max / makenotwork

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1	# Mailing List Data Processing
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3	Who is responsible for a subscriber's address when a creator sends mail through a project mailing list, and who answers when that subscriber asks a question about it.
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5	This page covers project mailing lists specifically. For everything else we hold, see the [Privacy Policy](./privacy-policy.md).
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7	---
8
9	## The Arrangement
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11	Makenotwork and the creator are joint controllers for a project mailing list.
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13	Neither party alone decides both what the list is for and how it runs:
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15	- Makenotwork holds the addresses, runs the send, and holds the contract with the email provider.
16	- The creator decides who is on the list and what the mail says.
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18	Joint controllership is what that split is called under GDPR Article 26. It is not a processor relationship, and describing it as one would put the whole responsibility on Makenotwork for decisions the creator makes.
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20	This page is the summary of the arrangement that Article 26 requires us to make available to subscribers.
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22	---
23
24	## One Contact for Every Request
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26	privacy@makenot.work.
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28	Article 26 lets joint controllers name a single point of contact, and we have. A subscriber can also go to either party directly, and a request that arrives anywhere gets handled rather than forwarded with instructions to try the other one.
29
30	Nothing below changes that. The division of responsibility is between us and the creator; a subscriber never has to work out which of us to write to.
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32	---
33
34	## Who Answers What
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36	\| Request \| Answered by \| Why \|
37	\|---------\|-------------\|-----\|
38	\| Access: what do you hold about me \| Makenotwork \| We hold the record. The creator sees a subscriber list, not our database. \|
39	\| Erasure: delete my address \| Makenotwork, and it takes effect on the creator's list \| See below. \|
40	\| Rectification: fix my address \| Makenotwork \| Same record. \|
41	\| Objection: stop sending me this \| Either. The unsubscribe link is the fastest route. \| Unsubscribing is instant and needs no request at all. \|
42	\| Why did I get this mail \| The creator, with our help if they need it \| The creator decided the content and the audience. \|
43
44	### Erasure, in detail
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46	Erasure is the request that a badly drawn arrangement leaves bouncing between two parties, so it is settled here.
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48	An erasure request against a project mailing list is fulfilled by Makenotwork, and it removes the address from the creator's list at the same time. The creator does not hold a separate copy to be chased down: the subscriber list a creator sees is a view of our database, and an erased address is gone from both at once.
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50	A creator can export their subscriber list, which puts a copy of the addresses on their own machine. That copy is outside our database, so it is worth being exact about it. Under this arrangement a creator must not keep mailing an address after it is erased, and must delete the exported copy when we tell them an erasure covers it. A subscriber does not have to chase that: write to privacy@makenot.work and we pass it on and follow it up. The same two obligations are written into the [Terms of Service](./terms-of-service.md), under Creator Terms, which is where a creator agrees to them.
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52	Suppression records are the exception, and they are the same exception the Privacy Policy already makes. If an address bounced or filed a complaint, we keep a one-way record that we must not mail it again. Erasing that record would mean mailing the address again the next time somebody adds it.
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54	---
55
56	## When a Creator Leaves
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58	A creator can close their account with a list still on it. Three things happen, in this order:
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60	1. Sending stops immediately. A closed account cannot trigger a broadcast or an automatic notification.
61	2. The list stops being a list. Subscribers are not transferred anywhere, not sold, and not folded into another creator's audience.
62	3. The addresses are deleted within 30 days, on the same schedule as the rest of the account's data.
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64	Makenotwork remains reachable at privacy@makenot.work for the whole of that window and afterwards. A departing creator does not take the obligation with them, which is the point of naming a single contact.
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66	Subscribers are not notified that a list has closed. The mail simply stops.
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68	---
69
70	## The Email Provider
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72	Our email provider is a processor, not a joint controller. It sends what we tell it to send and holds the addresses to do it. The current provider is named in [Infrastructure & Vendors](../tech/infrastructure.md).
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74	Processor and joint controller are different roles and this page keeps them apart. The creator decides who gets mailed; the provider decides nothing.
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76	---
77
78	## What This Does Not Cover
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80	- Account mail. Receipts, security notices and password resets are ours alone. No creator is involved and no creator can stop them. See [Email you cannot turn off](../guide/email-you-cannot-turn-off.md).
81	- Lists a creator runs somewhere else. If a creator exports their subscribers and mails them from another service, that service and that creator are the parties involved, and we are not one of them. The erasure obligations above still follow the addresses, because they came from here.
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83	---
84
85	## Contact
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87	Subscriber requests about a project mailing list: privacy@makenot.work
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89	Formal data protection inquiries: dpo@makenot.work
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91	---
92
93	## See Also
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95	- [Privacy Policy](./privacy-policy.md): Everything else we hold
96	- [Mailing Lists](../guide/mailing-lists.md): How lists work for creators
97	- [Email you cannot turn off](../guide/email-you-cannot-turn-off.md): The mail that ignores every preference
98	- [Terms of Service](./terms-of-service.md): Full legal terms
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