--- title: Data Protection and AI Commitments for B2B Outreach | Torke url: https://torke.tech/commitments description: How Torke handles GDPR, the Swiss UWG and FADP, approved claims and human release: seven commitments for B2B outreach, each with its limit. --- # Seven commitments, each with its limit These hold whether we run the work for you or your team runs Torke Engine. Each one comes from how the work is built rather than from a promise, and each one states where it stops, so your legal, security and engineering colleagues know exactly what they are agreeing to. Diagram: Every line checked before it is released A draft in which every line carries a check against approved facts, and which leaves only when a named person releases it. ## What does Torke commit to in every engagement? Seven commitments, each with its limit: only approved claims reach a buyer, every statement shows its source, a named person approves every release, a lawful basis is written down per country before contact, tracking is tested before spend, results are reported at their real confidence, and you own what is built. The [Method page](https://torke.tech/method) shows how the account data behind them is collected. ## Which rules sit behind these commitments? Each figure links to the page it comes from, so you can check it before you repeat it. | What the evidence says | Source | |---|---| | Swiss UWG Art. 3 para. 1 let. o: sending mass advertising by telecommunication without prior consent, without a correct sender or without a free opt-out is unfair. | Swiss Federal Chancellery, Fedlex, SR 241 (consolidated 3 January 2025) | | The revised Swiss Federal Act on Data Protection (FADP) came into force on 1 September 2023. | Federal Data Protection and Information Commissioner (FDPIC) (2023) | | Under the revised FADP, fines of up to CHF 250,000 can be imposed on the responsible natural person, and on companies up to CHF 50,000 as a subsidiary measure. | Federal Data Protection and Information Commissioner (FDPIC) (2023) | | GDPR Recital 47: processing personal data for direct marketing may be regarded as carried out for a legitimate interest. | Regulation (EU) 2016/679, Recital 47 (27 April 2016) | [](https://www.fedlex.admin.ch/eli/cc/1988/223_223_223/en) [](https://www.edoeb.admin.ch/en/new-fdpics-role) [](https://www.edoeb.admin.ch/en/new-fdpics-role) [](https://gdpr-info.eu/recitals/no-47/) ## What every client can rely on | Commitment | How it holds | Where it stops | |---|---|---| | Only approved claims reach a buyer | Every line is checked against the facts your company approved before it can leave | Approval confirms a person checked the claim. It doesn't make an untrue source true | | Every statement shows its source | Each signal carries a date and a link, each claim its source sentence, and a missing fact is reported as a gap | Sources behind a login are outside the work by design | | A named person approves every release | Nothing is sent, published or launched without a signed-in person | The approver is accountable for what they release | | A lawful basis before any contact | A written lawful basis per country before anything is sent | Countries without a confirmed basis are left out | | Tracking is tested before money is spent | Every conversion path is checked end to end before a campaign starts | A platform's own reporting can still differ from your CRM, and we report the gap | | Results are reported at the confidence they deserve | A change is called only when the sample supports it | Small samples are reported as unreadable, even when the number looks good | | You own what is built | Account data, definitions, campaigns and the operating record stay with you | Maintenance after a handover is a separate choice | ## Where the data comes from Account signals use what a buyer could check for themselves, and nothing else. **Your own site data** The companies that read your website and the pages they read, from your own first-party data. **Free public sources** Newsrooms, job boards, watched pages and regulator feeds, each event stored with its date and link. **What we never use** LinkedIn scraping, data brokers and device fingerprinting. An account with no public footprint is ranked on fit alone. ## What do teams ask about data and compliance? Each answer stands on its own, so you can forward one to a colleague, and an assistant asked the same question can quote it as it is. ### Is B2B cold email legal in Switzerland? The Swiss Unfair Competition Act (UWG Art. 3 para. 1 let. o) treats mass advertising by telecommunication as unfair without prior consent, a correct sender and a free way to opt out, and the revised Data Protection Act governs the personal data. Torke records a lawful basis per country before any send and leaves out countries without one, which describes how we work and is not legal advice. ### Can I send B2B cold emails under the GDPR? GDPR Recital 47 says direct marketing may be regarded as a legitimate interest, but that needs a documented balancing test, transparency and an opt-out, and national ePrivacy rules can require consent. Torke writes the basis down per country before anything is sent. ### What are the fines under the revised Swiss Data Protection Act? The Federal Data Protection and Information Commissioner states that fines of up to CHF 250,000 can be imposed on the responsible natural person, and companies can be fined up to CHF 50,000 only as a subsidiary measure. The revised Act came into force on 1 September 2023. ### Does Torke scrape LinkedIn or buy contact data? No. Account signals come from your own site data and free public sources such as newsrooms, job boards, watched pages and regulator feeds, with no LinkedIn scraping, data brokers or device fingerprinting. ### How do you stop an AI marketing tool from publishing false claims? Check every line against facts the company approved and require a named person to release it. Torke shows the source sentence for each claim and sends or publishes nothing without a signed-in approver. ## Where to go next Pages that answer the next question a reader in your position usually asks. ### Method Fit scores, fading signal scores and the dated triggers that open an account. [See how accounts are scored](https://torke.tech/method) ### Torke Engine Your own team runs the same engines from Claude, Codex or any MCP assistant. [How Torke Engine works](https://torke.tech/engine) ### Torke Service We run the work against your named accounts and deliver qualified leads, each with its evidence. [How Torke Service works](https://torke.tech/service)