What we hold, why, and how to make us stop.

Gulf & Ponte is the controller.

Gulf & Ponte is a business-to-business lead generation firm, founded and run by Yared Asefa. For our own contact records and our own marketing, we are the controller of the data described here.

Email: [email protected]

Gulf & Ponte operates from the United States. If you need our postal address in writing — to make a request, or to satisfy your own records — email us and we will send it.

Business contact data, and nothing beyond it.

• Name
• Job title
• Business email address
• Employer
• Publicly available professional information about the person's role

We do not seek or hold personal email addresses, home addresses, personal phone numbers, or any special category data.

Two sources, both stated.

Publicly available web sources, and licensed business-to-business contact data providers. We do not collect contact data from you directly unless you email us.

Business-to-business marketing.

We contact people at companies about services relevant to their professional role. That is the whole of it. We do not use this data for advertising, for profiling, or for any purpose unconnected to that contact.

Legitimate interests, Article 6(1)(f).

We rely on legitimate interests under Article 6(1)(f) of the UK GDPR. The interest is in marketing relevant professional services to businesses that plausibly need them.

We have weighed that against the interests and rights of the people we contact, and we limit the processing to match: business contact details only, work-relevant messages only, and an immediate stop on request.

For direct marketing, this right is absolute.

There are two ways to exercise it. They have exactly the same effect:

Either way, we add you to a permanent suppression list so you are not contacted again.

Access, correction, erasure, and the rest.

• Access the personal data we hold about you
• Have inaccurate data corrected
• Have your data erased
• Restrict how we process it
• Receive it in a portable form

You can also complain to a supervisory authority. In the UK that is the Information Commissioner's Office; elsewhere it is the data protection authority for your country. We would rather you came to us first, but you are under no obligation to.

Reviewed every 24 months. Suppression is forever.

Prospect contact records are reviewed at least every 24 months. If there has been no engagement and the person no longer appears to hold the role we were contacting them about, the record is deleted.

Suppression records are the deliberate exception. If you opt out or object, we keep a minimal record — enough to recognise your address and exclude it — permanently. It is the only way to guarantee you are never contacted again. Suppression records are never used for marketing.

We never sell or transfer contact data.

We do not sell contact data, and we do not pass it to anyone else for their own use. We use third-party software to store data and send email, and those providers process it only on our instructions. That is the extent of it.

This site sets no cookies and runs no analytics.

No tracking pixels, no third-party scripts, no hosted fonts, no embeds of any kind. Every file this site loads comes from this site. Nothing here reports your visit to anyone, and there is no banner to dismiss because there is nothing to consent to.

If this changes, the date changes.

If we change how we handle personal data, we will update this page and change the date at the top of it.