Privacy Policy
This policy explains what personal data RedditLab24 processes, where it comes from, why we process it, and how you can object or ask us to delete it. It covers this website and any business email we send.
If you received an unsolicited email from us and want it to stop, reply with the word UNSUBSCRIBE, or write to alex@redditlab24.net. We remove the address and add it to a permanent suppression list. No explanation needed.
1. Who is responsible for your data
The data controller is:
Aleksandr Roganin, operating as RedditLab24, sole trader
12F, No. 32, Gongyuan Rd., Zhongzheng Dist.
Taipei City 100, Taiwan
Email: alex@redditlab24.net
RedditLab24 is a trading name, not a separate legal entity. We have not appointed a Data Protection Officer, as we are not required to under Article 37 GDPR. For anything relating to your data, write to the address above — we handle these requests directly.
2. What data we process
| Category | Examples |
|---|---|
| Business contact data | Name, job title, business email address, employer, company website, publicly listed professional profile |
| Brand mention data | Public posts, comments and threads that mention a brand we are analysing: the text itself, the username or handle that wrote it, the community or subreddit, the date and the link |
| Analysis we generate | Summaries, sentiment and volume figures, themes and short verbatim quotes drawn from the brand mention data above, produced with the help of automated language models |
| Correspondence | Emails you send us and our replies, including any details you choose to share |
| Client data | For clients: company details, billing information, project briefs and approvals |
| Technical data | Server logs generated when you visit this site: IP address, user agent, requested page, timestamp |
We do not process special category data (health, beliefs, biometrics and similar) and we ask you not to send it to us. Our analysis produces no automated decision with legal or similarly significant effects on anyone, so Article 22 GDPR does not apply.
3. Where we get it, and how we contact you
Business contact data is collected from publicly available sources: company websites, published team and contact pages, business directories, public professional profiles and public posts. We do not buy contact lists, and we do not scrape private or login-protected areas of any platform.
Brand mention data is collected from publicly accessible discussion platforms, principally Reddit. We read what is already public. We do not log in to view restricted content, we do not contact the people who wrote the posts, and we do not attempt to identify them, resolve a username to a real name, or build a profile of any individual poster. Usernames appear only where they are already attached to the public post being quoted.
Each analysis is prepared for one brand and sent to that brand once. If the recipient asks for the full version, we send it. That is the whole sequence — we do not run follow-up campaigns and we do not re-contact people who did not reply.
This section is our notice under Article 14 GDPR, which applies when personal data is obtained from a source other than the individual. If you would like to know the specific source for your own record, ask and we will tell you.
3a. If you were quoted in one of our analyses
This part is for people whose public posts we quote, rather than the brands we write to. You did not ask to hear from us, and you may not know we exist, so here is the plain version.
- What we use: the text of your public post or comment, the username attached to it, the community it appeared in, the date and the permalink.
- Why: to show a brand what is being said about it publicly, in context. Our legal basis is legitimate interests under Article 6(1)(f). Reporting on public discussion of a product is, in our view, a use that a person posting publicly about that product would find unsurprising.
- How much: we prefer aggregated figures and themes. Verbatim quotes are kept short and used only where the specific wording matters. We do not quote posts unrelated to the brand being analysed.
- Who sees it: the brand the analysis is about, and no one else. We do not publish these analyses and we do not sell them on.
- How long: source material is deleted once the analysis is delivered or the lead is closed, and in any case within 12 months.
- Your rights: everything in section 7 applies to you as well, including the right to object under Article 21(1). Send us the permalink and we will remove the quote and delete the underlying record. We will not ask you to prove ownership of the account beyond what is needed to identify the post.
Requests go to alex@redditlab24.net. If an analysis containing your words has already been delivered to a brand, tell us and we will pass the removal request on to them.
4. Why we process it, and on what legal basis
| Purpose | Legal basis |
|---|---|
| Sending business-to-business introductions about our service | Legitimate interests — Article 6(1)(f) UK/EU GDPR |
| Collecting public brand mentions and preparing the analysis we send | Legitimate interests — Article 6(1)(f) |
| Replying to your enquiry | Legitimate interests, or steps prior to a contract — Article 6(1)(b) |
| Delivering the service to clients and invoicing | Performance of a contract — Article 6(1)(b) |
| Keeping a suppression list of people who opted out | Legal obligation and legitimate interests — Articles 6(1)(c) and 6(1)(f) |
| Keeping accounting records | Legal obligation under Taiwanese tax law — Article 6(1)(c) |
| Operating and securing this website | Legitimate interests — Article 6(1)(f) |
Our legitimate interests assessment, in short
We contact people in a professional capacity, at business addresses, about a service relevant to their role. We send one message per brand, containing work we have actually done on that brand rather than a generic pitch, and we identify ourselves honestly. There is no sequence and no follow-up unless the recipient asks for one. We consider this a proportionate use of business contact data that a professional would reasonably expect. If you disagree in your own case, your objection wins — see section 7.
