Data Processing Addendum
Last Updated: January 3, 2026
This Data Processing Addendum ("Addendum") forms part of the Terms of Use between Romain Berg, doing business as CampaignCommander ("Company," "we," "us," or "our"), and the customer ("Customer," "you," or "your").
This Addendum applies to the extent the Company processes Personal Data on behalf of the Customer in connection with the CampaignCommander platform.
Definitions
"Personal Data" means any information that identifies or relates to an identifiable individual and is processed on behalf of the Customer.
"Processing" means any operation performed on Personal Data, including collection, storage, use, transmission, or deletion.
"Applicable Data Protection Laws" means all laws and regulations relating to data protection, privacy, or security applicable to the Processing, including U.S. state privacy laws and, where applicable, GDPR.
For purposes of Applicable Data Protection Laws:
- Customer is the Data Controller of Personal Data uploaded to or processed through the platform.
- Company is the Data Processor and processes Personal Data solely on documented instructions from the Customer.
The Company does not determine the purposes or means of Customer communications.
Scope and Purpose of Processing
The Company processes Personal Data only to:
- Provide and operate the CampaignCommander platform
- Deliver email, SMS, MMS, voice, and mailing services as instructed
- Secure and maintain the platform
- Enforce Terms of Use and platform policies
- Comply with legal obligations
Processing is limited to what is necessary to perform the services.
Customer Responsibilities
Customer represents and warrants that:
- It has a lawful basis to collect, use, and provide Personal Data
- All communications sent through the platform comply with applicable laws
- Required consents and permissions have been obtained
- Data subjects have been informed as required by law
Customer remains solely responsible for the legality of its data and messaging practices.
Company Obligations
The Company agrees to:
- Process Personal Data only on Customer instructions
- Maintain reasonable administrative, technical, and physical safeguards
- Restrict access to Personal Data to authorized personnel
- Not sell Personal Data
- Assist with data subject requests where legally required, subject to verification and feasibility
The Company may engage subprocessors to provide infrastructure, messaging delivery, analytics, hosting, payment processing, or support services.
Customer authorizes the use of such subprocessors provided they are bound by data protection obligations consistent with this Addendum.
A current list of subprocessors may be made available upon request.
Data Security
The Company implements reasonable security measures designed to protect Personal Data from unauthorized access, disclosure, or loss.
Customer acknowledges that no system can guarantee absolute security. For more details on our security practices, see our Privacy Policy.
Data Retention and Deletion
The Company retains Personal Data:
- For the duration of the Customer account
- As required to provide services
- As required by law or to resolve disputes
Upon account termination, Personal Data will be deleted or anonymized within a reasonable period, subject to legal and operational requirements. For information on account cancellation, refunds, and balances, see our Billing and Cancellation Policy.
Data Subject Requests
Where required by law, the Company will assist the Customer in responding to data subject requests.
Requests must be submitted to support@campaigncommanderapp.com and may require verification.
International Data Transfers
Personal Data may be processed and stored in the United States or other jurisdictions where the Company or its subprocessors operate. Customer consents to such transfers.
Limitation of Liability
This Addendum does not expand the Company's liability beyond what is set forth in the Terms of Use.
Order of Precedence
If there is a conflict between this Addendum and the Terms of Use, this Addendum controls solely with respect to data protection obligations.
Contact Information
Romain Berg dba CampaignCommander
113 South Monroe Street
Tallahassee, FL 32301
Privacy Contact: privacy@campaigncommanderapp.com
Platform access, acceptable use policies, and user responsibilities
How we collect, use, store, and protect your personal information
Rules for email, SMS, voice, and mail communications
Pay-as-you-go billing, refunds, credits, and account cancellation
How charges work, rate visibility, and prepaid balance terms