Art. 14 GDPR notice template

Last updated: 13 June 2026

When personal data is not obtained directly from the data subject, Art. 14 GDPR requires providing privacy information — typically in the first contact (e.g. first cold email). This template is for ProperSend customers using B2B data from public registers or research. Customers must adapt it to their legal situation and seek legal advice.

1. When to use

Art. 14 GDPR applies when you (as a ProperSend customer) are the controller of business contact data obtained from KRS, CEIDG, company websites, LinkedIn, or ProperSend — not directly from the individual.

Provide the notice at first contact or within a reasonable period (usually the first email). Art. 14(5) exceptions require individual legal assessment.

2. Legal basis for B2B outreach

B2B outreach to work email addresses often relies on Art. 6(1)(f) GDPR (legitimate interest), subject to a balancing test (LIA) and easy objection/opt-out.

ProperSend does not provide legal advice. The customer is responsible for the legal basis and compliance with telecommunications and anti-spam rules.

3. Required elements (Art. 14(1)–(2))

The notice should include:

  • controller identity and contact details (the customer);
  • purposes and legal basis;
  • recipients or categories (including ProperSend as processor);
  • retention period or criteria;
  • data subject rights (access, rectification, erasure, objection, complaint);
  • data source (e.g. KRS, CEIDG);
  • automated decision-making information if applicable.

5. LinkedIn and similar platforms

Data from LinkedIn or similar platforms is subject to separate terms of use and often requires individual legal assessment (GDPR, telecom/anti-spam rules, platform ToS).

ProperSend does not recommend automated profile scraping or bulk export without an approved legal basis and platform compliance.

The customer is responsible for the lawfulness of data sources in campaigns. When in doubt, seek legal advice before sending.

6. ProperSend’s role

ZORDON INTELLIGENCE Sp. z o.o. provides the campaign tool and may store data as processor on the customer’s instructions. The customer remains controller towards prospects and is responsible for Art. 14 content and suppression lists.

We recommend linking to the customer’s privacy policy and a clear opt-out in every message.

First-email template (edit fields in [brackets])

Hello,

I'm reaching out regarding [brief business context].

The controller of your personal data is [CUSTOMER COMPANY NAME], [address], [contact email / DPO]. We obtained your business contact details (name, work email, role, company data) from publicly available sources, including public registers (e.g. KRS/CEIDG) and [other source if applicable], for B2B outreach (Art. 6(1)(f) GDPR — legitimate interest). Providing data is not a contractual requirement; without it we cannot pursue this business contact.

We retain data for [period, e.g. 12 months from last contact / until objection — specify].

Recipients may include: [CUSTOMER COMPANY NAME], the ProperSend platform (ZORDON INTELLIGENCE Sp. z o.o., processor — https://www.propersend.pl/umowa-powierzenia), [email/SMTP provider]. Data may be transferred to third countries (e.g. the US) only under Standard Contractual Clauses (SCC) and supplementary measures — details from the controller.

You have the right to access, rectify, erase, restrict processing, data portability (where applicable), object (including to marketing), and lodge a complaint with your supervisory authority. To opt out, reply “STOP” or email [address].

Best regards,
[Name]
[Role, Company]