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Home › Data Notice
⚠️ DRAFT – pending legal review; not in effect

This document has not yet been reviewed by an attorney and is not in effect. Passages marked [[ TO COMPLETE: … ]] are to be completed by the operator or by counsel.

Data Notice for People Listed in Public Business Records

Last updated:
October 2026 (draft)
Covers:
information under Article 14 GDPR (data not obtained from you)
Controller:
Martin Adamec, Czech business ID (IČO) 19552319
Status:
the Florida Business Database is active (as of October 15, 2026)

Do not want to be listed? You can ask us at any time to remove your details and not to add them again – use the form on the page Remove my data or write to info@flcontacts.com. It is free and you do not have to give a reason. Details in Section 10.

Contents

  1. Who this notice is for
  2. Who is responsible (controller)
  3. Categories of data
  4. Planned sources
  5. Purposes
  6. Legal basis and balancing of interests
  7. Recipients
  8. International transfers
  9. Retention
  10. Your rights and how to request removal
  11. Complaints
  12. How this notice is provided
  13. Changes

1. Who this notice is for

flcontacts.com has compiled a database of businesses registered in Florida and supplies exports from it to business customers. The Florida dataset is active as of October 15, 2026. This notice describes what we process and how.

Information about a business is personal data only where it relates to an identifiable individual. This notice is therefore addressed to:

  • officers, directors, managers, members and other authorized persons named in a business entity's public filings;
  • registered agents who are individuals;
  • sole proprietors and licensed professionals whose business name, address and contact details relate to them personally (for example owners of a registered fictitious name or holders of a state professional license);
  • contact persons whose name or personal business contact detail (for example an email address containing their name) a business has published.

Visitors of this website, people who contact us and customers are covered by the Privacy Policy.

2. Who is responsible (controller)

Martin Adamec (sole proprietor)
Mírová 1541, 516 01 Rychnov nad Kněžnou, Czech Republic
Czech business ID (IČO): 19552319
Email: info@flcontacts.com · Phone: +420 720 950 900 (Central European Time)

The operator is established in the European Union. The EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") therefore applies to this processing even though the records concern businesses and people in the United States (Article 3(1) GDPR). No data protection officer has been appointed. [[ TO COMPLETE: counsel – confirm that no data protection officer is required under Article 37 GDPR ]]

3. Categories of data

For each record we plan to process the following, to the extent the sources contain it:

Identification and registration data
Business name (for sole proprietors this is often the person's own name), entity type, Florida document number, status (active or inactive), filing date, and federal employer identification number (FEI/EIN) where the public record shows it.
Addresses
Principal and mailing address as shown in the public record, and the county derived from it. For small and home-based businesses the business address can be the same as a home address.
Officers and registered agent
Names, titles and addresses of officers, directors, managers or members and of the registered agent, as shown in the public record. [[ TO COMPLETE: confirm whether names and addresses of officers and registered agents will be included in exports, or only kept for matching ]]
License data
License type, license number and license status from state licensing records.
Published contact data
Phone number, email address and website address that the business itself has published.
Activity
Industry, an industry code (NAICS) assigned by us, and a short description of the activity taken from public pages.

We do not intend to process special categories of personal data (Article 9 GDPR), data about criminal convictions (Article 10 GDPR), Social Security numbers, dates of birth, or financial account data. [[ TO COMPLETE: confirm against the final data model – in particular that disciplinary history from licensing records and health-related inferences about individual license holders are not taken over ]]

4. Planned sources

We plan to use publicly available sources only. A fuller description is on the page Data sources and methodology.

  • Florida Department of State, Division of Corporations (Sunbiz) – the public record of corporations, limited liability companies, limited partnerships and fictitious names, which the Division publishes for search and as data downloads;
  • Florida Department of Business and Professional Regulation (DBPR) – public license records, for example in construction and real estate;
  • Florida Department of Health (DOH) – public license records of health care practitioners and facilities;
  • business websites – contact details and descriptions that businesses publish themselves.

