1. Who we are
This policy is issued by Redfluent Pte. Ltd. (UEN 202521822D), a company registered in Singapore ("Redfluent", "we"). It explains how we handle personal data in connection with Redfluent Mail, our hosted business email service, in line with the Personal Data Protection Act 2012 (PDPA). This policy applies to Redfluent Mail only; Redfluent's other products and websites have their own privacy notices.
2. Two different roles
(a) Mail content — we act for our customer. The messages, attachments and folders in a Redfluent Mail mailbox belong to the business that subscribes to the service (our "Customer"). For personal data in that content, the Customer is the organisation responsible under the PDPA, and Redfluent processes it on the Customer's behalf and on its instructions as a data intermediary, under a written Data Processing Addendum. If you are a User of a Customer's mailbox, or someone who corresponds with one, questions about that content (for example, access or correction requests) should go to that Customer; we will help the Customer respond.
(b) Account, billing and support data — we decide. For the personal data we collect to run our relationship with Customers (contacts, billing, support), Redfluent is the responsible organisation and this policy applies in full.
3. What personal data we handle
| Category | Examples | Role |
|---|---|---|
| CategoryMail content | ExamplesMessages, attachments, folders, and the names, email addresses and other personal data they contain | RoleData intermediary |
| CategoryMail metadata and logs | ExamplesSender and recipient addresses, message IDs, timestamps, message sizes, delivery status, spam scores | RoleData intermediary |
| CategoryMailbox account data | ExamplesUsers' names (display names), email addresses, aliases, storage quota and usage, password credentials | RoleData intermediary |
| CategoryConnection and security data | ExamplesIP addresses of devices connecting to the service, sign-in attempts and failures, AI Access keys and connections, AI Access audit log entries, one-time sign-in codes (stored only in hashed form) | RoleData intermediary (and Redfluent, for protecting the service) |
| CategoryCustomer contact data | ExamplesNames, job titles, email addresses and phone numbers of the Customer's contacts | RoleRedfluent |
| CategoryBilling data | ExamplesBilling contact, company details, invoices and payment records | RoleRedfluent |
| CategorySupport communications | ExamplesMessages you send us by email or WhatsApp, and our replies | RoleRedfluent |
We do not ask for, and Customers should not send us, NRIC numbers or other national identification numbers to set up the service.
4. Why we use it
- To provide the service — store, deliver and send mail; let Users sign in; filter spam; run backups; provide AI Access where a Customer has enabled it.
- To keep the service secure — detect and block unauthorised sign-in attempts, apply sending limits, investigate abuse, and protect our sending reputation.
- To support Customers — answer questions and fix problems.
- To bill and manage accounts — invoicing, payment and record-keeping.
- To meet legal obligations — including responding to lawful requests.
We do not sell personal data, we do not use mail content for advertising, and we do not use mail content to train AI models, other than our own spam filter, which may learn statistical patterns from messages only to filter spam within the service. Except for the limited use of our AI operations assistant and the summarising of support messages, both described below, we do not process mail content with any AI model operated by or for Redfluent unless the Customer has agreed in writing to a separately described feature.
AI Access. If a Customer's User connects an AI application of their choice to their mailbox (Redfluent Mail's optional AI Access feature), that application reads mailbox content and, depending on the access level the User chooses, drafts, sends and organises messages and changes mailbox settings (folders, filter rules, automatic replies and sender identities) at the User's direction, and its provider processes that content under the terms the User or Customer has with it. Redfluent does not choose, operate or control that AI application, and it is not our sub-processor. The Customer, as the organisation that decides to use that AI application, is responsible for that processing.
Automated processing by the service. Our systems automatically read mail in order to deliver it, filter spam and make backups. Redfluent staff look at the content of mail only at the Customer's request for support, where necessary to investigate a security incident or abuse, or where required by law.
