Data Processing Agreement

Standard terms under Article 28 GDPR: who is controller and processor, what we do with prospect data, who else touches it, and how it is deleted.

Last updated 12 October 2026

Standard terms, version of 12 October 2026. These terms form part of the Terms of Service for every customer that uses anymail to process personal data of third parties. A countersigned copy is available on request from privacy@anymail.watch. Print this page to keep a dated copy.

1. Parties and roles

The Customer (you, the holder of a anymail workspace) is the controller of the personal data it uploads, imports, receives or generates in anymail: prospects, their employers, replies, offer visits and everything derived from them ("Customer Data"). Meditium sp. z o.o., Odkryta 11C/12, 03-140 Warsaw, Poland, VAT PL5242921982, KRS 0000909721 ("anymail", we) is the processor. For account data of the Customer's own users (login email, name, billing) anymail is an independent controller; that processing is described in the Privacy Policy rather than in this agreement.

2. Subject matter, nature, purpose, duration

anymail stores Customer Data, sends email messages on the Customer's instruction from mailboxes the Customer connected, receives and classifies replies, records engagement events (sent, delivered, bounced, replied, clicked, offer visits), groups people by company and displays the result to the Customer's users. The purpose is the Customer's business outreach. Processing lasts for the term of the subscription and the deletion period in section 9.

3. Categories of data and data subjects

• Data subjects: business contacts the Customer chooses to write to, their colleagues at the same organisation, and readers of offers the Customer sends.
• Data: name, business email address, employer, position, timezone, custom fields the Customer defines, the content of messages the Customer sends and of replies received, engagement events with timestamps, coarse device and IP-derived information for offer visits, suppression and unsubscribe records.
• Special categories: none are intended. The Customer must not use anymail to process special categories of data or data of children.

4. Instructions

anymail processes Customer Data only on documented instructions from the Customer. The Customer's use of the product (creating campaigns, importing lists, connecting mailboxes, sending offers, calling the API) constitutes those instructions. anymail will inform the Customer if, in its opinion, an instruction infringes data protection law. anymail does not use Customer Data to train models, to build lists for other customers, or for any purpose of its own.

5. Confidentiality and personnel

Access to Customer Data inside anymail is limited to personnel who need it to operate and support the service, bound by confidentiality, and logged. Support access to a workspace happens only at the Customer's request.

6. Security

anymail implements the measures described on the Security page, which forms part of these terms, including: hosting inside the European Union (application and database in Germany); encryption in transit for every connection; encryption at rest for mailbox credentials and integration tokens with per-workspace keys; row-level isolation between workspaces enforced in the database; hashed API tokens; signed webhooks; daily backups; and a suppression list that is checked on every send. anymail may update these measures provided the level of protection does not decrease.

7. Sub-processors

The Customer authorises the sub-processors below. anymail will announce additions or replacements on this page and by email to the workspace owner at least 14 days before they take effect; the Customer may object on reasonable grounds within that period, in which case anymail will work with the Customer on a solution or the Customer may terminate the affected service.

8. Transfers

Core processing (storage, sending, receiving, display) happens inside the European Economic Area. Where a sub-processor processes data outside the EEA, anymail relies on the European Commission's Standard Contractual Clauses or an adequacy decision, and states this in the Privacy Policy.

9. Deletion and return

The Customer can export prospects, suppression lists and workspace data from the product at any time. On termination, anymail deletes Customer Data within 30 days, except where retention is required by law and except backups, which expire on their own schedule (currently 14 daily copies). Deletion removes data; it does not merely flag it.

10. Assistance

anymail assists the Customer with data subject requests by providing search, export and deletion in the product, and with security incidents by notifying the workspace owner without undue delay, and in any case within 48 hours of becoming aware of a personal data breach affecting Customer Data, with the information available at that time.

11. Audit

anymail provides the information needed to demonstrate compliance with this agreement on request: this page, the Security page, the sub-processor list and a description of the measures in place. An on-site audit may be requested once a year, at the Customer's cost, with 30 days' notice, limited to what is necessary and subject to confidentiality.

12. Precedence and changes

If these terms conflict with the Terms of Service, these terms prevail for the processing of Customer Data. anymail may update these terms to reflect changes in law or in the service; the version date at the top changes when it does, and material changes are announced to workspace owners.

Version of 12 October 2026. Questions: privacy@anymail.watch.