Data Processing Addendum

This addendum covers personal information about subscribers — mostly their names and the addresses their mail goes to — and how it is handled between Sendero Origen, LLC d/b/a Good Post Co and you, the creator. It is part of the Creator Agreement, and it applies automatically. There is nothing to sign and nothing to request.

Where this addendum and the rest of the Creator Agreement disagree about personal information, this addendum wins.

Who decides what, and why it is two answers

Most platforms can say "you are the controller, we are the processor" and leave it there. We cannot, honestly, because Good Post Co is the merchant of record and a merchant of record has decisions of its own to make.

We decide — we are the controller — for taking payment, working out and collecting sales tax, sending receipts, preventing fraud, answering card disputes, keeping the records tax and consumer law require, and running the platform safely. You cannot instruct us out of those; they are obligations the law puts on the seller.

You decide — you are the controller, and we act as your processor — for your subscriber list: who is on it, what you write about them in a note, what you mail them, and what you do with the copy you export.

Your own copy is yours. The moment you export the list, whatever you do with it is yours to answer for, and this addendum stops covering it.

What is handled, and about whom

About whom: people who subscribe to your club, and people who receive a gift membership to it.

What: their name, the name on the envelope, their postal address, their email address, which plan they bought and what they paid, the record of what has been mailed to them and when, address changes, replacement requests, returned mail, and any notes you write about their subscription.

What is not: card numbers, bank details, IP addresses, or anything about anybody's race, health, religion, politics, sex life or biometrics. We do not collect any of that. Do not put any of it in a note. If we find something like that in one, we will delete it.

How long: while the club runs, and then as described under "Deleting it" below.

What we promise, where we are your processor

We act on your instructions, and on ours only where running the service or the law requires it. The studio, the exports and this addendum are the instructions; there is no separate instruction process to learn. If the law makes us do something with your list that you did not ask for, we will tell you, unless we are forbidden from telling you.
Anybody who touches it is bound to keep it private, whether they are staff or a company working for us.
We keep it secure, as described below.
We help you answer people. If a subscriber asks you for a copy of what is held, or asks you to correct or delete it, tell us and we will do it. If they ask us directly, we do it and you can see the result in your studio.
We help you check. Once a year, if you ask, we will answer reasonable written questions about how your subscribers' information is handled and show you what we have. An inspection in person only where the law actually requires one, arranged in advance, at your cost, and without disturbing any other club's data.

The companies that help us

Each of these does one job, under a contract that holds them to the protections in this addendum:

Stripe, Inc. (United States) — payments, receipts, tax calculation, card storage, and paying you. Stripe holds the card; we never do. It is also given each subscriber's mailing address, a gift recipient's included, because sales tax depends on where the mail is delivered.
Cloudflare, Inc. (United States) — hosting, the database, and protection against attacks. The subscriber list lives in a Cloudflare database in the United States.
Resend / Plus Five Five, Inc. (United States) — sending our emails.
Google LLC (United States) — the mailbox behind support@goodpostco.com, so anything a subscriber emails us is held there.
An address-checking service — to catch typos before an envelope is printed. We have not chosen one yet. When we do, we will add it here and tell creators before it sees a single address.

We will give you at least 30 days' notice by email before adding a company to this list. If you object, tell us within those 30 days and we will try to sort it out; if we cannot, either of us may end the Creator Agreement without penalty, and your list is exportable the whole time.

Where it is handled

The United States, entirely. Nothing about your subscribers is sent to, or stored in, another country. If that ever changes we will tell you first and put the legal protections in place that the transfer needs.

How it is kept safe

Everything travels over an encrypted connection.
There is no card data in our systems at all, and no passwords — sign-in is by one-time link, and the link is stored only as a one-way fingerprint of itself.
No IP addresses are stored, anywhere, for anybody.
One club's data cannot be read from another club's pages. That is enforced by the database itself, not only by the code around it.
Addresses appear only where somebody is addressing mail. They are never written to a log, never in an error message, and never in an export nobody asked for.
Access is limited to the people who need it, and every time a member of our staff opens a creator's studio as that creator, it is recorded.
Third-party analytics and advertising scripts are not used on any page a subscriber sees. There are none to configure and none to turn off.

If something goes wrong

If personal information we hold for you is lost, taken, or seen by somebody who should not have seen it, we will tell you without undue delay and within 72 hours of finding out. We will tell you what happened, what was affected, what we are doing, and what you may need to do.

Where the law says the people affected have to be told, we will tell them — we are the seller and it is our contact details they have — and we will tell you what we said before we send it.

Neither of us announces the other's incident publicly without talking first, unless the law requires it.

Deleting it

A subscriber's address is deleted 90 days after their membership ends, from the current record and from every earlier address on it. The address printed on each past envelope is stripped out of the mailing history at the same time. That a mailing happened stays, because it is a business record; where it went does not.
A subscriber can ask for deletion at any time. We do it, and tell you if it affects a mailing already being prepared.
When your club ends, you export your list — always available, one click, including while suspended and including if you owe us money — and we delete what we hold, except payment and tax records, which we keep for seven years because the tax authorities can ask us to produce them.
The database keeps a rolling point-in-time history so it can be recovered after a disaster. It reaches back no more than 30 days. A deletion applies to the live system immediately and leaves that history as it rolls past.

What you promise

You have a proper reason to hold and use your subscriber list, and you use it only to run your club — see the Creator Agreement.
You keep any copy you export somewhere safe, and delete copies you no longer need.
You tell us promptly if a subscriber asks you for something we have to act on.
You do not put sensitive information, card details or government identifiers into a note, an export, or anywhere else in the system.
You follow the privacy laws that apply to you.

California, and similar state laws

For the parts where we act for you, Good Post Co is a service provider under the California Consumer Privacy Act, and the equivalent under the other state privacy laws.

We do not sell personal information and we do not share it for cross-context behavioural advertising — not your subscribers' information, not anybody's. We do not keep, use or disclose it for any purpose other than performing the service, except where the law allows. We will tell you if we can no longer meet those obligations, and you may stop us processing or ask us to put things right.

Contact

support@goodpostco.com, or by post to Sendero Origen, LLC d/b/a Good Post Co, 3126 S Boulevard St #154, Edmond, OK 73013. Put "data protection" in the subject line and it will reach the right person faster.