feat(skills): add marketing skills collection
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# Prospecting Compliance Reference
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The legal and platform-ToS constraints that apply to prospect list building. Read first, every engagement.
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> Operational guidance, not legal advice. For high-volume programs or programs touching EU/UK residents, run your setup past a privacy attorney.
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---
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## United States — CAN-SPAM (downstream)
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CAN-SPAM regulates the cold email **send**, not the list build. But the list build matters because:
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- You must be able to identify the source of every email address you contact (required if challenged)
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- The "from" line and email content rules apply at send time — but you can't lie about how you got the contact
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- Opt-out requests must be honored within 10 business days and tracked
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**For prospecting specifically**: capture and retain the source URL + date for every contact you add to a list. CAN-SPAM doesn't require it explicitly, but defending your sender practices does.
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---
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## EU / UK — GDPR
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The strictest applicable framework. Triggers when:
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- Your prospect resides in EU/UK
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- You're processing personal data (any identifiable info, including business emails tied to a named person)
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### Lawful bases for cold B2B outreach
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You have three credible options:
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1. **Legitimate interest** (most common for B2B). Requires:
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- The contact is in a business role likely to be interested in your offer
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- The data was collected from a public, business-context source
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- You provide a clear opt-out
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- You can articulate the legitimate interest test in writing
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2. **Consent** — typically not feasible for cold outreach (you don't have consent before first contact)
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3. **Existing customer relationship** — only applies to current customers, not prospects
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### What you must do
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- Capture **source + date + lawful basis** for every contact
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- Honor data subject access requests (DSARs) — you must be able to disclose, correct, or delete on request
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- Include a privacy notice / opt-out in the first outreach
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- Don't store personal data longer than necessary for the legitimate interest
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### What disqualifies a list
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- Bulk-scraped LinkedIn data — explicit ToS violation + GDPR risk
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- Email addresses purchased from a list broker without source provenance
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- "Anyone @ this domain" guessed emails sent without verification (multiplies risk + bounces)
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---
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## Canada — CASL
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Stricter than CAN-SPAM. Cold B2B outreach requires:
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- **Express consent** (explicit opt-in) — typically not present for cold prospecting
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- **OR implied consent** — existing business relationship within 24 months, OR business address publicly published on the company's own site for the purpose of receiving such communications
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**Practical implication for Canadian prospects**: relying on the publicly-published-address exception is the most defensible cold prospecting basis in Canada. You must include sender identification, mailing address, and an unsubscribe mechanism in every message.
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---
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## Platform Terms of Service
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### LinkedIn
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- **Sales Navigator** as a research tool: fine
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- **Scraping LinkedIn at any scale**: explicit ToS violation. Banned accounts are permanent. Don't.
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- **Apollo, Clay, and ZoomInfo** claim LinkedIn-overlap data through various legitimate channels — verify their data sources before assuming compliance
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- **InMail and Connection Requests**: governed by LinkedIn's own messaging rules, not by CAN-SPAM/GDPR (because LinkedIn-internal)
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### Google Maps
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- ToS prohibits bulk extraction or productizing Maps data
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- Browser-assisted research as a discovery aid: acceptable
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- Storing Place IDs or large structured Maps data in your CRM: explicit ToS prohibition
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- Use Maps to **find** local businesses, then cross-source from the business's own site for the data you retain
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### Apollo / ZoomInfo / Clearbit
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- All have their own ToS limiting reselling, downstream sharing, and use cases
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- Read your contract — typically you can use the data for your own outreach but not productize it
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- Don't share extracts publicly (e.g., on a leaderboard, in a public report)
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### Crunchbase
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- Free tier is read-only for personal use
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- Paid tier permits broader use within contractual scope
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- API access requires paid Pro+ tier
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---
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## Anti-Patterns (Don't Do These)
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1. **Bulk-scraping LinkedIn / Google Maps / Yelp**. Browser-assisted research is OK; automated scrapers pointed at these platforms are not. **Firecrawl and Browserbase are fine for an individual prospect's own website** (the URL you found through manual discovery) — not for the platforms hosting prospects.
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2. **Buying lists from random vendors** without source provenance. You inherit their legal exposure.
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3. **Guessing emails and sending unverified**. Bounce rates over 2% destroy sender reputation; legally, you can't claim a "legitimate interest" basis for an email you fabricated.
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4. **Harvesting personal email addresses** (Gmail, personal Outlook, etc.) from public profiles. Personal addresses raise GDPR risk significantly.
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5. **Storing data you don't need**. Minimize retention. Don't keep prospect lists forever — GDPR right to deletion applies.
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6. **Skipping the lawful basis documentation**. If challenged, you need to show your work. Capture source URL + collection date for every contact.
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7. **Reselling prospect lists**. You may not have the right to share them downstream. Read your data provider contracts.
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8. **CAPTCHA bypass / login wall bypass**. Even if technically possible, this signals bot behavior and violates virtually every ToS.
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---
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## Quick Audit Checklist
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Before shipping a list to the user (or downstream to cold-email):
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- [ ] Every contact has a source URL + collection date
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- [ ] No contacts sourced from scraped LinkedIn data
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- [ ] No Google Maps Place IDs or large Maps-structured data retained
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- [ ] Lawful basis documented (legitimate interest test for B2B, or relevant alternative)
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- [ ] Email addresses validated (deliverability check before outreach)
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- [ ] Personal addresses (Gmail, etc.) flagged or excluded
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- [ ] Source provider contracts permit the intended use case
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- [ ] Retention plan documented (when to delete)
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- [ ] First outreach will include unsubscribe + privacy notice (downstream concern for cold-email skill, but mention it now)
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