Business Contacts Privacy Notice

This notice applies to professionals we contact or correspond with for business purposes, such as programme managers, directors and team members at accelerators, incubators, universities, corporate innovation teams, public agencies and other organisations that support entrepreneurs. If you use the Babele platform, our Conditions générales (section 8) also apply to you.

1. Who we are

Babele Create Together S.R.L. is responsible for the personal information described in this notice (“Babele”, “we”, “us”). It is a company registered in Romania (sole identification code 33218665, VAT RO33218665), with its registered office at Strada Mitropolit Nifon 13, sector 4, 040501 Bucharest, Romania.

Babele Create Together ApS, registered in Denmark (CVR 42361798), is a wholly owned subsidiary of Babele Create Together S.R.L. Both companies are owned and managed by Babele’s founders. Some members of our team, including people who contact professionals on Babele’s behalf, are employed by Babele Create Together ApS.

2. How to contact us about privacy

For any question or request about your personal information, email ruxandra@babele.co. You can also reply to any email we have sent you.

3. What information we hold

Professional contact details are personal information, and we treat them that way. When we contact professionals, we aim to collect only information that is relevant to the person’s professional role and to our legitimate business purposes. This can include:

• your name, job title, the organisation you work for and its location (city and country);
• your work email address and, where available, your work phone number;
• publicly available information about your role and your organisation’s work, for example a programme your organisation runs;
• notes we make about the fit between your role and our work, for example the type of programme you manage;
• our correspondence and interactions with you: emails we send and receive, replies, meetings and calls we arrange, notes of our conversations, and any opportunity or collaboration we discuss;
• your communication preferences, including any request not to be contacted again;
• technical delivery information about our emails, for example whether an email was delivered or bounced.

We do not obtain personal email addresses or personal phone numbers for this purpose. We do not use open or click tracking in the emails we send through our CRM. We keep a record of our correspondence, meetings and business activity with you. We do not look for sensitive information about you. Visits to our website are covered separately by the cookies section of our Conditions générales.

4. Where we got your information

If we contacted you first, we did not get your details from you directly. They come from one or more of these sources:

• Apollo.io, a business contact-data provider (ZenLeads Inc., USA), which supplies professional details such as name, job title, organisation and work email address. Apollo is a separate controller of its own database and its own privacy policy applies to it.
• Your organisation’s public website, its programme pages and public professional directories, which we use to understand your organisation’s work and your role.
• Our existing relationships and correspondence, including earlier contact with you or your organisation.
• Introductions and referrals, for example when a colleague introduces you or names you as the right person to talk to, including in an automatic out-of-office reply.
• You, when you write to us, book a meeting, request a demonstration or share information with us.

We also use business databases and public lists to identify relevant organisations. We use them for organisation-level research, not as a source of personal contact details.

5. Why we use your information

We use it to:

• introduce ourselves and Babele’s work to people whose role relates to what we do;
• explore possible professional collaborations;
• invite you to share your perspective on entrepreneurship ecosystems;
• show you the Babele platform, if you are interested;
• discuss relevant programmes and initiatives;
• respond to your questions and requests;
• manage an ongoing professional relationship, including meetings, proposals and agreements with your organisation;
• keep a record of our correspondence;
• respect your choices, including recording that you do not want to hear from us again.

6. How we use automated tools and AI

We use software, including AI tools, to support this work. These tools help us to:

• research organisations from public sources;
• check whether someone’s role and organisation are relevant to our work, and whether the rules of their country allow us to contact them;
• check our records so that we do not contact someone who has asked us not to;
• prioritise which organisations and people to contact first;
• prepare a short personal reference to the organisation’s work for our first message;
• sort and summarise replies.

Our emails are written for each recipient, but they may be scheduled and sent using our CRM’s sequence tools.

One of the tools we use is Claude, an AI assistant provided by Anthropic. We use it to help with organisation research, business development, preparing correspondence and administrative tasks. When we use it, some professional contact information may be processed, for example a name, job title, organisation or a short excerpt of an email. Our current Claude account operates under Anthropic’s Consumer Terms, so Anthropic handles this information under its own privacy policy (for users in Europe, the controller named in that policy is Anthropic Ireland, Limited), not under a data-processing agreement with Babele.

We seek to minimise the personal information we share with AI tools. Contact records and correspondence are kept in our CRM and email systems. We do not share confidential customer contracts, financial records, employee information or customer platform data with these tools, and where possible we use short excerpts or summaries instead of full emails.

These automated assessments decide whether and when we contact you. They do not produce legal effects for you or affect you in a similarly significant way, for example on access to services, employment or credit. If you would like a person at Babele to review how we handled your contact, write to ruxandra@babele.co.

7. Our legal basis

Data protection law (the EU GDPR and the UK GDPR) requires a legal basis for each use of personal information:

• Legitimate interests (Article 6(1)(f)). We rely on legitimate interests for the uses described in this notice: introducing Babele to relevant professionals, building professional relationships, communicating with you as a representative of your organisation (including when your organisation considers or uses our services), and using the tools described in section 6 to run this work efficiently, limited to the information each task needs. We have assessed these interests against yours. We use information connected with your professional role. We contact only people whose work relates to what we offer. Our messages are individual and low in volume. Every message lets you opt out, and we stop as soon as you object. We do not sell your information. You can ask us for more detail about this assessment.
• Contract (Article 6(1)(b)). Where you personally, rather than your organisation, enter into an agreement with us or ask us to take steps before one (for example as a sole trader or independent consultant), we use your information to take those steps and to perform the agreement.
• Legal obligations (Article 6(1)(c)). We keep certain records where the law requires it, for example accounting records for agreements with your organisation.

