This page explains what personal data we process when we email you with a business proposal, where it came from, what we use it for and what you can do about it. It’s written to be understood, not to cover ourselves.
Controller: Matías Díaz — cmdseo
Contact: hola@cmdseo.com
Website: cmdseo.com
cmdseo is an organic visibility consultancy (SEO and GEO) for software development companies. The controller is established in Argentina, a country recognised by the European Commission as providing an adequate level of data protection (Decision 2003/490/EC).
You’re probably looking for this section, so it goes first.
You didn’t give it to us. We obtained it from three kinds of source, all of them public or commercial.
Your first and last name, your job title, your corporate email address, and your company’s name, domain and country. Nothing else. We hold nothing about your private life, no financial data and none of the special categories the Regulation lists.
We rely on the legitimate interest basis set out in Article 6(1)(f) of the General Data Protection Regulation. Recital 47 of the Regulation itself recognises that direct marketing may rely on that basis. Before the first send we carried out a written legitimate interest assessment, weighing our commercial interest against your rights, and we apply the safeguards described below.
You have two ways, both immediate and with no explanation needed.
Either one removes you permanently. And if you reply anything at all, even if it isn’t an opt-out, the sequence stops on its own.
One single use. Contacting you to introduce our consultancy services, in your capacity as a decision maker at a company that fits our client profile.
We don’t sell it, we don’t transfer it and we don’t share it with third parties for advertising purposes. We carry out no profiling with legal effects and no automated decision making about you.
Only with the providers we need in order to operate, which act as processors and solely on our instructions.
| Provider | What for | Located in |
|---|---|---|
| Instantly.ai | Sending and managing the email campaigns | United States |
| Google Workspace | Email inbox | United States |
| Google Sheets | Storage of the contact list | United States |
| Apollo.io | Contact data source | United States |
Transfers to the United States rely on the safeguard mechanisms provided for in Chapter V of the Regulation, either these providers’ certification under the EU-U.S. Data Privacy Framework or the standard contractual clauses approved by the European Commission.
Twelve months from the last contact, if you didn’t reply. After that it is deleted.
With two exceptions.
You can exercise all of these by writing to hola@cmdseo.com. It’s free, you don’t need to give a reason, and we reply within one month.
On objection it’s worth being clear. Where direct marketing is concerned, which is our case, Article 21(2) of the Regulation gives you an absolute right. There is no balancing test and no judgement of ours that counts. If you object, we stop processing, full stop.
And if our answer doesn’t satisfy you, you can lodge a complaint with the Spanish Data Protection Agency (AEPD), the competent supervisory authority in Spain.
We use no open tracking and no click tracking in our commercial emails. It’s a deliberate decision, taken before this page existed.
If we change it, we update the date at the top. If the change materially affects how we process your data, we’ll tell you through the same channel we used to contact you.