Privacy Policy

What personal data AgentMailMerge handles, where it is stored (EU or US), how long we keep it, and the choices you have.

Last updated

On this page

1. Who we are

The controller for the data described here is Alexander Duggleby, a sole proprietor trading as SimpleSoftware365, of Marxergasse 24/2, 1030 Vienna, Austria ("we", "us"). You can reach us at hello@agentmailmerge.com.

2. What this policy covers

This policy covers the AgentMailMerge website, the web app and the MCP server your AI agent connects to. The role we play depends on whose data it is:

  • Account holders. For the data of the people who sign up and use the service, we are the controller. This policy mainly describes that.
  • Campaign recipients. For the personal data of the people your campaigns are sent to, you (the account holder) are the controller and we are your processor. You decide whom to email and why, and we handle that data only on your instructions to provide the service. A data processing agreement under Article 28 GDPR is available on request at hello@agentmailmerge.com.

If you received an email sent through AgentMailMerge, please contact the sender first, since they are responsible for why you were emailed. You are also welcome to contact us, and we will help you reach the right person or deal with your request ourselves.

3. Data we collect

Account data

An account has an Owner, who can invite other members. When you or the members of your account sign in with Microsoft, we receive each person's name, email address and Microsoft account and tenant IDs. We do not receive Microsoft passwords. One Microsoft tenant can have only one account. We also record account settings, such as whether agent approval is allowed, and which member approved or released a campaign and through which channel (the MCP server or the web app).

Mailbox access

You grant us delegated Microsoft Graph permissions when you connect a mailbox. We use them to create scheduled drafts and send campaign messages from your mailbox, to check the drafts we created, and to read incoming mail only to detect bounces and replies to campaign messages. We record that a reply or a bounce happened. We do not store the content of replies. You can revoke the permissions at any time in your Microsoft account. System notifications, such as a campaign being paused, are sent to the Owner from the Owner's own connected mailbox.

Campaign and recipient data

Your agent gives us the campaign template, its merge fields and the recipient list: email addresses, names and any other merge values you choose to include. We also keep a report for each recipient showing what happened to their message.

Tracking and unsubscribe data

Messages can include a one-click unsubscribe link. It is optional and on by default, and it works on our standard domain (mailoptions.net, run by us) unless your account has a custom tracking domain, which it then uses. Addresses that unsubscribe or hard-bounce are added to your account-wide suppression list. We record opens, using a tracking pixel, and clicks, using tracked links, only when your account has set up a custom tracking domain. For each event we store the time, the IP address and the user agent. Open data is approximate, because mail apps may load images automatically or block them. Without a custom tracking domain, links are not rewritten and there is no pixel, so we record no opens or clicks.

Usage and technical logs

Our servers keep technical logs, such as requests, errors and security events, which can include IP addresses and user agents.

Website

The copy button on the website uses your clipboard locally, and nothing is sent to us. The web app uses only strictly necessary cookies to keep you signed in and secure your session. The website uses privacy-friendly, cookieless analytics (Rybbit, self-hosted on our own infrastructure) that do not track you across sites.

4. How and why we use it

We only use personal data when we have a legal basis under Article 6 GDPR.

PurposeDataLegal basis
Run your account, sign you in, and provide the serviceAccount data, mailbox access, campaign and tracking dataContract, Art. 6(1)(b)
Send campaigns and detect bounces and replies on your behalfRecipient data, tracking and unsubscribe dataAs your processor, on your instructions. Your own basis as controller applies to the recipients.
Keep the service secure, prevent abuse and spam, and improve the serviceTechnical logs, tracking and usage dataLegitimate interests, Art. 6(1)(f)
Keep the suppression list and meet legal duties such as accounting and responding to authoritiesSuppressed addresses, account and billing recordsLegal obligation, Art. 6(1)(c); legitimate interests, Art. 6(1)(f)

Where we rely on legitimate interests, we weigh them against your rights, and you can object as described in section 11.

5. Microsoft data

We use the data we get through Microsoft Graph only to provide the features you asked for: creating drafts, sending messages, and detecting bounces and replies. We do not sell it, we do not use it for advertising, and we do not use your mailbox content to train AI models.

