--- title: "Data Licence and Customer Suppression Schedule" url: "https://www.wren-data.co.uk/legal/data-licence" description: "Data Licence and Customer Suppression Schedule for WREN TECHNOLOGIES LTD." --- ## 1\. Purpose of this Schedule This Data Licence and Customer Suppression Schedule (the “Schedule”) sets out the specific terms that apply to any list of company or contact records (a “List”) you purchase, export or otherwise receive from WREN TECHNOLOGIES LTD (“Wren”, “we”, “us”), whether through our website, our app, or a Marketplace or Pulse order. It is supplementary to — and incorporated by reference into — our [Terms of Service](/legal/terms/) and our [Privacy and Fair Processing Notice](/legal/privacy/), each published at wren-data.co.uk/legal. By completing a purchase or accepting a delivered List, you accept the terms of this Schedule in force at the time of that purchase. A record of your acceptance, the document version you accepted, and the timestamp is retained for audit purposes. ## 2\. Definitions **“List”** — a dataset of company or contact records supplied to you as the output of a purchase or order, including any re-download of the same dataset. **“Licence Period”** — the period during which you are permitted to use a List, starting from the purchase date. **“Channel”** — the method by which you contact a Subject of a record. The three Channels recognised under this Schedule are postal, telephone, and email. **“Use”** — a single outbound communication to a record via a Channel, counted against the combined Use allowance for that record (for example, one email sent to one contact is one Use). **“Subject”** — the company or individual identified by a record in a List. **“Suppression”** — the permanent exclusion of a Subject from any further contact attempt. ## 3\. Licence Grant Subject to these terms, our Terms of Service, and payment of the applicable fees, Wren grants you a limited, non-exclusive, non-transferable, revocable licence to use each List you purchase, for the Licence Period and within the Use limits set out in Section 4 below. This licence is granted to the purchasing customer only. It may not be extended to any parent, subsidiary, affiliate, client, agent, or other third party without our prior written consent. Ownership of the underlying data remains with Wren. Nothing in this Schedule transfers any intellectual property right. ## 4\. Licence Period and Use Limits ### 4.1 Licence Period The Licence Period for every List is twelve (12) calendar months from the purchase date. On expiry of the Licence Period, your right to use the List ends. You must not initiate any new outreach using the List beyond the Licence Period, and you must delete or irrecoverably destroy the List in accordance with Section 8. ### 4.2 Use Limits Within the Licence Period you may use each record a maximum of twelve (12) times in total across all purchased Channels. This means, for example: - 12 emails to a record uses the whole allowance for that record; - 6 emails and 6 telephone calls uses the whole allowance for that record; and - 4 postal mailings, 4 telephone calls and 4 emails uses the whole allowance for that record. The limit is combined across Channels and cumulatively across the whole Licence Period. ### 4.3 What counts as a Use One Use is one outbound communication initiated by or on behalf of you. It includes: - Sending one piece of physical mail to the postal address. - Placing one outbound telephone call to the telephone number. - Sending one email to the email address. Automated bounce-backs, delivery failures, and out-of-office replies that result in no human contact do not consume a Use. Replies received from the Subject in response to a permitted Use are part of that same Use and do not count separately. ### 4.4 Channel selection at purchase At the point of purchase you select which Channels you require. You pay only for the Channels you select, and the licence to contact a record extends only to the Channels present in the List as delivered. A List purchased with postal data only does not carry a telephone or email licence, even if those data points exist in our underlying database. ### 4.5 Re-downloads and refreshed exports Depending on your Subscription, you may be able to re-download or refresh the same ordered List for a limited period after the original purchase. Unless an Order states otherwise, PRO Subscriptions include refresh and re-download access for 90 days from the original purchase date, and Enterprise Subscriptions include refresh and re-download access for 365 days from the original purchase date. A re-download or refreshed export does not create a new List, new licence, new Licence Period or new Use allowance. The 12-month Licence Period and Use limits continue to run from the original purchase date. Suppressed, erased, restricted or opted-out records may be removed from refreshed exports. ## 5\. Suppression and Opt-Out Obligations ### 5.1 Immediate suppression on request If at any time a Subject notifies you (by any means, and via any Channel) that they do not wish to be contacted, you must: - Cease all further contact with that Subject on all Channels, immediately and without requiring any second request. - Record the suppression in your own suppression records and apply it to all your subsequent marketing activity, not only to the List on which the Subject appeared. - Not re-introduce the Subject to any future outreach based on any subsequent List containing the same Subject. ### 5.2 Feeding opt-outs back If you wish, you may return an opt-out file to us at [dpo@wren-data.co.uk](mailto:dpo@wren-data.co.uk). We will apply it to our master suppression list so future Lists supplied to you (and to other customers) will exclude those Subjects. See our [Data Retention Policy](/legal/retention/) for how long we hold suppression records. ### 5.3 Wren suppression and rights updates Where we make suppression, erasure, correction or restriction updates available to you through the Platform or otherwise notify you of them, you must collect and apply those updates promptly to your own systems, suppression records, campaigns and connected services. You must stop using any record