This agreement —DPA— sets the terms for processing Sendiro performs on a customer’s behalf when operating its workspaces. It becomes part of the contract when the customer and Sendiro expressly accept it through a written or electronic means that records acceptance. Publication or a visit to this page does not constitute that acceptance. The operator is identified on the contact and legal identity page; acceptance identifies the customer, its authority and the covered workspaces.
1. Roles and scope
The customer determines the purposes and instructions concerning contact and message data. Sendiro acts on its behalf to provide the agreed features. If the customer is itself a processor for another organization, it must be authorized to appoint Sendiro as a subprocessor and transmit valid instructions.
Information Sendiro processes for its own account, commercial relationship, security and legal purposes is governed by the privacy policy. The same information may serve different purposes that must be distinguished and justified; this agreement does not authorize its reuse for Sendiro’s own marketing.
2. Description of processing
| Element | Scope |
|---|---|
| Subject and purpose | Manage contacts and consent, prepare communications, run campaigns, automations and transactional messages, record results and maintain sending restrictions. |
| Operations | Receipt, import, recording, organization, consultation, segmentation, storage, modification, transmission to sending providers and authorized destinations, restriction and deletion under lawful instructions. |
| Individuals | Subscribers, recipients, customers, prospects and other individuals lawfully added by the customer; users of its integrations when their information forms part of an instruction. |
| Information | Email address, name and custom fields; audience membership; consent evidence; subscription and suppression status; senders, recipients, subject and content; identifiers, dates and sending, delivery, open, click, bounce, complaint and unsubscribe events. |
| Duration | During provision of contracted features and, after termination, during return, deletion or limited retention under section 9. |
Processing sensitive data, health information, credentials, complete payment-card information or children’s data is not authorized by default. A use case involving specially protected categories requires prior assessment and a specific agreement; the availability of a custom field does not provide that authorization.
3. Instructions and customer obligations
Documented instructions consist of the contract, this agreement and authorized customer operations through the application or API. The customer must limit information to what is necessary, keep it accurate, provide prior information to individuals and obtain required consents or authorizations. It must retain evidence of contact sources and disclose email tracking.
The customer controls the members, keys, integrations and webhook destinations it enables. It must ensure its instructions, content and recipients are lawful and comply with the acceptable use and anti-spam policy. It may not instruct Sendiro to restore nonexistent consent, bypass an unsubscribe or erase evidence to evade a valid restriction.
By adding resources to the media library for its communications, the customer instructs their availability through token-bearing links that can be opened without signing in. The library must not be used for information requiring private access. This agreement’s confidentiality provisions do not make resources private where the customer has instructed their publication; after sharing, external copies or caches may persist even after the original is deleted.
Sendiro will process information only under documented instructions and applicable legal obligations. If an instruction appears unlawful, Sendiro will inform the customer and may suspend the affected operation pending clarification. Where legislation requires other processing, Sendiro will inform the customer beforehand unless legally prohibited.
4. Confidentiality and security
Access by authorized individuals must be limited to what their duties require and subject to confidentiality obligations that survive the relationship. Lists and messages may not be accessed merely for commercial interest.
Sendiro will maintain technical and organizational measures appropriate to the risks. Their scope includes authentication, separation of workspace permissions, server controls, integration access management and protection of sessions and communications. The customer remains responsible for its devices, credentials, permissions and connected external systems.
This agreement does not promise freedom from incidents, exclusive residency in one country, unverified certifications or particular controls not agreed by the parties. Additional measures needed for a specific use must be documented before it is accepted.
5. Personal data incidents
When Sendiro becomes aware of a security incident affecting information processed on a customer’s behalf, it will inform the customer without undue delay through its designated contact channel. Available information will include the incident’s nature, affected categories, foreseeable consequences and measures taken or proposed; information may be provided in stages as the investigation progresses.
Sendiro will reasonably assist containment, investigation and documentation. The customer determines its required notifications to individuals and authorities, without prejudice to Sendiro’s direct obligations. No universal 24-, 48- or 72-hour deadline is established; applicable legal deadlines and any specific commitments formalized by the parties prevail.
6. Rights requests and assistance
Sendiro will pass on requests that concern the customer’s controller role and assist with reasonably available information and operations. Where legislation requires Sendiro to respond directly, it will do so and coordinate with the customer where permitted.
