Privacy Policy

DB to Data company is a B2B and B2C email and phone list provider operating from Bangladesh, and considering the global nature of data brokering, your privacy policy must be robust and address various international data protection laws, including Bangladesh’s evolving data protection landscape, GDPR, and CCPA, as applicable to your operations and the data you process.

Here’s a comprehensive privacy policy template. Remember, this is a template and should be reviewed and customized by a legal professional to ensure full compliance with all relevant laws for your specific business practices and jurisdictions.

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Privacy Policy of Db to Data Company

Last Updated: July 12, 2025

1. Introduction

DB to Data  is a data company specializing in providing B2B (business-to-business) and B2C (business-to-consumer) email and phone lists. We understand the critical importance of privacy and are committed to protecting the personal data we collect, process, and provide. This Privacy Policy outlines our practices regarding data collection, use, storage, disclosure, and the rights of individuals whose data we handle.

We operate from Bangladesh and strive to comply with the relevant data protection laws in Bangladesh, including the Data Protection Act 2023 (or its latest iteration) and the Cyber Security Act 2023. Furthermore, given the international nature of data, we adhere to the principles of global privacy regulations such as the General Data Protection Regulation (GDPR) for data subjects in the European Union and the UK, and the California Consumer Privacy Act (CCPA) for California residents, where applicable to our activities.

2. Data We Collect and Process

We collect and process various types of personal data to compile our B2B and B2C email and phone lists. This data is primarily non-sensitive and obtained from legitimate and publicly available sources or through third-party data providers who adhere to strict data protection standards.

For B2B Data (Business Contacts):

• Contact Information: Business email addresses, business phone numbers, company name, job title, department, business address.
• Professional Information: Industry, company size, publicly available professional profiles (e.g., LinkedIn).
• Source Information: Details about where and when the data was originally collected (e.g., public directories, corporate websites, industry events).

For B2C Data (Consumer Contacts):

• Contact Information: Email addresses, phone numbers, postal addresses (where publicly available or consented).
• Demographic Information: General demographic data (e.g., age range, gender, general location) that is non-sensitive and derived from public or consented sources.
• General Interests/Preferences: Categories of general interest (e.g., “technology enthusiast,” “homeowner”) derived from public or consented sources, not sensitive personal data.
• Source Information: Details about where and when the data was originally collected (e.g., public records, consented surveys, reputable third-party data aggregators).

We DO NOT intentionally collect or process sensitive personal data, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning a person’s sex life or sexual orientation.

3. Sources of Data Collection

We collect data from various legitimate sources, which may include:

• Publicly Available Sources: Company websites, professional networking sites (like LinkedIn, where data is publicly displayed), government registries, public business directories, press releases, and news articles.
• Third-Party Data Providers/Aggregators: Reputable data partners who assure us that they collect data in compliance with relevant data protection laws, including obtaining necessary consents where required. We conduct due diligence on our data suppliers to ensure their practices align with our commitment to privacy.
• Government Records: Publicly accessible government databases or records where personal data is made available for commercial use.
• Open Source Intelligence (OSINT): Data lawfully gathered from open, publicly available sources.

4. How We Use the Data

We primarily use the collected data for the following purposes:

• Providing Data Lists to Clients: Compiling and providing B2B and B2C email and phone lists to our clients for their legitimate marketing, sales, and analytical purposes. Our clients are contractually obligated to use the data in compliance with all applicable privacy laws.
• Data Enhancement and Validation: Verifying and updating the accuracy of our data lists.
• Internal Operations: For our own internal business operations, such as administrative purposes, billing, and improving our services.
• Compliance and Legal Obligations: To comply with legal obligations, enforce our terms and conditions, and protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

We DO NOT use the data to directly market to individuals unless they are our direct clients and have provided us with explicit consent for such marketing.

