Last updated: 5 November 2026.

Contents

European Regulation (EU) 2016/679 on the protection of personal data (hereinafter the “Privacy Regulation” or “EU Regulation”) and Italian Legislative Decree no. 196 of 30 June 2003, as referred to by Legislative Decree 101/2018, the “Personal Data Protection Code” (hereinafter the “Code”), provide for the right to the protection of personal data and ensure that such data are processed with respect for the fundamental rights and freedoms, as well as the dignity, of the data subject, with particular reference to confidentiality and security, personal identity and the right to the protection of personal data.

This document (the “Privacy Notice”) has been drawn up to enable you to understand how your Personal Data, as defined below, will be processed in connection with your use of the Site. The Privacy Notice is intended to provide you with the information you need so that you can, if you see fit, give explicit and informed consent to the processing carried out through the Site.

MailSenpai, a service of Octotech Solutions, with registered office at Via E. Dandolo, 29 – 76123 Andria (BT), Italy, VAT IT07964530724 (“MailSenpai”), is constantly committed to protecting the online privacy of the users of its sites www.mailsenpai.com and all related subdomains (hereinafter, unless otherwise indicated, collectively the “Site”).

In general, any information or Personal Data that you provide to MailSenpai through the Site, or that is otherwise collected through the Site, in connection with the use of the services offered by MailSenpai (the “Services”), as further defined in Section 3 below, will be processed in accordance with the internationally recognised principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimisation, accuracy, integrity and confidentiality.

1. Data Controller

The Data Controller with regard to all Personal Data processed through the Site is Octotech Solutions, with registered office at Via E. Dandolo, 29 – 76123 Andria (BT), Italy, VAT IT07964530724, which provides its services under the MailSenpai brand (“MailSenpai” in this Privacy Notice). For any question about your personal data you can contact MailSenpai through the GDPR Privacy Center (contact form).

2. Personal Data processed

When you browse the Site, you may provide us with, or we may collect, certain Personal Data of yours, which, depending on the case, may consist of an identifier such as a name, an identification number, an online identifier, or one or more factors specific to your physical, physiological, mental, economic, cultural or social identity, capable of making you identified or identifiable (hereinafter only “Personal Data”).

Your Personal Data may be collected either because you voluntarily provide it (e.g. when you request information from MailSenpai through the Contacts section of the site (www.mailsenpai.com/contattaci), when you subscribe to our newsletter or when you request a free demo) or simply by analysing your behaviour on the Site.

Name, contact details and other Personal Data

In various sections of the Site, in particular the one relating to the request for a free trial or to requests for information about our Services, you will be asked to enter information such as your name, telephone number, email address, the company you work for, etc.

In addition, when you communicate with MailSenpai through the email addresses you find on the Site, MailSenpai may collect any further information you decide to provide.

Applications

By registering in the section of the Site relating to applications to work at MailSenpai (“Work with us”), you will be asked to fill in a form (the “Application”) through which you may provide MailSenpai with different types of Personal Data, such as your contact details and professional/employment details (e.g. university attended, knowledge of foreign languages, professional qualifications, links to your professional profiles on social networks, etc.) and to upload your CV using the dedicated function.

Upon receipt of an Application, MailSenpai may review, even if you have not indicated them in the Application, your professional profiles on social networks (e.g. LinkedIn) or professional websites attributable to you, if publicly accessible, in order to obtain further information useful for assessing your suitability for the position you are applying for.

Further information on the processing of your Personal Data that we collect through Applications can be found in the privacy notice available on the applications platform.

Special categories of personal data

Some sections of the Site (e.g. the form to be contacted again or the one to report spam) include free-text fields in which you can provide MailSenpai with certain information, which may contain Personal Data.

Since these fields are free-text, you might use them to communicate (voluntarily or otherwise) certain sensitive categories of Personal Data, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data intended to uniquely identify a natural person, data concerning health or a person’s sex life or sexual orientation.

MailSenpai asks you not to send such Personal Data unless strictly necessary. Indeed, such special categories of Personal Data may be processed only with your explicit consent and in compliance with the legislation in force from time to time. MailSenpai therefore stresses the importance of giving your explicit consent to the processing of special categories of Personal Data, should you decide to share such information.

