Data Processing Policy
Overview
This Data Processing & Compliance Policy (“Policy”) explains how APAC Leads collects, compiles, verifies, supplies, processes, and supports the lawful use of business-to-business (B2B) contact and company data. It is intended to help customers, partners, and data subjects understand APAC Leads’ role as a data provider and processor, the standards we apply to our data practices, and the responsibilities each party holds.
This Policy should be read alongside:
- The APAC Leads Privacy Policy, which governs the handling of personal data collected through our websites, forms, and customer enquiries
- Any applicable Customer Agreement, Order Form, or Data Processing Addendum signed with APAC Leads
- The laws and regulations applicable in your target markets and jurisdiction(s)
Where any conflict exists between this Policy and a signed Customer Agreement, the terms of the Customer Agreement will prevail to the extent of that conflict.
APAC Leads’ Role
APAC Leads operates in different capacities depending on the nature of the data and the service being provided.
2.1 As a B2B Data Provider / Compiler
When APAC Leads supplies its owned or licensed B2B database-comprising business contact and company information-to customers for outreach, marketing, or lead-generation activities, APAC Leads acts as the data provider and compiler. In this capacity, the customer becomes the end user and assumes responsibility for the lawful use of that data within their operations and target markets.
2.2 As a Data Processor / Service Provider When APAC Leads processes data supplied by the customer-for services such as email appending, data enrichment, list cleansing, validation, or campaign support-APAC Leads acts as a data processor or service provider on the customer’s behalf. In such cases, the customer retains the role of data controller and remains responsible for the underlying data and the lawfulness of the processing instruction.
2.3 As a Data Controller APAC Leads acts as a data controller for personal information collected directly through its websites, lead-capture forms, newsletter subscriptions, account registrations, and business enquiries. This data is handled in accordance with the APAC Leads Privacy Policy.
Role Summary Table
| Data Type | APAC Leads' Role | Customer's Role |
|---|---|---|
| APAC Leads-supplied B2B database data | Provider / Compiler | Lawful End User |
| Customer-provided data (for enrichment, cleansing, appending, or campaign services) | Processor / Service Provider | Data Controller / Owner |
| Website enquiry, account, and subscription data | Data Controller | Data Subject / Customer |
Data Sourcing Practices
APAC Leads compiles B2B contact and company information from reputable, lawful, and publicly accessible business sources. These may include, but are not limited to:
- Corporate and business websites
- Professional directories and business listings
- Government and industry business registries
- Industry publications, trade associations, and event listings
- Approved third-party data partners and licensed datasets
- Publicly accessible professional networking profiles and career pages
APAC Leads focuses on B2B contexts - meaning data relates primarily to individuals in their professional capacity and to business entities, rather than private individuals in a consumer context. Sourcing practices, available data fields, and coverage depth may vary by country, industry, and list type.
APAC Leads aims to align its data collection and collation practices with relevant data-protection and direct-marketing regulations, including the GDPR where applicable to EU/EEA data subjects, and equivalent frameworks across the Asia-Pacific region and other target markets. We regularly review our sourcing approach in light of regulatory guidance and industry best practice.
Data Verification & Quality Controls
APAC Leads applies a multi-layered verification process designed to support the accuracy, deliverability, and currency of the B2B data it provides. Our verification approach includes:
- Automated email validation: Syntax checks, domain validation, MX record lookups, and deliverability screening to identify and flag undeliverable or invalid addresses
- Manual quality review: Structured cross-checking of business records, job titles, and company information to identify anomalies and outdated entries
- Tele-verification: For selected B2B contact lists, telephone-based verification is conducted to confirm contact details, seniority, and employment status
- Periodic database refresh: Regular review cycles to identify, update, or remove records that are outdated, no longer deliverable, or have changed since original compilation
- Optional enrichment and replacement support: Where offered under applicable service terms, APAC Leads may provide validation, data enrichment, or bounce-replacement services to assist customers in maintaining list quality over time
Note on Data Accuracy
B2B data changes frequently - professionals change roles, companies restructure, and contact details become outdated. No data provider can guarantee permanent or absolute accuracy following delivery. APAC Leads’ commitment is to apply rigorous verification at the point of compilation, maintain meaningful refresh cycles, and provide responsive customer support when quality concerns arise. We encourage customers to implement their own hygiene practices and to contact us promptly if significant quality issues are identified.
