Data Processing Agreement

Draft of October 15, 2026 · Nederlands

Draft, not yet in force This is a draft, still to be reviewed by a lawyer. Points marked [to check] have not been confirmed yet. Until the final version is published here, the section “Your contacts' details” in our Terms of Service applies.

When you use Beeylo Business, Beeylo reads the mail in the mailbox you connect. That mail contains personal data of other people: your customers, suppliers and other contacts. For that data you decide why and how it is used, and Beeylo works on your behalf. The GDPR (article 28) requires an agreement for that. This is it. It is part of our Terms of Service and applies once it has been published as final.

1. Who this is between

You, the customer: the business or professional that uses Beeylo Business and connects a mailbox. You are the controller.
Beeylo, Rucphenseweg 38, 4882 KC Klein Zundert, the Netherlands, Chamber of Commerce (KvK) number 42050169. Beeylo is the processor.

Your own account details (your email address, sign-in data, settings) are not covered by this agreement. For those Beeylo is the controller, as set out in our Privacy Policy.

2. What Beeylo does with the data, and why

Beeylo processes personal data only to provide Beeylo Business to you. In practice:

reading the mail in the mailboxes you connect, and keeping a copy of it;
working out what each conversation asks for: what needs doing, from whom, by when, and for how much;
preparing replies in your words, which you check and send yourself;
sending a reply from your own mailbox, only after you press Send;
keeping your mailbox in step with what you do in Beeylo: marking as read, archiving, moving to the trash;
keeping the facts about your business that you approve, and learning how you write;
showing a notification on your phone when new mail needs you.

Beeylo does not use the data for anything else. No advertising, no profiling, no selling, and no training of general AI models.

3. Whose data, and which data

People involved

people who email you or whom you email: customers, prospects, suppliers, partners and other contacts;
people named in that mail or in its attachments;
colleagues in your team, if you use Beeylo with a team.

Types of data

names, email addresses and other contact details (for example in a signature);
the content of mail: subject, date, text, and attachments up to 10 MB, including text read from PDF files;
business details in that mail, such as amounts, invoice numbers, due dates and payment links;
what Beeylo works out from the mail: a summary of what is needed, the language, whether the sender writes formally, whether the sender is a person or an organisation, and a numeric fingerprint of the text to find similar questions;
facts about your business that you approve, which may mention a contact by name;
in a push notification: the sender's name and the subject.

Beeylo does not ask for special categories of personal data (such as health data). Mail can still contain them, because Beeylo cannot control what people send you. Such data gets the same protection as all other mail.

4. How long

This agreement runs as long as you have a Beeylo Business account. Some duties, such as confidentiality and deletion, continue until all data has been deleted.

5. Your instructions

Beeylo processes the data only on your instructions. Your instructions are these terms, this agreement, and what you do in the app: connecting a mailbox, sending a reply, archiving, disconnecting, deleting your account.
Beeylo does not process the data in any other way, unless the law requires it. In that case Beeylo tells you first, unless the law forbids that.
If Beeylo believes an instruction breaks privacy law, Beeylo tells you.

6. Confidentiality

Everyone at Beeylo who can access the data is bound to keep it confidential. Nobody at Beeylo reads your mail, unless you ask us to for support, it is needed for security, or the law requires it. [to check: written confidentiality commitment for everyone with access]

7. How Beeylo protects the data

Beeylo takes these measures, and keeps them up to date:

Encrypted connections. All traffic between the app, our server, your mail provider and our service providers is encrypted.
Encrypted mailbox access. Mailbox passwords and Google and Microsoft sign-in tokens are encrypted separately. The key is not in the database: only our server holds it, and only our server can unlock them. They never reach the app or our logs.
Encryption at rest. The database and file storage are encrypted on disk by our database provider.
Each account sees only its own data. Database rules check every request against the signed-in user. Attachments are stored privately, in a separate folder per user. In a team, a colleague sees a mailbox only when it is explicitly shared with them, and loses access as soon as they leave the team.
No more access than needed. For Gmail, Beeylo asks for permission to read, label and send mail, not to delete it permanently. Beeylo never sends anything without your action. The AI model has no access to your mailbox and cannot send anything.
Secure sign-in to mailboxes. Connecting a Google or Microsoft mailbox uses a signed, one-time, short-lived request bound to your browser.
Hosting in the EU. The database and files are in Frankfurt (Germany), the server runs in Amsterdam (the Netherlands), and AI processing takes place in the EU.
Logs without personal data. Our technical logs contain no email addresses, passwords, user identifiers in plain text or mail content. Crash reports go to an EU server and contain only the kind of error and where it happened.
Limits. Sign-in attempts and use of the service are limited to prevent abuse.
Separate systems. Beeylo Business has its own database, separate from any other Beeylo product.
Backups. Our database provider makes daily backups. [to check: retention period of backups]
Access by staff. Only the people at Beeylo who need it for their work can access the production systems, each with a personal account. [to check: two-step sign-in on all admin accounts]

8. Who helps us

You give Beeylo general permission to use the service providers below (sub-processors). Beeylo binds each of them to data protection obligations that are at least as strict as those in this agreement, and remains responsible to you for their work.

