Sales & Marketing Operations Privacy Notice


Last Updated: 5 January 2024

We, charles GmbH (charles), would be delighted to talk to you about our product and services. Protecting your Personal Information is paramount, which is why we comply with applicable data protection laws including the General Data Protection Regulation (GDPR) and the content of this Privacy Notice in all our sales and marketing activities.

In this Privacy Notice, we describe how we collect your personal information and, subject to your consent, store and further process it to provide you with valuable information on our products and services. It goes without saying that we will never sell or even pass on your personal information or company data to any third parties apart from our contracted service providers for storage, exchange or communication of information listed below.

Kindly note that we do only conduct sales and marketing on a “B2B basis” and thus are reaching out to you in your professional capacity as representative of a publicly registered company. If you do not wish us to contact you further, please let us know, and we will not process or store any of your personal information and cease any sales or marketing activities immediately. You can easily unsubscribe from all our sales and marketing communication by clicking on the unsubscribe link in any sales or marketing e-mail you received from us or by contacting us as stated below in Section 1 of this Privacy Notice.


  1. 1. Data Controller and Contact Details

The data controller for your personal information is:

Charles GmbH

Gartenstraße 86-87

10115 Berlin, Germany


Managing Director(s): Andreas Tussing, Artjem Weissbeck

You can reach our Data Protection Team directly for any questions or inquiries or exercise any of your rights as a data subject by contacting or by using our digital reporting channel


  1. 2. Categories of Personal Information processed for Sales and Marketing Operations

Initially, the categories of Personal Information processed by us depend on whether sales or marketing activities are inbound (“you reach out to us”) or outbound (“we contact you”).

For outbound sales activities, we will initially only process your name, title, the business you represent and some information about it like its size, industry and founding date, your position and the specific professional contact detail used to contact your company or you directly (eg., website or business e-mail address). We will, however, not create any customer or prospect profile and thus not store or further process any of your Personal Information unless required to record a potential “opt-out” or unless you clearly signal us to continue our conversation or to send you further communications or book a meeting with us. Once you consent to continue, we may ask for additional Personal Information or collect such data in the course of our conversation, such as your full professional contact details, job function and more detailed company profile.

For inbound sales activities, such as if you requested information or a demo on our website, we collect Personal Information as outlined on our in our Privacy Policy ( This may, in addition to name and contact details, include your job title and role, further company details, preferred language and the features you’re interested in.

In the course of further sales operations such as preparing an offer and concluding a contract, we may process and store further Personal Information about your company as provided by you in our meetings and conversations.

For our marketing activities, if you did provide us with your express consent, we may process Personal Information as required to provide you with our updates on latest news and events such as by email or WhatsApp. To further optimize the user experience and to tailor the information provided to you, we may occasionally also process information on your specified preferences, if any, and in some instances, follow your interaction with our newsletter. In this context, we will use a market-standard customer relations management (CRM) system like Hubspot (see below) as means of processing.


  1. 3. How Personal Information for Sales and Marketing Operations is collected

We collect your Personal Information for sales and marketing activities through the following means:

  • From you personally, such as if you reach out to us on our website, via telephone call, e-mail or social media or if you provided us with your consent to contact you on one of our marketing events.
  • From third party sources such as your company’s or other publicly available sources including business news or press websites, public registers, professional social media (such as LinkedIn) or from one of our sales service providers (see below for details)


  1. 4. Purposes of processing Personal Information for Sales and Marketing Operations

We process your Personal Information for the following sales or marketing purposes:

  • to assess whether your company or business may be interested in our products and services eg based on your company’s business operations, size and industry sector;
  • to initially contact you as a company representative via telephone, email or professional social media platforms regarding our products and services;
  • to provide further information about our offerings tailored to your professional interests including updates on news and events;
  • to make your company or business a custom-tailored offer and initiate or conclude a contract on our product or services;
  • to comply with legal obligations, such as to fulfill your statutory rights (eg under applicable data protection laws).


  1. 5. Legal Basis for our Processing Activities

We process your Personal Information (i) for inbound sales activities based on your intent to potentially conclude a service contract with us for your business or company (Article 6 (1) (b) GDPR) and/or your express consent (Article 6 (1) (a) GDPR) or (ii) for outbound sales activities based on a legitimate interest assessment considering your company and business needs and relying only on your professional contact details (Article 6 (1) (f) GDPR) and, where applicable, your consent for further processing and storing your Personal Information (Article 6 (1) (a) GDPR). For our marketing activities, we process your Personal Information based on your express consent and specified interests (Article 6 (1) (a) GDPR). For offerings and sales negotiations, we process your Personal Information to prepare and conclude a contract (Article 6 (1) (b) GDPR).


  1. 6. Data Disclosure

We will never pass on or sell your Personal Information or company data to any third parties although we may share your Personal Information with our contracted service providers, acting as our data processors, for data storage, data exchange or communications, only for the purposes outlined in this Privacy Notice.


