact page, legal notice or footer. The address I wrote to has to appear there; that is my own rule, and in several countries it is also the condition that makes writing to you lawful at all.
• from public company registers, to verify legal form and registration number: the Kamer van Koophandel (Netherlands), the Companies Registration Office (Ireland), the Registo Comercial and public company-information services (Portugal).
• from a technical retrieval of your website – my server visits it the way any visitor would and measures publicly visible characteristics.

I do not buy address lists. I do not use addresses from business directories, from social networks or from data brokers, and I do not guess address patterns such as firstname.lastname@.

4. Purpose and legal basis

Purpose: to offer you the design or rebuild of your website – once, with a specific reason measured on your actual site.

Legal basis: Article 6(1)(f) GDPR – legitimate interests. My interest is initiating a business relationship; Recital 47 GDPR expressly names direct marketing as a possible legitimate interest.

National law applies in addition to the message itself:

• Netherlands: Article 11.7(3) Telecommunicatiewet – permitted to legal persons (rechtspersonen), provided the address was published by the company itself for the purpose of being contacted and every message carries a free and simple way to opt out.
• Ireland: Regulation 13 S.I. 336/2011 – permitted to corporate subscribers on an opt-out basis, provided the message relates to their business activity.
• Portugal: Article 13.º-A(2) Lei n.º 41/2004 – permitted to legal persons on an opt-out basis.

I do not write to sole traders, to partnerships without separate legal personality, or to private email addresses.

5. My balancing test, set out openly

A legitimate interest requires that your interests do not override mine. Here is how I have narrowed it:

• I write to business role addresses your company published itself so that it could be contacted. Receiving business mail is what they exist for.
• The message relates to your business activity and names a specific, verifiable finding about your website – not general advertising.
• It stops at three messages: one first contact and at most two reminders. After that I stop of my own accord.
• Every message carries an opt-out link that works without signing in and without replying to me, plus this notice.
• I do not pass the data on and I do not build profiles.

6. Who else sees the data

Nobody, apart from the technical providers that make the operation possible: the website and outgoing mail run at Hostinger International Ltd. on servers inside the European Union, as a processor under Article 28 GDPR. No transfer to third countries outside the EU takes place. There is no sale, no disclosure to third parties, no advertising networks.

7. How long I keep the data

• No reply: deleted at the latest twelve months after the last message I sent you.
• You decline: deleted at the latest six months later.
• You object or opt out: your email address and your company domain stay on a suppression list permanently. That is not a contradiction of deletion but its precondition: it is the only way I can guarantee you are never written to again. That list holds nothing but the address, the date and the note "objection".
• An engagement follows: then the retention periods of contract and tax law apply.
• Send log: I record when which message went to whom, because I have to be able to demonstrate this (in Portugal expressly under Article 13.º-B(1) Lei n.º 41/2004). The log survives the deletion of the rest of the record.

8. Your rights

• access to the data held about you (Article 15 GDPR)
• rectification of inaccurate data (Article 16 GDPR)
• erasure (Article 17 GDPR) and restriction of processing (Article 18 GDPR)
• data portability (Article 20 GDPR)
• objection to the processing (Article 21 GDPR) – for direct marketing, without giving reasons and with immediate effect
• lodging a complaint with a supervisory authority (Article 77 GDPR)

An informal email to louis@kono-digital.de is enough to exercise any of these. It costs you nothing.

You may complain to the supervisory authority where you live or work. As a controller established in Portugal, mine is the Comissão Nacional de Proteção de Dados (CNPD), Av. D. Carlos I, 134 – 1.º, 1200-651 Lisbon. In the Netherlands it is the Autoriteit Persoonsgegevens in The Hague; in Ireland the Data Protection Commission in Dublin.

9. No automated decision-making

There is no automated decision-making, including profiling, within the meaning of Article 22 GDPR. The technical measurement of your website produces a score; whether and what I write to you is then my own decision.

10. How to stop me

Fastest through the opt-out link – one click, effective immediately, permanent. An informal reply to my email works just as well; one word is enough and I do not need a reason.

General privacy policy of this website · Legal notice

Last updated: 29 August 2026. This English version is provided for your convenience; the German version at kono-digital.de/datenschutz-akquise/ is the legally binding one.