Lead Generation Solus Email and Engagement Signal Campaigns Terms & Conditions

These Terms apply to lead generation, solus email, nurture, multiple-touch and engagement signal campaigns supplied by Executive Grapevine International Ltd (EGIL). They must be read with EGIL's General Terms and Conditions for Commercial Partners, Privacy Policy, applicable Data Sharing Schedule and the Booking Form.

The Booking Form identifies the product purchased and any campaign-specific targeting, delivery, data, retention and permitted-use requirements. A Named High-Engagement Signal is not a lead or an enquiry unless the individual has separately taken the action required to become a Qualified Response.

1. DEFINITIONS

1) 'Account Engagement Signal' means aggregated or company-level information indicating engagement by professionals associated with an organisation, which does not directly identify an individual.

2) 'Business Contact Information' means an individual's name and limited professional details, which may include corporate email address, job title, employer, business location and telephone number where lawfully supplied.

3) 'Campaign Data' means Personal Data, Business Contact Information, Account Engagement Signals, Named High-Engagement Signals, Qualified Responses and campaign reporting supplied or generated under the Contract.

4) 'Data Sharing Schedule' means the document specifying the parties' roles, data fields, lawful-basis responsibilities, Permitted Purpose, retention, security and other requirements for a campaign involving Personal Data.

5) 'Engagement Criteria' means the objective threshold stated in the Booking Form or Data Sharing Schedule for determining whether engagement qualifies as a Named High-Engagement Signal.

6) 'Lead' means a Qualified Response supplied to the Buyer following an affirmative interaction with a campaign, as defined in the Booking Form.

7) 'Named High-Engagement Signal' means limited Business Contact Information and a broad professional-interest category relating to a registered reader whose meaningful engagement with clearly identified Partner Content has met the Engagement Criteria. It is not an enquiry, purchase intention, recommendation or request to be contacted.

8) 'Nurture Campaign' means agreed follow-up activity delivered by EGIL to individuals who previously engaged with a campaign for the Buyer.

9) 'Partner Content' means content or resources that clearly identify the Buyer as the associated commercial partner.

10) 'Permitted Purpose' means the specific, limited use of Campaign Data stated in the Booking Form or Data Sharing Schedule.

11) 'Qualified Response' means an individual who has taken an affirmative action specified in the Booking Form, such as requesting content, registering for an activity or asking to be contacted, in circumstances where their details may lawfully be supplied to the Buyer.

12) 'Solus Email Campaign' means an email campaign sent by EGIL to a selected part of its audience on behalf of the Buyer, without disclosure of EGIL's recipient list to the Buyer unless an individual becomes a Qualified Response.

13) 'Multiple-Touch Engagement' means engagement with two or more campaign elements within the period stated in the Booking Form.

14) Capitalised expressions not defined in these Terms have the meanings given in the General Terms and Conditions for Commercial Partners.

2. CAMPAIGN DATA AND RIGHTS OF USE

1) Personal Data is not owned by either party. Nothing in the Contract transfers ownership of an individual's Personal Data to the Buyer.

2) Where EGIL lawfully supplies a Lead, Qualified Response or Named High-Engagement Signal, the Buyer receives a limited, non-exclusive and non-transferable right to use the supplied information solely for the Permitted Purpose and retention period stated in the Booking Form or Data Sharing Schedule.

3) For a Solus Email Campaign, EGIL's recipient list and all information about recipients who do not become Qualified Responses remain confidential to EGIL and must not be disclosed to the Buyer.

4) Account Engagement Signals may be used only for account prioritisation, campaign planning and other purposes expressly stated in the Booking Form. The Buyer must not attempt to identify the individuals represented by an Account Engagement Signal.

5) EGIL retains all intellectual property rights in its databases, methodologies, engagement thresholds, scoring systems, Campaign Data structures, reports and aggregated insights.

3. DATA PROTECTION ROLES AND LAWFUL BASIS

1) Each party shall comply with applicable Data Protection Legislation and the data protection section of the General Terms and Conditions for Commercial Partners.

2) Where EGIL supplies Personal Data to the Buyer, EGIL and the Buyer normally act as independent Controllers for their respective Processing unless a Data Sharing Schedule expressly states otherwise.

3) Each party is responsible for identifying and documenting its own lawful basis. Receipt of Campaign Data does not establish the Buyer's lawful basis and does not constitute consent to electronic marketing.

4) Where either party relies on legitimate interests, it must complete and retain an appropriate Legitimate Interests Assessment before Processing begins and keep the assessment under review.

5) EGIL shall determine the lawful basis and collection method applicable to each EGIL campaign. The relevant basis, data fields and restrictions must be recorded in the Booking Form or Data Sharing Schedule where Personal Data is supplied.

6) The Buyer shall provide EGIL, before delivery, with its current privacy notice, intended lawful basis, intended contact method, retention period and any other information reasonably required to assess lawful use.