Data voluntarily provided by the data subject

As already mentioned above, in some sections of the Site you are allowed to enter text messages, visible to MailSenpai, which may contain Personal Data of other persons.

In such cases, you act as an independent data controller, assuming all legal obligations and responsibilities. In this regard, you grant the broadest indemnity in respect of any claim, demand or request for compensation for damage arising from processing, etc. that may be made against MailSenpai by third parties whose Personal Data have been processed through your use of the functions of the Site in breach of the applicable personal data protection rules. In any case, should you provide or otherwise process third-party Personal Data in using the Site, you hereby warrant – assuming all related responsibility – that such particular processing is based on the consent of that third-party data subject or on another suitable legal basis that legitimises the processing of the information in question.

Data collected when we send you emails

In the emails we send you we may detect when the message is opened and when you click its links. What we collect, why, on what legal basis and how you can choose is explained in paragraph 4-ter.

Browsing data

The computer systems and software procedures used to operate the Site acquire, during their normal operation, certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected in order to be associated with identified data subjects, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computing environment. These data are used solely for the purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and/or abuse, and are deleted immediately after processing. The data could be used to ascertain liability in the event of hypothetical computer crimes against the site or third parties: save for this eventuality, at present the web contact data are not retained for more than five (5) days.

Cookies

Definitions, characteristics and application of the legislation

Cookies are small text files that the sites visited by the user send to and store on their computer or mobile device, to be then retransmitted to the same sites on the next visit. Thanks to cookies, a site remembers the user’s actions and preferences (such as, for example, login data, the chosen language, font size, other display settings, etc.) so that they do not have to be indicated again when the user returns to visit that site or navigates from one page to another. Cookies are therefore used to carry out computer authentication, session monitoring and the storage of information regarding the activities of users accessing a site, and may also contain a unique identification code that makes it possible to track the user’s browsing within the site itself for statistical or advertising purposes. While browsing a site, the user may also receive on their computer cookies from sites or web servers other than the one they are visiting (so-called “third-party” cookies).

Some operations could not be carried out without the use of cookies, which in certain cases are therefore technically necessary for the very functioning of the site.

There are various types of cookies, depending on their characteristics and functions, and these may remain on the user’s computer for different periods of time: so-called session cookies, which are automatically deleted when the browser is closed; so-called persistent cookies, which remain on the user’s device until a predetermined expiry date.

Under the applicable legislation, the use of cookies does not always require the express consent of the user. In particular, such consent is usually not required for “technical cookies”, i.e. those used for the sole purpose of carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user. In other words, these are cookies that are indispensable for the functioning of the site or necessary to perform activities requested by the user.

For “Profiling cookies”, on the other hand, i.e. those aimed at creating profiles relating to the user and used to send advertising messages in line with the preferences expressed by the user while browsing the web, the user’s prior consent is usually required, although this depends on the applicable legislation.

Types of cookies used by the Site and the possibility of opting in/out

The Site uses the following cookies, which can be deselected, except for third-party cookies, for which you must refer directly to the relevant procedures for selecting and deselecting the respective cookies, indicated by means of links:

– Technical browsing or session cookies, strictly necessary for the functioning of the Site or to enable you to enjoy the content and services requested.

– Analytics cookies, which make it possible to understand how the Site is used. These cookies do not collect information on your identity, nor any Personal Data. The information is processed in aggregate and anonymous form.

– Functionality cookies, i.e. those used to activate specific features of the Site and a series of selected criteria (for example, the language) in order to improve the service provided.

– Profiling cookies, used to send advertising messages in line with the preferences you have expressed while browsing the web.

MailSenpai also uses third-party cookies, i.e. cookies from sites or web servers other than MailSenpai’s, for the purposes of those third parties, including profiling cookies. Please note that these third parties, listed below with the relevant links to their privacy policies, are typically independent controllers of the data collected through the cookies they serve, or act as Data Processors for MailSenpai (i.e. they process Personal Data on behalf of MailSenpai).

