Privacy Policy
Last updated: July 12, 2026
This policy explains how THE DUG MEDIA LTD (“Smartletter”, “we”) processes personal data through the Smartletter platform (smartletter.ai). We act as data controller for our users' data, and as a data processor for the subscriber data our users import or collect through our tools.
1. Data controller
THE DUG MEDIA LTD, a company incorporated in Cyprus (Limited Company).
Registered office: Georgiou Karaiskaki 11-13, 7560 Pervolia, Cyprus. VAT: CY60221313C.
Contact / rights requests: contact@smartletter.ai.
2. Data we collect
- Account data: email, name, hashed password, language.
- Site data: public content of the sites you connect (branding, articles, products), analyzed to generate your newsletters.
- Audience data: email addresses and names of subscribers you import or collect through our forms and lead magnets. You are the controller of that data; we process it on your behalf.
- Usage and engagement data: sends, opens, clicks, bounces, complaints, statistics.
- Payment data: handled by our provider Stripe; we do not store your card details.
3. Purposes and legal bases
- Providing the service / performance of a contract (GDPR art. 6(1)(b)): account creation, newsletter generation and sending, billing.
- Legitimate interest (art. 6(1)(f)): security, abuse prevention, product improvement, aggregate engagement measurement.
- Consent (art. 6(1)(a)): optional marketing communications from us; withdrawable at any time.
- Legal obligation (art. 6(1)(c)): accounting, responding to competent authorities.
4. Email sending and subscriber consent
Smartletter sends emails on behalf of its users, to lists those users own. Each user is responsible for obtaining opt-in consent from their own subscribers and for not using purchased or unsolicited lists.
Every email sent through Smartletter contains a working unsubscribe link (including a one-click unsubscribe mechanism, RFC 8058). Unsubscribes, hard bounces and spam complaints are automatically added to a suppression list and never contacted again.
5. Sub-processors and hosting
We rely on sub-processors bound by confidentiality and security commitments:
- Amazon Web Services (Amazon SES) — email delivery, Europe (Paris) region.
- Supabase — database and authentication.
- Vercel — web application hosting.
- Cloudflare — DNS, CDN and background task execution.
- Stripe — payments and billing.
- AI model providers (via OpenRouter) — content generation, based on the data you submit.
6. International transfers
Our sending and application infrastructure is located in the European Union where possible. Some sub-processors may process data outside the EEA; in that case transfers are covered by the European Commission's Standard Contractual Clauses or an equivalent mechanism.
7. Retention
Account data is kept while the account is active, then deleted or anonymized within a reasonable period after closure. Audience data is kept while you use it and deleted at your request or on account closure. Billing data is retained as required by law.
8. Your rights
Under the GDPR you have the rights of access, rectification, erasure, restriction, portability and objection, as well as the right to withdraw consent. To exercise them: contact@smartletter.ai. You may also lodge a complaint with your competent supervisory authority.
9. Cookies
We use cookies strictly necessary for operation (session, authentication) and, where applicable, aggregate analytics. We do not use third-party advertising cookies.
10. Security
We implement appropriate technical and organizational measures: encryption in transit, per-workspace data isolation, access controls and logging. As no system is infallible, we cannot guarantee absolute security.
11. Changes
We may update this policy. For significant changes we will notify you by email or in-app. The last-updated date appears at the top of the page.