This note concerns the ways in which Revantage justifies any direct marketing activities it carries out (i.e. its "justification for processing"). As detailed below, direct marketing is justified in two ways: consent; and legitimate interests. This note does not, however, set out all requirements under the GDPR – for example, the requirement to keep a record of processing or any information-provision requirements.1
The low risk option would be to treat the direct marketing as B2C for the reasons set out in paragraph 4.6 above. Where this is the case, Revantage would only have justifiable grounds to carry out direct marketing to the extent it has the recipient's consent. To be valid, a recipient's consent must be: (i) freely given; (ii) specific; (iii) informed; (iv) unambiguous; and (v) a clear affirmative action.
Clifford Chance can review any language you draft in order to obtain consent. Please email Liebster@revantage.eu with your suggested language.