AI operations assistant. Redfluent uses an AI assistant provided by Anthropic, PBC (United States) to help operate and maintain its systems; in doing so it processes system logs, configuration and monitoring output, which can include mailbox addresses, domain names and message metadata (sender, recipient and time). The assistant does not read customer message content except at the Customer's request or when needed to investigate a security incident; a technical control blocks it from reading the storage that holds customer mail and backups, except through a logged override that may be used only for those two purposes. We currently use an individual Anthropic plan, which does not include a data processing agreement with Anthropic; we have switched off the setting that allows Anthropic to use our conversations with the assistant to train its models.
Support messages. Emails sent to our support and data-protection address (ai@redfluent.com) are held by Zoho (see Section 5) and copied to Redfluent's own server in Singapore, where an AI model running on that server summarises each new message so that our staff are alerted by WhatsApp. Follow-up tasks may be recorded in Redfluent's internal task list (hosted on Cloudflare), and our replies may be sent through Resend (United States). If you send us mail content for support, it is handled in this way.
5. Where personal data is stored and processed
Mailboxes and all backups are stored in Singapore. Some processing happens outside Singapore, as listed below — including, in limited cases, message content: SMTP2GO keeps a sample of sent messages for abuse review, mail sent to our support address is held by Zoho, and our AI operations assistant may see content in the cases described in Section 4.
| Provider / system | What it does | Location of the data |
|---|---|---|
| Provider / systemRedfluent mail server | What it doesPrimary storage of all mailboxes; spam filtering; sending queue | Location of the dataSingapore — a Redfluent-operated server at Redfluent's premises (not a commercial data centre) |
| Provider / systemRedfluent backup storage (network storage device) | What it doesNightly backup copies of all mailboxes; a near-real-time copy of new mail, updated about every 10 minutes | Location of the dataSingapore — Redfluent's premises |
| Provider / systemVultr (The Constant Company, LLC, USA) — gateway server | What it doesReceives all internet connections to the service and passes them to our mail server over an encrypted tunnel; serves the webmail; holds mail temporarily in a queue when our mail server or a recipient is unavailable; stores the encrypted off-site backup copies | Location of the dataSingapore (Vultr Singapore location) |
| Provider / systemVultr — second server | What it doesHolds a copy of the private key used to decrypt the off-site backups, for disaster recovery. No mail content is stored there. | Location of the dataJapan (Tokyo) |
| Provider / systemSMTP2GO (Sand Dune Mail Ltd, New Zealand) | What it doesRelays outgoing mail from Redfluent Mail to recipients' mail servers | Location of the dataMessage passes through SMTP2GO's sending network, which has servers in several countries including Singapore; Redfluent's SMTP2GO account, including account data and delivery records, is hosted in SMTP2GO's United States data centres. |
| Provider / systemCloudflare, Inc. (USA) | What it doesDNS hosting for Customer domains where Redfluent manages DNS; hosting of Redfluent's internal administration console, which handles mailbox account data (names, addresses, quotas) when our staff manage mailboxes; hosting of Redfluent's internal task list (follow-up tasks from support messages). Mail traffic does not pass through Cloudflare. | Location of the dataCloudflare global network (including the United States) |
| Provider / systemZoho Corporation | What it doesRedfluent's own business mailboxes on redfluent.com (including ai@redfluent.com), which receives support and data-protection emails from Customers and individuals; new messages are copied to Redfluent's server in Singapore for summarising (Section 4). Not used for Customer mailboxes. | Location of the dataUnited States (Zoho .com data centre) |
| Provider / systemMeta (WhatsApp) | What it doesSupport conversations with Customers who contact us by WhatsApp; delivery of initial mailbox passwords to the Customer's Authorised Contact; internal alerts to Redfluent staff, including service alerts (which may include a mailbox address or domain name) and summaries of support messages | Location of the dataMeta's global infrastructure |
| Provider / systemResend (Plus Five Five, Inc., USA) | What it doesSending Redfluent's replies from its support address | Location of the dataUnited States |
| Provider / systemntfy.sh | What it doesService-status alerts from our gateway to Redfluent staff. The alerts contain operational information only (times, queue counts and error messages) and no personal data. | Location of the dataUnited States (the ntfy.sh service resolves to DigitalOcean servers in the United States, checked 16 October 2026) |
| Provider / systemAnthropic, PBC (USA) | What it doesAI assistant used by Redfluent to operate and maintain its systems (see Section 4). It processes system logs, configuration and monitoring output; it does not read customer message content except at the Customer's request or during a security incident. Used on an individual plan without a data processing agreement; model training switched off. | Location of the dataUnited States |
Outgoing mail has been relayed by SMTP2GO since 16 October 2026. During an earlier pilot period, Amazon Web Services (Amazon SES, Singapore region) was configured as the outgoing mail relay; it is no longer used.
