Data Processing Addendum
How BlueSend acts as a processor of personal data on behalf of customers who act as controllers.
Last updated: Draft — pending review
Draft — not legal advice. This document is a placeholder pending review by counsel and is not yet binding. It will be finalized before BlueSend launches commercially.
1.Roles (link to this section)
For personal data contained in the email you send, you (the customer) are the data controller and Real Blue Software LLC, operating BlueSend, is the data processor. We process that data only to provide the service and on your documented instructions.
2.Scope of processing (link to this section)
We process recipient addresses and message content to deliver email and maintain delivery/audit records. We do not sell personal data and do not use recipient data to build our own marketing lists.
3.Subprocessors (link to this section)
We use Amazon SES (email delivery) and Google Cloud Platform (hosting) as subprocessors. A current list and notice of changes will be maintained here on finalization.
4.Security (link to this section)
We apply administrative and technical safeguards appropriate to the data, including access controls, encryption in transit, and per-tenant isolation of sending identities and keys.
5.International transfers (link to this section)
Where personal data is transferred across borders, we rely on appropriate safeguards (such as Standard Contractual Clauses) to be specified in the finalized addendum.
6.Assistance & deletion (link to this section)
We assist with data-subject requests and, on termination, delete or return personal data in accordance with the finalized terms and applicable retention obligations.