Data processing addendum

Roles

For the mailbox content that an organisation asks Loopster to copy, index and draft replies from, the organisation is the controller and Custom Services Limited acts as its processor. For account administration, authentication, security, support and metering of our own service we act as an independent controller, as set out in the privacy policy.

Scope of processing

• Subject matter: reading connected mailboxes, copying recent mail into the organisation's workspace, deriving a writing style profile, preparing reply drafts, and sending a draft only when a member confirms it.
• Duration: while the mailbox or organisation remains connected to the service, plus the deletion steps in this addendum.
• Data subjects: the organisation's users, and the people who appear in the mail being processed (senders, recipients, mention of other individuals).
• Personal data: names, email addresses, message content, attachment content, signature and style artefacts, and technical metadata such as dates, labels and message identifiers.
• Purpose: providing the drafting and review workflow, its security, support, and the audit trail of what was drafted and sent.

Instructions and confidentiality

We process personal data only on the organisation's documented instructions: connecting a mailbox, configuring axes such as style, prompts and schedules, and the choices made in the app. We do not use the data for our own purposes, we do not sell it, and we do not use it to train models. Anyone authorised to process it is bound by confidentiality and by role-based access controls.

Security

Measures include per-organisation access scoping on every query, encrypted storage of mailbox credentials and provider keys with AES-GCM, TLS in transit, the narrowest available provider scopes, single-writer locking on syncs, size and count limits on attachments, and logs that exclude mail bodies and secrets. We review these measures as the platform develops.

Sub-processors

Sub-processors are listed on the sub-processor page with what they do and where they process. We authorise them only for the service they provide, we require confidentiality and data protection terms at least equivalent to this addendum, and we publish additions before they start.

Breach notification

We investigate suspected incidents affecting personal data in systems we control and notify the organisation without undue delay after confirming a breach, describing what happened, the categories and approximate volume of data, the likely consequences, and the measures taken to contain and remediate it, so that the organisation can meet its own notification duties. We cooperate with the organisation's investigation and do not make public statements about a customer's incident without agreement.

Assistance

We help the organisation respond to data subject requests that concern data we hold — access, correction, deletion, restriction — and we assist with data protection impact assessments and consultations with supervisory authorities where the processing we carry out makes that necessary.

Deletion and return

Disconnecting a mailbox deletes that mailbox's stored credential, message rows and stored files. On termination of the service, or on request, we delete the organisation's data and confirm completion in writing, unless a law requires us to keep specific records such as invoices or security logs for a defined period. Drafts and sending records can also be exported by request before deletion.

Audits

We answer reasonable audit questions and provide the security-relevant documentation we hold, including our providers' certifications, under confidentiality. On-site audits are available where law or a supervisory authority requires one, subject to notice, scope and confidentiality.

International transfers

We are established in the United Kingdom. Where a sub-processor processes data outside the UK or the EEA, the transfer is covered by the UK International Data Transfer Addendum, the EU Standard Contractual Clauses or an equivalent mechanism, together with the security commitments above.

Order of precedence

If this addendum conflicts with the terms of service on a data protection point, this addendum prevails for that point. Questions and requests: support@loopster.email. To execute this addendum for your organisation, contact us and we will confirm it in writing.