In detail, the cookies sent by MailSenpai through the Site can be viewed by clicking on the link shown here, together with the relevant privacy policy:

www.mailsenpai.com

Cookie settings

You can block or delete (in whole or in part) technical and functionality cookies through the specific functions of your Browser.

However, please be aware that not authorising technical cookies may make it impossible to use the Site, view its content and enjoy the related services. Inhibiting functionality cookies may mean that some services or certain functions of the Site are not available or do not work properly, and you may be required to change or manually enter certain information or preferences each time you visit the Site.

The choices made with regard to the Site’s cookies will in turn be recorded in a dedicated cookie. However, in some circumstances this cookie may not work properly: in such cases, we recommend that you delete unwanted cookies and block their use also through the functions of your Browsers.

Your cookie preferences will need to be reset if you use different devices or Browsers to access the Site.

How to view and change cookies through the Browser

You can authorise, block or delete (in whole or in part) cookies through the specific functions of your Browser. For more information on how to set your preferences on the use of cookies through the Browser, you can consult the relevant instructions:

Internet Explorer

Firefox

Chrome

Safari

If you do not use any of the browsers listed above, select “cookies” in the relevant section of the help guide to find out where your cookie folder is located.

You can also manage your choices regarding third-party cookies by using online platforms such as AdChoice or All about cookies.

WARNING: by disabling technical and/or functionality cookies, the Site may become unavailable for consultation or some services or certain functions of the Site may become unavailable or may not work properly, and you may be required to change or manually enter certain information or preferences each time you visit the Site.

Deletion of Flash cookies

Click the following link to change your Flash cookie settings. Disabling Flash cookies.

Third-party websites

The Site contains links to other websites that have their own privacy notices. These privacy notices may differ from the one adopted by MailSenpai, which therefore is not responsible for third-party sites.

3. Purposes of the processing

MailSenpai will use your Personal Data, collected through the Site, for the following purposes:

to provide the Services, such as: allowing you to register on the Site in order to access the restricted-access platform and helping you if you lose or forget your login/password details for registration on the Site; responding to your requests for information sent through the Contacts section, contacting you again at the end of a free trial to support you in the process of purchasing our Services or to resolve any problems you may have encountered, and providing you with any other Service you request (“Service Provision“);

sending you the MailSenpai newsletter, with informational and commercial content about our services, if you have subscribed (“Newsletter”);

to send you marketing communications, promotions and advertising, market research and surveys, by email, SMS, telephone, banners, paper mail, instant messaging, through an operator, through MailSenpai’s official social media pages, as well as for marketing activities in the broad sense, including prize promotions, games and contests, relating to products and/or services attributable to MailSenpai or to third parties (“Marketing“);

to send you marketing communications by email concerning products and services similar to those you have purchased (“Soft Spam“);

to create a profile of you through the use of profiling cookies, where accepted, thereby collecting and analysing information on your general activities on the Site. This profile will be used to provide you with information on other products and/or services that MailSenpai believes may be of interest to you and to show you advertising that may be relevant to your tastes. All the algorithms involved in this automated or semi-automated process are regularly tested to make sure that you are not offered products that do not interest you (“Profiling“);

to fulfil legal obligations requiring MailSenpai to collect and/or further process certain types of Personal Data (“Compliance“);

to monitor how the Site is used, prevent or detect any abuse in the use of the Site, or any fraudulent activity, and thus allow MailSenpai to protect itself in legal proceedings (“Abuse/Fraud“).

4. Legal basis and mandatory or optional nature of the processing

The legal bases used by MailSenpai to process your Data, according to the purposes indicated in the previous section, are as follows:

Service Provision: processing for this purpose is necessary in order to provide you with the Services and, therefore, for the performance of pre-contractual or contractual measures requested by you. It is not mandatory to provide your Personal Data to MailSenpai for this purpose, but otherwise it will not be possible to provide you with any Service.;

Newsletter: processing for this purpose is based on your consent, which you give by subscribing and which includes the detection of opens and clicks described in paragraph 4-ter. Giving consent is not mandatory and you may withdraw it at any time without any consequence, through the link in every email or by following the instructions in the section “Rights of the data subject” of this Privacy Notice; through the “Tracking preferences” link you can also turn off open tracking only;

