Draft — pending legal review

Version 2026-10-17

Data Processing Agreement

In plain English

✓ For recipient and contact data you send through us, you are the controller and we are the processor.

✓ We process it only on your instructions.

Roles

For personal data of your recipients and contacts that you submit to DevelEmail, you are the controller (or processor for your own customer) and Develemit LLC is the processor. For account data, Develemit is the controller; see the Privacy Policy.

Processing Instructions

We process recipient data only to provide the service as described in the Terms and your configuration, and as otherwise documented in your written instructions. We will tell you if we believe an instruction infringes applicable law.

Confidentiality and Security

We ensure that personnel with access to recipient data are bound by confidentiality, and we maintain technical and organizational measures appropriate to the risk, including encryption in transit, access controls, and encrypted backups.

Subprocessors

You authorize the subprocessors listed on our Subprocessors page. We impose data-protection obligations on each and remain responsible for their performance. You may object to a new subprocessor on reasonable grounds by contacting us before it is engaged.

International Transfers

Data is hosted in the European Union and Develemit LLC is established in the United States. Where required, transfers rely on appropriate safeguards such as standard contractual clauses.

Assistance and Data Subject Requests

We will help you respond to data-subject requests, security obligations, and impact assessments, taking into account the nature of the processing. Forward any request we receive about your recipients to you rather than responding directly.

Breach Notification

We will notify you without undue delay after becoming aware of a personal data breach affecting your recipient data.

Deletion and Return

When your account ends, we delete or return recipient data at your choice, subject to retention required by law and a short lag for deletion from backups.

Audits and Contact

On reasonable request we will provide information needed to demonstrate compliance. Contact [email protected].