Update
11.02.2020
Every time you contact a customer or prospect directly – even through certain forms of online advertising – you have to bear in mind the rules that apply to direct marketing.

This isn't only true for e-mails announcing rock-bottom prices or prize competitions; even an automated response to an enquiry might qualify as direct marketing if it invites someone to visit the website to see the newest products or services. 

At least, that is how the Belgian Data Protection Authority (BDPA) interprets the concept of direct marketing in its new recommendation that covers a range of topics: concept of direct marketing, controller vs processor, using data brokers, cookies etc. 

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