This article describes in laymen terms the data privacy obligations of Sales & Marketing Professionals in various jurisdictions, with a special focus on US "opt-out" vs. UK/EU "opt-in" sales engagement requirements.

Aptivio in context of Data Privacy Regulations (CCPA, GDPR, etc.) is considered both as a Data Collector and a Data Processor.

Obligations as a Data Collector

Data collection is defined as the procedure of collecting, measuring and analyzing insights for advertising or research purposes, using standard validated techniques. Therefore, collecting data through its Data Providers and analyzing it to deliver accurate information to its clients positions AptivIO as a Data Collector. The company periodically ensures that its Data Providers take all possible measures to be compliant to any legislations or regulations concerning data privacy. It makes sure for example that the Providers have the clear and explicit consent of people whose data is collected, such as a positive opt-in, and that it gives the opportunity to withdraw at any time easily.

Obligations as a Data Processor

A Data Processor is defined as an entity which holds and processes data on behalf of a Data Controller whose role is to decide the purpose and manner to process the data. In the case of AptivIO, which is also considered as a Data Processor, its clients are the above-mentioned Data Controller and Data Co-Processor, as they are given the ability to decide how they process their data and process it on their own. As it applies for the Data Providers, AptivIO ensures the compliance of all processes done by the entity or the clients. Those processes have different level of identity resolution for different types of campaigns, divided between two major categories: Public data and Personal data.


Public Data Use Rules & Regulations

Public data is by default considered as “opted-in” by the owner, who explicitly consented that its data could be used when opting in, though AptivIO provides the possibility to opt-out at any time. Public data is composed by:

  • Job Roles on LinkedIn: public LinkedIn profiles enable Sales and Marketing to identify relevant buyer personas performing a business function at a target company. It provides a legal basis for reaching out to an individual in its professional capacity, so long as the offer matches the buyer persona in terms of buying influence and decision making ability.
  • LinkedIn IDs: enabling marketing and sales team to send a connection invitation. The data comes from public LinkedIn profiles, which is as an opt-in consent to communicate to the contact.
  • Digital IDs (aka Mobile Ad IDs, Email Hash IDs) : enabling the creation of anonymized custom audiences for digital advertising. They are collected thanks to cookies shared by people during their website visits. These Digital IDs are used to create high-intent fully-anonymized custom audiences on Social Media platforms such as LinkedIn, Facebook, Google, Baidu, WeChat, etc. to deliver ultra-personalized offers in their social feeds.
  • Work email Patterns ( These email patterns are tied to a company job role and used by Sales Development Professionals to reach out 1:1 with relevant buyers. Our AI engine calculates and recreates the pattern usually done by the companies, such as The role of the company is to automate what the sales teams already do. GDPR regulations allow for personalized sales messages that match a job title when sent from work email, which is what we encourage our clients to do.
  • Local HQ Phone: enabling direct phone calls towards the company. This data is collected on websites such as Google Maps, so the information is publicly available and designed for direct professional outreach to a business switchboard.

Personal Data Use & Regulations

Personal data is on the other hand considered as “opted-out” by the private data owner, so AptivIO asks for the clear and explicit consent before collecting and processing it. The company also provides the possibility to opt-out at any time if the user changes his mind. Personal data is composed of:

  • Direct Dial : enabling salespeople to launch a calling campaign. AptivIO requests the permission from the private data owner to use their phone number for a campaign. We also do not display any number registered on any “Do-Not-Call Screening Lists” globally, and do not allow any client to use these numbers if the consent is not explicitly given. We encourage our clients to reach out to the contacts 1:1 via LinkedIn or a work email to request the permission to call.
  • Opt-in Emails: AptivIO also requests the permission from the private data owner to use their email for a 1:Many Email Marketing Campaign. We ask our clients to wait for an explicit opt-in subscription (for example from an initial opt-in campaign, newsletter or white paper) before sending any emails without the consent of the contact.