As a cold emailer, your legitimate interests are always weighed against the data subject’s right to privacy. You must make it clear why this particular person might want to hear from you. You must have a legitimate interest for each person you prospect which makes purchasing a list built by a third party could get you into trouble.
First, Identify the legitimate interest and be prepared to answer the question “how did you get my email address?”
Your response needs to clearly describe the method you used and your legitimate interest:
- A Bad response citing your legitimate interest: “I bought a list of emails from a freelancer on Upwork”
- A Good response citing your legitimate interest: “In the process of my research, I discovered that your company recently changed CRMs and may be interested in our software that help companies who use ‘Abc CRM’ send and track email communication with prospects. After confirming that you are the VP of Sales, I researched that your company uses the same email pattern (FirstInitial.LastName@company.com), so I sent an introduction email and a Linkedin connection inquiring if you are interested in speaking to learn more.”