Data Processing Agreement
Version 2026-10-22.6 · Last updated 22 October 2026
This agreement forms part of the Terms of Service between the customer ("Customer") and The Send Labs, a unit of Homeasy Automation Private Limited ("The Send Labs"). It applies when The Send Labs processes personal data on the Customer's behalf, and is a contract with a Data Processor for the purposes of section 8(2) of the Digital Personal Data Protection Act, 2023.
1. Roles
1.1 For personal data contained in the Customer's connected mailboxes, in emails the Customer sends for spam tests, and in emails the Customer sends to its recipients through the service together with its unsubscribe list ("Customer Personal Data"), the Customer is the Data Fiduciary and The Send Labs is the Data Processor.
1.2 For the Customer's account, contact, billing and usage data, The Send Labs is a Data Fiduciary in its own right, as described in its Privacy Notice.
2. Scope of processing
| Subject matter | Email warmup, placement measurement, spam tests, domain checks and alerts |
| Nature | Logging in to mailboxes; sending warmup emails; sending the Customer's emails to the recipients it chooses, one by one, and recording the result; keeping the Customer's unsubscribe list; finding, reading, moving and flagging The Send Labs' own warmup and test emails; reading message headers and content of test emails |
| Personal data | Email addresses, names and other content in email headers and in test emails |
| Data Principals | The Customer's users; senders and recipients of email in the connected mailboxes and test emails; people the Customer emails through the service |
| Duration | For as long as the Customer uses the service, and until deletion under clause 8 |
3. The Send Labs' obligations
The Send Labs will:
- process Customer Personal Data only to provide the service and on the Customer's documented instructions, which are these terms and the Customer's use of the service settings;
- not read, use or keep emails in connected mailboxes other than The Send Labs' own warmup and test emails;
- ensure that its staff and contractors who process Customer Personal Data are bound by confidentiality;
- maintain reasonable security safeguards, including encryption of mailbox credentials and tokens, TLS for data in transit, separation of each customer's data, access control and logging, and backups;
- assist the Customer, taking into account the nature of the processing, in responding to requests from Data Principals under sections 11 to 14 of the DPDP Act;
- make available the information reasonably needed to demonstrate compliance with this agreement.
4. Sub-processors
4.1 The Customer authorises The Send Labs to engage the sub-processors listed in the Privacy Notice (currently Amazon Web Services in Mumbai, India, and, for mailboxes the Customer connects, the Customer's own mailbox providers).
4.2 The Send Labs will give at least 30 days' notice by email of a new sub-processor. The Customer may object on reasonable grounds; if the parties cannot resolve the objection, the Customer may stop using the affected part of the service.
4.3 The Send Labs will impose data protection obligations on each sub-processor no less protective than this agreement, and remains responsible for their performance.
5. Transfers outside India
Customer Personal Data is hosted in India. The Send Labs will transfer it outside India only as permitted under section 16 of the DPDP Act.
6. Personal data breaches
The Send Labs will notify the Customer without undue delay, and in any case within 48 hours, after becoming aware of a personal data breach affecting Customer Personal Data, with the information available about its nature, likely consequences and the measures taken, and will cooperate with the Customer so that the Customer can meet its own obligations to inform the Data Protection Board of India and affected Data Principals under section 8(6).
7. The Customer's obligations
The Customer confirms that it has a lawful basis under the DPDP Act, and has given any notices required, for The Send Labs to process Customer Personal Data as described here, and that it will only connect mailboxes and test emails it is entitled to, and only email through the service people it may lawfully email.
8. Deletion
When the Customer deletes a mailbox, a test or its account, The Send Labs deletes the related Customer Personal Data: at once from the live system, and from backups within 30 days. Spam test email content is in any case erased 7 days after the test, and records of emails sent through the service 90 days after sending.
9. Liability and precedence
The limits of liability in the Terms of Service apply to this agreement. If this agreement conflicts with the Terms of Service on the protection of personal data, this agreement prevails.
10. Contact
The Send Labs, a unit of Homeasy Automation Private Limited, B-Hub, 5th Floor, Mauryalok Complex, Patna 800001, Bihar, India · [email protected] · [email protected]