The short version
Sink or Swim Marketing, a small Irish company in Greystones, Co. Wicklow, run by Sean Willekens.
Public business details, the contact name and email address your business publishes, and our emails with you.
Your website, your Google Business Profile, business directories and the CRO register.
To offer services we think could help your business. Our legal basis is legitimate interests.
Up to 30 days if we never email you. 6 months after our last email if you don’t reply.
Object at any time, free of charge. One reply stops everything.
Your right to object
You can object at any time to us using your details for direct marketing, including any profiling for that purpose. You don’t need to give a reason and it costs nothing. If you object, we stop.
To object, reply “no thanks” or “stop” to any of our emails, email info@sink-or-swim-marketing.com, or call (01) 960 9250. We act on objections within one business day and add you to our do-not-contact list, so you won’t be contacted again.
1. Who we are
Sink or Swim Inbound Marketing Limited, trading as Sink or Swim Marketing, is the controller of the personal data described in this notice.
- RegisteredIreland, company number 745814
- VAT numberIE4222670AH
- Registered office70 Charlesland Wood, Greystones, Co. Wicklow, A63 AE79
- Privacy contactSean Willekens, director
- Emailinfo@sink-or-swim-marketing.com
- Phone(01) 960 9250
We are a small business. We are not required to appoint a data protection officer, so we have not.
2. Who this notice is for
Owners, managers and staff of businesses that we research, or email for the first time, to offer our services. It explains how we handle your details under the GDPR (Articles 13 and 14) and the Irish ePrivacy Regulations (S.I. No. 336 of 2011).
Clients and visitors to our main website are covered by the separate privacy policy on that website.
3. What information we use
- Business details: business name, trade, address or area served, phone number, website and opening hours.
- Contact details your business publishes: a contact name and role, where published, and the email address your business lists for enquiries. This can be a webmail address (for example Gmail) if your business publishes it as its contact address.
- Public facts about your business online: for example your website’s content and speed on a phone, your Google Business Profile, overall review ratings and counts (never the names of individual reviewers) and adverts you run publicly.
- Company register details for limited companies: company number and status.
- Our correspondence: the emails we send you, your replies, and notes of what you asked us to do (for example, to stop).
- Records that keep us honest: where and when we found each detail, and whether your email address passed a validity check.
We do not use home addresses, personal social media, information about your family or private life, or any special category data.
4. Where it comes from
Only public sources:
- your business’s own website;
- your Google Business Profile and Google Maps listing, obtained through a data provider (Apify);
- business directories where a business lists itself;
- the Companies Registration Office (CRO) open data.
We do not buy marketing lists and we do not collect data from LinkedIn.
CRO data: contains Irish Public Sector Data licensed under a Creative Commons Attribution 4.0 International (CC BY 4.0) licence.
5. Why we use it, and our legal basis
| What we do | Legal basis |
|---|---|
| Find businesses that our services could help, and research them | Legitimate interests (GDPR Article 6(1)(f)) |
| Send a small number of relevant business emails: at most 3 about any one idea | Legitimate interests. For email, Regulation 13 of S.I. No. 336 of 2011, which allows this where the address appears to be used mainly for business and the email relates solely to that business |
| Handle replies, opt-outs and requests, and keep our do-not-contact list | Legal obligation (Article 6(1)(c)) and legitimate interests |
| Keep records that show we follow the rules | Legal obligation and legitimate interests |
Our legitimate interest is offering our services to Irish businesses we believe they are relevant to. We have weighed this against your interests and rights: we use business information only, write only about your business, contact you rarely, keep data for a short time and make objecting easy. You can ask us for a copy of this assessment.
7. Transfers outside the EEA
Some of these providers are based outside the European Economic Area, or may process data there, including in the United States and India. Where they do, we rely on safeguards the GDPR allows: the European Commission’s adequacy decision for the EU-US Data Privacy Framework (for certified US companies), or the European Commission’s standard contractual clauses. You can ask us for details.
8. How long we keep it
| Situation | What happens |
|---|---|
| We researched your business but never emailed you | Personal details deleted within 30 days |
| We emailed you and you didn’t reply | Personal details deleted 6 months after our last email. We keep the business name and the date we last wrote, so we don’t contact the business too often. |
| You opted out or told us you’re not interested | A minimal do-not-contact record (your email address, and your business’s web domain if you ask us not to contact anyone there), kept for as long as we do outreach, so we never contact you again |
| You became a client | Our normal client records apply |
9. Your rights
You can ask us to:
- give you a copy of the information we hold about you (access);
- correct anything that is wrong;
- delete your information;
- restrict how we use it;
- stop using it for marketing (objection, see above).
Email info@sink-or-swim-marketing.com or reply to any of our emails. It’s free, and we reply within one month.
If you’re unhappy with how we handle your data, you can complain to the Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland, at dataprotection.ie. We’d appreciate the chance to put it right first.
10. Automated tools and profiling
We use software, including AI tools, to find businesses, check public information about them (such as how fast a website loads on a phone) and decide which businesses to contact and what might help them. This is profiling for direct marketing.
It does not lead to decisions with legal or similarly significant effects on you: the only outcome is that we email you, or we don’t. You can object to it at any time.
11. Our emails and this website
Our emails contain no tracking pixels and no tracked links, so we can’t see whether or when you open them.
This website uses no cookies, no analytics and no third-party services: the fonts, images and video all come from this website itself. Our hosting provider keeps standard server logs, such as IP addresses and the pages requested, for security and troubleshooting, for a short period.
Links to Google, Trustpilot, Instagram and our other social media profiles only open those sites if you click them. Those sites have their own privacy policies.
12. Changes to this notice
We update this notice when our tools or methods change. The version number and date at the top show the latest update.