Business outreach to the United States and the United Kingdom
Arbyn Partners · Version 1.2 (US/UK) · Effective date: 3 November 2026 · Last updated: 12 November 2026
This notice explains how Arbyn Partners uses personal data in two contexts: (1) business contact data from public sources used for B2B outreach to companies in the United States (US) and the United Kingdom (UK), and (2) contact data you voluntarily provide when you subscribe through the form on our website.
The controller of your personal data is:
Dawid Dymczyk, trading as Arbyn Partners Postal address: Arbyn Partners, ul. Opalińska 5/7, 01-739 Warszawa, Poland Email: privacy@arbynhq.pl
Our emails are signed by: Dawid, Arbyn Partners.
We have not appointed a data protection officer, as we are not required to. Please send any privacy question or request to the email or postal address above.
We hold only business contact data, limited to what we need to contact the right person at a company:
We do not collect special category data, data about children or home addresses, and we do not buy contact lists.
We collect personal data from two kinds of source. Not every contact comes from both.
For most B2B outreach contacts we did not receive the data from you. We collected it from public sources:
Each outreach record keeps a note of the exact source page, and the first email we send you names it. You can ask us for the source at any time. This section satisfies Article 14 UK GDPR for data not obtained from you.
If you use the subscribe form on our website, you give us your email address yourself and tick a consent box to receive commercial information and offers by email from Arbyn Partners.
We use your data to offer your company our B2B appointment-setting service. We book meetings between your company and business owners who may need your services.
Specifically, we:
| Purpose | Lawful basis |
|---|---|
| Sending you up to three short business emails (one first email and up to two follow-ups) offering our appointment-setting services to your company | Legitimate interests (Article 6(1)(f) UK GDPR) |
| Checking that a business email address exists before we write to it, using a third-party email verification service and public DNS (MX) records (no email is delivered to you) | Legitimate interests: avoiding misdirected email and protecting our sending infrastructure |
| Reading and replying to your answer, and arranging a call if you ask for one | Legitimate interests; steps before entering into a contract (Article 6(1)(b)) where your company wants to work with us |
| Keeping a suppression list so that we never contact you again after you opt out | Legal obligation (Article 21(3) UK GDPR and PECR) and legitimate interests |
| Sending commercial emails to people who subscribed through our website form | Consent (Article 6(1)(a) UK GDPR). You can withdraw consent at any time |
| Establishing, exercising or defending legal claims | Legitimate interests |
Summary of our legitimate interests assessment
You can ask us for a copy of the full assessment.
PECR allows unsolicited marketing email to corporate subscribers without prior consent, provided the sender is identified and an easy opt-out is offered. We therefore email only business addresses of incorporated bodies, such as private and public limited companies (Ltd, PLC) and limited liability partnerships (LLP).
We do not send marketing email to sole traders or unincorporated partnerships unless they have given us their consent. Scottish partnerships are an exception because they are legal persons. If you are a sole trader or a partner in such a firm and have received our email, please tell us. We will delete your data and add you to our suppression list.
Every email we send states who we are and includes our postal address, a link to this notice and a working opt-out.
We do not sell or rent your data, and we do not share it with other companies for their own marketing. In particular, we do not pass your details to our clients.
Your data is processed for us only by email and hosting service providers acting on our instructions under data processing terms (processors):
We do not use third-party email-sending platforms. Emails are sent from our own mail servers. To check whether an address exists we use the verification service named above; we do not probe other companies' mail servers from our own servers.
We may also disclose data where the law requires it, for example to a regulator or court.
Referral codes. If you reach our booking page through a partner's referral link, or type a referral code into the booking form, that code is stored with your booking in Cal.com (our booking provider, see above) so that we can settle our referral programme with the partner who referred you. Our legal basis is our legitimate interest in running and settling the referral programme (Article 6(1)(f) UK GDPR / EU GDPR). We keep the code for the duration of our client relationship plus five years from the end of the calendar year of the last commission payout. Our website does not store the code in your browser: we use no cookies or local storage for this.
