--- title: "Data processing addendum" canonical: https://pulsepigeon.com/dpa last_updated: 2026-07-19 --- # Data processing addendum PulsePigeon Data Processing Addendum: Article 28 processor terms covering roles, instructions, security, sub-processors, breach notification, and transfers. This Data Processing Addendum (DPA) governs PulsePigeon's processing of personal data on behalf of customers who are subject to the GDPR, UK GDPR, or comparable laws. It is incorporated into and forms part of the Terms of Service. Effective date: October 7, 2026 ## Roles of the parties For personal data contained in the mail you send (“Customer Personal Data”), you are the **controller** and PulsePigeon is the **processor**. Where you are yourself a processor for your end customer, PulsePigeon acts as a sub-processor and the same obligations apply. ## Scope and instructions PulsePigeon processes Customer Personal Data only to provide the service and only on your documented instructions, including as set out in the Terms, the console configuration, and your API calls. We will inform you if, in our opinion, an instruction infringes applicable data protection law. **Subject matter:** delivery of transactional and permission-based email and related reporting and abuse-prevention. **Duration:** the term of the agreement plus limited retention as described. **Nature and purpose:** sending, delivery, suppression, and delivery analytics. **Data subjects:** your recipients. **Data categories:** email addresses, message content and metadata, and delivery events. ## Confidentiality PulsePigeon ensures that personnel authorized to process Customer Personal Data are bound by confidentiality obligations and access it only on a need-to-know basis under least-privilege controls. ## Security measures PulsePigeon implements appropriate technical and organizational measures to protect Customer Personal Data, including: - encryption of data in transit and at rest; - tenant isolation and project-scoped access controls; - server-side secret management that never exposes credentials to clients; - access logging, monitoring, and abuse controls; and - regular review of controls and a vulnerability-management process. A summary of these measures is maintained on the [Security](/security) page and forms the technical and organizational measures (Annex II) for this DPA. ## Sub-processors You provide general authorization for PulsePigeon to engage sub-processors to provide the service. The current sub-processors are listed on the [Subprocessors](/subprocessors) page. PulsePigeon imposes data-protection obligations on each sub-processor no less protective than those in this DPA and remains responsible for their performance. We will give notice before adding or replacing a sub-processor. If you reasonably object on data-protection grounds, we will work with you in good faith to address the concern. ## Assistance and data subject rights Taking into account the nature of processing, PulsePigeon will assist you, by appropriate technical and organizational measures, in fulfilling your obligations to respond to data-subject rights requests and to ensure security, breach notification, and data-protection impact assessments. The console provides suppression export, data deletion, and retention controls to support this. ## Personal data breach notification PulsePigeon will notify you without undue delay after becoming aware of a personal data breach affecting Customer Personal Data, and will provide information reasonably available to help you meet your own notification obligations. ## Return and deletion On termination, and at your choice, PulsePigeon will delete or return Customer Personal Data and delete existing copies, subject to legal, suppression, and operational retention described in the [Privacy Policy](/privacy). As controller, you set a contact retention window of 1 to 24 months and instruct PulsePigeon as processor to schedule deletion of archived contacts, including churned contacts who have not requested erasure. The window begins when the contact is archived; former status alone does not start it. At the end of that window, contacts become eligible for automatic deletion. Automatic lifecycle deletion is disabled by default; until enabled, contacts remain archived. Active customers and legal holds defer deletion. Contacts who unsubscribe or opt out are not sent marketing or winback mail. We execute eligible contact erasure instructions, deleting the contact profile, events, consents, preferences, and list memberships. When a contact is erased, we keep only one-way fingerprints of the email address, never the address itself, so the erasure and any opt-out keep working. A fingerprint cannot be turned back into an address, but it can be matched against an address someone already has. If an erasure is deferred (for example because of a legal hold), the contact record is kept until the deferral ends. Suppression lists that customers keep for their own sending are stored as addresses and are deleted with the workspace. Limited operational data, including queued or in-flight message records and delivery-protection suppression entries, may remain. Operational retention windows apply where configured. Billing and invoice records are retained separately for the legally required accounting period and are never used for marketing. Delete requests for active customers may be deferred until their status changes or you explicitly proceed as controller. Legal holds suspend deletion until released. Marketing remains suppressed while a delete request is pending. Storage errors leave the request unfulfilled for repair and retry. ## Audits PulsePigeon will make available information reasonably necessary to demonstrate compliance with this DPA and will allow for and contribute to audits, including inspections, conducted by you or an auditor you mandate, subject to reasonable notice, confidentiality, and scope limits. ## International transfers Where PulsePigeon transfers Customer Personal Data outside the EEA, UK, or Switzerland to a country without an adequacy decision, the transfer is governed by the applicable Standard Contractual Clauses, which are incorporated into this DPA by reference and completed by the details in this document and the [Subprocessors](/subprocessors) page. ## Contact To request a countersigned copy of this DPA or ask questions, contact [privacy@pulsepigeon.com](mailto:privacy@pulsepigeon.com).