Description of Processing

This page describes the processing Reelevant performs as a data processor, in the structure usually expected in a DPA annex or a record of processing activities (Article 30 GDPR). The signed DPA and its annexes prevail over this page.

Data Lifecycle

Nature and Purpose

Item	Description
Nature	Hosting of customer datasets, automated execution of personalisation rules defined by the controller, generation of personalised marketing Content, measurement of exposures and clicks
Purpose	Display to each recipient the marketing Content selected by the controller’s rules, in emails, websites and apps operated by the controller, and measure its performance
Instructions	The Datasources connected and the Workflows configured by the controller’s users in the platform
Duration	The term of the contract, followed by deletion as described in Retention

Data Subjects

Customers and prospects of the controller who receive its marketing communications
Visitors of the controller’s website or app, when the optional web or mobile collection is deployed
The controller’s own users of the Reelevant platform (account data: name, professional email, role)

Categories of Personal Data

Category	Examples	Source
Identification	Pseudonymous customer identifier (CRM number, hashed value)	Controller’s systems and email platform
Customer profile	Loyalty status, preferences, language, country — only the fields the controller maps	Controller’s Datasources
Transaction history	Past bookings or purchases, products, dates, amounts	Controller’s Datasources
Interaction with the Content	Exposure (open) and click events, Content and Branch displayed, date	Generated by the Personalisation Engine
Technical request data	User agent, device type, email client, referrer, approximate location derived from the IP address	Transmitted by the email client or browser
Website behaviour (optional)	Pages and offers viewed, searches, cart and purchase events	Reelevant web or mobile collection, after consent

No special category data (Article 9) is required by the service. The controller should not map such fields into its Datasources.

Use an opaque identifier in the Content URL. The identifier is visible in the email HTML, in browser history and in logs, so it must never be an email address, a phone number or a name.

Retention

Data	Retention
Datasource records	Kept until updated or removed. With a full-replacement (Override) strategy, a record deleted at source disappears at the next sync; with Append or Upsert, existing rows persist until erased (see Data Subject Rights)
Behavioural events (exposures, clicks, website events)	90 days by default, configurable per Datasource
Security logs	1 year, in line with the CNIL recommendation
Backups	Encrypted, expire no later than 180 days after deletion
End of contract	All personal data deleted within 30 days; a written deletion attestation is provided on request

Recipients and Location

Recipient	Role	Location
Controller’s authorised users	Configure Workflows, read reports	—
Reelevant staff	Support, troubleshooting at the controller’s request and maintenance — under least privilege, MFA and audit logging	EU
OVH SAS (OVHcloud)	Subprocessor — hosting of the platform on dedicated servers	France
Google Cloud EMEA Limited	Subprocessor — analytics warehouse holding pseudonymous events and aggregates	Belgium (`europe-west1`)

No personal data is transferred outside the EU. See Vendor Management for the full vendor list.

Security Measures

A summary of the technical and organisational measures. Full details are on Security & Compliance and in the Trust Centre.

Area	Measure
Assurance	SOC 2 Type 2 attestation (annual), annual external penetration test
Encryption	TLS 1.2+ in transit, AES-256 at rest
Access	SAML SSO, TOTP two-factor authentication, role- and Team-based permissions, quarterly access reviews
Isolation	Logical tenant isolation; each customer’s data scoped to its company and Teams
Traceability	In-product audit log, security logs retained 1 year
Incidents	Personal data breach notification within 48 hours of detection

Data Subject Rights

The controller remains the point of contact for data subjects. Reelevant assists as follows:

Right	How it is handled
Access and portability	The controller already holds the source data; Reelevant assists on request for the events tied to an identifier
Erasure	Always delete the record at source first, otherwise the next sync imports it again. Override Datasources: it then disappears at the next sync. Upsert Datasources in Worker or Ingester mode: record-level anonymisation removes it without waiting. Append, PubSub or Proxy Datasources: ask Reelevant for assistance (for example, a data reset). Events expire with their retention period
Objection to marketing and profiling	Handled by the controller’s opt-out, which stops new emails. Emails already delivered still trigger the Personalisation Engine when reopened, so also exclude the identifier with a Workflow condition or erase their records
Withdrawal of consent (web collection)	Handled by the controller’s CMP, which stops loading the Reelevant web tag

Requests to Reelevant go to security@reelevant.com.

Checklist for the Controller

Add Reelevant as a processor in your record of processing, with the purposes above
Mention personalisation of marketing communications and open and click measurement in your privacy notice
If you deploy the web tag, add Reelevant as a recipient in your CMP and load the tag only after consent
Choose an opaque customer identifier for the Content URLs
Map only the fields your Use Cases need in each Datasource

Documents Available

Document	Where
Data Processing Agreement (DPA) and subprocessor list	Provided with the contract
SOC 2 Type 2 report, penetration test summary	Trust Centre, under NDA
Security questionnaire / self-assessment	On request to your account team

Overview

For Technical Evaluators

For Data Protection Officers

Data Lifecycle

Nature and Purpose

Data Subjects

Categories of Personal Data

Retention

Recipients and Location

Security Measures

Data Subject Rights

Checklist for the Controller

Documents Available

Next Steps

How Reelevant Works for DPOs

Security & Compliance

​Data Lifecycle

​Nature and Purpose

​Data Subjects

​Categories of Personal Data

​Retention

​Recipients and Location

​Security Measures

​Data Subject Rights

​Checklist for the Controller

​Documents Available

​Next Steps

How Reelevant Works for DPOs

Security & Compliance

Data Lifecycle

Nature and Purpose

Data Subjects

Categories of Personal Data

Retention

Recipients and Location

Security Measures

Data Subject Rights

Checklist for the Controller

Documents Available

Next Steps