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B2B cold outreach in Poland

Cold commercial contact in Poland sits under two independent layers of law that are easy to conflate: electronic communications law, which governs sending the message, and the GDPR, which governs processing the person’s data. Satisfying one does not discharge the other. This page covers both, and what Wrenwire checks automatically.

Sending commercial information by electronic means requires the recipient’s consent. The basis is Article 398 in conjunction with Article 400 of the Electronic Communications Law (Prawo komunikacji elektronicznej). The provision speaks of consent to receive commercial information and carries no general business-to-business exemption, so the widespread belief that “companies are fair game” has no footing in the wording of the act.

The practical line runs somewhere other than around the word “company”. What matters is whether the address reaches a specific person. A named address is simultaneously personal data and a communications endpoint, so both layers apply to it at once.

What changed on 10 November 2024

If you are working from older guidance, it most likely cites Article 10 of the Act on Providing Services by Electronic Means or Article 172 of the Telecommunications Law. Both were repealed on 10 November 2024 (Journal of Laws 2024, item 1222) and replaced by the Electronic Communications Law.

The consent requirement itself did not disappear. What changed is the numbering and the construction of the provisions. Citing Article 10 of the old act today means citing a provision that no longer exists.

Even once the sending question is settled, a separate one remains: on what basis are you processing the prospect’s data at all? For data gathered from public sources the basis is often legitimate interest, Article 6(1)(f) GDPR, which requires a documented balancing test.

Then comes the obligation people forget most often. Article 14 GDPR covers data you did not obtain from the person themselves, which is precisely the cold outreach situation. The privacy notice has to be delivered at the first communication, not merely published on a website. Publication alone does not discharge the duty towards someone whose contact details you actually hold.

What Wrenwire does automatically

Four mechanisms run whether or not you remember them.

A campaign declares its market and legal basis. Before a campaign can start you pick the basis for contact: existing consent, existing customer, or knowingly accepted risk. The choice is stored with the campaign, so what the decision rested on stays visible afterwards.

The Article 14 notice is injected into the body of the first message. Not as a placeholder resolved at send time, but as a permanent part of the stored text. The reason is practical: messages leave through external tools and by hand, so a placeholder would ship literally.

The suppression list is organization-wide. Unsubscribes, opt-out replies, hard bounces, Article 21 objections and manual entries all land in one register. The filter runs before every hand-off of contacts to sending, and an address suppressed in one campaign stays suppressed in every campaign that follows.

The unsubscribe link is signed with a key. Without that key configured, a campaign aimed at a market that requires the pre-flight checklist will not start.

What Wrenwire does not decide

The product does not judge whether your legal basis is sound in your particular case. The “accepted risk” option is exactly what it looks like: a deliberate decision to send without consent, recorded alongside the campaign.

Nor does the product send anything on its own. Every message series waits for your approval, and sending happens through the tool you connect.

LinkedIn and phone are different regimes

They are separate regimes, not variants of the same one.

LinkedIn is governed primarily by the platform’s terms rather than by email law. Wrenwire does not automate LinkedIn sending: a human sends the messages.

Phone has its own basis and its own limits. Wrenwire prepares a call script carrying a note on the basis for contact, not an autodialler.

Legal position as at 6 September 2026. This page describes how the product behaves and cites the provisions our behaviour rests on. It is not legal advice and does not determine whether your campaign is lawful. Have your own situation reviewed by a lawyer.