Privacy Policy

Draft for review. This document has not been reviewed by a lawyer and is not legal advice.

Effective date: [EFFECTIVE DATE]

This Privacy Policy explains how [LLC NAME], a [STATE] limited liability company located at [BUSINESS ADDRESS] ("GoSent", "we", "us"), handles personal information in connection with the website https://gosent.io and the GoSent email sending and verification service (the "Service").

We handle personal information in two different roles, and this policy treats them separately:

• As a controller for information about visitors to our website and about our customers and their team members (Sections 2 to 4).
• As a processor or service provider for information about the people our customers send email to or verify (Section 5). For that information, our customer decides how it is used, and the customer's own privacy notice applies.

1. Contact

For any privacy question or request, write to privacy@gosent.io or to [LLC NAME], [BUSINESS ADDRESS].

2. Information we collect about visitors and customers

Information you give us

• Account details: name, email address, password (stored only as a secure hash), company name, website and role.
• Review information: details you provide during account review, such as your business description, the types of email you plan to send and how your recipients sign up.
• Billing details: billing name, address and tax details. Card details are entered directly with Stripe; we see only limited information such as card brand, last four digits and expiry date.
• Support and communications: the content of messages you send to support@gosent.io or our other addresses.

Information collected automatically

• Usage and log data: IP address, browser and device type, pages viewed, API requests, timestamps and error logs.
• Cookies: cookies that keep you signed in, protect against fraud and remember your preferences. We do not use cookies for third-party advertising.

Information from others

• Payment status and fraud signals from Stripe.
• Domain and DNS information that is publicly available when you verify a sending domain.

3. How we use visitor and customer information

• To create and run your account, provide the Service and give you support (performance of our contract with you).
• To review new accounts, set sending limits, detect fraud and abuse, and protect our infrastructure and other customers (our legitimate interests in operating a safe service).
• To bill you and keep accounting and tax records (contract and legal obligation).
• To send service messages such as security alerts, billing notices, policy changes and limit warnings (contract and legitimate interests).
• To send product news, if you have not opted out. Every such message includes a way to unsubscribe (legitimate interests or consent, depending on where you are).
• To understand how the Service is used and improve it (legitimate interests).
• To comply with law and respond to lawful requests (legal obligation).

We do not sell personal information, and we do not share it for cross-context behavioural advertising.

4. How we share visitor and customer information

We share information only with:

• the sub-processors and service providers listed in Section 7, under contracts that limit their use of the information;
• professional advisers such as lawyers and accountants, under duties of confidentiality;
• authorities or other parties when the law requires it, or when needed to protect the rights, safety or property of GoSent, our customers or the public, including to investigate abuse; and
• a buyer or successor in a merger, acquisition or sale of assets, who will be bound by this policy for the information transferred.

5. Recipient data we process for customers

When customers use the Service, we process information about their recipients and their own end users on the customer's behalf ("Recipient Data"). This includes:

• email addresses and names of recipients;
• message content, subject lines, templates and attachments;
• delivery events such as delivered, bounced, complained, and, if the customer enables tracking, opened or clicked, along with related IP address and user agent;
• email addresses submitted for verification, through the API or in uploaded CSV files, and their results; and
• data from a customer's connected Stripe account that is needed to send Stripe-triggered emails, such as a customer's name, email address, and invoice or subscription details.

We use Recipient Data only to provide the Service to the customer as instructed, to keep the Service secure, to prevent abuse (for example, maintaining suppression lists of addresses that hard bounce or complain, so that they are not mailed again), and to meet legal obligations. We do not use Recipient Data to contact recipients for our own purposes, and we do not sell it.

The customer is responsible for having a lawful basis to send and verify, for giving recipients any required notice, and for answering recipients' privacy requests. If you received an email sent through GoSent and have questions about it, please contact the sender directly. If you contact us, we will pass your request to the relevant customer where we can identify them. To report unwanted email, see our Acceptable Use Policy or write to abuse@gosent.io.

Customers who need a data processing addendum, including standard contractual clauses for transfers from the EU, UK or Switzerland, can request one at legal@gosent.io.

6. Data retention

• Account and billing records: kept while your account is open, and afterwards for as long as needed for tax, accounting and legal purposes (typically up to seven years for billing records).
• Message content: kept for up to [30] days so customers can view and debug messages, then deleted.
• Message event logs and metadata: kept for up to [90] days, or the period shown for your plan in the dashboard.
• Bulk verification files: uploaded CSV files and result files are deleted [30] days after processing, or sooner if the customer deletes them.
• Suppression lists: kept for the life of the customer account so suppressed addresses are not mailed again.
• Security and abuse records: kept as long as reasonably needed to protect the Service.

When an account is closed, we delete or de-identify its Recipient Data within [60] days, except where the law requires us to keep it.

7. Sub-processors

We use the following providers to run GoSent. Each one processes personal information only to provide its service to us.

• Amazon Web Services, Inc. (United States): cloud hosting, databases and storage, and email delivery through Amazon Simple Email Service (Amazon SES). Processes account data and Recipient Data.
• Stripe, Inc. (United States): payment processing, invoicing and fraud prevention. Processes customer billing data and, where a customer connects their Stripe account, the Stripe event data used to trigger emails.
• Vercel Inc. (United States): hosting and delivery of our website and dashboard. Processes website visitor and dashboard usage data.
• Hostinger ([country]): our company email. Processes the content of emails sent to and from our @gosent.io addresses, such as support requests.

We will update this list before adding or replacing a sub-processor that handles Recipient Data, and customers who have signed our data processing addendum will receive advance notice and a chance to object.

8. International transfers

GoSent is based in the United States, and our providers store data mainly in the United States. If you are outside the US, your information will be transferred to and processed in the US. Where the law requires, we rely on appropriate safeguards for these transfers, such as the European Commission's standard contractual clauses and the UK addendum.

9. Security

We protect information with measures appropriate to the risk, including encryption in transit (TLS), encryption at rest at our hosting provider, hashed passwords and API keys, restricted staff access on a need-to-know basis, and logging of administrative access. No system is perfectly secure. If we become aware of a breach affecting your information, we will notify you and, where required, the authorities, as the law requires.

10. Your rights

GDPR and UK GDPR (EU, EEA and UK residents)

You may have the right to access your personal information, correct it, delete it, restrict or object to our processing of it, receive a portable copy, and withdraw consent at any time where we rely on consent. You also have the right to complain to your local data protection authority.

California and other US states

If you are a California resident, or live in another US state with a similar law, you may have the right to know what personal information we collect, use and disclose; to request a copy of it; to correct or delete it; and to opt out of its sale or sharing. We do not sell or share personal information as those terms are defined in California law, and we do not use sensitive personal information to infer characteristics about you. We will not discriminate against you for exercising your rights.

How to make a request

Email privacy@gosent.io from the address associated with your account, or describe your relationship with us so we can find your information. We may need to verify your identity before acting. An authorized agent may make a request for you with your signed permission. We aim to respond within 30 days (45 days for California requests), and will tell you if we need more time. If your request concerns Recipient Data, we will forward it to the customer who controls that data and help them respond.

11. Children

The Service is for businesses and is not directed to children under 16. We do not knowingly collect personal information from children. If you believe a child has given us personal information, contact privacy@gosent.io and we will delete it.

12. Changes to this policy

We may update this policy as the Service or the law changes. We will post the new version on this page with a new effective date and, if the changes are material, we will notify customers by email or in the dashboard before they take effect.