Remix.run Logo
andrewaylett 6 hours ago

Selected quotes from Apollo's GDPR page:

> Consent must be "freely given, specific, informed, and unambiguous."

and

> Apollo notifies them when their data is added to Apollo's database of business contact information and provides them with instructions on how to opt out.

https://knowledge.apollo.io/hc/en-us/articles/4409141087757-...

Now, their claim appears to be that they're processing business contact data under the legal basis of "Legitimate Interests". But as much as I am a big fan of not doing things that require a legal basis of "Consent", I'm unconvinced that they ensure their customers are sticking as tightly to their basis as they ought to be if they wish to claim it.

In other words: yes, if you have a CRM in then you might derive legitimate interests in sharing with Apollo. But you need to make sure you actually have the right legal basis for putting customer details into your CRM, and your support database almost certainly does not hold appropriate data!

So ultimately I think this is on both Browserstack (for connecting and sharing data other than in accordance with a legal basis) and Apollo (for making it too easy for their customers to send them data without a sound legal basis and then for sharing that data without suitably validating they had the legal basis to).

Apollo's privacy centre makes all the right claims about how they comply with GDPR, but the OP's story demonstrates that they're not as scrupulous in their verification as they claim to be. And strictly, both should be reporting the breach and taking steps to ensure it doesn't recur.