This Acceptable Use Policy ("AUP") defines the permitted and prohibited uses of the Blake platform and related services (the "Services") provided by Subduxion B.V. ("Subduxion", "we", or "our"). This AUP supplements the Terms of Service and applies to all users of the Services.
The Services are designed for legitimate B2B sales development activities. This AUP establishes boundaries to ensure that the Services are used responsibly, lawfully, and in a manner consistent with applicable EU and national legislation, including Regulation (EU) 2016/679 (GDPR), Directive 2002/58/EC (ePrivacy Directive), and Regulation (EU) 2024/1689 (EU AI Act).
1. General Obligations
Users of the Services shall:
- Use the Services only for lawful business-to-business sales development purposes.
- Comply with all applicable laws, regulations, and industry codes of conduct in the jurisdictions in which they operate.
- Maintain accurate and up-to-date account information.
- Ensure that all authorised users within their organisation are aware of and comply with this AUP.
- Promptly report any suspected violations of this AUP to legal@subduxion.com.
2. Data Sourcing and Processing
Users are responsible for ensuring that all personal data processed through the Services has been obtained and is processed in compliance with applicable data protection law. Specifically:
- Lawful Basis. Users must establish and maintain a valid legal basis under Article 6(1) GDPR for the processing of personal data submitted to the Services, including prospect and lead data. Where legitimate interest is relied upon, users must have conducted a balancing test as required by Article 6(1)(f) GDPR.
- Transparency. Users must have provided appropriate privacy notices to data subjects in accordance with Articles 13 and 14 GDPR, informing them of the processing activities conducted through the Services.
- Consent for Electronic Communications. Users must comply with the ePrivacy Directive and its national implementations (including the Dutch Telecommunicatiewet) when using the Services to send electronic communications. This includes obtaining prior consent for unsolicited commercial communications to individuals, except where the existing customer exemption applies.
- Data Accuracy. Users must take reasonable steps to ensure the accuracy of personal data submitted to the Services and must promptly correct or delete inaccurate data.
- Data Minimisation. Users shall not process more personal data through the Services than is necessary for the stated purpose.
3. AI-Generated Content
The Services generate content using artificial intelligence, including outreach emails, call scripts, prospect summaries, and engagement recommendations. Users acknowledge and agree that:
- Review Obligation. All AI-generated content must be reviewed and approved by a human user before it is sent to or used in connection with any third party. Users are solely responsible for the accuracy, appropriateness, and legal compliance of any AI-generated content they choose to use.
- No Deceptive Use. Users shall not use AI-generated content to impersonate real individuals, fabricate credentials, create fictitious references or testimonials, or otherwise deceive recipients about the nature or origin of communications.
- Disclosure. Where applicable law or industry standards require disclosure that communications have been generated or assisted by AI, users are responsible for ensuring appropriate disclosure.
- No Harmful Content. Users shall not use the Services to generate content that is discriminatory, harassing, threatening, defamatory, or otherwise harmful or illegal.
- No Circumvention. Users shall not attempt to manipulate AI systems to produce outputs that would violate this AUP, applicable law, or the rights of third parties. This includes prompt injection, system prompt extraction, or attempts to override safety mechanisms.
4. Outreach and Communication Standards
Users conducting outreach through the Services must adhere to the following standards:
- Anti-Spam. Users shall not use the Services to send unsolicited bulk communications in violation of applicable anti-spam legislation, including Directive 2002/58/EC, the Dutch Telecommunicatiewet, and comparable legislation in the recipient's jurisdiction.
- Opt-Out Compliance. Users must honour opt-out requests and suppression lists promptly and in any event within the timeframe required by applicable law. The Services provide suppression management features that users are required to utilise.
- Sender Identification. All outreach conducted through the Services must accurately identify the sender and provide a valid means for the recipient to contact the sender and opt out of further communications.
- Volume Limits. Users must comply with the sending limits established for their subscription tier. Attempts to circumvent rate limits or sending controls are prohibited.
- Recipient Relevance. Users should ensure that outreach is targeted and relevant to the recipient's professional context. Mass indiscriminate outreach without reasonable targeting is inconsistent with the intended use of the Services.
5. Prohibited Activities
The following activities are expressly prohibited when using the Services:
- Processing personal data of individuals under the age of 16.
- Processing special categories of personal data (Article 9 GDPR) without an appropriate legal basis and explicit agreement with Subduxion.
- Using the Services for consumer-to-consumer or business-to-consumer marketing where the applicable legal requirements for such communications differ from B2B standards and have not been met.
- Scraping, harvesting, or aggregating personal data from third-party sources in violation of those sources' terms of service or applicable law.
- Using the Services to facilitate or conceal fraudulent, deceptive, or illegal activities.
- Sharing account credentials with unauthorised individuals or allowing access by users not covered by the applicable subscription.
- Interfering with the operation, security, or performance of the Services, including through automated scripting, credential stuffing, or denial-of-service techniques.
- Reverse engineering, decompiling, or attempting to extract source code, model weights, training data, or proprietary algorithms from the Services.
- Using the Services in a manner that violates trade sanctions, export controls, or anti-bribery legislation applicable to the user or Subduxion.
- Reselling, sublicensing, or providing access to the Services to third parties without the prior written consent of Subduxion.
6. Enforcement
6.1 Monitoring
Subduxion reserves the right to monitor the use of the Services for compliance with this AUP. Monitoring is conducted in a manner consistent with our Privacy Policy and applicable data protection law. Subduxion does not routinely review the content of customer communications but may investigate specific accounts in response to complaints, abuse reports, or indicators of policy violation.
6.2 Violations
Upon becoming aware of a suspected violation of this AUP, Subduxion may, at its discretion and without prejudice to other available remedies:
- Request that the user cease the violating activity and provide a remediation plan.
- Suspend access to specific features or the entire Services pending investigation.
- Terminate the user's account in accordance with the Terms of Service.
- Report the violation to relevant law enforcement or regulatory authorities where required or appropriate.
Where practicable, Subduxion will provide notice and an opportunity to cure before taking enforcement action, except where the violation poses an immediate risk to the security, integrity, or availability of the Services or to the rights of other users or third parties.
6.3 Reporting
Users or third parties may report suspected violations of this AUP by contacting legal@subduxion.com. Subduxion will investigate all reports in good faith and respond within a reasonable timeframe.
7. Changes
Subduxion may update this AUP from time to time. Material changes will be communicated at least 30 days in advance through the Services or by email. Continued use of the Services following the effective date of any update constitutes acceptance of the revised AUP.
8. Contact
For questions regarding this Acceptable Use Policy:
Subduxion B.V.
Attn: Legal
High Tech Campus 5
5656 AE Eindhoven
The Netherlands
Email: legal@subduxion.com