Our point of view
The data published on the websites www.trendstop.be and www.trends-businessinformation.be are accessible via various (paying) login formulas. They are collected on the basis of official sources for which we have the necessary license and agreements with the publishers for the commercial re-use of that data, as well as our own enrichments through contacts (by telephone, email and post) with the companies themselves.
It only concerns data linked to the exercise of some professional activity (so-called B2B data). As mentioned earlier, the processing of that data, including personal data of business managers and companies/sole proprietorships, is crucial to give a complete and up-to-date picture of a company and of the entire population of Belgian companies.
As a commercial information office, the ‘legitimate interest’ is the basis of processing. With regard to the processing, recording and use of ‘unofficial’ functions and personal email addresses of official officers (directors, managers, partners, natural persons) and/or operational management functions, we confirm that the persons concerned are informed.
In function of the privacy legislation, the ‘data subject’ is informed about the purpose of its inclusion and rights. The use of these personal email addresses for communication purposes is governed by the Electronic Communications Act of 13 June 2005 (and not by the new GDPR). These are therefore the channels that use electronic communications (email, cookies, telemarketing, etc.). Since January 2017, the European Commission (EC) has also been working on the bill for a new ePrivacy Regulation which will replace the current Directive 2002/58/EC (on privacy and electronic communications).
If the personal email addresses are used for email marketing, there is an opt-in rule, i.e. that prior consent has been given by the recipient to the sender. The new ePrivacy Regulation will not change this and GDPR does not cover that matter. However, it is indeed allowed to conduct an email campaign to your own customer base (here the ‘legitimate interest’ is the legal basis). This also applies to a campaign to legal entities (generic or general email addresses) provided that it has an opt-out option.