Effective Date: March 2, 2023

Last Updated: April 7, 2025

Introduction

This Data Processing Agreement (“DPA”) forms part of the Terms of Service (“Agreement”) between you (“Customer”) and Inframail Inc. (“Processor”, “we”, “us”, or “our”), and applies when we process personal data on your behalf while providing our email hosting and infrastructure services.

1. Definitions

• “Personal Data” means any information relating to an identified or identifiable person.
  

• “Processing” means any operation performed on personal data (e.g. collection, storage, use, deletion).
  

• “Data Controller” means you, the Customer, who decides how and why Personal Data is processed.

• “Data Processor” means us, Inframail, who processes data on your behalf.
  

2. Roles and Responsibilities

• You (the Customer) are the Data Controller.

• Inframail is the Data Processor, acting on your instructions.

• You are responsible for ensuring you have the legal right to collect and send emails to your leads.

3. Scope of Processing

• We only process Personal Data as necessary to provide our services: hosting email inboxes, sending messages, and maintaining technical infrastructure.

• We do not sell, share, or use your data for any purpose other than operating Inframail.

4. Security Measures

• We implement industry-standard security:

  • Data encryption in transit

  • Access controls and authentication

  • Regular server and system monitoring

• We limit access to personal data to authorized personnel only.

5. Subprocessors

• We may use third-party infrastructure providers (e.g., cloud servers) to deliver our services.

• A list of subprocessors is available upon request.

• We ensure all subprocessors meet or exceed our data protection standards.

6. Data Subject Rights

• If a data subject (i.e., one of your contacts) requests access, deletion, or correction, we will assist you in fulfilling that request—at your instruction.

7. Data Breaches

• If we become aware of a personal data breach, we will notify you without undue delay and provide relevant details and support.

8. Deletion of Data

• Upon termination of your account, we will delete or anonymize all personal data within 30 days, unless legally required to retain it.

9. International Transfers

• We may transfer data outside the EEA.

• When we do, we ensure appropriate safeguards are in place (such as Standard Contractual Clauses).

10. Governing Law

• This DPA is governed by the same jurisdiction as our Terms of Service.

11. Contact

If you have any questions or data requests, please contact: support@inframail.io