Supabase: database, sign-in and file storage. Servers in Frankfurt, Germany.
Railway: runs the Beeylo server. EU West region, Amsterdam, the Netherlands.
Mistral AI (France): AI processing of mail text, to understand it and prepare replies. EU hosting. Use of our data for training is switched off; Mistral keeps the data for up to 30 days to detect abuse, then deletes it.
Google Firebase Cloud Messaging: delivers push notifications (sender name and subject), on an iPhone through Apple's push service.
Sentry: crash reports, on servers in the EU (Germany). No mail, addresses or identities.
Resend: sends Beeylo's own emails, such as sign-in links and team invitations. Your mail and replies never pass through Resend.

Not sub-processors: Google, Microsoft or your own mail provider, which you chose to host your mailbox, and Cloudflare, which hosts our website but processes none of your mail.

Changes. Before Beeylo adds or replaces a sub-processor, Beeylo tells you by email at least 30 days in advance. You can object within that time, with a reason. If we cannot find a solution together, you can end your use of Beeylo and delete your account, at no cost.

9. Data outside the EU

Your mail, attachments and what Beeylo knows are stored in the EU. Some providers are American companies, so data can be accessed from outside the EU, for example for support and maintenance, or because a notification or email passes through their systems. Beeylo allows that only with a valid safeguard:

Supabase, Railway, Resend: standard contractual clauses of the European Commission in their data processing terms. [to check per provider, and whether any is certified under the EU-US Data Privacy Framework]
Sentry, Google (Firebase), Apple: EU-US Data Privacy Framework and/or standard contractual clauses. [to check: current certification on dataprivacyframework.gov]
Mistral AI: EU company, EU hosting. Where Mistral's own providers process data outside the EU, Mistral says it uses standard contractual clauses.

10. Helping you

Requests from people. If one of your contacts asks to see, correct or delete their data, you can do part of it in the app, such as editing or removing facts about your business. For anything else, Beeylo helps you within a reasonable time. If such a request reaches Beeylo directly, Beeylo forwards it to you and does not answer it on your behalf.
Assessments. If you need to carry out a data protection impact assessment (DPIA) or consult a supervisory authority, Beeylo gives you the information you need about how Beeylo works.

11. Data breaches

If Beeylo discovers a breach of security that affects your data, Beeylo tells you without undue delay, and no later than 48 hours after discovering it. Beeylo tells you what happened, which data and people are likely affected, what the likely consequences are, and what Beeylo has done or will do about it. If not everything is known yet, Beeylo sends what it has and follows up. You decide whether to report it to the supervisory authority and the people involved; Beeylo helps you with that.

12. Audits

On request, Beeylo first gives you documentation showing that it meets this agreement, such as a description of the measures above and any assessment reports.
If that is not enough, you can have an audit carried out, at most once a year, with at least 30 days' notice, by an independent auditor bound to confidentiality, during business hours, and without access to other customers' data.
You bear the cost of the audit, unless it shows that Beeylo seriously failed to meet this agreement.
A supervisory authority can always carry out an audit when it is entitled to.

13. At the end

Your mail stays in your own mailbox. Beeylo never deletes it there.
If you disconnect a mailbox, Beeylo stops reading it at once and deletes the stored password or sign-in token. For Google, Beeylo also withdraws its access to your Google account.
If you delete your account (in the app at the bottom of Settings, or on our account deletion page), Beeylo deletes right away all data covered by this agreement: mailboxes, mail, attachments, cases, replies, facts and writing preferences. Facts you shared with a team stay with that team.
Want a copy first? Email [email protected] before you delete your account, and Beeylo sends it within one month.
Copies in database backups disappear as those backups are replaced. Until then they are not used. [to check: retention period, and that a restore cannot bring back deleted accounts]
Beeylo keeps data longer only where the law requires it.

14. Liability

The limits of liability in our Terms of Service also apply to this agreement. Each party remains responsible for fines that a supervisory authority imposes on it for its own part. [to check: how this relates to liability towards data subjects under GDPR article 82]

15. Other terms

If this agreement and the Terms of Service conflict on personal data, this agreement wins.
Beeylo may update this agreement, for example when the law changes or a provider changes. For significant changes Beeylo tells you by email or in the app before they take effect.
This agreement is governed by Dutch law, like the Terms of Service.

Contact

Questions about this agreement? Email us at [email protected].