Effective date: July 27, 2021
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data. Please refer to our GDPR Privacy Notice for EU Residents for more details.
Categories of Personal Data We Collect
Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
Categories of Personal Data
The chart in this section details the categories of Personal Data that we collect and have collected over the past 12 months:
|1. Category of Personal Data||2. Personal Data We Collect||3. Source(s) of Personal Data||4. Categories of Third Parties With Whom We Share this Personal Data for a Business Purpose:|
|Personal identifiers||IP Address||Service Providers|
|Commercial information||You (as described in subsection “Information Collected from Connected Email” below)||Service Providers|
In addition to the categories of Personal Data listed above, we also collect and process information, which may include Personal Data, from (i) email accounts you decide to connect with the MailTime App (as described in the subsection “Information Collected from Connected Email Accounts” below), and (ii) Cookies (as defined below, and further explained in the subsection “Information Collected Automatically”).
Information Collected from Connected Email Accounts
The information we receive will depend on the policies and your account settings with the third party services.
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We use the following types of Cookies:
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
How We Use Your Personal Data
We process Personal Data to operate, improve, understand and personalize our Services. We use Personal Data for the following purposes:
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive communications from us, please indicate your preference by emailing us at [email protected].
Information that’s been de-identified
For the purpose of this subsection on “Information that’s been de-identified”, we use Commercial Messages from your Connected Email Account for the de-identification and/or aggregation purposes as explained below, but we do not use any Non-Commercial Messages in doing so. We only access and process Non-Commercial Messages in your Connected Email Accounts as authorized by you to convert such email messages to text messages, to enable you to enjoy the functionalities and services provided by our MailTime App, and to provide the MailTime App Services to you.
We use information from Commercial Messages collected through your Connected Email Accounts, such as date , merchant, price, or other commercial or transactional information, to create de-identified or aggregated data so that you are not identified as an individual (the “De-identified or Aggregated Data”). We use the De-identified or Aggregated Data to develop alternative data products and for our business purposes, and provide such De-identified or Aggregated Data to subscribers of MAI Product (as further explained below).
MAI Products: We use the De-identified or Aggregated Data to create consumer insights, and to develop analytics and reports for market trends, industry development, and other business intelligence. For example, we scan and identify purchase receipts from Commercial Messages collected from your Connected Email Accounts, aggregate such de-identified information with other de-identified information from our other users of MailTime App to create De-identified or Aggregated Data, which will become part of the database or data feeds we provide to subscribers of the MAI Products. We share the De-identified or Aggregated Data with users of the MAI Products and our other partners for their research, development, or other commercial purposes.
In all cases where we provide De-identified or Aggregated Data to third party partners, we adopt the following protections:
OPT OUT: You may opt out of sharing information from your Commercial Messages for our use to create De-identified or Aggregated Data at any time by (i) going to https://mailtime.com/optout/optout.html , or (ii) changing the settings in the MailTime App (under “Legal & Privacy). You can continue to use the MailTime App services with no degradation to your experience.
About Gmail Users:
The way we can use the information we receive from your connected email accounts is also subject to the policies imposed by your email service providers and your account settings with them. As you may know, Google recently implemented an updated Google API Services: User Data Policy (https://developers.google.com/terms/api-services-user-data-policy, the “Google API Policy”), which restricts the use of data obtained from certain restricted Gmail APIs, as well as data aggregated, anonymized, or derived from them. In order to comply with the Google Policy, we decide not to include any data that we obtained from those restricted Gmail APIs in our big data products (including MAI). In order to comply with the Google Policy, we will only use the data that we obtained from the restricted Gmail APIs for the specific “Limited Uses” as permitted by the Google Policy. Our use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. These restrictions do not apply if you have used the 2-step verification process to create an App password for the Services using your Google account. If you have any questions, or would like to learn more about this, please feel free to reach out at [email protected].
How We Share Your Personal Data
Categories of Third Parties with Whom We Share Personal Data
We disclose your Personal Data as indicated in the chart above to the following categories of service providers and other parties:
Disclosures of Personal Data for a Business Purpose
We disclose your Personal Data to service providers and other parties for the following business purposes:
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. All Personal Information is transferred via Transport Layer Security (TLS) technology and stored encrypted at rest using AES-256 encryption. All Personal Information stored on our Services is hosted on Amazon Web Services (AWS) and Microsoft Azure, which undergo various third-party independent audits on a regular basis, covering compliance controls for its data centers, infrastructure, and operations. This includes SOC 2 certification and ISO 27001 certification.
You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Personal Data of Children
California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Please note that uninstalling the MailTime application from your mobile device does not delete your Personal Information we hold in our records. If you want to disassociate your email accounts from our Services and delete the Personal Information, you should submit a Valid Request for deletion. Some information may remain in our records after the deletion, but only in a way that would not identify you personally. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
Exercising Your Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Personal Data Sales Opt-Out and Opt-In
We will not sell your Personal Data, and have not done so over the last 12 months.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Other State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at [email protected].
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at [email protected] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.