8. Rules on business emails

Data protection law is not the only set of rules that applies to unsolicited business emails. Many countries also have specific rules on electronic marketing, and some require prior consent even between businesses. We check the rules that apply in the recipient’s country before sending such emails, and we do not send them where those rules require consent we do not have. Publishing this notice does not, by itself, make outreach permissible in every country.

9. Who receives your information

Service providers acting on our behalf (processors). These providers process information only on our instructions and under data-processing terms:

• HubSpot: our CRM and email system, where we manage contacts, correspondence, meetings and opportunities;
• Google Workspace: email, calendar and documents.

Providers that handle information under their own terms.

• Apollo.io is the source of some professional contact details (see section 4). When we ask Apollo to check whether contact details are still current, we send it the name, organisation and email address we already hold. Apollo processes this as an independent controller under its own privacy policy, not on our instructions.
• Anthropic receives information when we use Claude, as described in section 6. Because our account operates under Anthropic’s Consumer Terms, Anthropic handles that information under its own privacy policy.

Others. Authorised members of the Babele team, including colleagues at Babele Create Together ApS, can access your information where they need it for their work. We may disclose information where the law requires it. We do not sell your information, and we do not share it with other organisations for their own marketing.

10. International transfers

Our HubSpot account is hosted in HubSpot’s EU data centre. Even so, some of our providers, or their group companies and sub-processors, are located outside the EU/EEA and the UK, mainly in the United States, and may access or process information there.

• HubSpot: HubSpot, Inc. is certified under the EU-U.S. Data Privacy Framework, and HubSpot’s data-processing agreement includes the European Commission’s Standard Contractual Clauses.
• Google Workspace: Google states that it relies on the EU-U.S. Data Privacy Framework and on the Standard Contractual Clauses included in its data-processing terms for Workspace.
• Apollo.io: information we receive from or send to Apollo is exchanged with ZenLeads Inc. in the United States. ZenLeads states that it is certified under the EU-U.S. Data Privacy Framework, including its UK and Swiss extensions, and its terms include Standard Contractual Clauses for transfers of contact data between independent controllers.
• Anthropic: we use Claude under Anthropic’s Consumer Terms. Anthropic’s privacy policy describes how it transfers information outside the EEA, including its use of adequacy decisions and Standard Contractual Clauses. We do not have a separate data-transfer agreement with Anthropic.

You can ask us for more information about these safeguards.

11. How long we keep your information

• Prospective contacts: we have adopted a quarterly review of inactive prospect records, with an intended retention period of 24 months. A record becomes due for deletion 24 months after our last meaningful interaction with you, such as a reply from you, a meeting or call, or an active opportunity. If there has been no such interaction, the period runs from when we first recorded your details. Emails we send that receive no reply do not extend this period. Records that are due are identified at the next quarterly review and deleted from our CRM and prospecting files, unless an ongoing relationship justifies keeping them.
• Ongoing relationships: if we work together, or your organisation is a customer or partner or is in active discussions with us, we keep your information while the relationship continues. Afterwards we keep it for as long as we need it for legal, accounting or contractual purposes.
• Objections and opt-outs: if you ask us not to contact you, we stop and mark your record so that you are not contacted again. If you also ask us to delete your information, we delete it and keep only a minimal record (your email address, the date and the type of request) so that we can respect your request.
• Email archives: copies of emails may remain in our email accounts after a CRM record is deleted. We do not use them for further outreach.
• AI tools: information processed with Claude is kept by Anthropic under the retention rules in its privacy policy.

12. Your rights

You have the right to:

• object to our use of your information, at any time. If you object to receiving business emails from us, we will stop. You do not need to give a reason, and it costs nothing;
• access the information we hold about you;
• have inaccurate information corrected;
• have your information deleted;
• restrict how we use your information in certain circumstances;
• receive your information in a portable format, where this applies.

To stop hearing from us, use the unsubscribe link in any of our emails, reply “unsubscribe”, or email ruxandra@babele.co.

For any other request, email ruxandra@babele.co. We may need to confirm your identity. We will reply within one month.

13. Complaints

If you are unhappy with how we handle your information, please contact us first so that we can try to resolve it. You also have the right to complain to a data protection supervisory authority, in particular in the country where you live, where you work, or where you believe the problem occurred:

• in Romania, where Babele Create Together S.R.L. is established, the authority is the National Supervisory Authority for Personal Data Processing (ANSPDCP), www.dataprotection.ro;
• in the UK, it is the Information Commissioner’s Office, ico.org.uk;
• in Ireland, it is the Data Protection Commission, dataprotection.ie.

14. How we provide this notice

When we contact someone whose details we did not receive from them, we include a link to this notice in our first email. In any case, we provide it within one month of obtaining their details.

15. Changes to this notice

We may update this notice when our practices change. The date at the top shows the latest version. If we make a material change to how we use your information, we will tell you in our next message to you.