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Campaign Monitor

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What does Campaign Monitor do?

Campaign Monitor (now part of Marigold) is a US email marketing and automation platform used by brands to send newsletters, transactional emails and marketing journeys.

What Campaign Monitor is

Campaign Monitor is an email marketing and automation platform now part of the Marigold suite. Brands use it to send newsletters, promotional broadcasts, transactional notifications and multi step marketing journeys based on subscriber attributes and behaviour.

What data Campaign Monitor processes

Campaign Monitor stores subscriber email, name, custom fields and segmentation data. It tracks opens through a transparent pixel embedded in HTML messages and clicks through link redirects. When the embedded forms or web tracking pixel are used, Campaign Monitor also reads cookies on the visitor browser.

GDPR and ePrivacy implications

Marketing emails to natural persons require prior, freely given consent under Article 13 of the ePrivacy Directive (the soft opt in for own customers is allowed for similar products). Cookie storage falls under Article 5(3) of the ePrivacy Directive. The CNIL considers granular open and click tracking requires consent for prospective targeting.

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Consent requirements

Use a clear opt in checkbox at signup with separate boxes for newsletters and partner communications. Provide a one click unsubscribe in every email and honour it within 48 hours. Keep records of consent timestamp, source and IP for accountability.

Data transfers

Campaign Monitor is operated from the United States with infrastructure in the US and Australia. Transfers from the EEA require certification under the EU US Data Privacy Framework, Standard Contractual Clauses for Australia and a transfer impact assessment.

Practical compliance steps

Sign the Campaign Monitor Data Processing Agreement, document the integration in your record of processing activities, configure double opt in, gate any web tracking pixel through your CMP, allow subscribers to access and delete their profile and run a DPIA when sending to large lists.

GDPR consent category

Marketing

Websites using Campaign Monitor must obtain user consent under GDPR regulations.

Legal basisArticle 6(1)(a) GDPR (consent) for marketing emails and Article 6(1)(f) GDPR (legitimate interest) for transactional measurement, with Article 5(3) ePrivacy Directive applying to web cookies
Risk levelmedium
Applicable regulationsGDPR, ePrivacy Directive, PECR

DPIA considerations

A DPIA is recommended because Campaign Monitor combines marketing email tracking (opens, clicks), subscriber profiling and US transfers, and may centralise large contact databases.

Sample consent text

I agree to receive marketing emails from this brand sent through Campaign Monitor, including open and click tracking, and to the transfer of my email address to Campaign Monitor (Marigold) servers in the United States.

Technical details

Tracking methodEmail marketing platform that uses tracking pixels and link redirects to measure email opens, clicks and conversions, with optional web tracking through embedded forms
Server locationUnited States
Data transferred outside the EUCampaign Monitor (Marigold) is a US headquartered company with infrastructure in the United States and Australia. Personal data are transferred outside the European Economic Area.

Third-party domains contacted

campaignmonitor.comcreatesend.comcreatesend1.comcmail19.com

Cookies placed

NameTypeDurationPurpose
cm_sessionhttp_cookiesessionSession cookie used by Campaign Monitor embedded forms to keep the form state during submission
CMShttp_cookie1 yearSubscriber tracking cookie set when a visitor arrives via a tracked link, used to attribute conversions to the source email
open_pixeltracking_pixeln/aTransparent 1x1 pixel embedded in HTML emails to record opens. Loaded from the createsend.com domain and not stored as a cookie

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Frequently asked questions

Which cookies does Campaign Monitor set?

Campaign Monitor sets cookies on its embedded forms domain (createsend.com), including a session cookie and a subscriber tracking cookie when a visitor arrives via a link from a tracked email. Open tracking is performed through a transparent pixel embedded in the email body and does not set cookies in the browser.

Is consent required to use Campaign Monitor?

Yes. Marketing emails to natural persons require a clear opt in under Article 13 of the ePrivacy Directive. The soft opt in for similar products to existing customers is allowed in some jurisdictions. Cookies set by embedded forms or web tracking require Article 5(3) consent.

What legal basis applies?

Article 6(1)(a) GDPR (consent) for newsletter and prospect marketing. Article 6(1)(b) GDPR (contract) covers transactional notifications such as order confirmations and account events.

Are user data transferred to the United States?

Yes. Campaign Monitor (Marigold) operates US infrastructure and Australian infrastructure. Transfers require certification under the EU US Data Privacy Framework, Standard Contractual Clauses for Australia and a transfer impact assessment.

Do I need a DPIA for Campaign Monitor?

A DPIA is recommended when sending to large lists, when combining behavioural segmentation with sensitive categories or when integrating Campaign Monitor with other adtech tools.

How do I implement Campaign Monitor in a compliant way?

Use a clear opt in. Send a confirmation email (double opt in) for prospect lists. Provide a one click unsubscribe in every message. Keep consent records. Sign the Data Processing Agreement. Document Campaign Monitor in your record of processing activities.

Are there alternatives to Campaign Monitor?

Brevo (formerly Sendinblue) and Mailjet are EU based alternatives that reduce the third country surface. Mailchimp, HubSpot and Klaviyo are other US alternatives subject to similar GDPR considerations.

How should I update my cookie or privacy policy?

List Campaign Monitor (Marigold) as a processor with the categories of data (email, name, segmentation fields, open and click events, IP), purposes (email marketing, transactional messaging, automation), retention, US transfer mechanism and a direct unsubscribe link.