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Prospect privacy information

Art. 14 GDPR notice for data obtained other than from you directly (prudent B2B prospecting).

1. Controller

Controller: Pizzo Matteo Mario — UP101 VAT: IT02815530064 Fiscal address: Corso Crimea 35 15121 Alessandria (AL) Italia Privacy contact: info@up101.dev PEC: matteomariopizzo@pec.it UP101 Tenerife is the commercial/operating name used for services aimed at the Tenerife market. It does not denote a separate Spanish company.

2. Data sources

Professional data from public or semi-public sources (business websites, directories, public registers) for B2B prospecting related to direct booking and hospitality automation.

3. Purposes

Assess commercial fit, contact when a valid legal basis exists, manage pre-contractual relationship, CRM scoring, Art. 14 compliance, objection, retention, and suppression.

4. Legal basis

Legitimate interest in prudent B2B prospecting (Art. 6(1)(f) GDPR), consent, or prior contractual relationship where applicable. No contact when objection, erasure, or legal lock (LEGAL_OUTREACH_LOCK) applies.

5. Scoring and CRM

Internal scores (opportunity, ICP, contactability, priority) are internal sales tools only. They do not produce automated legal effects on you.

6. Categories and retention

Professional identity/contact data, business data, and interaction metadata. Retention limited to what is needed, with periodic review and minimal suppression after objection.

7. Recipients and transfers

Authorised staff and processors under contract. No sale of data. Extra-EEA transfers only with appropriate safeguards if ever needed.

8. Your rights

Object to prospecting, request access, rectification, or erasure, and withdraw consent where applicable. Contact: info@up101.dev or /privacy-rights. PEC: matteomariopizzo@pec.it. Complaint: AEPD www.aepd.es

9. Marketing opt-out

Opt out anytime via email unsubscribe links or info@up101.dev.

Commercial prospecting may be internally restricted (LEGAL_OUTREACH_LOCK) until remaining legal verifications are complete.