Customer Responsibilities
Customers who purchase, license, or otherwise access B2B data supplied by APAC Leads are solely responsible for ensuring that their use of that data is lawful, ethical, and compliant with all applicable laws and regulations in their target markets. APAC Leads’ supply of data does not transfer legal liability for its subsequent use.
Customers are expected to:
- Use supplied data only for legitimate, lawful business purposes consistent with the agreed scope of use
- Comply with all applicable privacy, data-protection, anti-spam, telemarketing, and electronic-communications laws in each jurisdiction where outreach is conducted
- Obtain additional consents or provide requisite notices where required by local law before initiating any communication
- Maintain appropriate technical and organizational security measures to protect supplied data against unauthorized access, loss, or misuse
- Honor and promptly process opt-out, objection, access, correction, and deletion requests received from data subjects in connection with the customer’s use of supplied data
- Refrain from unauthorized resale, redistribution, sublicensing, or public disclosure of any APAC Leads-supplied data
- Report promptly to APAC Leads any suspected misuse, unauthorized access, data breach, or incident involving supplied data
- Ensure that any third parties or subcontractors to whom supplied data is disclosed are bound by equivalent obligations
APAC Leads reserves the right to suspend or terminate access to data and services where there is reasonable evidence of misuse or non-compliance with these responsibilities or applicable law.
Applicable Legal & Regulatory Frameworks
APAC Leads serves customers targeting contacts across multiple regions and jurisdictions. Our data-handling approach takes into account a range of data-protection, privacy, and electronic-communications frameworks.
| Framework | Relevance |
|---|---|
| GDPR (EU/EEA) | Data protection principles, lawful basis for processing, and individual rights applicable where supplied data includes EU/EEA data subjects or where customers are established in the EU/EEA |
| Singapore PDPA | Obligations relating to the collection, use, and disclosure of personal data pertaining to individuals in Singapore, relevant to APAC Leads' primary operating jurisdiction |
| Australia Privacy Act | Requirements for handling personal information relating to Australian residents, applicable where supplied data includes Australian contacts or where customers are Australian entities |
| Japan APPI | Japanese requirements for personal information handling, applicable to data involving Japanese residents or businesses operating in Japan |
| China PIPL | China's personal information protection framework, including cross-border transfer considerations, relevant for data involving Chinese residents or entities |
| CAN-SPAM Act (US) | U.S. requirements for commercial email, including identification, opt-out mechanisms, and sender obligations, applicable when customers conduct email outreach to U.S. recipients |
| CASL (Canada) | Canadian requirements for commercial electronic messages, including consent requirements and unsubscribe mechanisms, applicable for outreach to Canadian recipients |
| CCPA / CPRA (California) | California privacy rights applicable where customers target California residents or where the CCPA/CPRA's business provisions apply |
| India IT Act & DPDP Act | Indian data protection and electronic communications requirements applicable to data involving Indian residents or companies operating in India |
Disclaimer: This policy is provided for general information only and does not constitute legal advice. The regulatory landscape across the Asia-Pacific region and globally is evolving. Customers should seek independent legal advice regarding their specific campaigns, target jurisdictions, data-processing activities, and compliance obligations before conducting outreach using any third-party B2B data.
Data Security & Retention
Security Measures
APAC Leads applies reasonable technical and organizational safeguards designed to protect B2B data against unauthorized access, disclosure, loss, or misuse. These measures include:
- Role-based access controls and user authentication for internal systems
- Secure transmission protocols for data delivery and platform access
- Encrypted or access-controlled storage for sensitive operational data
- Confidentiality obligations for staff and contractors with access to data assets
- Contractual safeguards where third-party vendors, partners, or service providers are involved in data processing
While APAC Leads takes reasonable steps to protect data within its custody and control, no system is entirely immune from security risks. Customers are responsible for maintaining appropriate security measures on their own systems and infrastructure.
