Effective date: November 13, 2026
This GDPR Data Processing Addendum (“DPA”) forms part of the Master Services Agreement or Terms of Use available at https://sendloop.com/terms-of-use/ or such other location as the Terms of Use may be posted from time to time (as applicable, the “Agreement”), entered into by and between the Customer and 50SAAS LLC, a Wyoming limited liability company (“Sendloop”), pursuant to which Customer has accessed Sendloop’s Application Services as defined in the applicable Agreement. The purpose of this DPA is to reflect the parties’ agreement with regard to the processing of personal data in accordance with the requirements of Data Protection Legislation as defined below.
If the Customer entity entering into this DPA has executed an order form or statement of work with Sendloop pursuant to the Agreement (an “Ordering Document”), but is not itself a party to the Agreement, this DPA is an addendum to that Ordering Document and applicable renewal Ordering Documents. If the Customer entity entering into this DPA is neither a party to an Ordering Document nor the Agreement, this DPA is not valid and is not legally binding. Such entity should request that the Customer entity that is a party to the Agreement executes this DPA.
This DPA shall not replace or supersede any agreement or addendum relating to processing of personal data negotiated by Customer and referenced in the Agreement, and any such individually negotiated agreement or addendum shall apply instead of this DPA.
In the course of providing the Application Services to Customer pursuant to the Agreement, Sendloop may process personal data on behalf of Customer. Sendloop agrees to comply with the following provisions with respect to any personal data submitted by or for Customer to the Application Services or collected and processed by or for Customer through the Application Services. Any capitalized but undefined terms herein shall have the meaning set forth in the Agreement.
Data Processing Terms
In this DPA, “Data Protection Legislation” means the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), Directive 2002/58/EC (as amended by Directive 2009/136/EC) and any legislation and/or regulation implementing or made pursuant to it, the GDPR as it forms part of the law of the United Kingdom (“UK GDPR”) and the UK Data Protection Act 2018, the Swiss Federal Act on Data Protection (“FADP”), any legislation which amends, replaces, re-enacts or consolidates any of them, and all other applicable laws relating to processing of personal data and privacy that may exist in any relevant jurisdiction.
“data controller”, “data processor”, “data subject”, “personal data”, “processing”, and “appropriate technical and organisational measures” shall be interpreted in accordance with applicable Data Protection Legislation;
The parties agree that Customer is the data controller and that Sendloop is its data processor in relation to personal data that is processed in the course of providing the Application Services. Customer shall comply at all times with Data Protection Legislation in respect of all personal data it provided to Sendloop pursuant to the Agreement.
The subject-matter of the data processing covered by this DPA is the Application Services ordered by Customer either through Sendloop’s website or through an Ordering Document and provided by Sendloop to Customer via the application at my.sendloop.net, or as additionally described in the Agreement or the DPA. The processing will be carried out until the term of Customer’s ordering of the Application Services ceases. Further details of the data processing are set out in Annex 1 hereto.
In respect of personal data processed in the course of providing the Application Services, Sendloop:
1. shall process the personal data only in accordance with the documented instructions from Customer (as set out in this DPA or the Agreement or as otherwise notified by Customer to Sendloop (from time to time) If Sendloop is required to process the personal data for any other purpose provided by applicable law to which it is subject, Sendloop will inform Customer of such requirement prior to the processing unless that law prohibits this on important grounds of public interest;
2. shall notify Customer without undue delay if, in Sendloop’s opinion, an instruction for the processing of personal data given by Customer infringes applicable Data Protection Legislation;
3. shall implement and maintain appropriate technical and organisational measures designed to protect the personal data against unauthorised or unlawful processing and against accidental loss, destruction, damage, theft, alteration or disclosure. These measures shall be appropriate to the harm which might result from any unauthorised or unlawful processing, accidental loss, destruction, damage or theft of the personal data and having regard to the nature of the personal data which is to be protected;
4. may hire other companies to provide limited services on its behalf, provided that Sendloop complies with the provisions of this Clause. Any such subcontractors will be permitted to process personal data only to deliver the services Sendloop has retained them to provide, and they shall be prohibited from using personal data for any other purpose. Sendloop remains responsible for its subcontractors’ compliance with the obligations of this DPA. Any subcontractors to whom Sendloop transfers personal data will have entered into written agreements with Sendloop requiring that the subcontractor abide by terms substantially similar to this DPA. Sendloop’s subcontractors (subprocessors) fall into the following categories: data center hosting providers (United States and European Union); Cloudflare (website hosting, content delivery, bot protection and file storage); SMS gateways (Infobip and Xeebi); card payment processors (Stripe or accept.blue, which capture card details in their own hosted forms, so Sendloop never stores card numbers); and workflow automation and email relay services used to deliver website form submissions. The current list of subprocessors is available to Customer on request at legal@sendloop.com. Sendloop will notify Customer at least thirty (30) days before adding or replacing a subprocessor. Customer may object to the change in writing within that period. Objections must contain reasonable and documented grounds relating to the subprocessor’s non-compliance with applicable Data Protection Legislation. If Customer objects and the parties cannot resolve the objection, Customer may, by providing written notice to Sendloop, terminate the affected Application Services.