Marketing: processing for this purpose is based on your consent. It is not mandatory to give your consent to MailSenpai for this purpose and you are free to withdraw it at any time without any consequence (except that you will no longer receive marketing communications from MailSenpai). You may withdraw your previously given consent by following the instructions in the section “Rights of the data subject” of this Privacy Notice;

Soft Spam: processing for this purpose is based on MailSenpai’s legitimate interest in sending you marketing communications by email concerning products and services similar to those you have already purchased through the Site. You may stop receiving these communications, without any consequence for you (except that you will no longer receive further communications of this kind from MailSenpai) by using the link you will find at the bottom of each of these emails;

Profiling: processing for this purpose is based on your consent collected through the cookie banner. It is not mandatory to give your consent to MailSenpai for this purpose and you are free to withdraw it at any time without any consequence. You may withdraw your previously given consent by following the instructions in the section “Rights of the data subject” of this Privacy Notice or, as regards cookies, the instructions in the Cookies section;

Compliance: processing for this purpose is necessary for MailSenpai in order to fulfil any legal obligations. When you provide Personal Data to MailSenpai, it must be processed in accordance with the applicable legislation, which could entail its retention and disclosure to the Authorities for accounting, tax or other obligations;

Abuse/Fraud: the information collected for this purpose will be used exclusively to prevent and/or detect any fraudulent activity or abuse in the use of the Site and thus allows MailSenpai to protect itself in legal proceedings.

4-bis. Details of specific processing

Orders, free trial and payments. When you start a trial or buy a plan through the checkout at app.mailsenpai.com, we process company and contact person data (company name, VAT number, tax code, address, email, phone, billing details) and order data. Payments are handled by Stripe, which processes your card or account details: MailSenpai does not store full card details. Italian invoices are sent through the Italian Revenue Agency Exchange System (SDI). Legal basis: performance of the contract and legal obligations. During the trial and the service we send you service communications (for example trial end reminders, volume alerts and a periodic sending report).

SMTP relay service (SMTP Senpai). For the messages the Client sends through the relay, MailSenpai acts as data processor on behalf of the Client, as set out in the Terms and Conditions. The sending log (recipient address, outcome, bounce reason, technical delivery data) is kept for 90 days; addresses that do not exist or that reported spam are kept in the Client’s suppression list to prevent further sending to them.

Phone verification. On the SMTP Senpai free plan we ask you to verify a mobile number before you send to external recipients, in order to prevent abuse and unwanted email. Legal basis: legitimate interest. To send the code we use an SMS provider, Link Mobility Poland Sp. z o.o. (Poland), which processes the number as a data processor. We do not keep your full number, only a fingerprint that stops it being reused on other accounts and its last 3 digits, together with your answers about how you use the service, for as long as the account exists.

Advertising measurement. Only if you accept advertising cookies in the banner, in addition to the Meta and Google pixels on the Site we send from our servers to Meta (Conversions API) and Google (enhanced conversions and conversion import) the relevant events of the purchase journey, such as trial request, checkout start, trial activation and purchase, with their value. Together with the event we may send your email address and phone number in hashed form (SHA-256), the ad click and advertising cookie identifiers (for example fbclid, _fbp, _fbc, gclid), IP address and browser type. The purpose is to measure the effectiveness of our campaigns and optimise their delivery. Legal basis: consent, which you can withdraw at any time from the cookie settings; without consent these data are not sent. Meta Platforms Ireland Ltd and Google Ireland Ltd also process the data under their own privacy policies.

Contact management and interest score. Contacts who have given us their details (for example by requesting a trial, subscribing to the newsletter or purchasing) are managed in a customer relationship management (CRM) system hosted on servers in the European Union. We record interactions with MailSenpai (requests, order stages, opens and clicks of our emails, use of the service) and derive a score and interest level that decreases over time without activity. For those who agreed to receive marketing communications, we use them to choose which informative emails to send and how often, and to organise sales follow-up. This processing does not lead to decisions with legal or similarly significant effects. Legal basis: consent (Marketing and Profiling), which you can withdraw at any time through the link in every email or through the GDPR Privacy Center.

