What qualifies as “publicly available” contact info?
The concept of publicly available data is frequently misunderstood in cold email contexts.
Generally considered public:
Contact pages on company websites
Published press releases and media kits
Government registries and filings
Professional directories where listing is voluntary
Business cards shared at events
More ambiguous:
LinkedIn profiles (public to users but governed by terms of service)
Social media profiles (platform rules apply)
Conference attendee lists (often have usage restrictions)
Professional association directories (may restrict commercial use)
Critical distinction:
Public availability is a question of access
Permission to use is a separate question
Under GDPR, public availability doesn't automatically provide lawful basis for marketing
Context matters: a journalist's email published for press inquiries may not be appropriate for sales outreach
Practical test: Would the person reasonably expect to receive your type of message based on where they published their contact information?
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