PRIVACY POLICY
MyIngredients
Controller:
Different Expansion
Business name: Marek Šarmír – Different Expansion
Registered office: Stredná 4267/57, 821 04 Bratislava – Ružinov, Slovak
Republic
Company ID No.: 56468105
Tax ID / VAT ID: 1074027603
E-mail: info@myingredients.eu
Website: www.myingredients.eu
This Privacy Policy explains how Different Expansion, as the operator of the MyIngredients service, processes personal data in connection with the provision of B2B services, in particular lead generation, searching for business contacts, database creation, business outreach, and communication with potential clients or business partners.
1. General Provisions
Different Expansion processes personal data in accordance with applicable legal regulations, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council, commonly known as the GDPR.
The MyIngredients service is intended exclusively for business entities operating in a B2B environment. As part of our activities, we may process personal data of contact persons working within companies, in particular manufacturers, distributors, buyers, importers, exporters, sales managers, category managers, business development managers, and other decision-makers.
2. What Personal Data We Process
Depending on the specific situation, we may process the following categories of personal data in particular:
- first name and surname,
- job title,
- company name,
- business e-mail address,
- business telephone number,
- country of operation,
- company website,
- LinkedIn profile or another publicly available professional profile,
- information about the person's professional focus,
- communication with the data subject,
- information about expressed interest in our services or in the services of our clients,
- technical data related to e-mail communication, such as information about delivery, opening, reply, or opt-out from communication.
We do not process personal data that is not related to the professional or business activity of the data subject, unless we have a specific legal basis for doing so.
3. Where We Obtain Personal Data From
We may obtain personal data mainly from the following sources:
- contact forms on the website,
- direct e-mail or telephone communication,
- publicly available company websites,
- professional networks, such as LinkedIn,
- public business registers,
- exhibitor catalogues from professional trade fairs,
- B2B databases and business information sources,
- referrals or business contacts,
- communication during business negotiations.
When obtaining data, we aim to work only with relevant professional contacts where there is a reasonable business reason for contacting them.
4. For What Purposes We Process Personal Data
We process personal data mainly for the following purposes:
4.1 Responding to a Contact Form or Enquiry
If a person submits a contact form, sends us an e-mail, or sends us another message, we process their data for the purpose of responding, preparing an offer, providing a consultation, or conducting business communication.
Legal basis:
Performance of pre-contractual measures or legitimate interest.
4.2 Providing Services to Clients
If we cooperate with a client, we process data necessary for the provision of our services, communication, invoicing, delivery of outputs, reporting, and business support.
Legal basis:
Performance of a contract or legitimate interest.
4.3 B2B Lead Generation and Database Creation
As part of the MyIngredients service, we may search for and process publicly available or lawfully obtained contact details of relevant persons working within business companies, provided that their professional role is related to the subject of the business communication.
The purpose is to identify relevant business partners, buyers, distributors, manufacturers, or other B2B partners.
Legal basis:
Legitimate interest under the GDPR.
4.4 B2B Business Outreach
We may contact relevant professional persons with business communication where there is a reasonable business reason, a connection with their job role or business activity, and where the communication may be potentially relevant to them.
Each person has the option to object to further processing or to opt out of the communication.
Legal basis:
Legitimate interest, while respecting the rules of the GDPR and the applicable
rules on electronic communication.
The ICO states that in B2B marketing, the GDPR still applies where personal data of an individual is processed, for example the name of a specific person representing a company. At the same time, legitimate interest may be applicable in direct marketing, but this always depends on the specific circumstances and requires an assessment of the impact on the rights of the individual.
4.5 Monitoring Deliverability and Database Quality
We process technical data related to e-mail communication in order to improve deliverability, remove invalid contacts, respect opt-out requests, and keep the database up to date.
Legal basis:
Legitimate interest.
4.6 Compliance with Legal Obligations
We may process certain data for accounting, tax, archiving, or legal claims purposes.
Legal basis:
Compliance with a legal obligation or legitimate interest.
5. Legitimate Interest
For certain processing activities, we rely on legitimate interest.
Our legitimate interest includes in particular:
- development of B2B business relationships,
- identification of relevant business partners,
- provision of lead generation services,
- direct business communication in a B2B environment,
- protection of our rights and legal claims,
- maintenance of up-to-date databases,
- improvement of the quality of our services.
