Privacy – AnyMail

AnyMail, brought to you by Koltir LLC., is a mobile application (“Application”) designed to transform the way you manage your emails. Offering an array of functionalities and features, AnyMail aims to streamline your email interaction directly through your mobile device. At the core of our service delivery is a sophisticated backend infrastructure, affectionately known as our “Cloud,” which plays a pivotal role in powering the Application. This Privacy Policy is dedicated to explaining our practices regarding the collection, use, protection, and storage of your personal information, underscoring our unwavering commitment to safeguarding your privacy and security. Should there be any terms within this document that are unfamiliar, they are defined in accordance with our Terms of Service. We advise against downloading the Application or utilizing any of our Services, including the Website, if you find any part of our Terms of Service or this Privacy Policy unacceptable.

This Privacy Policy contains the following information.

What information do we collect?
How do we use the information we collect?
Whether and how the information is shared
Communications
Your rights as a data subject
Data Retention
Security
Transfers of information across boundaries
Children
Updates to Privacy Policy
Contact us

1. What Information do we collect?

1.1 Information that you provide to us:

When you set up your account after downloading our app, you share some details with us. These include the email addresses you want to connect with our app, and optionally, your name or a nickname you like, as well as a photo if you wish to use one for your profile. If you decide to upload a different photo later, just make sure you’re allowed to use that image.
If you reach out to us for help, we’ll collect and keep any information you provide. This might include your name, email addresses, and details about your phone or tablet, like what kind it is and its operating system. We’ll also note how you’ve been using our app.
Our app offers optional Sync Services. If you choose to use them, they let you sync things like app settings, contacts, and tasks. They’re stored safely in our cloud. For this service, we might ask for your phone number to send a verification code via text message.
When you make a new group within our app, we store details like the group’s name, its picture, any notes you’ve made, and the email addresses of all members in the group on our cloud.
You also have the option to tell us about any emails you find incorrect, safe, or harmful by reporting them. We analyze and categorize these reports in our cloud. Additionally, you can share email links by uploading them to a cloud-sharing service.

Are you obligated to provide us with this private data?

You are not obligated to provide us with any of the above information.

However, we will not be able to provide you with the Application and Services or part of them, as applicable, if you do not agree, or withdraw your consent, or request to object (all as detailed under section 5 with respect to your rights) to our processing of these data items.

1.2 Information that we collect from third parties:

Analytics for Web and Mobile

We use web and mobile analytics software to measure traffic and usage patterns and to help us better understand the functionality of the Application on your device or general information regarding how users use the Application. When using our Website, the web analytic tools collect information sent by your browser, including the pages you visit and other information that assists us in improving the Website. The Application on your device may collect information such as what kind of device you are using, how often you use the Application, the way you use the Application (what functions are used for example) performance data (technical issues concerning crashes, operation metrics, memory consumption and that type of information), and which store the Application was downloaded from and send this information Cloud. We use this information only to administer, improve, monitor and analyze the use of the Application.

Cookie Information

We use cookies and similar technologies in our Website that help us collect information. The Website may also include cookies and similar tracking technologies of third parties such as Google Analytics which may collect information about you via the Website. For more details please see our Cookie Policy.

Non-Hardware Identifiers

When you use AnyMail on a mobile device, like a smartphone or tablet, our app might generate and store unique codes, known as Instance ID or GUID. These codes are special to AnyMail and help the app work on your device. We promise not to collect any unique hardware identifiers like UDID, SSAID (Android ID), or IMEI, meaning we don’t track the specific physical device you use.

The unique codes our app creates stay on your device and in our cloud. They help you log into the app more quickly and make moving around within the app smoother. However, some parts of AnyMail might not work as intended if these codes are deleted or blocked.

We regularly and safely check that your app version matches the latest one available on our cloud to suggest updates if necessary. Additionally, we verify your subscription and special features in a secure manner to ensure you get access to everything you’re entitled to in the app.

2. How do we use the information we collect?

We use all of the above information to operate, maintain, and provide to you with Application features and functionality.
We use the email address to establish the accounts you wish to use within the Application, and let you manage your email account through the Application.
We use your display name to display the different account names as you assigned them.
We use your information to send you emails with regards to your operation of the Application (e.g., account verification, notify you of changes/updates to features, credentials change, technical and security notices), as well as to send you marketing communications (please see more details regarding this under chapter 4, “Communications”).
We may use the above information to respond to your requests and messages, including with respect to your rights as data subject, as well as to initiate contact with you on issues related to the Services or support and maintenance issues.
To prevent, detect and fight fraud or other illegal or unauthorized activities.
We use anonymized, aggregate data, in order to gain insight on how you and other users use the Services and try and improve our Service, as well as to plan our marketing and advertisements.
Whenever we share data with external parties, we first remove personal identifiers to prevent the data from being traced back to you. This de-identification process includes the elimination of email addresses, names, and physical addresses. The anonymized data is then used exclusively for generating aggregate research insights. We explicitly prohibit third parties from using this data to track, market to, or attempt to re-identify individuals.
To ensure legal compliance – from our side (to legal requirements that apply to us and to our obligations under the Terms of Use) and from your side (Compliance with laws applicable to you and with the Terms of Use).

Our Legal Bases for Processing

The following are the legal bases under which we process your information in the manners specified above:

Performance of a contract to which AnyMail and you, the data subject, are parties. Many of the uses described above are actions that involve processing of your information in order to meet our undertakings to you and respond to your requests and indications within the Services.
Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, and we process information for administrative, fraud detection and other legal purposes.
Consent – some of the information you provide is based on your agreement and will to provide it. In addition, we may ask you from time to time, through the Service interface, to provide your consent for specific uses.

