Privacy Policy

1. Data Controller

TennoTenRyu Inh. Cesarano, Baarerstrasse 87, 6300 Zug, Switzerland (CHE-272.196.618) is the data controller for personal data processed via APEX Outreach Intelligence.

2. Data We Collect

• Client data: Email address, company name, ICP description, offer description — submitted when generating sequences or subscribing.
• Prospect data: Publicly available firmographic data on B2B companies and named decision-makers in their professional capacity, sourced for sequence generation. This data is not retained beyond 90 days without an active subscription.
• Usage data: Query counts and timestamps for service quality.
• Payment data: Processed exclusively by Stripe.

3. Legal Basis

• Contract performance (Art. 6(1)(b) GDPR / nDSG §31): Delivering outreach sequences.
• Legitimate interests (Art. 6(1)(f) GDPR): B2B outreach to professional decision-makers using publicly sourced information.
• Consent (Art. 6(1)(a) GDPR): Marketing communications via DOI only.

4. Prospect Data

Prospect profiles are built from publicly available sources. Clients are responsible for their own outreach activities and compliance with applicable law in their jurisdiction. APEX Outreach Intelligence provides tooling and templates; the client controls sending and maintains their own opt-out obligations.

5. Third-Party Processors

• Stripe: Payment processing
• Resend: Transactional email
• OpenAI / Anthropic / Google: AI inference (no training retention per DPA)

6. Your Rights

Access, correction, deletion, restriction, portability. Contact: info@cesaranogilbert.com