7) Where consent is required for a particular campaign activity, neither party may substitute legitimate interests merely because consent has not been obtained.

4. NAMED HIGH ENGAGEMENT SIGNALS

1) A Named High-Engagement Signal may be created only from meaningful engagement with Partner Content that clearly identifies the Buyer before the relevant engagement is counted.

2) The Engagement Criteria must be objective, documented before campaign launch and stated in the Booking Form or Data Sharing Schedule. A single page impression, advertisement impression, email open or brief accidental visit shall not qualify.

3) Unless otherwise approved following a documented assessment, the signal supplied to the Buyer is limited to:

(a) name;

(b) corporate email address;

(c) job title and employer;

(d) business location where relevant;

(e) broad professional-interest category;

(f) engagement level or band; and

(g) date or recency band of the qualifying engagement.

4) EGIL shall not supply the individual's complete browsing history, detailed article-by-article history, scroll history, exact reading times or unrelated engagement unless separately justified, disclosed and recorded in the Data Sharing Schedule.

5) A Named High-Engagement Signal must not be represented as a Lead, enquiry, endorsement, recommendation, purchase intention or request for contact.

6) The Buyer may use a Named High-Engagement Signal only for proportionate business-to-business communication directly related to the supplied professional-interest category. Unless the Booking Form states otherwise, first contact must occur within 30 days and no more than three contact attempts may be made without a response.

7) The Buyer must identify itself, explain that the information was supplied by HR Grapevine, provide required privacy information and offer a simple method of objecting to further contact.

8) Neither party shall infer or disclose health, ethnicity, religion, political opinion, trade union membership, sexual life or orientation, or another Special Category Data attribute from engagement. Content on a potentially sensitive topic must be classified only as a broad professional interest unless a separate lawful basis and Article 9 condition have been documented.

5. LEAD GENERATION

1) The action required for an individual to become a Lead must be stated in the Booking Form and clearly explained to the individual at the point of interaction.

2) The information supplied for each Lead is limited to the fields stated in the Booking Form or Data Sharing Schedule and must be relevant to the campaign action taken by the individual.

3) EGIL shall provide appropriate information about the identity of the Buyer, the purpose of disclosure and the applicable privacy terms at the point required by Data Protection Legislation.

4) The Buyer acknowledges that a Lead demonstrates the specified campaign action only. EGIL gives no warranty that the person has budget, authority, a live procurement requirement or an intention to purchase unless the Booking Form expressly includes and defines that qualification.

5) Any replacement criteria, validation rules or exclusions must be expressly stated in the Booking Form. Unless stated otherwise, job changes, non-response after delivery or the Buyer's sales assessment do not automatically make a Lead invalid.

6. SOLUS EMAIL CAMPAIGNS

1) EGIL selects recipients and sends the Solus Email Campaign through its own systems. The Buyer does not acquire access to EGIL's underlying audience or recipient list.

2) The email must clearly identify EGIL as the sender or the organisation sending on the Buyer's behalf, identify the Buyer and include the information required by applicable electronic marketing rules.

3) Every email must include a functioning method for recipients to unsubscribe or object. EGIL controls suppression against its own lists, and the Buyer must apply any objection relevant to its subsequent Processing.

4) The Buyer receives aggregate delivery and engagement reporting. A recipient's identity may be supplied only where the campaign terms and lawful basis permit it, including where the recipient becomes a Qualified Response or separately qualifies for a Named High-Engagement Signal.

5) Email opens may be incomplete or inaccurate because of privacy technologies, image blocking, automated security scanning and other technical factors. Open and click reporting is therefore indicative.

7. CAMPAIGN PERFORMANCE AND DELIVERY

1) Campaign performance, scale, response, engagement and availability may be affected by market conditions, audience availability, targeting, timing, competing campaigns, prior exposure, saturation and the quality and relevance of Buyer Materials.

2) Lead estimates, audience forecasts, engagement projections and delivery assumptions are indicative unless expressly guaranteed in the Booking Form.

3) If targeting, compliance restrictions, approvals or Buyer instructions materially restrict delivery, EGIL may recommend changes to the targeting, timing, criteria, audience or format.

4) The Buyer's refusal of a commercially reasonable recommendation does not constitute a failure by EGIL where the original requirement is not reasonably deliverable.

5) EGIL is not liable for reduced performance or scale to the extent caused by:

(a) restrictive or niche targeting;

(b) limited reachable audience;

(c) late, incomplete or unsuitable Buyer Materials;

(d) market saturation or audience fatigue; or

(e) changes in market conditions or audience responsiveness.

6) EGIL may delay, amend or suspend a campaign where Buyer Materials are likely to impair effectiveness, deliverability or legal compliance.

