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Marketing

SendGrid

Marketing

SendGrid (owned by Twilio) is a US-based cloud email delivery service used for transactional and marketing emails. Developers use SendGrid's API or SMTP relay to send password resets, order confirmations, newsletters, and automated campaigns at scale. For GDPR compliance, the key distinctions are: transactional emails may rely on legitimate interest or contract performance, while marketing emails require consent. All data is processed in the US requiring SCCs.

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Overview

What does SendGrid do?

What is SendGrid?

SendGrid (owned by Twilio since 2019) is a cloud-based email delivery service providing an API and SMTP relay for sending transactional and marketing emails at scale. It is one of the most widely used email infrastructure platforms, processing billions of emails monthly for developers, SaaS products, e-commerce platforms, and enterprise marketing teams. SendGrid provides email analytics (opens, clicks, bounces, spam reports), email validation, and marketing campaign tools.

Transactional vs marketing email: the key GDPR distinction

SendGrid is used for both transactional emails (password resets, order confirmations, account alerts) and marketing emails (newsletters, promotional campaigns). The GDPR legal basis differs: transactional emails may rely on contract performance or legitimate interest, while marketing emails require explicit consent from EU recipients. Configure your SendGrid integration to ensure marketing and transactional emails are clearly separated and routed through appropriate verification flows.

Email tracking pixels under GDPR

SendGrid's open tracking (1x1 pixel image) and click tracking (link wrapping through SendGrid's servers) constitute personal data processing by linking engagement to individual email addresses. For marketing emails, this tracking is justified by the same consent as the email itself. For transactional emails, tracking should be disclosed in your privacy policy. Consider disabling open tracking for privacy-conscious implementations: it is increasingly blocked by email clients anyway.

US transfers and DPA

All SendGrid data is processed in the US. SCCs are required. Sign the Twilio/SendGrid Data Processing Addendum available from the Twilio Trust Hub. Note that as a Twilio company, the DPA covers SendGrid under the broader Twilio DPA framework.

Practical compliance steps

Sign the Twilio DPA covering SendGrid. Separate transactional and marketing email streams. Obtain and record valid consent for marketing email recipients before adding to SendGrid. Disclose email tracking in your privacy policy. Implement unsubscribe handling with list unsubscribe headers. Use SendGrid's suppression list management to honour opt-outs. Process erasure requests by removing contacts from SendGrid's contact database.

Compliance

SendGrid and the GDPR

SendGrid is classified as “Marketing”. On a site that targets European visitors, it must only load after the visitor consents, and it must be listed in your cookie policy.

Legal basis
Consent (Art. 6(1)(a) GDPR) for marketing emails to EU contacts. Legitimate interest (Art. 6(1)(f)) for transactional emails triggered by user actions (password resets, order confirmations). Contract performance (Art. 6(1)(b)) for service-essential notifications. Separate consent required for email open and click tracking analytics.
Risk level
medium
Applicable regulations
GDPR, ePrivacy Directive, SCCs for US data transfers

Impact assessment (DPIA)

A DPIA is generally not required for standard SendGrid transactional email use. It may become relevant for large-scale email marketing programmes combining SendGrid with extensive behavioural tracking and personalisation at individual level.

Sample text for your banner

Emails from this service are delivered via SendGrid (Twilio), a US email delivery platform. Transactional emails (account notifications, order confirmations) are sent based on your service relationship. Marketing emails are sent only with your consent. See our privacy policy for details.
Cookies and trackers

What SendGrid sets and contacts

Tracking method
Transactional and marketing email API, email open and click tracking pixels, SMTP relay, email analytics dashboard
Server location
United States (SendGrid/Twilio is a US company with US infrastructure)
Cookieless mode available
Yes
Data transferred outside the EU
SendGrid (owned by Twilio) is a US-based email delivery platform. All email processing, delivery infrastructure, and analytics data are processed on US infrastructure. EU personal data transfers require Standard Contractual Clauses. SendGrid provides a GDPR-compliant DPA.

Cookies set (1)

NameTypeDurationPurpose
__sg_persistent1 yearSendGrid email engagement tracking cookie linking email clicks to recipient identities for campaign analytics

Third-party domains contacted (3)

  • sendgrid.com
  • sendgrid.net
  • api.sendgrid.com
Questions

Frequently asked questions about SendGrid

Can't find your question? Write to us, we answer fast.

Does SendGrid require GDPR consent for email marketing?

Yes. Marketing emails sent via SendGrid to EU contacts require valid consent: freely given, specific, informed, unambiguous. Ensure recipients opted in through a GDPR-compliant process before adding them to SendGrid marketing lists.

Does SendGrid require consent for transactional emails?

Generally no. Transactional emails triggered by user actions (password resets, order confirmations, account alerts) may rely on contract performance or legitimate interest. Disclose SendGrid in your privacy policy as the email delivery processor.

Does SendGrid transfer EU data outside the EU?

Yes. All SendGrid processing occurs on US infrastructure. SCCs are required. Sign the Twilio Data Processing Addendum covering SendGrid, available from the Twilio Trust Hub at twilio.com/en-us/legal/privacy/gdpr.

Does SendGrid email tracking require consent?

Open tracking (pixel image) and click tracking (link wrapping) for marketing emails are covered by the marketing consent. For transactional emails, tracking should be disclosed in your privacy policy. Consider disabling open tracking as it is increasingly blocked by email clients.

How do I implement unsubscribe handling in SendGrid?

Use SendGrid's Unsubscribe Group feature to manage subscription preferences. Include a List-Unsubscribe header in all marketing emails. Process unsubscribe requests from SendGrid webhooks and update your contact database to honour opt-outs within 10 business days.

What legal basis applies to SendGrid?

Contract performance for transactional emails. Legitimate interest for service notifications. Consent for marketing emails and newsletters. The legal basis follows the purpose of the email, not the delivery platform.

How do I handle erasure requests for SendGrid contacts?

Delete the contact from SendGrid Marketing Campaigns contact lists. Add the email address to SendGrid's global suppression list to prevent future emails. For transactional email logs, use the SendGrid API to delete email activity records. Respond within 30 days.

Are there EU-based alternatives to SendGrid?

Brevo (formerly Sendinblue, France) provides transactional email API and marketing email with EU data residency. Mailjet (France) provides a comparable transactional and marketing email API with EU infrastructure. Both are strong GDPR-compliant SendGrid alternatives.

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