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Privacy texts

You are the controller of your subscribers' data and Closed Loop processes it for you. These are the two texts your side needs. Closed Loop's own side is public: the Enrich sections of the privacy notice, the data processing terms and the sub-processor list.

Privacy notice (Enrich)Data processing terms (Enrich)Sub-processors (Enrich)

Your details
Both texts below fill in as you type. Nothing here is saved; copy the texts when they read right.
Article 14 notice
Your subscribers gave you their address, not their job: GDPR Art. 14 says you must tell them what you derive, from where and why. Paste this into your privacy policy. Then tell your list within a month of the first run, for example with one line and a link in your next issue.
How Compound Weekly learns about its readers

When you subscribe to [your newsletter], Compound Weekly learns more about which companies and roles its readers come from, so it can write for them and offer them things that fit. To do that we use Closed Loop Enrich, which matches subscriber email addresses to public professional information.

Who is responsible: Compound Weekly is the controller of this data. Contact: [your privacy email].

What we collect and where it comes from: from public professional profiles and company websites, the information anyone can see without logging in, we derive your company, industry, company size, job title, seniority band, job function, country and the public profile link. We do not use private accounts or anything behind a login. Using what we know about your role and company, we also give each subscriber a grade for how well our offers fit. The grade is not a decision with legal or similarly significant effects on you.

Why, and on what basis: to understand our readership and tailor what we send and offer. Our legal basis is our legitimate interest in understanding our readers (GDPR Art. 6(1)(f)). We have assessed it against your interests. If you are in the EU, the EEA or the UK, we keep company-level information only (company, industry, company size, seniority band, job function and country) unless that assessment says otherwise.

Who receives it: Closed Loop, which processes it for us, and the sub-processors Closed Loop uses, listed at https://enrich.getclosedloop.io/legal/subprocessors#enrich. We do not sell your data.

Transfers: this processing happens in the United States, under the European Commission’s Standard Contractual Clauses and the UK Addendum.

How long: the raw lookup answer is kept for 30 days and then reduced to company, seniority band, job function and country. The derived information stays while you are on our list. Ask us and we delete it.

Your rights: you can ask us for a copy of your data, to correct it, to delete it, to restrict it or to object to this processing, at [your privacy email]. You can stop all enrichment of your address at once at https://enrich.getclosedloop.io/remove. You can also complain to your data protection authority.
Legitimate interest assessment
Your legal basis for enriching subscribers is legitimate interest (GDPR Art. 6(1)(f)), and you must be able to show you weighed it. What Enrich does and the safeguards it applies are filled in; replace the [bracketed] parts with your own judgement and keep the result with your records. If it supports full fields for EU and UK subscribers, record it under Settings → EU and UK contacts.
Legitimate interest assessment: enriching the subscribers of [your newsletter]
Controller: Compound Weekly · Contact: [your privacy email] · Date: 2026-11-05 · Review: every 12 months, or when the purpose or the tool changes

1. Purpose test: what is the legitimate interest?
- Interest: understanding which companies and roles read [your newsletter], so that Compound Weekly can write for its readers and offer them products and sponsorships that fit.
- Benefit to us: [e.g. fewer irrelevant offers sent, better-matched sponsors, a clearer picture of the readership].
- Benefit to subscribers: offers and content that fit their role, instead of the same email to everyone.
- Is the interest lawful and clearly stated? Yes: it is described in our privacy notice (Article 14 text, added on [date]).

2. Necessity test: is this processing needed for it?
- What is processed: the subscriber’s email address, sent to Closed Loop Enrich, which derives company, industry, company size, job title, seniority band, job function, country and the public profile link from public professional profiles and company websites, and a fit grade.
- Could we do it with less? A sign-up survey reaches few readers and goes stale. [Note anything you tried, and why it was not enough.]
- Minimisation: derived fields only; raw lookup answers reduced after 30 days; EU, EEA and UK subscribers kept to company-level fields (company, industry, company size, seniority band, job function and country) unless this assessment supports full fields.

3. Balancing test: do the subscriber’s interests override ours?
- Relationship: the people concerned subscribed to [your newsletter] and receive it from us. [Business or personal readership? Mostly work addresses?]
- Reasonable expectation: professional information people publish to be found in a work context, used by a publication they chose to receive. [Do your sign-up form or welcome email say you learn about readers?]
- Nature of the data: professional, not sensitive; no special categories; no private accounts and nothing behind a login (Enrich never uses session cookies).
- Impact: the grade only decides which offers we send. It has no legal or similarly significant effect. [Any vulnerable readers, e.g. a list for students or patients? If so, do not enrich them.]
- Safeguards: Article 14 notice; a one-click opt-out that covers every customer of Closed Loop (https://enrich.getclosedloop.io/remove); a global suppression list honoured on every run; no shared people database across customers; data processing terms and listed sub-processors (https://enrich.getclosedloop.io/legal/subprocessors#enrich).

Outcome
- Conclusion: [Legitimate interest applies / does not apply]. For subscribers in the EU, the EEA and the UK: [company-level fields only / full fields].
- Decided by: [name, role] on [date].
- Where this assessment is kept: [link or file path]. Record it in Closed Loop Enrich under Settings → Privacy → EU and UK contacts if you chose full fields.