The state records are public records under Florida law. Chapter 119 of the Florida Statutes provides: "It is the policy of this state that all state, county, and municipal records are open for personal inspection and copying by any person" (Fla. Stat. § 119.01(1)). Being a public record does not mean that the information is current, and it does not by itself make every use of it lawful.

On request we will tell you which source the details in your record came from. [[ TO COMPLETE: confirm the final list of sources before the first export; list each agency data set actually used and its terms of use ]]

Note for counsel (remove before publishing): Public records and commercial use. Please confirm (1) that no Florida statute or agency term restricts the commercial reuse or resale of the Division of Corporations bulk files or of DBPR and DOH license data (for example statutory exemptions from Chapter 119 for particular fields, or agency terms of use); (2) whether any record category carries a statutory ban on use for commercial solicitation, as some Florida statutes provide for specific records; (3) whether automated collection from agency websites, as opposed to official bulk downloads and public records requests, raises contract or computer-access issues; and (4) the same for automated collection of contact details from business websites (see also the CAN-SPAM note in the Terms of Sale, Section 7).

5. Purposes

We will process the data to build and maintain a business database and to supply exports from it to business customers for business-to-business purposes: sales prospecting and direct marketing by mail, phone or email, enriching customer relationship management (CRM) systems, and market analysis. Our customers are contractually required to follow the laws that govern their outreach (Terms of Sale, Section 7).

We do not build profiles of individuals, we do not evaluate personal characteristics, and we do not make automated decisions within the meaning of Article 22 GDPR. The database is not a consumer report and may not be used for credit, employment, insurance or housing decisions.

6. Legal basis and balancing of interests

The legal basis is Article 6(1)(f) GDPR: processing is necessary for the legitimate interests of the operator and of its customers in making information about businesses available and usable for dealings between businesses. Recital 47 GDPR recognizes that processing for direct marketing purposes may be regarded as carried out for a legitimate interest.

In weighing these interests against yours, we take into account in particular that:

  • the data concerns your business or professional activity, not your private life;
  • the data is public – it was filed with a state agency under a legal duty and is open to anyone under Florida's public records law, or you published it yourself for business contact;
  • we do not process special categories of data and do not create profiles;
  • safeguards are in place: this notice, a simple removal request, a suppression list that prevents your details from being added again, and contract terms that bind customers to the applicable outreach and privacy laws and forbid resale and publication.

Against this stands, in particular, that a business address may be a home address and that you may not expect a record filed with a state agency to be used for marketing. We give weight to this by honoring every removal request from an individual without asking for reasons. [[ TO COMPLETE: document the legitimate interests assessment in writing; state whether a summary is available on request ]]

7. Recipients

  • Business customers that buy an export. They are identified in general terms as businesses that use the data for the purposes in Section 5; they process the data as independent controllers and are themselves responsible for their outreach.
  • Processors, in particular the provider of our server (see Privacy Policy, Section 3), under contracts that meet Article 28 GDPR.

If you received marketing from a business, that business is responsible for it; please send your opt-out to that business as well. If you know that the business obtained your details from us, tell us so in your request.

8. International transfers

We will store and process the database on servers in the European Union. Customers are expected to be located mainly in the United States, so supplying an export will regularly mean transferring the data from the EU to the United States – the country the records originally came from. [[ TO COMPLETE: counsel – transfer mechanism under Chapter V GDPR for deliveries to U.S. customers (adequacy decision for the EU-U.S. Data Privacy Framework for certified recipients; otherwise standard contractual clauses under Article 46(2)(c) GDPR), and where a copy of the safeguards can be obtained (Article 14(1)(f) GDPR) ]]

9. Retention

We will keep a record for as long as the business is shown as active in the sources and the record is needed for the purposes above. Once a business is no longer shown as active, we will delete the personal details in the record [[ TO COMPLETE: deletion period after a business becomes inactive in the source ]].

