Direct Marketing

What is considered Direct Marketing?

According to Investopedia, “Direct marketing is an advertising strategy that relies on the individual distribution of a sales pitch to potential customers. Mail, e-mail, and texting are among the delivery systems used. It is called direct marketing because it generally eliminates the middleman, such as advertising media.”

Essentially, this explanation of direct marketing demonstrates that not every marketing communication is considered direct marketing.

Direct marketing happens when an organization uses promotional channels that communicate directly with customers through:

➡️E-mail marketing
➡️ Telemarketing
➡️ Targeted website advertising and more…

There is no definition of direct marketing in the GDPR, there is, however, a description of marketing purposes in Recital 30 of Directive 95/46/EC, (WP29).

It explains that direct marketing includes communication for commercial purposes but also includes marketing communication by non-profit organizations, political organizations and other associations and includes any form of sales promotion directed towards individuals if their personal data is being processed.

What is NOT considered Direct Marketing?

If you are carrying out marketing communication that is not directed towards an individual, it is not considered to be direct marketing. An example of marketing channels that are not targeting individuals are:

➡️ Promotional banner
➡️ Website advertising if it is not targeted
➡️ TV commercial which is defined as a part of a broadcasting service provided over a public communications network and does not define as a direct communication via an electronic channel (video-on-demand services excluded)
➡️ Newsletter campaigns that are targeting e-mail addresses with no data subject information
➡️ Promotional messages that are informational and related to customer-service

However, any additional personal data processing will be subjected to the GDPR.

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