Transfers outside Singapore. Section 26 of the PDPA and Part 3 of the Personal Data Protection Regulations 2021 require that a recipient outside Singapore is bound by legally enforceable obligations to protect personal data to a standard at least comparable to the PDPA. Our position for each provider is:
- Cloudflare holds Global CBPR and Global PRP certifications, which those Regulations recognise.
- Resend's data processing addendum forms part of its terms of service and applies to our account; Resend processes data in the United States.
- Vultr: our data processing agreement with Vultr is in place (signed 22 October 2026).
- SMTP2GO and Zoho: our data processing agreements with them are being executed (October 2026).
- Anthropic: we use an individual plan, which does not include a data processing agreement (see Section 4).
- WhatsApp: used under WhatsApp's own terms; we have no separate data processing agreement with WhatsApp.
- ntfy.sh receives no personal data.
6. How long we keep it
| Data | Retention |
|---|---|
| DataMail content and folders | RetentionKept until deleted by the User or Customer, or until the Customer's subscription ends (see below). |
| DataDeleted mail | RetentionRemoved from the live mailbox when deleted (and, if moved to Trash first, when Trash is emptied). Copies remain in our nightly backups for up to 14 days, in the encrypted off-site copies (the 7 most recent daily copies) for up to 7 days, and in our near-real-time copy for up to 30 days (see the next rows). |
| DataNightly backups | RetentionEach nightly backup is kept for 14 days, then deleted. |
| DataNear-real-time copy | RetentionNew mail is copied to our backup storage in Singapore about every 10 minutes. A message that is removed from a mailbox is removed from this copy within 30 days (an automated job checks every day). The rest of the copy is deleted when the subscription ends (last row of this table). |
| DataEncrypted off-site copies | RetentionThe 7 most recent daily copies are kept; older copies are deleted automatically. |
| DataMail queued on our gateway | RetentionMail waiting for our mail server (during an outage) or for a recipient's server is retried for up to 14 days; after that, undeliverable outgoing mail is returned to the sender. |
| DataSMTP2GO delivery records | RetentionMessage headers and delivery data are kept by SMTP2GO for up to 35 days. SMTP2GO's privacy policy (last updated 23 July 2023) also states that it keeps one in every thousand sent emails for review for 35 days. |
| DataServer and security logs that contain personal data (IP addresses, email addresses) | Retention90 days, then deleted. |
| DataAI Access audit log | RetentionUp to 180 days, then deleted. |
| DataAI Access draft records (which drafts a connected AI has created) | Retention90 days, then deleted. |
| DataRecords of revoked AI Access keys and connections | Retention400 days after revocation, then deleted. |
| DataAdministrator audit trail (records of administration actions Redfluent staff take on mailboxes) | Retention1 year, then deleted. |
| DataDeletion records (proof that data was deleted, including the deleted mailbox address) | Retention2 years, then deleted. |
| DataAfter the subscription ends | RetentionMailboxes remain available for 30 days for export, are deleted from the live service and from the near-real-time copy within 30 days after that, and disappear from nightly backups and encrypted off-site copies within a further 14 days. |
| DataBilling and accounting records | RetentionFor the periods required by section 199 of the Companies Act 1967 and section 67 of the Income Tax Act 1947 (5 years, counted from the end of the relevant financial year or year of assessment), then deleted; longer only if needed for an ongoing dispute. |
| DataCustomer contact and support records | RetentionAs long as the Customer relationship lasts, then up to 5 years, for handling follow-up questions and legal claims. |
| DataMail content sent to us for support, and summaries of support messages | RetentionKept with the support records (previous row). |
| DataAI operations assistant records | RetentionUp to 90 days on Redfluent's systems; Anthropic keeps conversation data under its own terms for individual plans. |
7. How we protect it
The measures we currently use include:
- Encrypted connections — webmail, IMAP and SMTP submission use TLS with publicly trusted, automatically renewed certificates.
