Effective date: September 8, 2026
This document is a supplement to the general Kiges Privacy Policy and regulates data processing issues specific to the Kiges Send service — an email marketing platform for creating, sending, and analyzing email campaigns, located at https://send.kiges.cc.
1. General Provisions
1.1. This document supplements the general Kiges Privacy Policy and applies in conjunction with it. In case of discrepancies between the documents regarding Kiges Send, this document prevails.
1.2. Use of the Kiges Send service implies the User's consent to the terms of this document and the general Kiges Privacy Policy.
1.3. Terms used in this document are applied in the meanings defined in the general Kiges Privacy Policy and the Public Offer.
2. Data Processed within Kiges Send
2.1. To ensure the functionality of the Kiges Send service, the following categories of data are processed:
2.1.1. Account data: email address, password (hashed), User's name, notification settings, sending domain configuration.
2.1.2. Subscriber data: email addresses of Subscribers included in the Customer's Subscriber Lists, Subscriber metadata (name, custom fields, consent status, subscription date, subscription source).
2.1.3. Campaign data: email content, subject lines, sending parameters, templates, scheduling information, A/B test configurations.
2.1.4. Campaign analytics: delivery status, open rates, click rates, bounce rates, complaint rates, unsubscribe rates, geolocation data, device and client information of recipients.
2.1.5. Payment data: tariff information, payment history, bank card details (processed by the payment provider; Kiges Send does not store full payment data). From the payment provider, Kiges Send may receive partial (masked) card data, which is displayed in the "Payment Methods" section of Kiges Pay for the purpose of identifying the User's payment method. Such partial data does not allow a payment to be made and cannot be used for unauthorized debiting of funds.
2.1.6. Technical data: IP address, browser information, access time, cookies, sending logs, SMTP logs, DNS records (SPF, DKIM, DMARC).
2.2. Kiges Send does not request or process special categories of personal data (information about health, racial or ethnic origin, political opinions, religious beliefs, etc.).
2.3. Kiges Send does not verify the accuracy of the data provided by Users about themselves and is not responsible for their reliability.
3. Purposes of Data Processing
3.1. Data is processed for the following purposes:
3.1.1. Creating, scheduling, and sending email campaigns.
3.1.2. Managing Subscriber Lists and subscriber metadata.
3.1.3. Tracking and displaying campaign analytics.
3.1.4. Managing unsubscribe requests and bounce handling.
3.1.5. Ensuring User authorization and access to service features.
3.1.6. Invoicing and payment processing.
3.1.7. Providing technical support.
3.1.8. Preventing spam, abuse, and violations of the Public Offer.
3.1.9. Maintaining email deliverability and sender reputation.
3.1.10. Sending notifications to the User about service status, campaigns, and account.
4. Subscriber Data and Consent
4.1. The Customer is solely responsible for obtaining and maintaining verifiable consent from each Subscriber before adding them to a Subscriber List and sending them email campaigns.
4.2. Kiges Send processes Subscriber data (email addresses, metadata) on behalf of the Customer as a data processor. The Customer acts as the data controller and bears full responsibility for the lawful collection, storage, and use of Subscriber data in accordance with applicable data protection legislation (GDPR, CAN-SPAM Act, ePrivacy Directive, and equivalent legislation).
4.3. Kiges Send does not verify whether the Customer has obtained consent from Subscribers and is not responsible for the Customer's compliance with data protection and anti-spam legislation.
4.4. Kiges Send stores Subscriber data for the period of the Customer's use of the Service and for a reasonable period thereafter, unless the Customer deletes the data or the account is terminated.
4.5. The Customer can delete Subscriber data at any time through the service interface. Upon deletion, the data is removed without the possibility of recovery, except for data that must be retained in accordance with applicable legislation.
4.6. Kiges Send may process Subscriber data for the purpose of bounce handling, unsubscribe management, and spam complaint tracking, as necessary to provide the service and maintain deliverability.
5. Campaign Content and Analytics
5.1. Campaign content (email text, images, links, templates) created by the Customer is stored on the Service's servers for the purpose of providing the service and generating analytics.
5.2. Kiges Send is not liable for the content of email campaigns created by the Customer, including their legality, accuracy, or compliance with the rights of third parties.
5.3. Campaign analytics (open rates, click rates, bounce rates, etc.) are generated based on technical tracking mechanisms (tracking pixels, link redirects) and may not be 100% accurate due to technical limitations, recipient email client settings, and anti-tracking measures.