After a removal request we delete the details concerned. To prevent them from being added again at the next update from the sources, we keep only the identifiers needed for that (for example document number, phone number or email address) on a suppression list [[ TO COMPLETE: retention period of the suppression list ]].

10. Your rights and how to request removal

Removal request (right to object, Article 21 GDPR): you may object to the processing of your data at any time. Where the processing serves direct marketing, you do not have to give reasons, and we will no longer process your data for that purpose (Article 21(2) and (3) GDPR). We apply this to every individual, wherever you live.

The easiest way is the form on the page Remove my data. You can also write to info@flcontacts.com or send a letter to the address in Section 2.

Subject to the conditions set by GDPR, you also have the right of access (Article 15), the right to rectification (Article 16), the right to erasure (Article 17) and the right to restriction of processing (Article 18). The right to data portability (Article 20) does not apply to processing based on Article 6(1)(f) GDPR.

We will inform the customers to whom we previously supplied your data about a rectification, erasure or restriction, unless this proves impossible or involves disproportionate effort (Article 19 GDPR). [[ TO COMPLETE: confirm the procedure for notifying customers ]]

We reply without undue delay and at the latest within one month of receiving the request; for complex requests the period may be extended by two further months, in which case we tell you within the first month and explain why (Article 12(3) GDPR). Handling a request is free of charge (Article 12(5) GDPR). If we have reasonable doubts about your identity, we may ask for additional information (Article 12(6) GDPR). If the public record itself is wrong or outdated, we correct our record; a lasting correction also requires a filing with the agency that keeps the record.

11. Complaints

You may lodge a complaint with a data protection supervisory authority (Article 77 GDPR). The authority competent for the operator is the Úřad pro ochranu osobních údajů (Office for Personal Data Protection), Pplk. Sochora 27, 170 00 Praha 7, Czech Republic (uoou.gov.cz). Complaints may be submitted from outside the European Union.

U.S. state privacy laws. The Florida Digital Bill of Rights does not apply to the operator, for the reasons given in the Privacy Policy, Section 12; in addition, its definition of personal data excludes information lawfully made available through government records (Fla. Stat. § 501.702(19) and (28)). We honor removal requests regardless.

12. How this notice is provided

The planned database would cover a very large number of records obtained from public sources and not from the people concerned. In our assessment, notifying each person individually would involve a disproportionate effort. We therefore make this information publicly available on this website under Article 14(5)(b) GDPR and apply the safeguards described in Section 6. On request we give you the information about your own record individually.

Note for counsel (remove before publishing): Article 14(5)(b) GDPR is the main open risk of the business model.

  • Supervisory authorities read the exception narrowly and expect a documented balancing of the effort against the impact on the people concerned. The Polish authority (UODO) fined Bisnode Polska in 2019 for relying on a website notice where it held postal addresses and phone numbers but notified only the people for whom it had an email address (subsequent court review of that decision to be checked by counsel).
  • For Florida records we would hold a mailing address for nearly every entity, and an email address for part of them. Is a website notice sufficient, or must at least the individuals with a published email address be notified one by one – and how does that sit with CAN-SPAM?
  • Timing under Article 14(3)(c): the information is due at the latest when the data is first disclosed to a customer. This page must therefore be final and published before the first export.
  • Whether the people concerned – U.S. residents with no expectation of GDPR protection – change the balancing, and whether Article 27 or any U.S. representative question arises (we assume not, as the operator is established in the EU).
  • Transfers: Article 49(1)(g) GDPR (transfer from a public register) refers to registers under Union or Member State law and will not cover Florida records; see Section 8.

13. Changes

We update this notice when the sources, the scope or the purposes of processing or the law change, and in any case before the first export from the Florida data set is delivered. The version published at flcontacts.com/data-notice/ applies.

Last updated: October 2026 (draft)

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  • +420 720 950 900 (CET)

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Operator: Martin Adamec, Mírová 1541, 516 01 Rychnov nad Kněžnou, Czech Republic · Czech business ID (IČO) 19552319 · Prices are quoted in USD.