Privacy & data

Legitimate Interest Assessment

The three-part balancing test (purpose, necessity, balance) behind the two processing activities that rely on legitimate interest. Published so customers, their DPOs and the people we may contact can see how we reasoned.

Operating policy · v1Last updated 27 September 2026·Questions: dpo@leadradar.example

Scope

Two activities: (1) extracting company-level evidence from public sources, which occasionally includes names of executives or sole traders; (2) identifying a role-relevant professional contact at a company so that a customer's sales representative can decide whether to reach out. Everything else runs on contract or legal obligation.

1 · Purpose test

2 · Necessity test

3 · Balancing test

FactorAssessmentWeight
Reasonable expectationsA professional whose role and address are published by their employer expects role-relevant B2B contact.Favourable
Nature of dataName, role, professional address; no special categories, no private life data.Favourable
ImpactOne reviewed message from a human; no automated sequence, no profiling of the person.Low
SafeguardsTransparency notice at first contact (Art. 14), one-click objection honoured globally before any further draft is generated, retention limit, suppression log, human approval gate, DPIA screening.Mitigating
Vulnerable personsNot targeted; B2B roles only.n/a

Outcome

Legitimate interest is an eligible basis for both activities under the safeguards listed. It does not authorise sending unsolicited electronic marketing where national law requires opt-in for the message itself (Legea 506/2004 art. 12 in Romania): in those cases the draft is routed to a channel or a person for which a basis exists, or not sent.

Review

Owner: DPO. Reviewed at every change of the prospecting flow and at least annually. Version 1, 27 September 2026.

Items highlighted like this are filled in per customer or before launch. We describe controls we operate; we do not present GDPR compliance, AI Act conformity or ISO certification as achieved results until verified.