1. Who we are
"Outbound to Close", "OTC", "we", "us" and "our" mean the two companies below. Which one is responsible for your data depends on where you are and who you deal with.
| Entity | Where it is registered | Responsible for |
|---|---|---|
| Outbound to Close LLC | Wyoming, United States. Mailing address: 30 N Gould St, Ste R, Sheridan, WY 82801 | The website outboundtoclose.com; visitors, prospects and clients outside India; any client that signs with the LLC |
| Outbound to Close LLP (LLPIN ADD-5485) | Karnataka, India. Registered office: No. 39/7-1, 3rd Floor, 7th Main, Appareddy Palya, Indiranagar, Bengaluru, Karnataka 560038 | Visitors, prospects and clients in India; any client that signs with the LLP |
Both companies are owned and run by the same founder and share the same team, tools and practices. Where we share data between them, this policy still applies. If you are unsure which entity holds your data, email privacy@outboundtoclose.com and we will tell you.
2. What this policy covers
This policy applies when you:
- visit outboundtoclose.com or any page that links to this policy;
- book a call, fill in a form, or download a free resource such as our ICP template;
- receive an email, call or LinkedIn message from us;
- work with us as a client, or as an employee or contact of a client;
- work with us as a contractor, supplier or partner.
It does not cover websites, products or emails run by our clients or by other companies, even if we link to them. Their own privacy policies apply.
3. The two roles we play
We handle personal data in two different roles. This matters because it decides who you should contact and who is responsible.
- For our own business (we are the "controller"). When we run our website, market our own services, talk to prospective clients, and manage client relationships, we decide what data is used and why. This policy fully applies, and you can come to us directly.
- For our clients (we are the "processor" or "service provider"). When a client hires us to find and contact potential customers for them, the client decides who should be contacted and why. We act on their written instructions. The client is responsible for that data, and their privacy policy applies. Outreach we send for a client identifies that client by name, usually from the client's own email domain.
If we contacted you on behalf of a client and you want to stop it or exercise your rights, you can contact that client or email us at privacy@outboundtoclose.com. We will stop contacting you on that client's behalf and pass your request to the client without delay.
4. What we collect and where it comes from
We collect business and professional data. We do not intentionally collect sensitive data such as health, religion, political views, financial account numbers or government ID numbers. Please do not send it to us.
What you give us
- Forms and call booking. Name, work email, company, role, company website, funding stage, and your answers to our short qualifying questions. Our booking tool also records the time you chose and any notes you add.
- Free resources. Name and work email when you request our ICP template or another resource.
- Conversations. What you tell us by email, phone, video call, LinkedIn or chat.
- Client and supplier details. Contract signer and billing contact details, company address, tax registration numbers (such as GST or EIN), and payment records. Card and bank details are entered with our payment providers; we do not store full card numbers.
What we collect automatically on our website
- Device and usage data. IP address, browser and device type, pages viewed, links clicked, time on page, referring website, and approximate location (country or city) worked out from your IP address.
- Cookies, pixels and similar tools. Used for analytics, measuring our ads, and visitor identification. Section 12 explains each type and how to switch them off.
- Visitor identification. We use tools that match website visits to the company the visitor works for, using IP address and similar signals. For visitors in the United States, some of these tools may also match a visit to a professional profile (such as name, job title and work email) held by the tool's provider. We do not use person-level identification for visitors we detect in the UK, the European Economic Area or Canada, and anywhere consent is required we only run these tools after you agree.
What we collect from other sources
- Public and professional sources. Business contact details and professional information that people or companies have made public, such as company websites, professional networking profiles, press releases, funding announcements, job postings, and public posts or interviews.
- Business data providers. Work email addresses, phone numbers, job titles, company size, industry, technology used, and similar business information from data and enrichment providers.
- Buying signals. Business events that suggest a company may need help, such as a recent funding round, sales hiring, leadership changes, or public discussion of sales and pipeline challenges.
