Who is responsible
The controller is Arman Airapetov, self-employed individual (professional income tax payer), Russian Federation, trading as OffloadDesk. For anything about your data, write to hello@offloaddesk.com or reply to any of our emails.
What we process and where it comes from
- If we emailed you first: your business email address as published on your organisation's own website or public page, and your name and role if they are published there; your company's name, domain and country; the exact address of the page where we found the email address; and the public post, job ad or tender that made the email relevant. We do not buy lists and we do not guess addresses.
- If you reply: your emails and ours, and what you choose to tell us about your needs, such as volumes, systems, timeline or budget.
- If you become a customer: contact and billing details, the agreed scope and our correspondence. Card details are handled by the payment service Prodamus; we only receive confirmation of the payment.
- Market research: we read public forum posts, job ads and tenders to find problems worth solving, and keep short quotes with the link and the author's name or handle as published. We do not use them to email the authors. When a public post asks for help, we may answer it in the same public thread.
- If you visit this website: the server uses your IP address only to deliver the page and keeps no access logs. The site uses no cookies, no analytics and no third-party scripts.
Why, and on what legal basis
- Contacting businesses about a problem we can solve and answering replies: our legitimate interest in offering a business service (GDPR Art. 6(1)(f)). We keep it proportionate: one email to a published business address, at most two short follow-ups, only where a public signal shows the topic is relevant to the recipient's role, and an immediate stop when you ask.
- Getting back to you when a solution is ready, or introducing you to a specialist partner: only if you said yes when we asked (consent, Art. 6(1)(a)). We tell you which partner before sharing anything, and you can withdraw your consent at any time.
- Preparing and performing a contract: Art. 6(1)(b).
- Accounting and tax records: legal obligation, Art. 6(1)(c).
- Market research from public sources: our legitimate interest in understanding which problems businesses need solved (Art. 6(1)(f)).
AI assistants
Our emails are researched, drafted and answered with the help of AI models (Claude, provided by Anthropic). Every such email says so, and replying "human" reaches Arman Airapetov personally. The assistants do not make decisions about you that have legal or similarly significant effects.
Who receives your data
We do not sell your data. Service providers process it for us under contract:
- Email hosting providers: our mailboxes
- Anthropic PBC (USA): AI processing of emails and research notes
- Telegram: internal alerts to our team, which can include a company name and a short excerpt of a message
- HostVDS: hosting of this website, in Latvia
- Prodamus: card payments (customers only)
A specialist partner receives your requirements only with your consent, as described above.
Where your data is processed
Our team works from Armenia, outside the EU. Some of our service providers, including Anthropic, are in the USA. Where the law requires a transfer mechanism, such as the European Commission's standard contractual clauses, we rely on the one our provider offers. Write to us for details.
How long we keep it
- If you never reply, your name, role and email address are deleted 180 days after we found them.
- If you ask us to stop, we stop at once and add a one-way hash of your email address to a do-not-contact list, which we keep so we never write to you again. The hash cannot be turned back into the address.
- Conversations with people who replied are kept while the enquiry is relevant, and at most 24 months after the last contact, unless you ask us to delete them sooner.
- Customer and billing records are kept for as long as tax law requires.
- Research quotes are kept while the topic is being worked on, and deleted on request.
Your rights
You can ask for access to your data, correction, deletion, restriction or a copy in a portable format. You can object to processing based on legitimate interest at any time, and you have an absolute right to object to direct marketing: reply "unsubscribe" or write to us, and we stop immediately. You can withdraw consent at any time. You can also complain to a data protection authority, for example in the country where you live or work: the Data Protection Commission (Ireland), the Autoriteit Persoonsgegevens (Netherlands), IMY (Sweden) or the CNIL (France).
Changes
We update this notice when our processing changes and show the date at the top.