8. NURTURE AND MULTIPLE TOUCH CAMPAIGNS

1) A Nurture Campaign may be delivered only to the audience and for the Buyer identified in the Booking Form, using the agreed timing, channels and content.

2) The Buyer must supply nurture content and resources by the agreed campaign start date. Later additions or material changes require written agreement and may affect timing or price.

3) A person becomes a nurtured Lead only if the definition and qualifying events are stated in the Booking Form. Completion of scheduled follow-up activity does not itself demonstrate purchase intention.

4) Multiple-Touch Engagement means only that the individual completed the specified interactions. At least one counted interaction must contain any transparency information required for the intended use and disclosure.

5) Where nurture or multiple-touch activity uses profiling or scoring, EGIL shall explain the categories and purposes as required by law. Human intervention rights apply only where the law provides them, including where solely automated processing produces legal or similarly significant effects.

9. BUYER OBLIGATIONS

1) Before campaign launch or data delivery, the Buyer shall:

(a) provide a current privacy notice and accurate company details;

(b) identify and document its intended lawful basis;

(c) complete EGIL's compliance questionnaire and, where applicable, a Legitimate Interests Assessment;

(d) describe its intended contact methods, purpose, retention and geographic scope;

(e) confirm whether it will apply additional profiling, scoring or automated decision-making;

(f) maintain appropriate security, complaint and breach-response procedures; and

(g) ensure that Buyer Materials and claims are lawful, accurate, substantiated and suitable for the intended audience.

2) The Buyer shall use Campaign Data only for the Permitted Purpose and shall not sell it, disclose it onward, use it for unrelated marketing or recruitment, enrich it for an incompatible purpose, infer sensitive attributes or use it to train an artificial intelligence model without EGIL's prior written agreement and a separately established lawful basis.

3) The Buyer shall provide privacy information required under Article 14 of the UK GDPR or EU GDPR, where applicable, at first contact and within the applicable statutory period.

4) The Buyer shall comply with every objection, unsubscribe and suppression request and shall notify EGIL where the request affects data supplied or activity performed by EGIL.

5) The Buyer must not describe a Named High-Engagement Signal as a Lead when communicating with the individual or within campaign reporting.

6) Late, incomplete or unsuitable Buyer Materials may reduce delivery, cause loss of a reserved slot or require rescheduling without liability to EGIL to the extent provided in the General Terms.

10. SECURITY RETENTION RIGHTS AND TRANSFERS

1) Each party shall implement appropriate technical and organisational measures proportionate to the risk, including access controls, secure transfer, staff training and appropriate testing.

2) EGIL shall retain Campaign Data according to its retention schedule and the campaign purpose. The Buyer shall retain supplied Personal Data only for the period in the Booking Form or Data Sharing Schedule. Unless stated otherwise, Named High-Engagement Signals must be deleted after 90 days unless a direct relationship has lawfully been established.

3) At the end of the applicable period, the Buyer shall securely delete or irreversibly anonymise the supplied Personal Data unless retention is required by law.

4) Each party is responsible for responding to rights requests concerning its own Processing. The parties shall promptly forward relevant requests and provide reasonable assistance to one another.

5) The Buyer shall notify EGIL without undue delay, and where practicable within 24 hours, of a Personal Data Breach, complaint, regulatory enquiry or rights request concerning Campaign Data supplied by EGIL.

6) Personal Data may be transferred outside the United Kingdom only where the transfer complies with applicable Data Protection Legislation and an appropriate transfer mechanism is in place. EU Personal Data must also be handled in accordance with applicable EU transfer requirements.

7) The Buyer remains responsible for transfer mechanisms required for its own systems, group companies and service providers and shall provide reasonable evidence of those safeguards on request.

11. LIABILITY PRIORITY AND SUSPENSION

1) Liability under these Terms is governed by the General Terms and Conditions for Commercial Partners.

2) EGIL does not warrant the commercial outcome, completeness, continuing accuracy, responsiveness or fitness for an unstated purpose of Campaign Data.

3) EGIL is not responsible for the Buyer's unlawful communication, incompatible use, failure to provide privacy information, failure to honour an objection, onward disclosure or retention beyond the permitted period.

4) EGIL may suspend a campaign or data delivery, or require the Buyer to stop using and delete Campaign Data, where EGIL reasonably believes that the Buyer has breached these Terms, the Data Sharing Schedule or Data Protection Legislation.

5) If these Terms conflict with the General Terms, these Terms take precedence for lead generation, solus email and engagement signal Services. A Data Sharing Schedule takes precedence for the Processing of Personal Data, and the Booking Form takes precedence for the expressly agreed commercial scope.

Executive Grapevine International Ltd

Registered in England & Wales: 2789779 | VAT: 6259453 20

Gate House, Fretherne Road, Welwyn Garden City, AL8 6NS, United Kingdom | +44 (0)1707 351451

Last reviewed by: Helen Fish, Director, 11 September 2026