Review requests. Customers who have used one of our paid services for at least 30 days may receive a single email asking for feedback on review platforms (for example Trustpilot or Google). Legal basis: legitimate interest in collecting customer feedback; you can object at any time by replying to the email or through the GDPR Privacy Center. Reviews are published on the chosen platform under its own terms.

Record of acceptances and consents. When you accept the general terms, view this notice, give or refuse an optional consent (checkout, website forms) or choose whether to accept advertising cookies (website banner and checkout box), we record: the version of the document shown to you with its digital fingerprint (SHA-256), the text of the checkbox or button, your choice, date and time, IP address and browser, and the related order or account. This allows us to prove acceptance and consents and to defend our rights. Legal basis: compliance with legal obligations and legitimate interest in evidence and legal defence. Retention: for the duration of the contract and 10 years after it ends for contractual acceptances; 5 years for cookie choices and optional consents.

Free website tools (DNS check, blocklist check and monitor, spam test, delivery test, flash test). When you use a free tool we process the email address you enter, the domain checked, the IP address and browser of the request and the result of the check, in order to run the service, send you the result by email and limit abuse. In the flash test we send a test email and one with the result to the address you give, and we record how long the mail server took to accept it, any rejection response and, if you tell us, the folder where you found it. In the DNS check the form has a single required box: by ticking it you also agree to receive commercial emails from MailSenpai. Your consent is valid for 365 days from when you give it, you can unsubscribe at any time from the link in every email and, if you do not renew it, we remove you from the list after 365 days. For the other tools, without marketing consent we do not add you to any list and we do not send you commercial communications. Legal basis: performance of your request for the check and for sending the results; consent for commercial communications. Retention: 365 days from the request (for the blocklist monitor, as long as it stays active), after which we keep only statistical data without the address; the details of the message analysed by the spam test are deleted after 24 hours.

Where data are stored. Platform, relay and CRM data are hosted on servers located in the European Union. Transfers to third countries may take place in the cases described in paragraph 6.

Main providers. In addition to the categories listed in paragraph 5, data may be processed by: infrastructure and hosting providers with data centres in the European Union; Stripe (payments); Meta Platforms Ireland Ltd and Google Ireland Ltd (measurement and advertising, only with your consent); network and site protection providers (CDN).

4-ter. Emails: opens and clicks

This paragraph covers two different cases:

  • A) emails that MailSenpai sends to its own subscribers and contacts (newsletters, informational and commercial messages). Here MailSenpai is the data controller.
  • B) emails that our clients send to their subscribers using the MailSenpai platform. Here the controller is the client who sends the email; MailSenpai processes the data only on the client’s behalf, as data processor.

How it works.

  • Opens. The email contains a small invisible image (a “pixel”). When your email program loads it, our server records that the email was opened.
  • Clicks. Links in the email first go through our servers, which record the click and then take you straight to the requested page.

What data. Date and time of the open or click; IP address; type of email program, browser and device (user agent); approximate location derived from the IP address (country and city, used for clicks and unsubscribes); a code that identifies the subscriber and the campaign.

Opens: individual or anonymous only.

  • Individual open tracking: only if you have given consent or, for people who were already subscribed before 29 October 2026, until you choose to turn it off (see “Subscribers who joined before 29 October 2026” below).
  • Anonymous count: if you have not given consent or have withdrawn it, the email contains, instead of the individual pixel, a pixel that is the same for every recipient of the campaign. It is used only to count total opens. We do not store your IP address or device data, and the count cannot be linked to you.

Clicks. Clicks on links are recorded individually for all recipients, including people who have turned off open tracking. Tracking preferences apply to opens only.

Your choices. At the bottom of every email you will find two links:

  • “Tracking preferences”: opens a page where you can choose to keep receiving emails without open tracking, turn it back on, or unsubscribe. Your choice applies to all lists of the same sender.
  • “Unsubscribe”: you stop receiving emails from that list.

Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

A) Emails sent by MailSenpai

Purposes.

  • Individual opens: understanding who reads our emails, choosing better content and frequency and, if you have also consented to profiling, updating the interest score described in paragraph 4-bis.
  • Anonymous open count: measuring the overall result of each mailing.
  • Clicks: measuring which content is of interest, recognising automatic clicks made by email security systems and protecting the service from abuse; with consent to profiling, updating the interest score.

Legal basis.

  • Newsletters and commercial communications you subscribed to: the consent you give by subscribing, which includes individual open and click tracking (art. 6(1)(a) GDPR and art. 122 of the Italian Privacy Code). You can withdraw it by unsubscribing, or turn off open tracking only through the “Tracking preferences” link.
  • Subscribers who joined before 29 October 2026: they receive this notice with the first relevant mailing and can turn off open tracking at any time through the “Tracking preferences” link, under the transitional regime set out in the Italian Data Protection Authority’s guidelines on tracking pixels (decision no. 284 of 17 April 2026).
  • Anonymous count: no personal data is stored.
  • Clicks in the other emails we send you: the legal basis provided by Italian data protection law (Regulation (EU) 2016/679, Legislative Decree 196/2003 “Italian Privacy Code” and the Italian Data Protection Authority’s 2026 guidelines on tracking pixels) for the type of communication you receive, as set out in paragraphs 4 and 4-bis.

Retention.

  • Individual opens and clicks: 12 months from the date of the event, then deleted.
  • Anonymous campaign totals: they contain no personal data and may be kept without time limit.
  • Record of your choice (consent, withdrawal, reactivation) with date and time: according to the retention of the record of optional consents described in paragraph 4-bis, so that the choice can be proven.
  • The interest score in the CRM follows the rules in paragraph 4-bis.

Recipients. Data is hosted on servers in the European Union. It may be processed, as our processors, by infrastructure and hosting providers with data centres in the European Union and by the network and site protection provider (CDN). We do not sell or transfer this data to third parties.

B) Emails sent by clients through the platform

Who is the controller. The controller is the client who sent you the email: their name and contact details are shown in the email itself (usually at the bottom). MailSenpai processes the data only on the client’s behalf and under the client’s instructions, as data processor, under the contract and the data processing agreement (Annex A).

What the platform does.

  • It detects opens and clicks as described above, on behalf of the client.
  • For each list the client chooses the rule for opens: individual tracking for subscribers who joined before 29 October 2026 until they turn it off, and consent only for new subscribers; consent only; or never.
  • It adds the “Tracking preferences” link to every email. The choice applies to all lists of the same client and does not affect MailSenpai’s other clients.
  • For people who have not given consent or have withdrawn it, it uses only the anonymous count.
  • Clicks are recorded individually when the client keeps link tracking active.

Purposes and legal basis. These are decided by the client, in compliance with Italian data protection law: the client must give you their own privacy notice and, where required, ask for your consent.

Retention. Individual opens and clicks are kept for 12 months from the date of the event and then deleted, unless the client deletes them earlier. When the client’s contract ends, data is deleted as set out in the Terms and Conditions.

Where the data is and who processes it. Servers in the European Union. MailSenpai’s sub-processors are listed in Annex A.

Your rights. To exercise your rights, contact the sender of the email. If you write to MailSenpai, we forward your request to the sender. You can always use the “Tracking preferences” and “Unsubscribe” links in the email.

5. Recipients of Personal Data

Your Personal Data may be shared with the parties indicated below (the “Recipients”):

parties who typically act as data processors, namely: i) individuals, companies or professional firms providing assistance and consultancy to MailSenpai in accounting, administrative, legal, tax, financial and credit recovery matters in relation to the provision of the Services; ii) parties delegated to carry out technical maintenance activities (including the maintenance of network equipment and electronic communications networks);

parties with whom it is necessary to interact for the provision of the Services (for example, hosting providers);

persons authorised by MailSenpai to process Personal Data as necessary to carry out activities strictly related to the provision of the Services, who have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality (e.g. MailSenpai employees);

MailSenpai partners for internal administrative purposes;

parties, bodies or authorities to which it is mandatory to disclose your Personal Data for Compliance, Abuse or Fraud purposes, or by order of the authorities;

commercial partners, only where you have given specific consent to that effect.

