Prospect data & rights
Ember Lead Intelligence helps professional users identify, prioritize, and monitor relevant B2B prospects. Ember limits these workflows to information useful for a professional business relationship and keeps objection, do-not-contact, and rights request mechanisms available. This page serves as information for data subjects under Articles 13 and 14 of the GDPR, including where the data is not collected directly from them.
Who is responsible for this processing?
Prospecting missions are configured and managed by our client users, who determine their targets, channels and objectives: they act as data controllers for their prospecting. EMBER ORIGIN SAS, 16 place des Quinconces, 33000 Bordeaux, France (support@ember.do), which publishes the Ember platform, acts as a data processor on behalf of its clients, and as a data controller for the operation, security and improvement of the Platform.
What categories of data are processed?
The processing covers professional data: public LinkedIn profile information (first name, last name, job title, company, public career history and posts), professional contact details (professional email address, company, role) and public professional signals (company news, posts, job changes). No sensitive data within the meaning of the GDPR is sought or deliberately processed.
Legal basis and purposes
B2B prospect processing relies on the legitimate interest of business-to-business commercial prospecting (Article 6(1)(f) of the GDPR), following a documented balancing test between this interest and the rights and freedoms of the data subjects: the processing remains proportionate, expected in a professional context, and supported by effective safeguards. Ember documents the relevant purposes: public data sourcing, professional contact enrichment, scoring and prioritization, mission-signal monitoring, sales action preparation, and performance measurement.
Objection, opt-out, and DNC
When an objection, opt-out, or do-not-contact entry applies to a prospect, Ember blocks active actions, follow-ups, monitoring, digests, and paid enrichments for that contact. The product must apply this block before generating, copying, or sending a sales action.
Deletion, access, and export
You have the rights of access, rectification, erasure, restriction and objection. In particular, you may object at any time, without justification, to the processing of your data for prospecting purposes (Article 21 of the GDPR). Prospect rights requests are prepared for manual review by Ember support. A request may cover access, export, rectification, objection, or deletion, subject to identity checks, legal obligations, and the applicable processing context. You may also lodge a complaint with the CNIL (www.cnil.fr).
Data sources
Prospect data may come from public sources, professional signals, LinkedIn through the user's authorized connections (Unipile service), web searches performed by the agents (Serper service), contractually governed enrichment providers, and information already present in the user's workspace. Paid providers must only be triggered when the contract, DPA, and purpose are ready.
How long is the data retained?
Prospect data is retained for the duration of the user's prospecting mission, then deleted or anonymized no later than three (3) years after the last contact, in line with the standards applicable to B2B prospecting. Objections and do-not-contact entries are retained for as long as necessary to guarantee their effectiveness.
Recipients and subcontractors
Prospect data is accessible to the user managing the prospecting mission and to authorized Ember teams. It is processed by the following technical subcontractors: Unipile (LinkedIn connection, France), Serper (web search, United States), Supabase (database hosted on AWS, Paris region), the AI model providers (Anthropic, OpenAI, Google, directly or via OpenRouter, United States) when preparing messages, and FullEnrich (contact enrichment, service not active to date). The full table of subcontractors and transfer safeguards is set out in our privacy policy.
Product safeguards
- Sales actions must respect known preferences, objections, and do-not-contact lists.
- Paid enrichments must remain gated by provider availability, the applicable contract, and DPA safeguards.
- Rights requests are audited and routed to manual support review, with no automatic deletion or export from the prospect drawer.
- Audit logs should make it possible to trace the source, mission, channel, and main product decisions associated with a prospect.
Contact
To exercise a right or report an objection related to a prospect processed in Ember Lead Intelligence, contact support@ember.do. Ember may ask for additional information to verify the requester identity or the validity of the mandate presented.
Need help?
For questions about prospect data or a rights request, contact us: