About

GreyList Trace Limited (GLT) was incorporated in the UK in late 2017 to commercialise the GreyList algorithm, originally developed in 2013 by John Rawson, Bob Duffield and Nigel Nicholson.

After extensive testing and use on internal investigations the founders decided to de-merge the algorithm into a separate company.

GLT raised funding from prominent UK EIS funder Deepbridge Capital LLC in April 2018 and set about developing and commercialising a suite of software solutions.

Backed by UK and US legal opinions, GLT commenced full trading operations in Autumn 2019 and has aggressively developed its product offerings and geographic and sectoral penetration.

Our technical operations are based in Sheffield in the United Kingdom. We operate via our in-house and external data centres and all our information is transmitted via secure portals.

We operate in a Legal, Ethical, Transparent and GDPR compliant manner. We have engaged industry-leading lawyers, law firms and consultants to ensure that our legal advice and procedures are up to date.

UK Opinion

Philip Coppel QC, author of ‘Information Rights’

Dr Matthew Richardson, author of ‘Cyber Crime: Law & Practice’

There are, it seems, multiple separate reasons why the use of the GreyList System does not result in an offence under either s1 or s3[1] of the CMA 1990.
The GreyList System does not interact with any human let alone induce them to behaviour which is detrimental to them or any other person, or advantageous to the sender or any other person, and thus is not a “Phishing” scam nor can it be a fraud, and does not fall foul of the CMA 1998.
Passing off is not a relevant consideration because the basic elements of Passing off are not met.
The GreyList System does not take any unauthorised data from any computer system. Instead, the system generates its own data from information it does NOT receive. There is therefore no issue of data theft or data protection.

US Opinion

Gerald Ferguson, BakerHostetler

The GreyList Service does not constitute illegal or deceptive access of any Computer Systems or Electronic Information. The Service does not violate the Federal Computer Fraud and Abuse Act.
The Service does not constitute phishing as is outlawed in numerous states.
The Service does not expose GLT to liability under Federal Data Privacy Laws. The California Consumer Privacy Act does not apply to GLT.
The Service does not expose GLT to Tort Liability for Invasion of Privacy.
GreyList is not subject to the Bank Secrecy Act.
The Service does not violate Can-Spam.