3. Whether and How Your Information is Shared?

The privacy and security of your information are paramount. We commit to not sharing, renting, or selling your information to any third parties outside of AnyMail and its affiliated entities (this includes subsidiaries and affiliates) without your explicit consent, except under the circumstances outlined below:

Service Providers: To enhance the provision of our Services, we collaborate with external business partners, such as Amazon AWS and Google for cloud services, as well as analytics. These partners are granted access to your information on a need-to-know basis, strictly governed by our directives, to facilitate the Services you receive.
Compliance with the Law: We may disclose your information if we believe it’s necessary in order to comply with the law, such as to comply with a subpoena, regulation or legal request, respond to a government request, to address fraud or security issues, to protect the safety of any person, to enforce our agreements with you; to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing or to protect our own rights or property. If you are located in the EU, we may only do so based on legal requirements specified above of EU authorities. This includes sharing such information with our legal counsels.
In instances where we share information with external entities, we ensure that all data is cleansed of personal identifiers. This means we eliminate all details like email addresses, names, and physical addresses that could trace back to you specifically.
This sanitized data is utilized solely for generating combined research findings. We strictly forbid any third parties from using this data to follow, advertise to, or attempt to personally identify any individual.
Business Transfers: In the event of significant business changes, such as bankruptcy, mergers, acquisitions, reorganization, or asset sales, your information may be transferred as part of the transaction. This includes passing your information to a successor entity or relevant legal authorities, as well as to our legal, financial, and government advisors involved in the transaction.

Links to Third Party Websites

We may place links on the Website. When you click on a link to a third party website from our website, you will be redirected to such third party site, and your activity and use on the linked website is governed by that website’s terms of use, privacy policies and other policies, not by those of AnyMail. We encourage you to review their privacy and use policies.

4. Communications

If you are located in the EU, the following shall apply only if you marked your consent to receive such communications.

If you are located in the US or elsewhere in the world, the following shall apply for as long as you have not opted-out of this activity:

We may use the information we collect or receive to communicate with you directly. For example, you may receive emails from us containing company updates, promotions, marketing, or special offers. We do this to be sure our communications and our products get better over time. If you’d rather not receive these emails, you may opt-out of receiving them by following the unsubscribe link located at the bottom of each communication or by emailing us at privacy@anymailapp.com. Even after you opt-out from receiving communications messages from us, you will continue to receive administrative messages from us regarding our services (such as requirement to upgrade the Application).

5. Your rights as a data subject

You may access and update your information by visiting your account settings within the Application or by emailing us at the email address listed below.
In case our processing is based on your consent, you have the right to withdraw your consent at any time, by contacting us via email.
You have the right to object to the processing of your personal data for direct marketing purposes at any time.
You have the right to object to our processing of your personal data if processing is based on our legitimate interests.
You have the right of portability with respect to your personal data, in case it is processed by automatic means, and if processing is based on your consent.
You have the right to request that we erase all of your personal data that we keep, without undue delay, unless processing is necessary as further detailed under “Data Retention”
In certain countries, you have a right to lodge a complaint with the appropriate supervisory authority in charge of data protection, in case you think that we are breaching any of your right relating to your personal data. If you are located in the EEA, The complaint may be lodged at the country which is your place of residence, your place of work or place of the alleged infringement.

If you have questions on how to exercise your rights, please contact privacy@anymailapp.com We will respond to your access request without undue delay, or within 30 days at the latest (as the law may require)

6. Data Retention

We will retain your information for as long as we need it for legitimate business purposes (as laid out in chapter (“How we use your information”) and as permitted by applicable law. Once no longer used as stated herein, it will be either deleted or completely de-identified in a manner that does not allow re-identification thereof.

We will also retain and use your information in the following instances:

Keep evidence to our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years).
If there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved.
The information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

7. Security

At AnyMail, your security is our top priority. We adhere to the best industry practices to protect all your data. For instance, we use secure socket layer technology (SSL) to encrypt sensitive information during transmission, as well as when sending and receiving emails. However, it’s important to understand that no electronic transmission or storage method is completely infallible. While we strive for total security, we cannot offer an absolute guarantee. Additionally, AnyMail does not hold responsibility for the security practices or functionalities of third-party entities. If you have any concerns or questions regarding our security measures, please do not hesitate to get in touch with us at privacy@anymailapp.com.

8. Transfer of PII across boundaries

Your information collected through AnyMail may be stored and processed in the United States or any other countries in which we or our affiliates operate. To provide the service to you, we may transfer personal information to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which we or our parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

Our legal basis for performing such transfer across boundaries are:

Model Clauses. With some of our processors, we use standard contract clauses, that are binding standards of processing of personal data committed to contractually by third parties processing information for us and on our behalf, approved by the European Commission.
In the absence of Model Clauses, Your consent. By using the Service, you agree and understand that your information may be transferred from the EEA or other countries in which you may be using the Services, to other countries outside your own location (including outside the EEA), and specifically to the USA. You agree to such transfer, and you understand that data processed in the USA is subject to different data protection laws, which may sometimes grant lesser degree of protection that the privacy laws and regulations applicable within the EEA for example.

9. Children

Our Services are not directed to persons under 13. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to remove such information and terminate the child’s account. If you learn that your child has provided us with personal information without your consent, please contact us at privacy@anymailapp.com.

10. Updates to Privacy Policy

We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and to keep up with any new compliance requirements. When we change the policy in a material manner, we will update the ‘last modified’ date at the bottom of this page, post a notice to the Website or Application and/or reach out to you via email or otherwise. The most up-to-date version can always be found at anymailapp.com/privacy

11. Contact Us

If you have any questions, please send your inquiries to privacy@anymailapp.com support via Privacy Policy. We will aim to respond to you within 30 days from receipt of the request.

Last Modified: May 1st, 2019