Renzo may be right and I may be wrong.
The distinction seems to be whether the marketer is to be regarded as sending an email to me, who is not a subscriber, or to the company that employs me. Neither PECR or ICO guidance really helps with that. What if they start off the email "Dear Phil ... "? Does that even matter?
What if I have put a message on my profile - which the scrape would not pick up - "I object to any marketing based on the information based in this profile"?
What is not in doubt however is that any such scrape based exercise will involve multiple PECR breaches as there is simply no way of determining the true status of the subscriber from the email address.
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