We made some updates to our Privacy Policy that will go into effect on May 25, 2018.
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Postmark and EU flags

EU Data Protection

We value your trust and work hard to protect your information

Summary

When you use our services you entrust us with your valuable information. We have made it a priority to protect your data and to provide you with choices about controlling it. We understand that there are particular concerns from companies in the EU about how we use and protect your data, so we put this page together as a guide to answer some of the most common questions you may have.

We provide more detail about all of this in our Privacy Policy, but here are some highlights:

Security and data center location

Data center

Postmark's primary data and servers are hosted at ServerCentral's data center (located outside of Chicago). We currently don't have plans to add servers in the EU (GDPR does not require physical servers in the EU).

A DuPont Fabros facility, the ServerCenter data center is Type 2 SSAE 16 SOC 1 accredited and includes keycard protocols, biometric scanning protocols and round-the-clock surveillance. Our environment is colocated, meaning we have full control of the physical environment and only our policies affect the access and use of the hardware, network and software. We provide multiple levels of backups and redundancy to ensure uptime and peace of mind. Data transferred from our customers to our servers is encrypted via SSL that is configured to meet or exceed all industry standards. Cold data at rest is encrypted with 2048-bit RSA.

Even though Postmark itself has not undergone a SOC audit, our data center has. We can provide a copy of the SOC report for the data center after completing an NDA.

We use technical and physical controls designed to prevent unauthorized access to your personal data. We restrict access to personal data only to our employees, contractors and agents who need to know this information in order to operate, develop or improve our service. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

App security

All access to the Postmark interface is secured over SSL (HTTPS), ensuring the information is encrypted. Our SSL configurations are regularly and automatically scanned to ensure we can quickly remediate any vulnerabilities discovered, such as Heartbleed. Additionally, we provide both TLS and HTTPS connections to the Postmark SMTP and API services, ensuring emails sent to the service are encrypted. Account passwords are encrypted in the Postmark database, preventing even our own staff from viewing them. We offer a method to recycle API keys at anytime in the Postmark interface.

For even more detailed information about our security practices, you can review this help doc.

Data retention

As described on our feature pages, Postmark collects and retains content and metadata for all emails for 45 days to give customers the ability to access their full message history during that time.

After 45 days, original email content and metadata are removed from our system. For bounce reports the original email content is also removed after 45 days, but metadata and the content of the actual bounce message are retained for up to 1 year to enable troubleshooting.

After this time the bounce message content and some metadata are removed, but we retain certain fields like Recipient, Subject, Sender, Date, and Bounce details indefinitely for compliance purposes. This is essential data for accurate spam and delivery monitoring, and to have a record in circumstances where end users ask about why/how they are getting emails from certain companies.

Privacy Shield

We comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework with respect to the transfer of personal data from the EEA or Switzerland, to our servers which are located In the US.

These frameworks were designed to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring personal data from the EEA and Switzerland to the United States.

Using the EU US Privacy Shield Framework for data transfers from the EU to the US was approved on July 12, 2016 for the EU and on July 8, 2017 for the EEA. It was approved for transfer from Switzerland to the US on January 12, 2017. You can view our current certification here: https://www.privacyshield.gov/...

We are preparing for the EU General Data Protection Regulation (GDPR)

What is GDPR?

In 2016, the European Commission approved and adopted the new General Data Protection Regulation (GDPR). GDPR is a significant change in data protection regulation in the EU and replaces the existing legal framework (the Data Protection Directive and the various member state laws). It will come into effect on May 25, 2018.

Why is GDPR important?

GDPR adds some new requirements regarding how companies should protect individuals' data that they process. It also raises the stakes for compliance by increasing enforcement and imposing greater fines for breaches. We are following the developments about GDPR and are taking the necessary steps to become compliant.

Does GDPR require that my information be stored in the EU?