When processing personal data on the basis of legitimate interest, we assess whether our interests are not overridden by the rights and freedoms of the data subjects. The European Commission states that, when relying on legitimate interest, an organisation must assess whether its interest does not seriously interfere with the rights and freedoms of the individual and must inform the person about the processing.
6. How We Respect the GDPR in B2B Outreach
In B2B outreach, we follow in particular these principles:
- we contact only relevant professional persons,
- we prioritise business and professional contact details,
- we do not send random mass spam,
- we contact persons in connection with their job function,
- the communication is factual, proportionate, and commercially relevant,
- we clearly identify the sender,
- we provide the possibility to refuse further communication,
- we respect every request for removal,
- we regularly clean and update databases,
- we minimise the scope of processed personal data.
7. Who We May Disclose Personal Data To
Personal data may be disclosed only to the extent necessary to the following categories of recipients:
- our clients, if this is part of the ordered B2B service,
- providers of e-mail and communication tools,
- providers of CRM systems,
- providers of cloud services,
- accounting, tax, or legal advisers,
- IT suppliers,
- public authorities, where required by law.
With suppliers who process personal data on our behalf, we enter into appropriate contractual relationships or data processing agreements where necessary.
8. Transfer of Data Outside the EU/EEA
Some providers of technical tools may process data outside the European Union or the European Economic Area.
If such transfer takes place, we ensure that it is carried out in accordance with the GDPR, in particular on the basis of appropriate safeguards, such as standard contractual clauses or another suitable legal mechanism.
9. How Long We Retain Personal Data
We retain personal data only for as long as necessary for the purpose for which it was obtained.
Indicative retention periods:
- data from contact forms: [e.g. 24 months],
- client data during cooperation: for the duration of the cooperation and subsequently in accordance with statutory retention periods,
- accounting and tax documents: in accordance with applicable legal regulations,
- B2B lead databases: [e.g. 24–36 months], continuously updated,
- records of opt-out or objection: for the period necessary to ensure that the person is not contacted again.
If a person objects to further communication, we may retain their contact details to a limited extent in a so-called suppression list in order to ensure that we no longer contact them.
10. Rights of Data Subjects
Under the GDPR, the data subject has in particular the following rights:
- the right of access to personal data,
- the right to rectification of inaccurate data,
- the right to erasure of data,
- the right to restriction of processing,
- the right to object to processing,
- the right to data portability, where applicable,
- the right to lodge a complaint with a supervisory authority,
- the right to withdraw consent where processing is based on consent.
If processing is based on legitimate interest, the data subject has the right to object to such processing.
In the case of direct marketing, the person has the right to object at any time. After such objection has been made, we will no longer contact the person for this purpose.
11. How a Person Can Exercise Their Rights
A data subject may exercise their rights by contacting us at the following e-mail address:
info@myingredients.eu
We will respond to the request within the statutory period, generally within one month of receiving it.
12. Security of Personal Data
We adopt appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, disclosure, or damage.
These measures may include in particular:
- restricted access to databases,
- use of passwords and two-factor authentication,
- regular database cleaning,
- access rights control,
- secure cloud solutions,
- monitoring of deliverability and communication quality,
- training of persons working with data.
13. Cookies and Web Analytics
On the website www.myingredients.eu, we may use cookies or similar technologies.
Cookies may serve mainly for:
- ensuring the functionality of the website,
- traffic analytics,
- improving the user experience,
- marketing or remarketing purposes, if used.
Essential cookies may be used without consent. Analytical or marketing cookies are used only where the consent of the website visitor is required.
Details may be provided in a separate document titled Cookie Policy.
14. Automated Decision-Making
When processing personal data, we do not carry out automated decision-making that would have legal effects concerning the data subject or similarly significantly affect them.
Some technical tools may assist with filtering, segmentation, or evaluation of the relevance of B2B contacts; however, final business decisions are not subject to fully automated decision-making with legal effects.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time, in particular in the event of changes to legal regulations, our services, technologies, or the method of processing personal data.
The current version will be available on the website www.myingredients.eu.
16. Contact
If you have any questions regarding the protection of personal data or wish to exercise your rights, please contact us:
Different Expansion
Operator of the MyIngredients service
E-mail: info@myingredients.eu
Website: www.myingredients.eu
17. Effective Date
This Privacy Policy is effective from:
15 June 2026
