Legal Specification

Privacy Notice

Last updated: September 4, 2026

This Privacy Notice for Relay Capture ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

  • Visit our website at relaycapture.com or any website of ours that links to this Privacy Notice
  • Purchase dedicated outbound email fleet infrastructure through our checkout process
  • Engage with us in other related ways, including any marketing or events

This Privacy Notice should be read in conjunction with our Terms of Service and our Refund Policy, all of which govern your relationship with Relay Capture.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at sam@relaycapture.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice. You can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so.

Who handles payment data? Paddle.com Market Limited ("Paddle") acts as the Merchant of Record for all transactions. Paddle—not Relay Capture—collects, processes, and stores your payment instrument data (credit card numbers, CVV, billing addresses). Relay Capture never has access to your full payment card details. For details, see Paddle's Privacy Policy.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties, as described below.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us at sam@relaycapture.com. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. MERCHANT OF RECORD & PAYMENT DATA
  4. WHAT LEGAL BASES DO WE RELY ON?
  5. WHEN AND WITH WHOM DO WE SHARE INFO?
  6. HOW LONG DO WE KEEP YOUR INFORMATION?
  7. HOW DO WE KEEP YOUR INFORMATION SAFE?
  8. DO WE COLLECT INFORMATION FROM MINORS?
  9. WHAT ARE YOUR PRIVACY RIGHTS?
  10. CONTROLS FOR DO-NOT-TRACK FEATURES
  11. UNITED STATES SPECIFIC PRIVACY RIGHTS
  12. OTHER REGIONS SPECIFIC PRIVACY RIGHTS
  13. DO WE MAKE UPDATES TO THIS NOTICE?
  14. HOW CAN YOU CONTACT US?
  15. REVIEW, UPDATE, OR DELETE DATA

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • Names (individual or corporate entity)
  • Email addresses
  • Domain names submitted through the Fleet configurator
  • Fleet size and configuration preferences

Sensitive Information. We do not process sensitive information.

Payment Data. All payment data is collected, processed, and stored exclusively by Paddle.com Market Limited ("Paddle"), our Merchant of Record. Paddle handles all billing, transaction processing, regional currency conversion, and global sales tax/VAT compliance. Relay Capture does not collect, store, or have access to your credit card numbers, debit card numbers, CVV/CVC codes, or other payment instrument security data at any time. You may find Paddle's privacy notice here: https://www.paddle.com/legal/privacy.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provision your Fleet infrastructure, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To fulfill orders and provision infrastructure. We process your information to register domains, configure DNS records, provision mailbox inboxes, and deliver the purchased Fleet within the 48-hour SLA.
  • To send administrative information. We may process your information to send you details about your Fleet provisioning status, delivery confirmation, and changes to our terms, conditions, and policies.
  • To enforce acceptable use. We process Fleet usage metadata (sending volume, bounce rates, spam complaint rates) to detect violations of our Acceptable Use Policy (Terms of Service, Section 9). This processing is necessary for our legitimate interest in preventing abuse.
  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. MERCHANT OF RECORD & PAYMENT DATA

In Short: Paddle is the Merchant of Record. They handle all payment processing. We never see your card details.

Paddle.com Market Limited ("Paddle") serves as the Merchant of Record for all transactions placed through the Services. In this capacity, Paddle is the entity responsible for:

  • Collecting and processing payments from your chosen payment instrument (credit card, debit card, PayPal, Google Pay, Apple Pay)
  • PCI DSS compliance for all cardholder data
  • Regional currency conversion
  • Calculating, collecting, and remitting all applicable sales tax, VAT, GST, and other transaction taxes
  • Issuing receipts, invoices, and managing billing-related support
  • Managing chargebacks and payment disputes

Relay Capture receives from Paddle only the following order metadata necessary to fulfill your purchase: your name, email address, the transaction ID, the Fleet configuration (number of domains), and the confirmed payment amount. We do not receive, store, or process your full card number, CVV/CVC, or billing address.

For full details on how Paddle processes your data, see Paddle's Privacy Policy and Paddle's Terms of Service.

4. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including provisioning Fleet infrastructure and delivering services described in our Terms of Service.
  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, such as enforcing our Acceptable Use Policy (Terms of Service, Section 9) and preventing infrastructure abuse.
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as cooperating with law enforcement or regulatory bodies.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with specific third parties.

We may need to share your personal information in the following situations:

  • Merchant of Record (Paddle). As described in Section 3, Paddle processes all payment transactions on our behalf. Your name, email, and order details are shared with Paddle to facilitate payment processing, tax compliance, and invoice generation.
  • Infrastructure Providers. We share limited information (domain names, mailbox configuration data) with third-party infrastructure providers (ICANN-accredited domain registrars, Google Workspace, DNS hosting providers) solely for the purpose of provisioning your purchased Fleet. These providers process this information under their own privacy policies and terms.
  • Law Enforcement & Legal Compliance. We may disclose your information to law enforcement, regulatory authorities, or other third parties if required by applicable law, subpoena, court order, or governmental regulation, or if we believe disclosure is necessary to protect our rights, your safety, or the safety of others, to investigate fraud, or to respond to a government request.
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

For active Fleet orders, we retain your name, email, and order configuration data for the duration of the Fleet's operational lifecycle plus thirty (30) days after termination or expiry for administrative and dispute resolution purposes. Transactional records (order ID, amount paid, timestamp) may be retained for up to seven (7) years to comply with applicable tax and accounting regulations.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at sam@relaycapture.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

How to contact us:
• Online: relaycapture.com
• Email: sam@relaycapture.com

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the details provided above.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

Global Privacy Control: We recognize and honor Global Privacy Control (GPC) signals. If you use a browser or extension that supports GPC, we will treat this as a valid request to opt out of the sale or sharing of your personal information.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have specific rights regarding your personal information.

Categories of Personal Information We Collect

We collect Identifiers (contact details such as name and email address) and Commercial Information (Fleet order configuration and purchase history). We do not collect Protected Classification Characteristics, Biometric Information, Geolocation Data, Audio/Visual Information, or Sensitive Personal Information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months, except as necessary for payment processing by our Merchant of Record, Paddle (see Section 3). We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. These rights include:

  • Right to know whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request the deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to non-discrimination for exercising your rights
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling

To exercise these rights, you can contact us by emailing us at sam@relaycapture.com.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (NZPA). At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us at the details provided below.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the contact details provided below. If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the Information Regulator (South Africa) at enquiries@inforegulator.org.za.

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at sam@relaycapture.com.

For questions specifically related to billing, payments, tax invoices, or chargebacks, please contact Paddle directly through the link provided in your purchase receipt, as Paddle is the Merchant of Record for your transaction (see Section 3 above and our Terms of Service, Section 2).

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. To request to review, update, or delete your personal information, please contact us at sam@relaycapture.com.

Please note that deletion of personal information does not entitle you to a refund of any Engineering Fee or reverse the provisioning of Fleet infrastructure. Refund eligibility is governed exclusively by our Refund Policy.

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