No. Under GDPR a company is allowed to transfer personal data outside of the EU provided that it puts in place a mechanism, approved under GDPR, to make sure that personal data is adequately protected even when it is transferred outside of the EU. We have certified under the EU-U.S. and Swiss-U.S. Privacy Shield frameworks to satisfy this requirement (more detail in the Privacy Shield tab), and also offer a Data Processing Addendum (DPA) to all customer who require it (see below information about cross border data transfers).

Who are your sub-processors?

We share certain information with companies that may be considered our "sub-processors" under GDPR. This information is limited to the following:

  • We use HelpScout and Olark as help desk software to communicate with our customers. Sometimes these communications includes the personal information of your customers' information.
  • We use Server Central, Amazon Web Services, Packet.net, and Digital Ocean to process our emails. These companies host the data on physical and cloud servers that we pay for. For more information about our security practices as it relates to our data centers, see this document: https://postmarkapp.com/support/article/917-is-postmark-secure-and-redundant

For a detailed list of sub-processors and to sign up for updates when we start using a new sub-processors, view the sub-processor tab.

How do you manage access to my information (DSR requests)

As of now our intention is to service DSR requests (such as delete and export) manually. If you have an account with us, you may access, correct, or request that we delete your personal data by contacting us at support@postmarkapp.com.

This request can include personal data of other individuals, like your employees or customers that you have provided to us and who have requested this of you. We will respond to these requests within 14 days or less, which is well within the GDPR requirement of 30 days.

What happens when the UK leaves the EU?

We chose the UK as a reasonable location for GDPR enforcement, and will reassess in 2019 before Brexit takes effect. The UK is hoping for a unique status under GDPR and are working towards it. For the time being the UK has declared it will be GDPR compliant and its new data protection bill is in line with GDPR.

What has Postmark done to comply with GDPR?

We have implemented and are implementing changes

Our compliance, data protection, and information security teams are working to prepare our services for GDPR. We reviewed our data processing activities, and are making any changes that are needed in advance of the GDPR effective date.

We have addressed cross border data transfers

Like the Data Protection Directive that is presently in effect, GDPR includes provisions on international data transfer mechanisms. In order to comply with these provisions we have certified under the EU-U.S. and Swiss-U.S. Privacy Shield frameworks, a mechanism that had been approved for cross border transfer of personal data under the Directive and expected to apply under GDPR as well.

We have also worked with legal counsel to create a standard Data Processing Addendum (DPA), which meets with GDPR requirements for agreements between Data Controllers (you) and Data Processors (us). This outlines in detail our current security practices. To receive and sign a copy of our DPA, please visit the Data Processing Addendum tab on this page.

We are here for you

We are working with our customers to answer any questions and address any concerns regarding how we protect their personal data and gearing up for GDPR. If you have any questions, please don't hesitate to contact us at privacy@wildbit.com.


Data Processing Addendum

We offer data processing addendums (DPAs) for our customers that operate in the EU. Our DPA offers contractual terms that meet GDPR requirements and that reflect our data privacy and security commitments to our clients. You can see a sample of the addendum here.

To ensure no inconsistent or additional terms are imposed on us beyond that reflected in our standard DPA and model clauses, we cannot agree to sign customers’ DPAs. As a small team we also can’t make individual changes to our DPA since we don't have a legal team on staff. Any changes to the standard DPA would require legal counsel and a lot of back and forth discussion that would be cost prohibitive for our team.

Once you complete this form, the addendum will be signed electronically by both parties, and become legally binding. A copy of the signed addendum will be emailed to you. Drop us a line if you have any questions.

We’ll never use this email for marketing purposes.


List of sub-processors

We share certain information with companies that may be considered our "sub-processors" under GDPR. Below is a list of these companies.

CompanyPurpose
Server CentralInfrastructure hosting
Amazon Web ServicesCloud infrastructure hosting
PacketCloud infrastructure hosting
Digital OceanCloud infrastructure hosting
HelpScoutCustomer support
OlarkCustomer support

Sub-processor updates

If you would like to be notified when we start working with a new company that may be considered a "sub-processor", you can sign up below. We will only use your email to send notifications about new sub-processors.