- Our clients. When we work for a client, they may give us their target lists, customer lists, CRM records, meeting notes and call recordings so we can do the work. We use this only for that client.
- Referrals. If someone introduces you to us, they may share your name and contact details.
Calls
When we make or join calls, we may take notes. If a call is recorded or transcribed (by us or by a client's tool), we say so at the start, and we get consent where the law requires it. If you do not want to be recorded, tell us and we will turn it off or end the call.
5. How we use your data, and our legal basis
We only use personal data for the purposes below. The right-hand column is the legal basis we rely on under UK and EU data protection law (UK GDPR and GDPR).
| What we use it for | Typical data | Legal basis (UK / EEA) |
|---|---|---|
| Reply to enquiries and run discovery calls you book | Form answers, booking details, call notes | Steps you asked for before a contract; legitimate interests |
| Send you a free resource you requested | Name, work email | Steps you asked for (delivering what you requested) |
| Send you our newsletter or follow-up marketing emails after a download | Name, work email | Your consent, where the law requires it; otherwise legitimate interests. You can opt out any time |
| Find and contact businesses that may need our services (our own outreach) | Business contact details, role, company data, buying signals | Legitimate interests: telling relevant businesses about a relevant B2B service |
| Deliver services to clients | Client staff contacts, client data, prospect data | Our contract with the client; for prospect data, the client's instructions (Section 3) |
| Invoicing, payments, tax and accounting | Billing contacts, tax IDs, payment records | Legal obligation; contract |
| Measure and improve our website and ads | Usage data, cookies, pixels | Your consent (via our cookie banner) |
| Identify which companies visit our website | IP address, company match, profile match (US only) | Legitimate interests; your consent where required |
| Improve our methods, playbooks and internal tools | Engagement results, such as which message types get replies, in de-identified and aggregated form | Legitimate interests |
| Keep our systems secure, prevent fraud and abuse | Logs, IP address, account activity | Legitimate interests; legal obligation |
| Comply with law and defend legal claims | Any relevant records | Legal obligation; legitimate interests |
Where we rely on legitimate interests, we have weighed our interest against your rights. We only contact people about matters relevant to their professional role, we keep messages short and infrequent, and we stop as soon as you ask. You can object at any time (Section 11).
In India, we process personal data with your consent or for a legitimate use allowed by the Digital Personal Data Protection Act, 2023, including personal data you have made publicly available yourself. Where we need your consent, we ask for it clearly and you can withdraw it as easily as you gave it.
In Canada, we send commercial emails only where Canada's Anti-Spam Legislation (CASL) allows, for example where your business email address is published without a statement that you do not want unsolicited messages, and our message is relevant to your role.
What we never do: sell personal data for money; use it to make decisions with legal or similarly significant effects on you by automated means alone; or use one client's lists, contacts or materials to do work for another client. The aggregated learnings above never identify a client, a client's customers, or any person.
6. How our outreach works, and how to opt out
Outbound outreach is what we do, so we want to be clear about it.
Who we contact. We contact people at businesses, in their professional capacity, about matters relevant to their role. We select companies based on fit and public business signals, not on personal characteristics. We use work email addresses and business phone numbers wherever we can.
What every email includes. Who is sending it (OTC, or the client we act for), a real reply address, a valid postal address, and a simple way to opt out.
Calls. We call business numbers. We do not use automated dialers or prerecorded messages to call mobile numbers without the consent the law requires. For UK numbers, we check the Telephone Preference Service and Corporate Telephone Preference Service registers before calling.
LinkedIn and other platforms. We may send connection requests or messages. You can ignore, decline, or tell us to stop.
How to stop all contact from us. Do any one of these:
- reply "unsubscribe" or "stop" to any email or message;
- use the opt-out link in an email;
- tell us on a call;
- email privacy@outboundtoclose.com with the email address or phone number to block.
