Trustleads – Commercial Opportunity Intelligence Platform
Effective Date: Feb. 24th 2026
Last Updated: Feb. 24th 2026

 

1. INTRODUCTION

Trustleads (“Trustleads”, “we”, “us”, “our”) is a Commercial Opportunity Intelligence Platform dedicated to identifying, structuring, qualifying, and prioritizing real international commercial opportunities between exporting companies and international buyers.

Trustleads operates strictly within a professional B2B context.

This Privacy Policy explains how we process professional business information in connection with the production and distribution of our Commercial Opportunity Intelligence products.

 

2. CONTROLLER INFORMATION

Controller: Trustleads
Registered Entity: Sourcingest Lda.
Data Protection Contact: privacy@trust-leads.com

Trustleads acts as Data Controller for the processing activities described in this Policy.

 

3. SCOPE

This Policy applies to:

• Professional business data included in Trustleads intelligence products

• Business customers purchasing our products

• Website visitors

• Business professionals whose publicly available information may be included in our datasets

This Policy does not apply to consumer data.

 

4. NATURE OF OUR SERVICE

Trustleads produces and distributes structured Commercial Opportunity Intelligence.

Trustleads:

• Is not a consumer data broker

• Does not sell private personal data

• Does not process sensitive personal information

• Does not engage in consumer behavioral profiling

We structure publicly available professional business information exclusively for lawful B2B commercial engagement.

 

5. CATEGORIES OF DATA WE PROCESS

5.1 Professional Identification Data

• Full name (professional capacity)

• Professional job title

• Department or functional role

• Authority classification

5.2 Professional Contact Data

• Professional business email address

• Public business telephone number (where available)

• Public professional profile link (e.g., LinkedIn)

5.3 Company Identification Data

• Legal or commercial name

• Verified primary domain

• Country and city

• Operational presence type

• Business role classification

5.4 Intelligence Metadata

• Validation status

• Validation timestamp

• Dataset version

• Contact confidence index

• Opportunity probability score

• Commercial trigger context

Trustleads does not process:

• Private personal email addresses

• Personal residential addresses

• Sensitive personal data

• Health, political, biometric, or financial data

• Consumer browsing behavior

 

6. SOURCE OF DATA

All data is obtained exclusively from publicly available business sources, including:

• Official corporate websites

• Public contact pages

• Trade fair directories

• Public procurement disclosures

• Public company registries

• Public professional profiles

• Public press releases

Trustleads does not:

• Circumvent authentication systems

• Bypass paywalls

• Access private databases unlawfully

• Use intrusive surveillance technologies

 

7. LEGAL BASIS FOR PROCESSING (EU / EEA / UK)

Trustleads processes professional business data under:

Article 6(1)(f) GDPR – Legitimate Interest.

Our legitimate interests include:

• Facilitating lawful B2B commercial engagement

• Supporting international trade and procurement connectivity

• Improving targeting accuracy in professional contexts

• Reducing irrelevant outreach

A documented Legitimate Interest Assessment (LIA) has been conducted.

 

8. PURPOSES OF PROCESSING

We process professional data to:

• Identify commercially active entities

• Map real decision-making authority

• Structure procurement intelligence

• Contextualize commercial triggers

• Produce structured intelligence products

• Maintain dataset validation cycles

• Ensure quality control and versioning

We do not process data for consumer marketing.

 

9. DATA MINIMISATION

Trustleads applies strict minimisation principles:

• Maximum of 1–2 decision-makers per entity

• Professional capacity only

• Sector-specific dataset limitation

• Time-bound dataset validity

• No sensitive data inclusion

 

10. DATA SHARING

Professional data contained in intelligence products is shared only with:

• Business customers purchasing the dataset

• Internal authorized personnel

• Infrastructure providers acting as processors

Customers act as independent Data Controllers for any subsequent processing.

Trustleads is not responsible for downstream misuse.

We do not provide datasets to consumer marketing networks.

 

11. INTERNATIONAL TRANSFERS

Where data is transferred outside the EEA or UK, appropriate safeguards are implemented, including:

• Standard Contractual Clauses (SCCs)

• Contractual data protection provisions

• Technical security measures

 

12. RETENTION

Trustleads applies structured freshness windows:

• Premium datasets: 60–90 days

• Standard datasets: up to 120 days

After expiration:

• Data may be revalidated

• Dataset versions may be renewed

• Or records may be securely deleted

We do not retain professional data indefinitely without review.

 

13. SECURITY MEASURES

Trustleads implements appropriate technical and organizational safeguards, including:

• Encrypted storage

• Role-based access control

• Dataset version control

• Secure deletion procedures

• Incident response protocol

 

14. DATA SUBJECT RIGHTS (EU / UK)

Where applicable, data subjects may exercise:

• Right of access

• Right to rectification

• Right to erasure

• Right to restriction

• Right to object

• Right to lodge a complaint

Requests should be submitted to:

privacy@trust-leads.com

Verified requests are processed promptly, typically within 15 business days.

 

15. BRAZIL – LGPD COMPLIANCE

If professional data relates to individuals located in Brazil, processing is conducted in accordance with Lei nº 13.709/2018 (LGPD).

Legal basis may include:

• Legitimate interest (Art. 7, IX LGPD)

• Regular exercise of rights in commercial context

Brazilian data subjects may request:

• Confirmation of processing

• Access

• Correction

• Deletion (where applicable)

• Information about data sharing

Requests should be sent to:

privacy@trust-leads.com

 

16. CALIFORNIA – CCPA / CPRA

If professional data relates to individuals located in California:

16.1 Categories of Personal Information

Trustleads may collect:

• Identifiers (name, professional email)

• Professional employment information

• Public business contact information

We do not collect sensitive personal information as defined by CPRA.

 

16.2 Sale or Sharing

Certain B2B transfers may qualify as a “sale” under California law.

California residents may opt out of sale or sharing by contacting:

privacy@trust-leads.com

 

16.3 California Rights

California residents may request:

• Access to collected categories

• Deletion

• Correction

• Opt-out of sale or sharing

• Non-discrimination

Identity verification is required.

 

17. LIMITATION OF PURPOSE

Trustleads processes professional data exclusively within the context of structured B2B Commercial Opportunity Intelligence.

We do not:

• Conduct automated decision-making affecting individuals

• Perform consumer behavioral profiling

• Use data for unrelated purposes

 

18. CUSTOMER RESPONSIBILITY

Customers purchasing intelligence products are solely responsible for ensuring lawful use of data.

Trustleads does not authorize unlawful mass unsolicited communications.

Trustleads disclaims responsibility for regulatory violations arising from customer misuse.

 

19. DATA BREACH RESPONSE

In the event of a confirmed data breach, Trustleads will:

• Assess risk level

• Notify authorities where legally required

• Notify affected individuals where required

• Implement corrective measures

 

20. CHILDREN’S DATA

Trustleads does not knowingly process data relating to minors.

All data processed relates to professionals acting in a commercial capacity.

 

21. LIMITATION OF LIABILITY

To the maximum extent permitted by applicable law:

Trustleads shall not be liable for:

• Indirect damages

• Regulatory fines imposed on customers

• Customer misuse of datasets

• Business losses arising from outdated information

 

22. UPDATES

Trustleads may update this Policy as required by legal or operational changes.

The updated version will include a revised “Last Updated” date.

 

23. CONTACT

For all privacy inquiries:

privacy@trust-leads.com