1. Roles and details
The customer is controller and Natio Connect is processor under Article 28 GDPR for data placed in or processed through the email and mini-site services. The subject is managed professional email and a contact mini-site; processing includes hosting, form collection, transmission, technical access, backup, restoration, deletion and support for the service term and deletion cycle.
Data may include identities, addresses, mini-site form entries, message content, attachments, metadata, contacts, calendars, logs and support data relating to users, staff, members, customers, prospects, suppliers, partners and correspondents.
2. Instructions and confidentiality
Natio Connect processes data only on documented instructions formed by the contract, requested configuration and support tickets, unless law requires otherwise. Authorised personnel are bound by confidentiality and access data only where necessary. Mail content is not read for marketing purposes.
3. Security
- access control and logical tenant separation;
- encryption in transit where supported;
- dedicated secret management and temporary access links;
- antispam, antivirus, logging, patching and monitoring;
- technical backups, restoration procedures and least privilege.
4. Subprocessors and transfers
The customer gives general authorisation for the published subprocessor list. Equivalent data protection duties are imposed on them. A material change is normally notified at least 15 days in advance. A reasoned objection based on data protection risk may be raised; if no solution is available, the affected service may be terminated. Transfers outside the EEA require a valid Chapter V GDPR mechanism.
5. Assistance and breaches
Natio Connect reasonably assists with data subject requests, impact assessments, authority consultations and security obligations. It notifies the customer without undue delay after becoming aware of a personal data breach and provides available details progressively where needed.
6. Return, deletion and audit
The customer may export email using the supported protocols before termination. On termination, active data is returned or deleted as reasonably requested unless law requires retention; residual copies expire through normal backup cycles and remain protected. Natio Connect provides reasonable compliance information and allows one proportionate audit per year with 30 days’ notice, subject to security and confidentiality safeguards.
7. Customer duties
The customer is responsible for lawful purposes, notices to individuals, data minimisation, endpoint security, access management and any special-category safeguards. Data requiring exceptional guarantees must not be entrusted without an appropriate prior agreement.