We act on opt-outs within 10 business days, and usually much sooner. After you opt out, we keep a minimal record (such as your email address, phone number or company domain) on a do-not-contact list. We do this only so that we never contact you again, including when your details reappear in a data source later. We share the opt-out with the client concerned if the outreach was for a client.
Outreach for clients. When we run outreach for a client, it is sent in the client's name and the client decides who is contacted. Opting out of that outreach stops it for that client. If you also want us to never contact you for any client or for ourselves, say "stop all" or email us, and we will add you to our master do-not-contact list.
7. Who we share your data with
We share personal data only with the people below, and only what they need.
| Who | Why | Examples (categories, not a full list) |
|---|---|---|
| Service providers | To run our website, outreach and business | Website hosting, email, scheduling, email sending and deliverability, data enrichment and contact data, CRM and workflow automation, AI tools, document and note storage, analytics and advertising, video calls, payments, banking and accounting |
| The other OTC entity | Both entities share one team and toolset (Section 1) | Outbound to Close LLC and Outbound to Close LLP |
| Our team and contractors | People who do the work, under confidentiality obligations | Specialists who build lists, run campaigns or make calls under our direction |
| Our clients | When we work for a client, we share with that client the replies, meeting bookings and notes about prospects contacted for them | The client named in the outreach |
| Professional advisers | Legal, tax and accounting advice | Lawyers, chartered accountants, auditors |
| Authorities | When the law requires it, or to protect rights, safety or property | Courts, regulators, tax authorities, law enforcement |
| A buyer or successor | If our business or assets are reorganised, merged, renamed or sold | The new owner, who must keep honoring this policy for data it receives |
Our service providers may only use the data to provide services to us, not for their own purposes, except where a provider acts independently under its own privacy policy (for example, a professional data provider). A current list of our main service providers is available on request from privacy@outboundtoclose.com.
Sales and "sharing" under US state laws. We do not sell personal data for money. Some advertising pixels on our website may count as "sharing" for targeted advertising under some US state laws. You can opt out through our cookie settings, and we treat a Global Privacy Control signal from your browser as an opt-out.
8. International transfers
We operate from India and the United States, and our service providers may store or process data in other countries. Your data may therefore be processed outside the country where you live.
When we transfer personal data from the UK or the European Economic Area to a country without an adequacy decision, we use a recognised safeguard, such as the UK International Data Transfer Agreement or Addendum, or the EU Standard Contractual Clauses, or rely on the provider's certification under the EU–US Data Privacy Framework and its UK Extension. You can ask for more information at privacy@outboundtoclose.com.
9. How long we keep your data
We keep personal data only as long as we need it for the purpose we collected it, then delete or anonymise it.
| Data | How long we keep it |
|---|---|
| Enquiries, booked calls and form answers that do not lead to a contract | 24 months after our last contact with you |
| Prospect data for our own outreach | Up to 12 months after our last interaction, unless you engage with us |
| Free-resource and newsletter sign-ups | Until you unsubscribe, then moved to our do-not-contact list |
| Do-not-contact list | Indefinitely, limited to what we need to honor your opt-out |
| Client data and prospect data processed for a client | For the engagement, then returned or deleted within 30 days of it ending, unless the client contract says otherwise |
| Call recordings and transcripts | Up to 12 months, unless a client contract sets a shorter period |
| Contracts, invoices, tax and accounting records | As long as tax and company laws require, generally up to 8 years |
| Website analytics | Up to 14 months |
| Security logs | Up to 12 months |
We may keep data longer only where the law requires it, or to establish, exercise or defend a legal claim.
10. How we protect your data
We use reasonable technical and organisational measures suited to a business of our size. These include multi-factor authentication on our key accounts, access limited to people who need it, separate workspaces for each client, reputable providers that encrypt data, and confidentiality obligations for everyone who works with us.
No system is completely secure. If a personal data breach affects you, we will tell you and the relevant regulator where the law requires, and we will explain what happened and what we are doing about it.
