Data Processing Addendum

Effective date: 2026-05-07

MiraMail (operated by [Operator Legal Entity Name TBD]) is a technical platform. We process Personal Data only on the documented instructions of the Customer acting as Data Controller. We do not, and are not obligated to, verify the legal basis under which Customer processes Personal Data. Responsibility for compliance with applicable data-protection law lies with the Customer (see §5 and §16 below).

This Data Processing Addendum ("DPA") applies when MiraMail (the "Processor", operated by [Operator Legal Entity Name TBD]) processes Personal Data on behalf of a customer (the "Controller") in providing the Service. It supplements the Terms of Service and Privacy Policy.

1. Definitions

Terms used here have the meanings given to them under the EU General Data Protection Regulation 2016/679 ("GDPR") and equivalent laws in other jurisdictions (UK GDPR, CCPA, LGPD, etc.).

2. Subject Matter and Duration

Subject matter: Processing of Personal Data uploaded by the Controller to the Service (contact records, email addresses, custom attributes, behavioral events, email content).

Duration: For the term of the Controller's account, plus the retention periods specified in the Privacy Policy and §13 of this DPA.

3. Nature and Purpose of Processing

The Processor processes Personal Data only to:

4. Categories of Data and Data Subjects

5. Controller's Obligations

The Controller is solely responsible for the lawfulness of the processing it instructs the Processor to perform. Without limiting the generality of the foregoing, the Controller shall:

6. Processor's Obligations

7. Sub-Processors

The Controller authorizes the Processor to engage:

We provide 30 days' notice via email before adding a new sub-processor. The Controller may object on reasonable grounds by emailing dpo@miramail.io; if no resolution is found, the Controller may terminate without penalty.

8. Security Measures (Art. 32)

9. Data-Subject Requests

The Service provides self-service tooling for the Controller to handle subject requests:

Requests that cannot be completed via tooling are forwarded to dpo@miramail.io and actioned within 30 days.

10. Personal Data Breach Notification

The Processor will notify the Controller without undue delay, and in any event within 72 hours, of becoming aware of a Personal Data Breach affecting the Controller's data, including: nature of the breach, categories and approximate number of data subjects affected, likely consequences, and measures taken or proposed.

The Controller is responsible for any downstream notifications — to its own recipients, end-users, and to the competent supervisory authority (Article 33 GDPR), where the Controller is the entity required to make such notification. The Processor's notification to the Controller does not discharge the Controller's statutory duties.

11. Audit and Inspection

On reasonable notice (≥ 30 days, no more than once per year) the Controller may audit the Processor's compliance with this DPA. The Processor provides access to relevant compliance documentation and SOC reports if available. Audits are at the Controller's expense unless they reveal material non-compliance.

12. International Transfers

Where Personal Data is transferred outside the EU/EEA, the Processor relies on the European Commission's Standard Contractual Clauses (Module Two: Controller-to-Processor) and supplementary measures as appropriate. The SCCs are incorporated by reference into this DPA.

13. Data Return and Deletion

On termination, the Controller may export all data via the self-service export tool. Within 30 days of termination, the Processor deletes all Controller data from production systems. Data may persist in encrypted backups for up to 30 additional days before backup rotation removes it.

14. Conflicts

In the event of a conflict between this DPA and the Terms of Service, this DPA prevails for matters relating to the processing of Personal Data.

15. Governing Law

This DPA is governed by the laws of Bulgaria and, where applicable, the European Union. Disputes shall be subject to the exclusive jurisdiction of the courts of Bulgaria, subject to mandatory rules of the Data Subject's jurisdiction.

16. Tech-Platform Acknowledgement

Customer acknowledges that [Operator Legal Entity Name TBD] provides infrastructure and tools only. [Operator Legal Entity Name TBD] does not, and is not obligated to, verify the legal basis under which Customer processes Personal Data. Customer is the sole determining party for the purposes and means of processing within the meaning of GDPR Article 4(7), and bears full responsibility under Article 5 for compliance with the data-protection principles (lawfulness, fairness, and transparency; purpose limitation; data minimisation; accuracy; storage limitation; integrity and confidentiality; and accountability).

17. Contact

Data Protection Officer: dpo@miramail.io Operator: [Operator Legal Entity Name TBD], [Registered Address TBD], Bulgaria (reg. [Registration Number TBD]).