  1. 7. Means of Processing and Service Providers

We process your Personal Information using the following means and service providers:


  1. a. Collection of Information

We may collect Personal Information for our outbound sales activities only as outlined in the Privacy Notice above with the following service providers:

  • LinkedIn Sales Navigator, provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; for more information on how LinkedIn protects your privacy or for inquiries regarding the processing of your Personal Information, you may log in to your account and adjust the privacy settings or contact LinkedIn via the contact details given in their Privacy Policy (
  • Lusha Systems Inc., 800 Boylston Street, Suite 1410 Boston, MA 02199, USA; for more information on how Lusha protects your privacy or for inquiries regarding the processing of your Personal Information such as to edit your Personal Information or “opt-out” you may find more information under
  • Evaboot S.A.S., 78 Avenue Des Champs-Élysées, 75008 Paris, France registered with R.C.S. Paris under number 907 956 916; for more information on how Evaboot protects your privacy or for inquiries regarding the processing of your Personal Information you may find more information in their Privacy Policy under
  1. b. Information Storage and Administration

Personal Information collected during outbound or inbound sales activities may be stored and managed, provided consent has been given or it is necessary to comply with legal obligations under applicable data protection law, relying on:

  • HubSpot Inc, Two Canal Park, Cambridge, MA 02141 USA, a third-party data processor and CRM service provider; data is stored with Hubspot provided you have given us your consent or contacted us directly. For more information on how Hubspot protects your privacy or for inquiries regarding the processing of your Personal Information you may find more information in their Privacy Policy under
  • SharePoint by Microsoft Inc, One Microsoft Way, Redmond, WA 98052-6399, USA. Microsoft adheres to GDPR standards (
  • Salesloft, Inc., 1180 West Peachtree Street NW, Suite 2400, Atlanta, GA 30309 USA, a third-party data processor and service provider for prospect account administration which allows us to track your “opt-out” to ensure compliance with GDPR; you may find more information in the Sales Loft Privacy Policies (


  1. c. Information Exchange and Communication

Personal Information may be exchanged with you and within charles using market standard office and videoconferencing software, including:


  1. 8. Data Processing abroad

Where service providers based abroad are mentioned above in Section 7 of this Privacy Notice, we may transfer the data we process to recipients who may be located outside the European Economic Area (EEA). If these countries do not have a level of data protection comparable to European data protection laws, we will take appropriate measures to ensure that your Personal Information is adequately protected in these countries. In particular, we use service providers for data storage or CRM purposes like Hubspot, communication providers like Microsoft or Zoom or for lead generation like LinkedIn which are registered under the new EU-US Data Privacy Framework and for whom a comparable level of data protection can hence be assumed according to the EU Commission. In other cases, we will see to it that the standard contractual clauses published by the European Commission apply. You can contact our data protection officer for further information and, in particular, request access to the standard contracts concluded.


  1. 9. Retention of Personal Information

We retain your Personal Information only for as long as there is a legitimate legal justification to do so and will keep these legal bases under regular review. In particular, in our outbound sales operations, we will not store your Personal Information unless to the extent required to comply with GDPR and to fulfill your data subject’s rights by tracking your potential “opt-out” in order not to send you any further communication. If you provide us with your consent, we will keep your Personal Information as long as necessary to conclude the sales process or to provide you with further communication on our product and services. If you revoke your consent, which you may at any time, we will delete all Personal Information promptly unless name, professional e-mail address and your decision to “opt-out” in order not to provide you with any further communication.


  1. 10 Your Rights

Under the GDPR, you have the following rights which you may exercise towards our data protection contact as provided in Section 1 of this Privacy Notice:

  • Right to Access Personal Information (Article 15 GDPR): You have the right to confirm whether and how we process Personal Information about you and, if so, have access to the processed information.
  • Right to Rectification (Article 16 GDPR): You have the right to request correction of inaccurate Personal Information.
  • Right to Erasure (Article 17 GDPR): Under certain circumstances, you have the right to request the deletion of your Personal Information.
  • Right to Restriction of Processing (Article 18 GDPR): Under certain circumstances you have the right to request restriction of the processing of your Personal Information.
  • Right to Data Portability (Article 20 GDPR): You have the right to receive the Personal Information concerning you, which you provided to us, in a structured, commonly used, and machine-readable format.
  • Right to Object (Article 21): You have the right to object to the processing of your Personal Information for reasons arising from your particular situation in the event that we processing your Personal Information based on legitimate interests (Article 6 (1) (f) GDPR) such as in case of our initial contact in outbound sales activities.
  • Right to file a complaint to a supervisory authority (Article 77 GDPR). You may contact the competent supervisory authority for our registered headquarter in Berlin (Berliner Beauftragte für Datenschutz und Informationsfreiheit, Friedrichstr. 219, 10969 Berlin).


Withdraw Consent

If we process or store your Personal Information based on your consent, then you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.



  1. 11. Data Security

We take appropriate measures to ensure the security of your Personal Information in our sales and marketing activities which is why we have certified our Information Security Management System under the ISO 27001:2013 Industry Standard.


  1. 12. Changes to This Privacy Notice

We may update this privacy notice to reflect changes in our sales or marketing practices. Please check this page periodically for updates.