This template DPA forms part of the Terms of Service between Customer (you) and LIMERION GmbH (us) governing our processing of personal data on your behalf. Pro and Enterprise customers can request a signed counter-part by emailing legal@mailnix.ch.
1. Introduction
You are the controller; we are the processor. We process personal data only on your documented instructions, including the instruction to operate the Service.
2. Scope of processing
- Categories of data subjects: your end-users, customers, employees, anyone you send to, and visitors who submit forms you publish.
- Categories of data: recipient email addresses, message content (subject, body, attachments), delivery metadata (timestamps, response codes, provider IDs), form submission field values, uploaded files, and transient submitter metadata used for rate limiting and spam scoring.
- Purposes: message delivery, trace storage, suppression management, form hosting and submission storage, malware scanning of uploads, spam scoring, and owner notification delivery.
- Duration: the term of your subscription plus 30 days, then erasure. Form submissions additionally follow the per-form retention window you configure.
3. Processor obligations
- Process personal data only on your documented instructions.
- Ensure personnel authorised to process personal data have committed to confidentiality.
- Implement appropriate technical and organisational measures (see Section 5).
- Assist you in fulfilling data subject requests where the data is held by us.
- Delete or return all personal data at the end of the engagement, at your choice, except where retention is required by EU or member-state law.
4. Sub-processors
You authorise us to engage the sub-processors listed in our Privacy Policy. We will notify you at least 30 days before adding a new sub-processor; you may object on reasonable grounds, in which case we will work with you to resolve the concern or you may terminate the affected services without penalty.
5. Security measures
- TLS 1.3 in transit; AES-256-GCM at rest with HKDF per-row keys.
- OAuth 2.1 audience-bound JWTs; refresh-token rotation with theft detection.
- Principle of least privilege for personnel access; full audit logging.
- Backups encrypted at rest; restoration tested quarterly.
- Production runs on Hetzner DCs in Germany (Nuremberg primary, Falkenstein DR).
6. Data subject requests
Where a data subject contacts us directly, we will not respond on your behalf unless you authorise us to do so. We will refer the request to you and assist you in fulfilling it.
7. Breach notification
We will notify you without undue delay (and in any event within 72 hours) after becoming aware of a personal data breach affecting your personal data, providing the categories of data and approximate number of records affected, likely consequences, and measures taken or proposed.