11. Your rights
Everyone, wherever you live, can ask us to:
- tell you what personal data we hold about you and where we got it;
- correct or update it;
- delete it;
- stop contacting you (Section 6);
- withdraw any consent you gave, without affecting what we did before.
Depending on where you live, you also have these rights:
| Where you live | Additional rights | Where to complain |
|---|---|---|
| UK and European Economic Area | Restrict our use of your data; object to processing based on legitimate interests; receive your data in a portable format; not be subject to decisions made solely by automated means that significantly affect you | UK: the Information Commissioner's Office (ico.org.uk). EEA: your local data protection authority |
| India | Get a summary of your data and of who we shared it with; correction, completion, updating and erasure; grievance redressal through our Grievance Officer (Section 16); nominate someone to exercise your rights if you die or become incapacitated | The Data Protection Board of India, after first raising it with our Grievance Officer |
| Canada | Access and correct your data; ask how it was collected and used | The Office of the Privacy Commissioner of Canada |
| United States (where your state's privacy law applies to us) | Access, correction, deletion, a copy of your data, and opting out of targeted advertising and any "sale" or "sharing"; appeal if we refuse your request | Your state Attorney General or privacy regulator |
How to make a request. Email privacy@outboundtoclose.com with your request and the email address or phone number we have for you. We may ask you to confirm your identity before we act, and we will only ask for what we need to do that. You can use an authorised agent; we may ask for proof of their authority.
When we respond. Within one month in the UK and EEA, within 30 days in India and Canada, and within 45 days where a US state law applies. If a request is complex, we may extend this where the law allows, and we will tell you why. Requests are free unless they are clearly unfounded or excessive.
We will not treat you differently for exercising your rights.
If we hold your data as a processor for a client (Section 3), we will pass your request to that client and help them respond.
12. Cookies, pixels and tracking
| Type | What it does | Can you switch it off? |
|---|---|---|
| Strictly necessary | Makes the site, forms and booking work, and remembers your cookie choice | No, the site needs these |
| Analytics | Counts visits and shows which pages are useful | Yes |
| Advertising | Measures our ads on platforms such as LinkedIn and Google, and builds audiences for them | Yes |
| Visitor identification | Matches visits to companies and, in the US only, to professional profiles (Section 4) | Yes |
In the UK, the EEA and anywhere else the law requires consent, only strictly necessary cookies run until you choose "Accept" in our cookie banner. Elsewhere, you can opt out at any time through "Cookie settings" in our website footer. You can also block or delete cookies in your browser, and we honor Global Privacy Control signals.
13. How we use AI
We use AI tools to research companies, draft and personalise messages, summarise calls and organise our work. A person on our team is responsible for the outreach we send and the advice we give. Where a provider lets us choose, we set our AI tools so that the data we submit is not used to train the provider's general models. We do not use AI to make decisions about you that have legal or similarly significant effects.
14. Children
Our website and services are for businesses and are not directed at anyone under 18. We do not knowingly collect personal data from children. If you believe we have, email privacy@outboundtoclose.com and we will delete it.
15. Changes to this policy
We may update this policy as our business, tools or the law change. We will post the new version on this page with a new effective date. If a change materially affects how we use personal data we already hold, we will tell clients by email and highlight the change on our website before it takes effect.
16. Contact us
Privacy questions and requests: privacy@outboundtoclose.com
Grievance Officer (India): Aquil Ansari, Founder, privacy@outboundtoclose.com, No. 39/7-1, 3rd Floor, 7th Main, Appareddy Palya, Indiranagar, Bengaluru, Karnataka 560038. We will acknowledge grievances promptly and resolve them within one month.
Post:
- Outbound to Close LLC, 30 N Gould St, Ste R, Sheridan, WY 82801, United States
- Outbound to Close LLP, No. 39/7-1, 3rd Floor, 7th Main, Appareddy Palya, Indiranagar, Bengaluru, Karnataka 560038, India