5.4. Kiges Send does not guarantee the accuracy of campaign analytics and is not liable for decisions made by the Customer based on such analytics.
6. Email Deliverability and Sending Infrastructure
6.1. Kiges Send uses shared and/or dedicated sending infrastructure to deliver the Customer's email campaigns. The deliverability of emails depends on numerous factors beyond the Contractor's control, including recipient ISP policies, spam filters, blacklist operators, and recipient engagement.
6.2. Kiges Send does not guarantee that emails will reach recipients' inboxes, avoid spam filters, or achieve any specific delivery rate.
6.3. The Contractor reserves the right to suspend or reject any Campaign that, in the Contractor's sole discretion, may harm the Service's sending reputation or violate anti-spam policies.
6.4. Kiges Send may share sending metrics (complaint rates, bounce rates, sending volume) with email service providers, ISPs, and blacklist operators for the purpose of maintaining deliverability and preventing abuse.
7. Data Storage and Protection
7.1. Subscriber data and campaign data are stored for the period of use of the Service and for a reasonable period thereafter, except for data that must be stored in accordance with applicable legislation.
7.2. Kiges Send takes technical and organizational measures to protect User data, including encrypting data transmission via HTTPS, restricting employee access to data, and regular backups.
7.3. In the event of a data security breach, Kiges Send takes measures to eliminate the breach and notifies affected Users within a reasonable time.
7.4. Kiges Send does not guarantee absolute data security and is not liable for the disclosure of data resulting from circumstances beyond the Contractor's control, including hacker attacks, failures of third-party services, or actions of government authorities.
8. Data Sharing with Third Parties
8.1. Kiges Send does not share Users' personal data with third parties, except in cases provided for by the legislation of the Republic of Serbia.
8.2. Kiges Send may use the services of third-party providers (payment providers, email sending infrastructure providers, analytics services, hosting providers) to ensure the operation of the service. Data sharing with such providers is carried out under confidentiality agreements.
8.3. Kiges Send may share aggregated and anonymized statistical data with third parties for the purpose of analysis and service improvement.
8.4. Kiges Send may share User data with authorized state authorities of the Republic of Serbia on the grounds and in the manner established by the legislation of the Republic of Serbia.
9. User Rights
9.1. The User has the right to:
9.1.1. Request information about the personal data processed by Kiges Send.
9.1.2. Demand clarification, blocking, or destruction of their personal data if it is incomplete, outdated, inaccurate, or unlawfully obtained.
9.1.3. Withdraw consent to the processing of personal data by sending a notification to info@kiges.cc.
9.1.4. Delete their account and all associated data by contacting support.
9.2. Upon account deletion, Kiges Send deletes the User's data within a reasonable time, except for data that must be stored in accordance with applicable legislation (e.g., transaction data, sending logs for abuse prevention).
9.3. The User is responsible for fulfilling data subject requests (access, deletion, rectification) from their Subscribers, as Kiges Send processes Subscriber data on behalf of the User as a data processor.
10. Data Deletion
10.1. The User can delete their Subscriber Lists, campaigns, templates, and analytics data at any time through the service interface.
10.2. When an account is deleted, all associated data, including Subscriber Lists, campaigns, templates, and analytics, is deleted without the possibility of recovery, except for data subject to mandatory storage by law.
10.3. Kiges Send reserves the right to delete data of inactive accounts after 12 (twelve) months from the date of the User's last activity.
10.4. The Contractor is not liable for any losses of the User arising from the deletion of data, including loss of Subscriber Lists, campaigns, or analytics.
11. Cookies and Analytics
11.1. Kiges Send uses cookies to ensure the operation of authorization and remember User settings.
11.2. Kiges Send may collect aggregated anonymous statistics on service usage to improve the service.
11.3. Disabling cookies may result in the inability to access parts of the service that require authorization.
12. Additional Conditions
12.1. Kiges Send reserves the right to make changes to this document. The User undertakes to independently monitor the current version.
12.2. All questions regarding data processing in Kiges Send should be sent to: info@kiges.cc.
12.3. This document is an integral part of the Public Offer for the provision of services dated September 8, 2026 and the general Kiges Privacy Policy, available at: https://help.kiges.cc/en/documents-rules/kiges-privacy-policy?app=kiges