5. shall ensure that all Sendloop personnel required to access the personal data are informed of the confidential nature of the personal data and comply with the obligations sets out in this Clause;
6. at the Customer’s request and cost (and insofar as is possible), shall assist the Customer by implementing appropriate and reasonable technical and organisational measures to assist with the Customer’s obligation to respond to requests from data subjects under Data Protection Legislation (including requests for information relating to the processing, and requests relating to access, rectification, erasure or portability of the personal data) provided that Sendloop reserves the right to reimbursement from Customer for the reasonable cost of any time, expenditures or fees incurred in connection with such assistance;
7. shall take reasonable steps at the Customer’s request and cost to assist Customer in meeting Customer’s obligations under Articles 32 to 36 of the GDPR (and the equivalent provisions of the UK GDPR and the FADP) taking into account the nature of the processing under this DPA, provided that Sendloop reserves the right to reimbursement from Customer for the reasonable cost of any time, expenditures or fees incurred in connection with such assistance;
8. at the end of the applicable term of the Application Services, upon Customer’s request, shall securely destroy or return such personal data to Customer;
9. hosts personal data in data centers in the United States and the European Union, and Sendloop staff located in Turkey access personal data for support and operations. Sendloop does not rely on an adequacy decision for these transfers. Sendloop may transfer personal data from the European Economic Area, the United Kingdom and Switzerland to the United States and Turkey for the purposes of this DPA only on the following basis, which the parties incorporate into this DPA by reference: (a) the Standard Contractual Clauses approved by Commission Implementing Decision (EU) 2021/914 (the “SCCs”), Module 2 (controller to processor) between Customer as data exporter and Sendloop as data importer, and Module 3 (processor to processor) between Sendloop and its subprocessors; (b) for personal data subject to the UK GDPR, the International Data Transfer Addendum to the SCCs issued by the UK Information Commissioner; and (c) for personal data subject to the FADP, the SCCs as adapted for Switzerland, with references to the GDPR read as references to the FADP and the Swiss Federal Data Protection and Information Commissioner as the competent supervisory authority. Annex 1 to this DPA provides the details of the processing required by the SCCs. In addition, Sendloop applies supplementary measures to protect transferred personal data, including encryption in transit and at rest, access control, staff access limited to a need-to-know basis, and logging of access;
10. shall allow Customer and its respective auditors or authorized agents to conduct audits or inspections during the term of the Agreement, which shall include providing reasonable access to the premises, resources and personnel used by Sendloop in connection with the provision of the Application Services, and provide all reasonable assistance in order to assist Customer in exercising its audit rights under this Clause. The purposes of an audit pursuant to this Clause include to verify that Sendloop is processing personal data in accordance with its obligations under the DPA and applicable Data Protection Legislation. Notwithstanding the foregoing, such audit shall consist solely of: (i) the provision by Sendloop of written information (including, without limitation, questionnaires and information about security policies) that may include information relating to subcontractors; and (ii) interviews with Sendloop’s IT personnel. Such audit may be carried out by Customer or an inspection body composed of independent members and in possession of the required professional qualifications bound by a duty of confidentiality. For the avoidance of doubt no access to any part of Sendloop’s IT system, data hosting sites or centers, or infrastructure will be permitted;
11. If Sendloop becomes aware of any accidental, unauthorised or unlawful destruction, loss, alteration, or disclosure of, or access to the personal data that is processed by Sendloop in the course of providing the Application Services (an “Incident”) under the Agreement it shall notify Customer without undue delay, and in any event within seventy-two (72) hours of becoming aware of the Incident, and provide Customer (as soon as possible) with a description of the Incident as well as periodic updates to information about the Incident, including its impact on Customer Content. Sendloop shall additionally take action to investigate the Incident and reasonably prevent or mitigate the effects of the Incident;
12. Sendloop shall provide information requested by Customer to demonstrate compliance with the obligations set out in this DPA.
Annex 1
Details of the Data Processing
This Annex describes the processing for the purposes of this DPA and the Standard Contractual Clauses.
Subject Matter and Purpose
Storing and managing Customer’s contact lists, and sending email and SMS messages (campaigns, journeys and transactional messages) on Customer’s instructions, including tracking delivery, opens, clicks, replies, bounces, complaints and unsubscribes, and reporting on them.
Duration
For the term of the Agreement, then until the personal data is deleted in accordance with this DPA.
Categories of Data Subjects
- Contacts and recipients of Customer’s messages (Customer’s subscribers, customers, leads and prospects)
- Customer’s users of the Application Services (account owners and team members)
Types of Personal Data
- Contact details: email address, mobile phone number, name
- Any custom fields Customer chooses to store, such as company, city, country, time zone or preferences
- List, segment and tag membership, subscription status and consent records (date, source and IP address of opt-in or opt-out)
- Engagement data: delivery status, opens, clicks, replies, bounces, complaints and unsubscribes, with the date, time, IP address and user agent of each event
- Message content that Customer sends, which may contain personal data
- For Customer’s users: name, email address, login and activity records
Special Categories of Data
None intended. Customer shall not upload special categories of personal data (GDPR Article 9) or data relating to criminal convictions without Sendloop’s prior written agreement.
Frequency of Transfer
Continuous, for as long as Customer uses the Application Services.
Additional detail regarding what information Customer may send to Sendloop can be found in the terms of the Agreement or by contacting support@sendloop.com.
For any questions or comments, please contact us via legal@sendloop.com. Sendloop’s Data Protection Officer can be reached at dpo@sendloop.com.