Privacy Policy
How Dottor Mail collects, processes, and safeguards your personal data across our 4-in-1 email deliverability and outreach platform in strict accordance with the GDPR.
01.Overview & Scope
This Privacy Policy describes how Dottor Mail SRL (“Dottor Mail,” “we,” “us,” or “our”), registered in Turin, Italy (Headquarters: Strada Val S. Martino, 111, 10131 Turin), collects, uses, stores, and protects personal information when you access or use our website (dottormail.com), API, applications, and unified 4-in-1 platform services (collectively, the “Services”).
We are committed to operating in full compliance with the General Data Protection Regulation (Regulation (EU) 2016/679 - “GDPR”), the Italian Personal Data Protection Code (Legislative Decree no. 196/2003 as amended), and applicable international privacy legislation.
02.Data Controller vs. Data Processor
Under EU data protection law, our role and responsibilities depend on the context of the processing activity:
When We Control Your Information
We act as the Data Controller for information related to your account registration, billing credentials, communication records, support tickets, and telemetry generated during your use of our website.
When We Process Customer Lists
When you upload email contact lists for verification, connect mailboxes for AI warmup, or launch outbound marketing campaigns, you remain the Data Controller and Dottor Mail acts solely as your Data Processor under a binding Data Processing Addendum (DPA).
03.Categories of Data Collected
We collect only the minimum necessary data required to deliver high-deliverability services:
- Account Registration Data: Full name, professional business email address, company name, country, and password hash (bcrypt salted).
- Financial & Billing Records: Transaction identifiers, currency, billing address, VAT number, and payment status. Credit card numbers are handled directly by PCI-DSS Level 1 certified processors (Stripe/PayPal) and are never stored on Dottor Mail servers.
- Customer Outreach & Verification Inputs: Email addresses and contact metadata uploaded by you to clean, warm, or email.
- Technical & Log Telemetry: IP address, user-agent string, API authentication tokens, request timestamps, and rate-limiting metrics.
04.Feature-Specific Processing & Zero-Retention
Email Verifier — Zero List Retention Architecture
When verifying emails, our 12-layer pipeline queries mail exchangers, DNS records, and SMTP handshakes in memory. We do not save, compile, sell, or train public models on your private customer lists. Verification results are stored in encrypted form only for the duration specified in your retention settings (default 30 days, or instant scrub on download), after which they are permanently purged from database tables and cache.
Email Finder — Public B2B Directory Crawling
Our B2B search algorithms index publicly accessible domain registrar records, corporate websites, and published business bios. We do not extract sensitive consumer or personal data. Any individual can submit an instant removal request at privacy@dottormail.com.
Email Warmup — Autonomous Peer-to-Peer Network
To warm your mailboxes, you grant OAuth tokens or SMTP credentials. Credentials are encrypted at rest with AES-256. Our warmup engine only generates, reads, and replies to synthetic warmup threads labeled specifically with our internal warmup headers. We never read, index, or interact with your personal inbox messages.
Email Marketing — Outbound Campaigns & RFC 8058 Compliance
When sending outbound campaigns, our infrastructure automatically embeds RFC 8058 compliant `List-Unsubscribe` headers, tracks unsubscribe requests in global suppression lists, and pauses delivery when bounces or complaints exceed safety thresholds.
05.Lawful Basis for Processing (GDPR Article 6)
We only process your personal data where we have a lawful legal basis:
| Purpose | Data Categories | Legal Basis (GDPR Art. 6) |
|---|---|---|
| Account setup & authentication | Name, email, password | Performance of Contract (Art. 6(1)(b)) |
| Credit package purchasing & invoices | Billing address, VAT ID, payment ID | Legal Obligation (Art. 6(1)(c)) |
| List verification & Warmup routing | Customer-provided contact lists | Data Processing Agreement / Contract |
| System security & abuse prevention | IP address, request logs, rates | Legitimate Interests (Art. 6(1)(f)) |
06.Authorized Subprocessors
We engage select third-party service providers (“Subprocessors”) to assist in providing our Services. All subprocessors are vetted for GDPR compliance and bound by written Data Processing Agreements:
07.Data Retention & Automatic Deletion
We retain personal data only as long as necessary to fulfill the purposes for which it was collected:
- Account Data: Retained while your account is active. If you request account closure, all personal records are purged within 30 days.
- Customer Verification Files: Automatically permanently deleted 30 days after job completion, or immediately when you click “Purge List Data.”
- Accounting & Invoices: Retained for 10 years in compliance with Italian statutory tax and commercial record retention laws.
08.Security & Encryption Standards
We employ state-of-the-art technical and organizational measures (TOMs) to protect personal data:
09.Your Rights Under GDPR
Under Articles 15 through 22 of the GDPR, you have the following rights regarding your personal data:
To exercise any of these rights, email dpo@dottormail.com. We respond to all verified requests within 30 days free of charge.
10.International Transfers & Adequacy
Primary data storage is maintained within the European Economic Area (EEA). If personal data is transferred outside the EEA, we ensure appropriate safeguards are implemented in accordance with Chapter V of the GDPR, such as the European Commission’s Standard Contractual Clauses (SCCs) or applicable EU-U.S. Data Privacy Framework adequacy decisions.
11.Contacting Our DPO & Supervisory Authority
If you have questions about this policy or our data practices, contact our Data Protection Officer:
Data Protection Officer: Dottor Mail Legal & Compliance Team
Email: dpo@dottormail.com
Headquarters: Strada Val S. Martino, 111, 10131 Turin, Italy
You also have the right to lodge a complaint with your local supervisory authority. In Italy, this is the Garante per la protezione dei dati personali (www.garanteprivacy.it).
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