Your details in my lead lists

01Who is responsible

Jose Mbugua, Nairobi, Kenya. I build these lists on my own, as a freelancer under my own name. Contact: josekingp23@gmail.com.

02What I collect

For each person, usually:

• your name
• your job title or role
• your work email address, and sometimes whether it passed an email check
• the organisation you work for, and your team, lab or department
• the address of the public page where I found these details

Sometimes also, if a public page shows them:

• your work phone number
• a short professional biography
• your ORCID iD
• your research topics

For some lists I also write a one-line summary of your research or public work from that page, so a client can see why you are relevant.

I only collect details published for work. I don't collect a home address, a personal email address, a personal phone number, or anything sensitive, such as health or religion.

03Where it comes from

Publicly available web pages of universities, research institutes and companies, such as a staff directory, a lab website or a team page. Every row in a list links to the page it came from.

04Why I use it

Clients ask me for lists of professionals in a given field, so they can contact the right people about their work.

I also build a few sample lists to show my work. In the public versions, names are cut to initials, and emails and source links are masked.

05Legal basis

Legitimate interests: my clients' interest in reaching the right professional contacts, and mine in providing that service and showing samples of it.

I think this is fair to you. I use only work details that are already public for professional contact. The use is business to business and tied to your role. One email is enough to be left out. In public samples, I cut names to initials, mask emails and source links, and remove you if you ask.

06Who receives it

• The client who ordered the list. Once it is delivered, the client decides how to use it and is responsible for that use, including the email rules in its own country.
• If the client ordered through a freelance platform such as Upwork, that platform also keeps the delivered file.
• Google, which stores my working copy in Gmail and Google Drive. I also keep a working copy on my own laptop.
• An AI tool that helps me read the public pages and sort the results.
• An email-checking service, when I use one to test whether your work address still accepts mail.
• If you are in one of my public sample lists: visitors to my website, which Cloudflare hosts. Your name is cut to initials, and your email and source link are masked.
• Authorities, only if the law requires it.

I don't sell the same list to anyone else.

07Where your data goes

I work from Kenya, so your details are processed there. Clients may be in the UK, the EU or the US, so a list may be sent there. Cloudflare, Google, Upwork, the AI tool and any email-checking service I use may store or process data outside Kenya, including in the US. Each one explains its safeguards in its own privacy policy, and I can send you the links. Kenya's Data Protection Act 2019 applies, and UK or EU law may apply too. The UK and EU have not formally rated Kenya's law as equal to theirs. My promises on this page cover my own copy. The client is responsible for its copy.

08How long I keep it

• My working copy of a list, including copies in my email and trash folders: deleted 30 days after I deliver it. If I never deliver it, I delete it 30 days after the order stops.
• A list I deliver as a file through a platform such as Upwork stays there under that platform's rules, and I can't delete it there.
• Sample lists: kept while I use them to show my work. I remove you from them if you ask.
• If you ask to be left out: I keep that email address, and nothing else, on a "do not add" list, and check every new list against it. If you move to a new work address, tell me and I add that one too. I keep this list for as long as I build lists.
• If you email me: our emails are deleted 12 months after we last wrote.
• The client keeps its own copy under its own rules.

09Your rights

You can ask me to:

• tell you whether I hold details about you, and show you them
• correct them
• delete them
• pause their use while we sort out a question
• stop using them, if you object
• leave you out of all future lists

Email me in any words, for example "please leave me out". I deal with your request within 7 days. If I sent your details to a client, I pass your correction or deletion on to that client, and you can ask me who it is. After I delete my working copy, I can still check lists I delivered as a file through a platform such as Upwork. The file stays with the order there. For lists I delivered any other way, I no longer know which client received your details.

If you are unhappy, please tell me first. You can also complain to Kenya's Office of the Data Protection Commissioner, the UK ICO, your national authority in the EU, or the data protection authority where you live.

10Automated decisions

I make no automated decisions about you.

11Security

Only I work on these lists, using the services named above. My Google account uses 2-step verification, and I work only on my own password-protected laptop, which nobody else uses. I collect only details published for work, and I delete my working copy on the schedule above. My "do not add" list holds only email addresses. If something goes wrong with your details, I tell you without delay. I email you where I can, and post on this page if I can't reach everyone.

12Changes

If I change this notice, I update the date at the top.