Data processing addendum

This addendum applies when emailservicesolutions ("Processor") processes personal data on behalf of a customer ("Controller") while providing the service, for example addresses in lists you upload for validation or data on servers you connect. It forms part of the Terms of Service.

1. Subject matter and duration

We process personal data to provide the features you use, for as long as your account is active and for the retention periods in the Privacy Policy afterwards.

2. Categories of data and people

Personal data in lists you upload (usually email addresses and related fields) and data your servers handle that we read during checks. The people concerned are your own contacts and users.

3. Our obligations

• Process the data only on your documented instructions, which are your use of the service and these terms.
• Make sure the people authorised to process the data are bound by confidentiality.
• Apply appropriate technical and organisational security measures, including encryption of credentials, access control and logging, and tenant separation.
• Assist you, taking account of the nature of processing, with requests from the people concerned and with your own obligations on security, breach notification and impact assessments.
• Tell you without undue delay after becoming aware of a personal data breach that affects your data.
• At the end of the service, delete your data after the retention period, or return it on request, unless the law requires us to keep it.
• Make available the information needed to show compliance and allow reasonable audits, with notice and without exposing other customers' data.

4. Your obligations

You must have a lawful basis for the data you submit, must not submit purchased or scraped lists (see the Acceptable Use Policy), and must give us lawful instructions.

5. Subprocessors

You authorise the subprocessors on the subprocessors page. We will update that page before we add or replace one so you can object.

6. International transfers

[Transfer mechanisms to be confirmed by counsel.]

7. Contact