Privacy Policy

Controller & Contact Information

1. Introduction

PitchDonkey ("we", "us", "our"), operated by The AIWhisperer (Cao Hung Nguyen), provides an outreach and lead enrichment SaaS platform that lets you run cold email outreach, enrich contact/prospect data using publicly available sources (company websites, public LinkedIn etc.), manage contact lists that you upload, handle payments / account management, analytics etc. This Privacy Policy describes how we collect, process, store, protect, and share your personal data, especially for Users in the EU/EEA, in compliance with the GDPR. By using our Service, you agree to the practices described here.

2. Definitions

• Personal Data: Any information relating to an identified or identifiable natural person
• User: Any person who uses our PitchDonkey service
• Prospect/Contact Data: Information about potential customers or leads uploaded by Users
• Enriched Data: Additional information we append to contact data from publicly available sources

3. What Data We Collect

• Account / Registration Data: name, business email, company name, job title, billing address, payment information etc.
• Prospect / Contact Data provided by Users: names, emails, company, role etc uploaded or imported by you.
• Enriched Data: public business/professional information appended to your prospect/contact data (only what is publicly available).
• Usage/Technical Data: IPs, device/browser info, usage logs.
• Support / Communications Data: messages you send us.
• Cookies & Tracking Data: session cookies, analytics, possibly email open/click tracking etc.

4. How We Collect Data

• From you directly (registration, upload).
• From public sources to enrich data you supplied.
• Automatically via logs, cookies etc.
• Via third-parties / integrations (if you connect them).

5. Legal Basis for Processing

• Performance of contract (providing the Service etc.).
• Legitimate interests (enrichment, analytics, fraud prevention).
• Consent (for non-essential tracking / cookies etc.).
• Legal obligations.

6. Purpose of Processing

• Provide, maintain, improve Service.
• Account, billing, payments.
• Enrichment for your contact data.
• Outreach features (email delivery, tracking if applicable).
• Security, abuse prevention.
• Analytics, support, communications.

7. Sharing & Disclosure

• With service providers / sub-processors who help with hosting / email delivery / analytics / payments.
• Legal / regulatory authorities if required.
• In case of a merger, sale etc.
• We do not sell or provide your contact/prospect or enriched data to parties beyond those needed to operate the Service (unless you direct us to).

8. Cross-Border Transfers

May transfer data outside EU/EEA via providers / infrastructure, but we ensure appropriate safeguards (Standard Contractual Clauses, etc.).

9. Data Retention

• Keep data as long as needed for the purposes (service, billing, outreach/enrichment).
• After deletion of account, retain required records for legal / financial compliance (statutory period) then delete or anonymize.
• Enriched data retained as long as underlying contact/prospect data remains.

10. Security Measures

We implement appropriate technical and organizational measures to protect your data, including encryption, access controls, regular backups, and minimal privilege access principles.

11. Cookies, Tracking & Third-Party Tools

• Use cookies / analytics / possibly open/click tracking in outreach.
• Allow you to manage cookie preferences / disable non-essential tracking.
• Disclose what third-party tools / trackers we use.

12. Your Rights under GDPR

You have the following rights regarding your personal data:

• Access: Request access to your personal data
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your data
• Portability: Request transfer of your data
• Objection: Object to processing based on legitimate interests
• Withdraw consent: Withdraw consent where processing is based on consent

To exercise these rights, contact us at hung@theaiwhisperer.de

13. Data Breaches & Notification

In the event of a data breach that affects your personal data, we will notify you and relevant authorities in accordance with GDPR requirements.

14. Children's Privacy

Our Service is not aimed at children under 16. We do not knowingly collect Personal Data from children under that age. If discovered, we will delete it.

15. Changes to This Policy

We may update this policy; material changes will be communicated (email or notice), "Last updated" reflects changes.

16. Governing Law & Jurisdiction

This Policy is governed by German law (for The AIWhisperer / PitchDonkey), consistent with GDPR. Disputes will be handled in courts of appropriate jurisdiction in Germany, unless otherwise required by law.

17. Contact Information

If you have questions about this Privacy Policy or our data practices, please contact us at: