1. Who we are
1.1. We are CRAIGPARK LIMITED located at Trident Chambers, P.O. Box 146, Road Town, Tortola, British Virgin Islands.
1.2. This Privacy Policy sets out how we collect and use your personal information when you use our mail services ("Services") offered by CRAIGPARK LIMITED and the choices available to you in connection with our use of your personal information (the Privacy Policy).
2. This Privacy Policy
2.1 By making available the Services we, acting reasonably and in good faith, believe that you:
(a) have all necessary rights to register on and use the Services;
(b) provide true information about yourself to the extent necessary for use of the Services;
(c) understand that by the posting your personal information you have manifestly made this information public, and this information may become available to other Service users, be copied and disseminated by them;
(d) understand that some types of information transferred by you to other Service users cannot be deleted by you or us;
(e) are aware of and accept this Privacy Policy.
2.2. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.
3. Information we collect about you
3.1 In order to implement the agreement between you and us, and provide you with access to the use of the Services, we will improve, develop and implement new features to our Services, and enhance the available Services functionality. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data (hereinafter “processing”). We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.
3.2. We set out in more detail the information we collect when you use our Services, why we collect and process it and the legal bases below.
|
Information Collected |
Purpose |
Legal Basis |
|
| 1 |
Data you provide for registering in the Services such as you first and last name, avatar picture, chosen mailbox name and mobile phone number |
We use this information in order to manage and administer the Services provided to you. |
Legitimate interests |
| 2 |
Data you provide when you edit application settings, such as changing your first, last names and avatar pictures for the email accounts, changing mobile phone number, add external mailbox accounts to the application, providing access to contacts from your phonebook, list of your email contacts. incoming and outgoing emails, sent and received by your using the application and Services. |
We use this information in order to provide our Services to you, to manage and administer Services. |
Legitimate interests |
| 3 |
Additional data received when you use the application and Services or send as part of you problem reports and support requests, including information regarding technical devices, technical interaction with the Services (your device name, host IP-address, your operating system, type of a browser, geographic position, the Internet provider), mobile application logs. |
We use your data for internal review in order to constantly improve the content of our Services and web pages, optimizing your user experience, to understand any errors you may encounter when using the Services, to notify you of changes to the Services and to personalise the use of our Services. |
Legitimate Interests |
| 4 |
Information that is created by you while placing requests to our Services support. |
We use this information in order to verify your identity and to fullfil your support request. |
Legitimate interests |
| 5 |
Data obtained via third parties, including your sent and received emails, when you connect your external emails accounts (e.g. Yahoo, Hotmail etc.) to the application. |
We import this information into the application. |
Legitimate interests |
3.3. Our legitimate interests include (1) maintaining and administrating the Services; (2) providing the Services to you; (3) improving the Services; (4) processing of the data that was manifestly made public by you; (5) ensuring your account is adequately protected; and (6) compliance with any contractual, legal or regulatory obligations under any applicable law.
3.4. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defence or exercise of legal claims.
We will not delete personal information if it is relevant to an investigation or a dispute.
It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.
3.5. You may withdraw your consent the processing of your phonebook contacts by amending your phone settings.
3.6. Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to post this information or share this data when using the Services.
Once you have provided this data it will be accessible by other Service users and it becomes difficult for us to remove this data.
3.7. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Services, you may not be able to access the Services.
3.8. If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.
4. Data sharing
4.1. We may share your data with our affiliates. Sometimes we may also need to share your data with a third party in order to provide our Services to you or to administer the Services.
4.2. CRAIGPARK LIMITED, our affiliates or our selected third party partners with our permission, such as participants of the Facebook Audience Network (https://m.facebook.com/ads/ad_choices), Google AdWords , using their own ad servers, can show advertisements to you.
5. Privacy Settings
5.1. You may provide and withdraw you consent to receiving latest news about our products that we think you may be interested in via email and SMS by changing respective option in the "Privacy settings" section of the application settings.
5.2. You can manage your ad prefernces for Facebook Audiences Network via Facebook AdChoices on your Facebook account section of the application settings.
5.3. The Services may contain links to sites or products operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party services and you should ensure you review the relevant third party's privacy statement which will govern your data privacy rights.
5.4. We bear no liability for the actions of third parties which, as the result of your use of the internet or the Services, obtain access to your information in accordance with the confidentiality level selected by you.
5.5. We bear no liability for the consequences of use of the information which, due to the Services nature, is available to any internet user. We ask you to take a responsible approach to the scope of their information posted on the Site.
6. International Transfers
6.1. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in Russia.
6.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standartd Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.
7. Retention Periods
7.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.
8. Your Rights
8.1. You have the following rights, in certain circumstances, in relation to your personal information:
(a) Right to access your personal information.
(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
(c) Right to restrict the use of your personal information.
(d) Right to request that your personal information is erased.
(e) Right to object to processing of your personal information.
(f) Right to data portability (in certain specific circumstances).
(g) Right not to be subject to an automated decision.
(h) Right to lodge a complaint with a supervisory authority.
8.2. You also have a right to independently remove personal information on your account and make changes and corrections to your information, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you.
8.3. If you would like to exercise these rights, please contact Support Service via "Support" section of the application or send your request to us, in writing to Trident Chambers, P.O. Box 146, Road Town, Tortola, British Virgin Islands. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.
9. Security Measures
9.1. We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.
9.2. Access to the Service is authorized using your mobile phone. Each time you login into the Service, one-time code is sent to the mobile phone number you have provided upon registering in the Service.
10. Changes to this Policy
10.1.From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.
11. Contact Us
11.1.If you have any questions, please send your inquiries to Service support via "Support" section of the application or in writing to Trident Chambers, P.O. Box 146, Road Town, Tortola, British Virgin Islands. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.
11.2.All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.
11.3.The e-mail address of our DPO is dpo@mailapps.me.