Assistance covers locating, correcting, restricting, returning or deleting information as appropriate, and providing relevant information for risk assessments, authority requests and security obligations. This does not authorize disclosure of other customers’ information or third-party secrets or credentials.
7. Subprocessing and international processing
The providers used and their functions appear on the providers and subprocessors page. By accepting this agreement, the customer authorizes the subprocessors identified there for its contracted service features, subject to required safeguards. This authorization does not itself enable a disabled feature or replace additional conditions a particular flow requires. Sendiro will require its subprocessors to accept data-protection obligations appropriate to their function and retain its responsibilities to the customer under applicable legislation and the contract.
Material changes will be communicated to the designated contact before new processing, with sufficient information to assess a reasoned data-protection objection. The parties will seek a feasible alternative; if none exists, they must address continuation of the affected feature under the contract without activating processing that lacks required authorization.
Providers may process information outside the customer’s country. The parties must determine and formalize consents, instructions, clauses or safeguards required for each flow. This agreement does not automatically incorporate European standard contractual clauses or by itself ensure that every transfer is lawful.
8. Information and verification
Sendiro will provide reasonable information to demonstrate compliance with its obligations, prioritizing documentation and responses to inquiries. Where legislation or a substantiated risk warrants an additional audit, the parties will agree proportionate scope, confidentiality, notice and conditions, without limiting a competent authority’s powers.
Verification must protect other customers’ information, security and service continuity. Extraordinary assistance costs may be agreed in advance, without conditioning rights that legislation requires to be exercised free of charge.
9. Information at the end of service
At the end of service, the customer may choose return or deletion by instructing support@sendiro.app, with “Privacy,” the affected workspaces and its choice. Sendiro verifies the requester’s identity and authority, explains the electronic format available for return and manually handles the necessary operations. Returning information does not authorize retaining a copy for further sending; the customer may request return followed by deletion. Commercial cancellation alone does not perform complete account or workspace erasure.
Handling follows the retention criteria by category in the privacy policy: account and settings, profiles, messages and results, consent and restrictions, media, technical records and commercial or request documentation. Sendiro communicates the outcome, operations performed and any retained information, with its purpose, basis and duration criteria, within applicable legal deadlines. Identity verification or operational coordination does not authorize improper delay of a right. No uniform automatic purge is established, and token expiry is not presumed to delete the information it granted access to.
Deleting a contact in the application minimizes its profile but retains its email identity and consent or suppression evidence. Deleting a design or resource does not automatically erase messages, revisions or recipients’ copies either. A broader erasure instruction requires reviewing those linked records and restrictions that must be preserved; these application actions are not complete erasure.
Any later retention is limited to a legal obligation, a claim or a justified need to document and maintain sending restrictions. Information is kept with restricted access, without restarting campaigns, and deleted or anonymized when the purpose ends. If copies remain under Sendiro’s or a subprocessor’s control, their treatment and applicable limitations are explained; erasure is not instant. Confidentiality and protection obligations continue while information is retained.
10. Adjustments for applicable legislation
- Costa Rica: the contract must respect prior information, consent, rights and security duties under Law 8968, as well as conditions applicable to disclosures and international processing.
- Mexico: where the customer is subject to Mexican legislation, Sendiro will act under the controller’s documented engagement; it will not determine different purposes or assume every disclosure to a processor is a transfer between controllers. Applicable subprocessing and ARCO-rights assistance must be formalized.
- United States: where applicable state legislation requires service-provider or contractor terms, the relevant addendum must be incorporated. This agreement does not authorize selling or sharing information for cross-context behavioral advertising, or combining lists for purposes unrelated to the service.
Customers whose individuals or activities fall under other regimes must disclose this before processing so additional conditions can be assessed. The customer’s billing country alone does not determine every applicable law.
11. Contact, acceptance and precedence
Send contractual instructions and questions about this agreement through the contact channel. In a conflict concerning processing on the customer’s behalf, this agreement prevails over general terms, subject to mandatory law. Remaining commercial conditions continue to be governed by the terms of service.
Acceptance identifies the parties and their authority, covered workspaces, incident channel and any agreed additional addenda. A record of the accepted version and the subprocessor authorization in section 7 is retained. Instructions and closure requests follow section 9 unless additional lawful conditions are expressly agreed. Visiting this page does not establish acceptance.