Grounds for Processing Personal Data

This document outlines our legitimate grounds for processing personal data. Please read it in conjunction with our Privacy Policy.

Our purposes of processing personal data for marketing

We process personal data for marketing when:

  • We discover a company providing a product or service that aligns with our style of outbound marketing.
  • We believe we can provide genuine value to that company, we contact relevant individuals such as the owners, founders, the CEO, or other relevant decision makers. We contact them using a blended approach of email, telephone, letter, LinkedIn, and other social media platforms such as, but not limited to, Twitter. The data we hold is not sensitive data as determined by the GDPR. This data is limited to:
    • First name, Last name, Job title, Company name, Company registration number, Website, Email address, LinkedIn profile ID, Company telephone number, Trading or registered address, Sector, Turnover or estimated turnover, Employee numbers or estimated employee numbers, Profit or estimated profit, Growth rate or estimated growth rate, Year founded

This data can either be found within the public domain or sourced from a GDPR compliant provider. Consequently, the risk to the data subjects’ fundamental rights and freedoms is extremely limited.

Lawfulness of processing

We conduct outbound marketing on the grounds of Legitimate Interests. We contact companies where we believe our services can add legitimate value to their operations. This is based upon UK GDPR – Legitimate Interests.


In the event that data subjects have consented to receive marketing communications from Foro Tech Ltd, the data subject has the right to withdraw that consent at any time either by confirming in writing or by clicking on unsubscribe links in the email communications.

Data transfers to third countries

The Controller may, from time-to-time, transfer data to 3rd countries where the processor within the 3rd country has signed a contract including Standard Contractual Clauses, (as stipulated by UK GDPR) and where the processor has been subject to data protection training and security controls in order to ensure secure processing of personal data. Details of these security protocols will be made available on request.

Storage of personal data

Upon first contact with a prospect, Foro updates the personal data within 4 weeks. We audit data annually to ensure that it is accurate. If a data subject asks to be unsubscribed, we continue to hold personal data so that we have a record of the data in order to avoid contacting the unsubscribed person again in the future. Data subjects are entitled to request we remove their data from our database. We will comply with such requests on the grounds that the data subject understands that if we remove their data, this means that we also remove the data record of their request to be unsubscribed. Consequently, in the future, a situation could arise where we contact the data subject again.

The right to complain to a supervisory authority

Data subjects can lodge a complaint with a supervisory authority if they reject our grounds for communication.