Veri işleme sözleşmesi

1. Processing entrusted

• Purpose: running the Customer's email prospecting campaigns and tracking their results.
• Data subjects: the Customer's prospects and contacts, people mentioned in the replies they receive.
• Data: identity and contact details, job title, company, message content, opens, clicks, conversions, relevance score.
• Duration: that of the subscription or trial, until the workspace is deleted.

2. Addresses picked up from replies

When a reply names another person to contact, the service may add that address to the campaign's prospects. The Customer remains responsible for the legitimacy of that contact and for the opt-outs received, including for these people.

3. Publisher's commitments

• process the data only on the Customer's instructions, expressed through their use of the service, and alert them if an instruction seems unlawful;
• bind the people authorised to access it to confidentiality;
• ensure security: encrypted connection (HTTPS), encrypted mailbox credentials, hashed passwords, database not exposed to the internet, daily backups;
• notify the Customer of any data breach without undue delay, and at the latest 48 hours after becoming aware of it;
• help them respond to data subjects' requests and meet their obligations; unsubscribes are applied automatically;
• provide, on written request to commercial@smartoutbound.cloud, the information needed to verify compliance with this agreement, within 30 days.

4. Sub-processors

The Customer authorises the use of the following providers:

• Hostinger: hosting, on a server located in France.
• Anthropic (United States): AI processing, governed by the European Commission's standard contractual clauses.

Any new provider is announced by email at least 30 days in advance; the Customer may object on legitimate grounds and, failing agreement, cancel their subscription.

5. End of the contract

On request before the end of the contract, the Publisher gives the Customer a copy of their data. The Customer can delete their workspace from their settings: everything is then erased from the database immediately, and from backups within 14 days.