CYBORA
Last updated: 2026-01-30
1. Purpose
This Outbound Communications & Marketing Policy (“Policy”) describes how CYBORA conducts outbound communications in a lawful, transparent, and responsible manner.
The Policy applies to outbound calls, messages, emails, and other direct communications conducted by CYBORA or on behalf of its clients.
Its purpose is to ensure compliance with applicable data protection, telecommunications, and consumer protection laws.
This Policy forms part of CYBORA’s overall compliance and trust framework.
2. Scope
This Policy applies to:
- outbound telephone calls (manual or automated),
- AI-assisted or voice bot communications,
- sales, marketing, research, and customer engagement activities,
- B2B and B2C communications.
The Policy applies to activities targeting individuals in the European Union, United Kingdom, and United States.
3. Legal and Regulatory Framework
CYBORA conducts outbound communications in accordance with applicable laws, including but not limited to:
- EU GDPR and ePrivacy Directive,
- UK GDPR and Privacy and Electronic Communications Regulations (PECR),
- United States Telephone Consumer Protection Act (TCPA) and relevant state laws.
Where local laws impose stricter requirements, those requirements take precedence.
4. Lawful Basis and Consent
Outbound communications are initiated only where a valid lawful basis exists.
Depending on the jurisdiction and type of communication, this may include consent, performance of a contract, or legitimate interests.
Where consent is required, it must be freely given, informed, specific, and documented.
Clients are responsible for ensuring that appropriate consent or lawful basis exists prior to initiating outbound campaigns.
5. Responsibilities of Clients and CYBORA
Clients acting as data controllers are responsible for:
- providing lawful and accurate contact data,
- ensuring compliance with consent and disclosure requirements,
- maintaining and honoring suppression and opt-out lists.
CYBORA, acting as a data processor or service provider, implements technical and organizational measures to support compliance and respects client instructions that are lawful and documented.
6. Use of Automated Systems and AI
CYBORA may use automated dialing systems, AI-assisted call handling, or voice bots in outbound communications.
Individuals are informed when interacting with AI-based or automated systems, where required by law.
AI systems are subject to human oversight and are used only for permitted purposes.
CYBORA does not use AI for prohibited practices or deceptive communications.
7. Transparency and Identification
Outbound communications must clearly identify the caller and the purpose of the communication.
Where required, disclosures are provided at the beginning of the interaction.
Misleading, deceptive, or hidden marketing practices are strictly prohibited.
CYBORA promotes honest and transparent communication standards.
8. Opt-Out and Do-Not-Contact Rights
Individuals have the right to opt out of marketing communications at any time.
Opt-out requests are respected without undue delay.
Do-not-call lists and similar registries are honored where applicable.
Suppression mechanisms are implemented to prevent further contact after opt-out.
9. Calling Times and Frequency
Outbound communications must respect legally permitted calling times and frequency limits.
CYBORA implements controls to reduce excessive or intrusive contact.
Campaigns are designed to minimize disruption to recipients.
Local time zones are taken into account.
10. Data Protection and Security
Personal data used for outbound communications is processed in accordance with CYBORA’s Privacy Policy and Data Processing Agreement (DPA).
Data is limited to what is necessary for the communication purpose.
Appropriate security measures protect data against unauthorized access or misuse.
Special categories of personal data are not used unless lawfully permitted.
11. Monitoring, Auditing, and Enforcement
CYBORA may monitor outbound activities to ensure compliance with this Policy.
Violations may result in suspension or termination of campaigns or services.
Serious or repeated violations may lead to contractual remedies.
CYBORA reserves the right to refuse campaigns that pose unacceptable legal or reputational risk.
12. Training and Awareness
Personnel involved in outbound communications receive appropriate training on compliance requirements.
Training covers consent, transparency, AI use, and handling of opt-out requests.
Awareness is maintained through regular updates and guidance.
Compliance responsibilities are clearly communicated.
13. Policy Updates
This Policy may be updated from time to time to reflect legal or operational changes.
Material updates will be communicated where required.
The updated version becomes effective upon publication.
Continued use of CYBORA services constitutes acceptance of the revised Policy.
14. Contact Information
For questions regarding outbound communications or to report concerns:
📧 support@cybora.tech
📧 abuse@cybora.tech
📧 dpo@cybora.tech
📞 +370 640 12261
