Privacy

Who we are

TOLVEN is run by Kristers Gabrāns, a self-employed business owner registered in Latvia. Address: Madaras iela 25, Rauna, LV-4131, Latvia. For our own prospecting and for this website we are the data controller. Contact: team@withtolven.co.

When we run outreach for a client, the client is the controller of its own contacts and we act as its processor under a written data processing agreement.

If we contacted you

What we hold: your name, your job title or role, your work email address, company details (name, website, location, size and a public description), and a record of the messages we sent you and your reply or opt-out. We don't hold personal addresses, personal phone numbers, payment details or any special category data.

Where it came from: we don't buy ready-made lists. We build each record from public business sources, such as professional profiles like LinkedIn, your company's website and public business registers, and we use paid lookup services to find and check work email addresses without sending you anything.

Why, and our legal basis: we contact businesses to ask whether they want help winning clients. Our legal basis is legitimate interests (Article 6(1)(f) of the GDPR and the UK GDPR): business-to-business marketing to a company contact, limited to your work address and easy to stop. We don't use your data for anything else, we don't sell it, and we don't profile you.

How long: up to 12 months after our last contact with you, then deleted. If you opt out, we keep your email address on a do-not-contact list indefinitely, because that's the only way to make sure we never contact you again.

If you visit this website, write to us or book a call

• We don't use analytics or advertising trackers, and this website doesn't set cookies.
• The site is hosted on Cloudflare, which processes technical data such as your IP address, browser and the pages requested, to deliver the site and protect it from abuse.
• The booking calendar is provided by Cal.com and only loads if you choose to show it. Cal.com then sets its own cookies, and if you book, it processes the name, email and notes you enter so we can hold the call.
• If you email us, including through the “Get your free 20” form (which opens your own email app), we receive what you write in our mailbox.

Our legal basis is legitimate interests for running a secure website, and taking the steps you ask for before a contract when you write to us or book a call. We keep enquiries and bookings for up to 24 months after our last contact, unless we start working together.

Who processes it for us

• Instantly: sends our email and records delivery
• Google Workspace: our mailboxes
• treg: the data service we use to look up company details and check work email addresses
• Cloudflare: hosts this website
• Cal.com: booking calendar

These providers act on our instructions only. Some of them process data in the United States. Where that happens, the transfer relies on the EU-US Data Privacy Framework where the provider is certified under it, or on the European Commission's standard contractual clauses.

Your rights

• Object to this marketing at any time, and we must stop
• Ask for a copy of what we hold about you
• Ask us to correct or delete it, or to restrict how we use it

Email team@withtolven.co and we'll answer within one month. If you're unhappy with our answer, you can complain to Latvia's Data State Inspectorate (Datu valsts inspekcija), the Information Commissioner's Office in the UK, or the Data Protection Commission in Ireland.