that we identify as erased, restricted or no longer available for use, and you must correct or suppress affected records in accordance with the update we provide. You remain responsible for ensuring that the update is applied to any copy of the List under your control, including copies held by your service providers or in connected CRM, marketing or automation platforms. We may send reminders for outstanding updates and may suspend access to the Services, future Lists, refreshes or downloads where you do not collect or apply required suppression, erasure, correction or restriction updates. ### 5.4 Regulator-mandated channels You must honour the Telephone Preference Service (TPS), the Corporate Telephone Preference Service (CTPS), and any equivalent future regulator-operated suppression mechanism. You are responsible for screening your outreach against those channels in addition to any suppression data we supply. ## 6\. Compliance with Applicable Law You are responsible for ensuring that your use of every List complies with all laws applicable to your outreach, including: - The UK General Data Protection Regulation and the Data Protection Act 2018. - The Privacy and Electronic Communications Regulations 2003 (PECR) as amended, including the requirements for valid soft opt-in, clear sender identification, and a functional unsubscribe mechanism on every electronic communication. - Any sector-specific or jurisdiction-specific regulations applicable to your industry or the geographic location of the Subjects you contact. We provide Lists on the basis that you, as data controller for your outbound activity, will perform your own legitimate-interests assessment where required and will operate lawful, accurate, and proportionate marketing practices. ## 7\. Prohibited Uses In addition to the restrictions in our Terms of Service, you may not: - Resell, sublicense, transfer, publish or otherwise make any List available to any third party. - Use any List, in whole or in part, to build, enhance or operate a competing database or data service. - Use any List to train, fine-tune, or improve any artificial intelligence, machine learning, scoring, or automated-decision system without our prior written consent. - Use any List for any unlawful purpose, including discriminatory targeting prohibited by the Equality Act 2010. - Combine any List with data obtained from another source in a way that reconstructs or approximates our underlying database. - Use any List after the expiry of the applicable Licence Period. ## 8\. Delivery and Retention ### 8.1 Delivery Lists are delivered to you as a CSV download, via the Wren app, at the time of purchase (or, for purchases requiring your own internal approval, at the time that approval is granted). Every List includes a footer row containing the customer name, order reference, licence summary, and List identifier. This footer is present for audit and licensing-identification purposes and must not be altered or removed. ### 8.2 Your retention You may retain a purchased List only for the duration of the Licence Period. When the Licence Period ends, you must delete or irrecoverably destroy the List from your active systems, marketing platforms, connected services and ordinary working copies. After deletion, you may retain the Business ID and Contact ID only where this is necessary to maintain a suppression record and prevent further contact. You must not retain the name, email address, telephone number, postal address, job title or other supplied List fields after the Licence Period unless the law requires you to keep a specific record. ## 9\. Auditing and Anti-Misuse Measures ### 9.1 Seeded records We may insert a small number of tracked seed records into any List as an anti-misuse and audit measure. Between 0.1% and 1% of the records in any List may be seeded. Seeded records are indistinguishable from genuine records in their industry, size and geographic profile; the communications those records receive are logged and allow us to detect List misuse. Seeding is used solely to protect against unauthorised resale or sublicence. It does not materially reduce the commercial value of your List. ### 9.2 Consequences of detected misuse If we detect that a List has been used in breach of this Schedule (for example, through contact received by seeded records on a Channel, from a sender, or during a period that is inconsistent with the terms of your purchase), we may, at our sole discretion: - Suspend or terminate your account. - Invoice you for the full retail value of the improperly accessed data. - Report the breach to the Information Commissioner’s Office where required. - Pursue any other remedy available under contract or law. The liability provisions of our Terms of Service apply to any claim arising from misuse of a List. ## 10\. Refunds and Credits Purchased Lists are non-refundable once delivered. If a List contains a material quality defect (more than 5% of records being undeliverable across all selected Channels) and you notify us within 30 days of purchase, we will at our discretion replace the affected records or credit your account. Changes to filters or Channel selection after purchase require a new purchase — we cannot retrospectively modify the scope of an existing List. ## 11\. Changes to this Schedule We may update this Schedule from time to time. Material changes (for example, a change to the Licence Period, Use Limits, or Prohibited Uses) will require you to re-accept the updated version before your next purchase. Lists already purchased are governed by the version of this Schedule that was in force at the time of their purchase. Non-material changes (for example, clarifying wording, typographical corrections, or updates to contact details) take effect on publication. ## 12\. Contact Questions about this Schedule should be directed to: - General queries: [hello@wren-data.co.uk](mailto:hello@wren-data.co.uk) - Privacy and opt-outs: [dpo@wren-data.co.uk](mailto:dpo@wren-data.co.uk) - Licensing and compliance: [dpo@wren-data.co.uk](mailto:dpo@wren-data.co.uk) WREN TECHNOLOGIES LTD, 128 City Road, London, EC1V 2NX, United Kingdom. Registered in England and Wales, company number 17382891.