- No direct internet exposure of the mail server — all internet connections end at our Singapore gateway and reach the mail server only through an authenticated, encrypted tunnel; the gateway exposes only the ports needed for email, webmail and our own secure administration (SSH).
- Isolation — the mail server software runs under its own restricted system account inside an operating-system sandbox that blocks access to other data on the machine and limits its network access. System-generated messages (bounce notices and delivery reports) use Redfluent's neutral system domain
mx1.redfluent.com, so they do not reveal other customers' domains. - Restricted administration — administrator credentials work only from the server itself; our administration console requires Redfluent staff sign-in and signed requests; the public webmail exposes only the mail functions.
- Sign-in protection — repeated failed sign-ins from the same address are blocked, with additional rate limits on AI Access sign-in; AI Access authorisation uses one-time codes delivered to the mailbox rather than asking for the password.
- Sending limits per mailbox to contain the damage from a compromised account.
- Backups — nightly backups with checksums; a near-real-time copy of new mail about every 10 minutes, with an alert to our staff if it falls more than 25 minutes behind; an off-site copy encrypted with public-key encryption, whose decryption key is not stored on the server holding the copy; an automated test restore at least weekly.
- Monitoring — automated checks of the service every 5 minutes, with an independent watchdog on the gateway that alerts our staff if the mail server becomes unreachable.
- Sender authentication — SPF, DKIM and DMARC for Customer domains; SPF checks on mail received while our mail server is unavailable.
- Not yet in place — encryption at rest of the mail server and of our local backup storage (being implemented), and two-factor sign-in (on our roadmap).
No system is completely secure. If a data breach occurs, we will act in line with Section 9.
8. Your choices and rights
- Users and correspondents of a Customer's mailbox: please contact the Customer (your employer or the business you wrote to). We will assist the Customer with access and correction requests relating to mail content.
- Customer contacts: you may ask us for access to, or correction of, personal data we hold about you, or withdraw consent for any processing based on consent, by writing to our Data Protection Officer. We will respond within the time required by the PDPA. Withdrawing consent may mean we cannot continue to provide the service.
9. Data breaches
If we become aware of a data breach affecting personal data in Customer mailboxes, we will notify the affected Customer without undue delay so that it can assess the breach and, where required, notify the Personal Data Protection Commission and affected individuals (the Data Processing Addendum sets out our commitments). For personal data for which Redfluent is the responsible organisation, we will assess and notify as required by Part 6A of the PDPA.
10. Contact — Data Protection Officer
For questions about this policy or about your personal data, contact our Data Protection Officer:
- Data Protection Officer: Gao Chenglong, Director
- Email: ai@redfluent.com
- Address: Redfluent Pte. Ltd., 28 Senang Crescent, #03-06 BizHub28, Singapore 416601
If you are not satisfied with our response, you may contact the Personal Data Protection Commission of Singapore (pdpc.gov.sg).
11. Changes
We may update this policy. We will post the updated version with a new date, and notify Customers by email of material changes.