6. Who we share data with

We do not sell personal data. We share it only with:

  • Microsoft, because your mailbox is hosted there and the service works through it. Microsoft handles that data under its own terms and privacy statement.
  • Service providers (subprocessors) who help us run the service, under contracts that require them to protect the data. They are listed below.
  • Authorities and advisers, where the law requires it or where we need to protect our rights.
ProviderPurposeLocation
Microsoft (Azure)Hosting, database, storage, logging and monitoring (Application Insights)Your account's region: Sweden Central (EU) or East US 2 (US)
Approximated (approximated.app)Custom tracking domains: certificates, and passing tracking requests through to our tracking service in your account's region. It stores no request data.Global edge network (pass-through only)
Stripe (when payments go live)Payments for paid plansIreland / US

7. Where your data is stored

We run two separate regions: the EU (Microsoft Azure, Sweden Central) and the US (Microsoft Azure, East US 2).

  • You choose a region. Each account lives in exactly one region, chosen at sign-up. It cannot be moved later.
  • It stays in that region. All data we store for your account stays in its region, including backups, logs, tracking events, recipients, templates, mailbox tokens and audit records. The two regions share no customer data.
  • One global component. The sign-in service (Login) is hosted in the EU (Microsoft Azure, Sweden Central). It holds only a hash of your Microsoft tenant ID with its region, and whether the tenant has an account or has used its trial, plus MCP client registrations and agent authorisations, keyed by a pseudonymous user ID.

Some data is outside our regions:

  • Mail content (drafts, sent mail and replies) stays in your own Microsoft 365 tenant, under Microsoft's data residency.
  • Sign-in uses Microsoft Entra ID, a Microsoft global service.
  • If you use a custom tracking domain, open and click requests pass through Approximated's global edge network on their way to your region. Approximated only passes them on and stores no request data.
  • Content your AI agent reads through the MCP server goes to the AI provider you chose. That is outside our control, so check that provider's terms.

8. International transfers

For accounts in the US region, data is stored in the US. For accounts in the EU region, it is stored in the EU. Some of the providers in section 6, and your own Microsoft and AI services, may process data elsewhere. Where personal data is transferred outside the European Economic Area, we rely on an adequacy decision, such as the EU-US Data Privacy Framework for certified US providers, or on the European Commission's Standard Contractual Clauses, together with additional safeguards where needed. You can ask us for details at hello@agentmailmerge.com.

9. How long we keep data

  • Campaign personal data. Each account has a campaign data retention period, 1 year by default. The Owner can set it from 30 days up to the plan's maximum: 1 year on Solo, and up to 5 years on higher plans. It counts from when a campaign completed or was cancelled. After it, we delete recipient email addresses, merge values, message identifiers, and tracking IP addresses and user agents. We keep aggregate results and anonymous per-recipient outcomes, which contain no address.
  • The suppression list is kept for as long as the account exists and is not subject to the campaign retention period, so people who unsubscribed are never emailed again.
  • Trial accounts that are not upgraded are deleted in full on day 37, suppression list included. Only a hash of the Microsoft tenant ID remains, to show that the trial was used.
  • Account deletion. When an account ends, we delete its data within 30 days.
  • Technical logs are kept for 30 days.

We may keep some data longer where the law requires it, for example accounting records, or where we need it to handle a legal claim.

10. Security

We use reasonable technical and organisational measures to protect personal data, including encrypted connections and limiting access to people who need it. No system is perfectly secure. If a breach affects your personal data in a way the law says we must report, we will tell you and the authorities as required.

11. Your rights

Under the GDPR you have the right to access your data, to have it corrected or erased, to restrict or object to how we use it, to receive it in a portable format, and to withdraw consent where we rely on it. To use any of these rights, email hello@agentmailmerge.com. We will answer within one month.

You can also complain to the supervisory authority. For us that is the Austrian Data Protection Authority (Datenschutzbehörde), Barichgasse 40–42, 1030 Vienna, www.dsb.gv.at. You may complain to the authority in your own country instead.

12. Children

The service is not for anyone under 16, and we do not knowingly collect personal data from children. If you think a child has given us data, please tell us and we will delete it.

13. Changes to this policy

We may update this policy. If a change is significant, we will tell you by email or in the app before it takes effect. The date at the top shows when it was last updated.

14. Contact

For questions or requests about your data, email hello@agentmailmerge.com, or write to Alexander Duggleby, Marxergasse 24/2, 1030 Vienna, Austria.