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EU data residency

MiniMailer stores customer and recipient data in the European Union (Ireland) by default — on every tier, including the free one. EU residency is not an enterprise add-on; it is the architecture.

If you build for European users, this answers the two questions your DPO will ask: where does the data live? and what paperwork exists?

Where the data lives

  • Recipient and account data — contact records, suppression and consent records, send metadata, inbound message content — is stored in the EU (Ireland), within MiniMailer's own EU cloud environment.
  • The application layer (cache, sessions, queue workers, scheduler) runs in the EU (Ireland) as well; observability data stays in the EU (Frankfurt).
  • Billing runs through our Merchant of Record — card data is collected by the payment processor and never touches MiniMailer.

The full picture, per vendor, with locations and transfer mechanisms, is published on the sub-processors page — that list, not this article, is the authoritative reference.

The GDPR paperwork

Everything a data-protection review asks for is public:

Compliance is in the API, not just the PDFs

The design position: compliance features belong in the product, as API surfaces you can build on.

  • Right to erasure — POST /recipients/{recipient}/forget (scope compliance:write) permanently erases a recipient's data. Wire your own deletion flow to it and a data-subject request becomes one API call.
  • Tracking is off by default. Open and click tracking are opt-in per domain, and per-send flags can only narrow what the domain allows — you enable measurement when you have the lawful basis for it, not the other way round. Tracking →
  • Unsubscribes are honoured immediately — one-click unsubscribe (RFC 8058) is configured for you, and opt-outs become permanent-by-default suppressions. Opt-out records are retained so the opt-out itself is never forgotten.
  • Consent fields on contacts — consent type and source travel with the contact record, so your audit trail lives where the addresses do.
  • Consent and its withdrawal are both recordable — you can log the consent you hold for a recipient, and log a withdrawal against it later. The ledger is append-only: a withdrawal is stamped onto the record rather than erasing it, so you can still demonstrate what was consented to and when it ended.
  • A recipient's own unsubscribe withdraws their consent automatically. When someone opts out — one-click from their mail client or through the footer link — the opt-out is honoured and their consent record is stamped as withdrawn in the same moment, with the unsubscribe recorded as the channel. Withdrawal is therefore exactly as easy as consenting, which is what the law asks for, and it happens without you doing anything.
  • Defined retention — operational data follows published windows (inbound email, for example, is retained for 30 days); account data lives as long as your account plus what the law requires.

Who is responsible for what

For your recipients' data, you are the controller and MiniMailer is your processor: you decide who gets mailed and why; MiniMailer processes on your instructions under the DPA. MiniMailer's infrastructure gives you residency, erasure, suppression, and consent primitives — obtaining valid consent, honouring your own privacy policy, and the lawfulness of your campaigns remain yours. The Acceptable Use Policy draws the hard lines.