6. Transfers of Personal Data

Some of your Personal Data may be shared with Recipients, both internal and external to MailSenpai, who may be located outside the European Economic Area. MailSenpai ensures that the processing of your Personal Data by these Recipients will be carried out in compliance with the applicable legislation. Indeed, transfers will be made subject to appropriate safeguards, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or other safeguards considered adequate. Further information is available through the GDPR Privacy Center (contact form).

In particular, Meta and Google may transfer data to the United States under the EU-US Data Privacy Framework and Standard Contractual Clauses; the same applies to Stripe where relevant.

7. Retention of Personal Data

Personal Data processed for the purpose of Service Provision will be retained by MailSenpai for the time strictly necessary for that purpose (e.g. to respond to requests for information sent to us through the Contacts section). In any case, since such Personal Data are processed in order to provide you with the Services, MailSenpai may retain them for a longer period, in particular to the extent that may be necessary to protect MailSenpai’s interests against possible claims relating to the Services.

Personal Data processed for Marketing, Newsletter and Profiling purposes will be retained by MailSenpai until you withdraw your consent. Once consent has been withdrawn, MailSenpai will no longer use your Personal Data for such purposes, but may nevertheless retain them, in particular to the extent that may be necessary to protect MailSenpai’s interests against possible claims based on such processing.

Personal Data processed for the purpose of Soft Spam will be retained by MailSenpai until you object to such processing through the link you will find at the bottom of each Soft Spam email.

Personal Data processed for the purpose of Compliance will be retained by MailSenpai for the period provided for by specific legal obligations or by the applicable legislation.

Personal Data processed in order to prevent Abuse/Fraud will be retained by MailSenpai for the time strictly necessary for that purpose and therefore until the moment when MailSenpai is required to retain them in order to protect itself in legal proceedings or to disclose such data to the competent Authorities.

In particular: tax and accounting data relating to orders are kept for 10 years as required by law; the relay sending log for 90 days; data from the free website tools for 365 days (paragraph 4-bis); data used for the interest score until consent is withdrawn or you object; individual email opens and clicks for 12 months from the date of the event (paragraph 4-ter); the record of tracking choices according to the retention of the record of optional consents (paragraph 4-bis).

8. Rights of the data subject

You have the right to ask MailSenpai, at any time:

for access to your Personal Data (or a copy of such Personal Data), as well as further information on the processing being carried out on them;

for the rectification or updating of your Personal Data processed by MailSenpai, where they are incomplete or not up to date;

for the erasure of your Personal Data from MailSenpai’s databases;

for the restriction of the processing of your Personal Data by MailSenpai;

to obtain the Personal Data concerning you in a structured, commonly used and machine-readable format;

You may also:

object to the processing of your Personal Data by MailSenpai (e.g. Soft Spam);

withdraw your consent for the purposes of Marketing, Newsletter and Profiling.

You may withdraw consent to Marketing sent by email and stop receiving Soft Spam by using the link you will find at the bottom of every email received. The same method may be used to stop receiving the MailSenpai newsletter. Through the “Tracking preferences” link in every email you can instead turn off open tracking only (paragraph 4-ter).

Consent to Profiling through cookies may be withdrawn by means of the procedures indicated in Section 2 above.

In addition to the above, you may also exercise your rights by contacting MailSenpai through the GDPR Privacy Center (contact form).

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Garante per la Protezione dei Dati Personali (Italian Data Protection Authority)) if you believe that the processing of your Personal Data is contrary to the legislation in force.

9. Amendments

MailSenpai reserves the right to modify or simply update its content, in whole or in part, also as a result of changes in the applicable legislation. MailSenpai will inform you of such changes by means of a notice on the site and they will be binding as soon as they are published on the Site. MailSenpai therefore invites you to visit this section regularly in order to become aware of the most recent and updated version of the privacy policy, so as to always be up to date on the data collected and on the use MailSenpai makes of it.