5. Legal Basis for Processing (Applicable to GDPR/UK GDPR)

For data subjects located in the European Union or the UK, our legal bases for processing personal data typically include:

• Legitimate Interests: We process B2B data based on our legitimate interest in providing business contact information to our clients for their legitimate business activities, and our clients’ legitimate interest in conducting B2B marketing and sales. We ensure that these interests are balanced against the data subjects’ rights and freedoms. For B2C data, we rely on legitimate interests only where explicit consent is not required or has been obtained by our data suppliers.
• Consent: For certain types of B2C data or specific marketing activities where required, we rely on the explicit consent obtained by our data suppliers. We require our suppliers to provide demonstrable proof of consent.
• Compliance with Legal Obligations: Processing data when necessary to comply with legal or regulatory obligations.

6. Data Sharing and Disclosure

We share personal data with:

• Our Clients: The primary purpose of our service is to provide B2B and B2C email and phone lists to our clients. Our contracts with clients require them to use the data in a compliant and responsible manner, respecting all applicable data protection laws.
• Service Providers: Third-party vendors and service providers who perform services on our behalf, such as data storage, data processing, security, and analytics. These providers are contractually bound to protect the data and only use it for the purposes for which we provide it.
• Legal and Regulatory Authorities: When required by law, court order, or to cooperate with law enforcement or other governmental agencies.
• Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

We DO NOT sell raw personal data lists to any entity without ensuring that the intended use by that entity is compliant with all applicable privacy laws and that the data subjects’ rights are respected.

7. Data Retention

We retain personal data for as long as necessary to fulfill the purposes for which it was collected, to provide services to our clients, and to comply with our legal and contractual obligations. We regularly review our data holdings and securely delete or anonymize data that is no longer required.

8. Data Security

We implement appropriate technical and organizational measures to protect personal data from unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Access controls and authentication.
• Encryption of data in transit and at rest where appropriate.
• Regular security assessments and vulnerability testing.
• Employee training on data privacy and security.
• Strict contractual obligations with third-party service providers regarding data security.

9. International Data Transfers

As a company operating from Bangladesh and providing data globally, data transfers may occur across international borders. We ensure that any such transfers comply with applicable data protection laws.

• For data subjects in the EU/UK, we strive to utilize data processed in jurisdictions deemed “adequate” by the European Commission or rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) to ensure data protection.
• For data transfers from other regions, we implement measures to ensure that personal data remains protected in accordance with the laws of the originating jurisdiction.

10. Your Data Protection Rights

Depending on your location and applicable data protection laws, you may have the following rights regarding your personal data:

• Right to Access/Know: The right to request information about the personal data we hold about you and how we process it.
• Right to Rectification/Correction: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure/Deletion (“Right to be Forgotten”): The right to request the deletion of your personal data under certain circumstances.
• Right to Object to Processing: The right to object to the processing of your personal data, particularly for direct marketing purposes.
• Right to Restrict Processing: The right to request the restriction of processing of your personal data under certain conditions.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.
• Right to Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time.

For California Residents (CCPA): If you are a California resident, you have specific rights under the CCPA, including:

• The right to know what personal information is collected, used, sold, or shared.
• The right to request deletion of personal information.
• The right to opt-out of the sale or sharing of personal information.
• The right to non-discrimination for exercising your CCPA rights.
• We commit to reporting specific metrics related to consumer requests as required by the CCPA for data brokers.

To exercise any of these rights, please contact us using the details provided in the “Contact Us” section below. We will respond to your request in accordance with applicable law.

11. Children’s Privacy

Our services are not directed to individuals under the age of 18, and we do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child, we will take steps to delete such information as soon as possible.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, and other factors. We will notify you of any material changes by posting the updated policy on our website with a new “Last Updated” date. We encourage you to review this Privacy Policy periodically.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

company name: DB TO DATA

address: Baridhara, uttara, Dhaka, bangladesh

Email:info@dbtodata.com Phone: +8801918754550 Website: https://dbtodata.com

For data protection inquiries, especially if you are located in the EU/UK, you may also specify a dedicated contact person or Data Protection Officer (if applicable).