We are based in Poland, in the European Economic Area (EEA). The UK recognises the EEA as providing adequate protection, so transfers of your data to us in Poland are covered by UK adequacy regulations.
Where a provider processes data outside the UK and the EEA, we rely on:
You can ask us for details of the safeguards used.
We do not make decisions about you based solely on automated processing, including profiling, that have legal or similarly significant effects.
We select companies by simple business criteria (industry, company type and whether a business email is published). The address check only tells us whether a mailbox appears to exist.
We keep your business contact data until you object or opt out, unless it is deleted earlier under the limits below. After you object or opt out, we delete the rest of your data. We keep only your email address (or domain) on our suppression list, so that we never write to you again.
| Data | How long |
|---|---|
| Contacts who do not reply | Deleted 12 months after our last email to them |
| Contacts who reply but do not become clients | Deleted 24 months after our last exchange |
| Client contacts and business records | For the duration of the contract and then as long as Polish tax and accounting law requires (generally 5 years from the end of the tax year) |
| Address verification results | Kept with the contact record and deleted with it |
| Server logs (mail server logs and website access logs, which can include email addresses and IP addresses) | Mail server log files are rotated weekly and the last 4 weekly files are kept, so entries are deleted after about 5 weeks. Website and unsubscribe page access logs are rotated daily and kept for 14 days. The servers' system journal also records events from the mail servers and our other services; it has no fixed time limit but is limited in size (by default 10% of the disk, at most 4 GB), and the oldest entries are deleted automatically when that limit is reached. |
| Website opt-in subscribers (email, consent text, signup time, IP, hostname) | Kept while your consent is active and you remain subscribed. After you withdraw consent we remove you from the active subscriber list and keep only a suppression record as below. |
| Suppression list (opt-outs, objections, bounces, withdrawn consent) | Kept indefinitely, so that we can keep honouring your choice. We keep only the minimum: email address or domain, date, sending domain, reason and, for link clicks or form actions, the IP address. |
Right to object to direct marketing (Article 21). You can object at any time to our use of your data for direct marketing. This right is absolute: once you object, we will stop, with no need for a reason, and we will add you to our suppression list.
You also have the right to:
The right to data portability does not apply, as we do not process your data on the basis of consent or a contract with you.
We reply to requests within one month. Exercising your rights is free.
We would like the chance to deal with any concern first, so please contact us.
You also have the right to complain to the UK Information Commissioner's Office (ICO): ico.org.uk, telephone 0303 123 1113.
Because we are based in Poland, you may also complain to the Polish supervisory authority, the President of the Personal Data Protection Office (UODO): uodo.gov.pl.
Our emails to US businesses are commercial messages. They follow the CAN-SPAM Act:
Your right to opt out. You can opt out of our emails at any time, free of charge, as described in section 14. Once you opt out:
For any other question about your data, please write to privacy@arbynhq.pl.
No sale of personal information. We do not sell your personal information, and we do not share it for cross-context behavioural or targeted advertising.
You can stop our emails at any time, free of charge, in any of these ways:
If you subscribed through our website form, the same steps withdraw your consent to receive commercial emails. After withdrawal we stop marketing emails to that address and keep only what we need on the suppression list so we do not contact you again by mistake.
We act on opt-outs and consent withdrawals immediately, normally within 2 working days and in any case within 10 business days.
For outreach based on public business data, an opt-out by anyone at your company stops all further emails to that company.
We do not use advertising or tracking cookies on this website or in our emails. This page and our unsubscribe page do not set any cookies.
No. For outreach contacts we collected data from public sources, and you have no obligation to provide any data to us. Website subscription is voluntary: you do not have to fill in the form, and you can withdraw consent later using the methods in section 14.
We may update this notice. The version number and date at the top show when it last changed.
Arbyn Partners · ul. Opalińska 5/7, 01-739 Warszawa, Poland · privacy@arbynhq.pl