Data Processing Agreement

Parties and scope

This agreement is between you, the Dubsend customer (the controller), and ANGVIS LTD, company 12763866 (the processor, "we"). It is part of our Terms of Service and applies whenever we process personal data for you under the UK GDPR, or the EU GDPR where it applies to you. If anything here conflicts with the Terms on data protection, this agreement wins.

Details of the processing

Subject matter	Storing your contacts and sending your promos with Dubsend.
Duration	While you have an account, and up to 30 days after it is closed.
Nature and purpose	Storing and organising contacts; sending promo and reminder emails; hosting each recipient's promo page; recording delivery, opens, page visits, listening time, downloads, feedback and unsubscribes; tagging downloaded files with the recipient's name and email; producing stats, CSV exports and reports for you.
Personal data	Email address, name, role, country, tags, notes, consent record (basis, date, source), join page sign-ups, the activity listed above, and feedback (rating, favourite track, comment).
Data subjects	Your contacts: DJs, radio presenters, journalists, curators and others you send promos to; people who sign up on your join page.
Special category data	None expected. Don't put health, political, religious or similar information in notes or tags.

Our obligations

We process the data only on your documented instructions: these terms and the settings and actions you take in Dubsend. If we think an instruction breaks data protection law, we will tell you.
Everyone who can access the data is bound by confidentiality.
We keep the security measures in the annex below in place and improve them over time.
We help you answer requests from your contacts (access, correction, deletion, objection). Dubsend lets you edit, export and delete contacts yourself; for anything else, email support@dubsend.com.
We help you with security, data protection impact assessments and consultations with the regulator, as far as they concern Dubsend.
We tell you about a personal data breach affecting your data without undue delay, and in any case within 48 hours of becoming aware of it, with the information you need to meet your own obligations.
When your account is closed we delete your data within 30 days, unless the law requires us to keep it. Data in backups is deleted when those backups expire.
We give you the information you need to show this agreement is met. Once a year, with 30 days' notice, you may audit our compliance at your own cost, under confidentiality, in a way that doesn't disrupt the service or other customers' data.

Your obligations

You have a lawful basis to send promos to every contact, and where the Privacy and Electronic Communications Regulations apply, the consent they require. You record the consent basis truthfully for each contact.
You tell your contacts who you are and how you use their data. Dubsend shows your brand as the sender, and every promo email and promo page has an unsubscribe link. On the Free plan the promo page also links to our For DJs page.
You answer your contacts' requests about their data, with our help where needed.
You follow our Acceptable Use Policy.

Sub-processors

You authorise us to use these sub-processors:

Sub-processor	What for	Where
Supabase, Inc.	Database and login (accounts, brands, contacts, campaigns, activity; login records: the IP address and browser of each login)	London, United Kingdom (AWS eu-west-2)
Cloudflare, Inc.	Website and app hosting (Workers; request logs: IP address, browser, page and time, kept for up to 7 days), file storage (R2: music, artwork, logos, tagged copies), the email copy of cover art (Images) and the bot check on join pages (Turnstile)	R2: European Union jurisdiction. Workers, Images and Turnstile: Cloudflare's global network (each request is handled in the data centre nearest the visitor)
Amazon Web Services EMEA SARL	Sending email (Amazon SES, which also keeps our account's suppression list of addresses that hard-bounced or reported spam) and delivery, bounce and complaint notices (Amazon SNS)	Ireland (eu-west-1)
Infomaniak Network SA	The support mailbox (support@dubsend.com)	Switzerland

Each has a written contract with data protection terms at least as protective as this agreement. We will email account holders at least 30 days before adding or replacing a sub-processor. If you object for a reasonable data protection reason and we can't solve it, you may close your account before the change applies.

International transfers

Your data is stored in the UK and the EU, and support emails are stored in Switzerland. Where a sub-processor accesses it from another country, the transfer is covered by UK adequacy regulations, the UK Extension to the EU-US Data Privacy Framework, or the UK International Data Transfer Agreement or Addendum to the EU Standard Contractual Clauses.

Data we keep as controller

To keep email delivery working for all customers and to stop misuse, we keep some records as an independent controller, as our Privacy Policy explains: the Dubsend-wide block list (a hash of addresses that hard-bounced or reported spam; Amazon SES also keeps those addresses on our account's suppression list), the sending record (a hash of each recipient's address with the send details, for 90 days), import counts and rate-limit records. The block list, the SES suppression list and the sending record stay after you delete a contact or close your account; the Privacy Policy says for how long.

Liability and end

The liability limits in the Terms of Service apply to this agreement. This agreement ends when we no longer process personal data for you.

Annex: security measures

Encryption in transit (HTTPS and TLS for every connection) and at rest at our hosting providers.
Row-level security in the database: each account can only read and change its own data.
Files in private storage, served only through signed links that expire within an hour.
Personal promo links and report links stored only as hashes. Recipients' IP addresses, browsers and locations are not stored in Dubsend's database (our hosting provider's request logs and the join page bot check see them for a short time, as the Privacy Policy explains).
Provider keys limited to the permissions they need; secrets kept out of the code.
Automatic suppression of addresses that unsubscribe, bounce or complain, and automatic sending pauses on high bounce or complaint rates.
Automated tests that check no account can read another account's data.