Data Retention
APAC Leads retains data only for as long as is necessary to:
- Provide the contracted services and fulfil the applicable agreement
- Meet legal, regulatory, or contractual retention requirements
- Resolve disputes, handle complaints, or support ongoing customer relationships
- Maintain audit records and ensure compliance with applicable laws
Customer-provided data processed under a service arrangement remains the property of the respective customer and will be handled, retained, and deleted in accordance with the applicable agreement or upon receipt of a written customer instruction, subject to any legal hold or retention obligation.
Data Requests & Opt-Outs
APAC Leads has processes in place to receive and action data-related requests from data subjects, customers, and other relevant parties.
| Request Type | What It Covers |
|---|---|
| Access Request | Confirmation of what data APAC Leads holds relating to a data subject or customer, and/or a copy of that data |
| Correction Request | Update or correction of inaccurate, incomplete, or outdated data held by APAC Leads |
| Deletion / Erasure Request | Removal of a data subject's information from APAC Leads' active database, subject to applicable legal obligations and retention requirements |
| Objection / Opt-Out Request | Request to cease inclusion of a contact's details in APAC Leads' database or to prevent further supply of those details to customers |
| Suppression Request | Request to suppress a contact or domain from future data deliveries or active use, while retaining the record for suppression-list purposes |
| Customer Data Export or Deletion | A customer's request for return, export, or deletion of their own data held by APAC Leads in connection with a service engagement |
| Suspected Misuse or Breach Report | Notification of suspected unauthorized access, data misuse, or breach involving APAC Leads-supplied or customer-provided data |
How to Submit a Request
All data-related requests should be submitted in writing. To enable efficient handling, requests should include:
- The name and contact details of the requesting individual or organization
- A clear description of the request type and the specific data or record(s) concerned
- Any supporting information to assist identification and verification (e.g., email address, company name)
APAC Leads may request identity verification or additional details before actioning a request, particularly for access, deletion, or correction requests, in order to prevent unauthorized data disclosures or modifications.
We aim to acknowledge all data-related requests promptly upon receipt and to respond within a reasonable timeframe, subject to applicable legal requirements, the complexity of the request, and our verification process. Where a request cannot be fully fulfilled - for example, due to a legal retention obligation or legitimate business interest - we will explain the reason.
Phone: +65-6990-3855
Email: info@apacleads.com
Prohibited Uses
APAC Leads-supplied data must not be used for any purpose that is unlawful, deceptive, harmful, or inconsistent with the terms of the applicable Customer Agreement. Prohibited uses include:
- Sending spam or unsolicited commercial messages where consent or another valid lawful basis is required under applicable law and has not been established
- Any form of deceptive, harassing, discriminatory, or fraudulent outreach, including misrepresentation of the sender’s identity or purpose
- Unauthorized resale, redistribution, sublicensing, or public disclosure of any portion of APAC Leads-supplied data to third parties not covered by the applicable agreement
- Use of data for purposes outside the agreed business purpose or for personal, non-commercial activities
- Any use that violates applicable privacy, consumer-protection, anti-spam, telemarketing, or electronic-communications laws in the customer’s operating jurisdiction or the jurisdiction of intended recipients
- Processing of data in ways that could endanger the physical safety or welfare of any individual
- Use of data in connection with illegal goods or services, or activities that breach applicable sanctions or export-control regulations
APAC Leads reserves the right to immediately suspend supply, terminate agreements, and report suspected illegal use to relevant authorities where prohibited uses are identified or reasonably suspected.
Policy Updates
APAC Leads may update this Data Processing & Compliance Policy from time to time to reflect changes in applicable laws and regulations, our service offerings and operational practices, industry standards and regulatory guidance, or feedback from customers, partners, and data subjects.
Material updates will be communicated to existing customers where required by applicable law or where they substantially affect customer obligations. Continued use of APAC Leads’ data or services following any update constitutes acceptance of the revised Policy.
Contact APAC Leads
Need clarification about data sourcing, compliance, or your data-use obligations? Contact APAC Leads at:
Phone: +65-6990-3855Email: info@apacleads.com
Website: https://www.apacleads.com/
This policy does not constitute legal advice. Seek independent legal counsel for jurisdiction-specific compliance guidance.
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