For the people quoted inside an analysis, the balancing test is set out in section 3a: public material, minimal extraction, a single private recipient, short retention, and removal on request.
Where the law of your country requires prior consent for unsolicited commercial email to individuals, we rely on consent instead and will not contact you without it.
5. How long we keep it
- Outreach contact data: up to 12 months from the last meaningful contact, then deleted.
- Suppression list: retained indefinitely. We keep the minimum needed — normally a hashed or plain email address — precisely so we never contact you again. This is why an opt-out is not a full erasure.
- Brand mention data and generated analyses: deleted once the analysis is delivered or the lead is closed, and in any case within 12 months.
- Correspondence: up to 24 months, unless it forms part of a client record.
- Client and accounting records: as required by Taiwanese tax law, currently five to seven years.
- Server logs: retained by our hosting provider on their standard schedule, typically under 30 days.
6. Who we share it with
We do not sell personal data and we do not share it for anyone else's marketing. We use a small number of processors to run the business:
- Cloudflare, Inc. — domain registration, DNS, CDN and website hosting.
- Our email provider — sending and receiving mail on this domain.
- Our AI provider — automated language models used to summarise public brand mentions into the analysis. Content sent for processing is not used to train their models.
- Our payment processor — for clients only, to issue and collect invoices.
- Professional advisers and authorities — where we are legally required to disclose.
These providers operate in the United States and elsewhere, so your data may be transferred outside the EEA, the UK or your home country. Where that happens, transfers are covered by the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or the EU–US Data Privacy Framework, depending on the provider.
7. Your rights
Subject to the conditions in the applicable law, you can ask us to:
- Access the personal data we hold about you, and receive a copy.
- Correct anything inaccurate or incomplete.
- Erase your data where we no longer have grounds to keep it.
- Restrict or object to our processing.
- Receive your data in a portable format, where the right applies.
Direct marketing is absolute. Under Article 21(2) GDPR you can object to marketing at any time, for any reason or none, and we must stop. There is no balancing test and we will not ask you to justify it.
To exercise any right, email alex@redditlab24.net. We respond within one month. Exercising your rights is free, and we will not treat you differently for it.
If you are unhappy with how we handled your request, you can complain to a supervisory authority: in the EU, the data protection authority of your country of residence; in the UK, the Information Commissioner's Office (ico.org.uk); in Taiwan, the Personal Data Protection Commission. You may complain without contacting us first, though we would rather have the chance to fix it.
8. Notice for recipients in the United States
Our commercial emails comply with the CAN-SPAM Act of 2003. Specifically: header and sender information is accurate and not misleading, subject lines reflect the content of the message, each message identifies itself as a commercial message and includes our valid physical postal address (section 1 above), and each message contains a working opt-out. Opt-out requests are processed within ten business days and at no cost to you. We do not transfer opted-out addresses to any third party for their own use.
If you are a California resident, we do not sell or share personal information as those terms are defined by the CCPA/CPRA, and we do not use personal information for cross-context behavioural advertising.
9. Notice under Taiwan's Personal Data Protection Act
The purposes of collection are set out in section 4, corresponding to marketing (040), business administration (090) and contract management (069) under the PDPA classification. Data may be used within and outside Taiwan, for the periods in section 5, by us and by the processors in section 6. Under Article 3 of the PDPA you may request review, copies, correction, supplementation, suspension of processing or deletion, and you are free to decline to provide data — though we may then be unable to reply or deliver a service. Where we use your data for marketing, we will stop upon your first request.
10. Cookies and tracking
This site sets no cookies. There is no analytics, no advertising pixel, no session tracking and no cross-site profiling. Fonts are served from this domain rather than from a third-party font service, so loading this page does not disclose your IP address to a font provider. Our emails contain no tracking pixels, so we cannot tell whether you opened one.
Our host records standard server logs for security and abuse prevention, as described in sections 2 and 5. Cloudflare may set a strictly necessary security cookie to detect malicious traffic; it does not track you across sites.
11. Security
Data is held in access-controlled accounts protected by unique credentials and two-factor authentication, and all traffic to this site is encrypted in transit with TLS. No system is perfectly secure, but we keep the data footprint small on purpose: the less we hold, the less there is to lose.
12. Children
This is a business-to-business service. It is not directed at children, and we do not knowingly collect data from anyone under 18. If you believe we hold a child's data, tell us and we will delete it.
13. Changes to this policy
If we change this policy we will update the effective date at the top of the page. Material changes affecting how we use data already collected will be communicated to affected people by email where we hold a valid address.
14. Contact
Questions, requests and complaints: alex@redditlab24.net, or by post to the address in section 1. We answer every message, including the ones telling us to go away.