I am a US-based marketer who manages lists (in Constant Contact) for a client located in Europe. All additions to the list come from the client, and they are either names and email addresses or just emails (or other contact information) and all have expressly asked to receive communications via email from the client (messages they create and I distribute). The client wants to be sure the company is compliant with the General Data Protection Regulation (GDPR). As such, the client is not sure they can receive the actual file as a spreadsheet periodically (to give them the chance to review the databases and see who is on the lists) as they are not the ones holding the database (Constant Contact, in their view, is). I am of the view that the list belongs to the client; that I (and Constant Contact) are third parties who just hold and manage the list; the client is the owner. Looking for opinions. Thank you!
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