EmailMassivo

Privacy policy

This Privacy Policy ("Policy", "Privacy Policy") forms an integral part of the License Agreement with the User and defines the rules for processing personal data that Compubyte Limited (hereinafter referred to as "EmailMassivo", "we") may collect about users ("User" or "you") in connection with the User's use of the EmailMassivo service (the "Service"). In particular, it determines the categories of data collected, the ways and methods of data collection, the purposes and measures for ensuring the protection of data, as well as the User's rights in relation to his/her Personal Data.

By this Policy the User gives us consent to the processing of his/her Personal Data under the terms of this Privacy Policy. The User's actions aimed at using the Service constitute unconditional acceptance of this Policy and of the terms of processing his/her Personal Data specified herein. We strongly urge you to read this Policy and make sure that you fully understand and agree with it before you start using our Service. If you have not read this Policy in full, do not understand something or do not accept the terms of this Privacy Policy, you must immediately stop using the Service.

The User warrants that, in accordance with the User's jurisdiction, he/she has reached the age that allows him/her to independently give consent to the processing of his/her personal data (but not less than 16 years), or the User can duly confirm the appropriate permission of the holder of parental responsibility over him/her.

Please note that, according to law, you are not obliged to provide us with any data; however, the provision of such data is a mandatory condition for the use of our Service. You hereby confirm, warrant and agree that any data you provide to us is provided of your own free will, is specific and unambiguous, and corresponds to your wish to have your data used for the purposes described below.

You may withdraw your consent to the processing of your personal data at any time, as we strive to ensure that the procedure for withdrawal of consent is no less simple than the procedure for granting it. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Terms and Definitions

Personal Data — any information relating to an identified or identifiable natural person who, in accordance with the Agreement, is a User of the Service.

Agreement — the license agreement between the User and EmailMassivo for the use of the Service, duly accepted by the User and having binding legal force for the User and EmailMassivo.

Service — the EmailMassivo software intended for sending mailings, including, but not limited to, a set of information, texts, graphic elements, designs, images, photo and video materials, and other results of intellectual activity, as well as computer programs contained in an information system that ensures the availability of such information on the Internet.

User — a natural or legal person who has accepted the Agreement and uses the Service.

All other terms and definitions used in the text of the Policy shall be interpreted in accordance with other rules governing the use of the Service, with established practice on the Internet and with applicable legislation governing the processing of personal data.

1. Personal Data Collected

1.1. In our activities we are guided by the legislation of the Republic of Cyprus in the field of personal data processing and by the GDPR.

1.2. In accordance with the principle of "data minimisation", we collect Personal Data only to the extent sufficient for the convenient use of the Service and for achieving the purposes of its collection.

1.3. In the course of the User's use of the Service, we collect two types of Personal Data: Personal Information and Anonymised Information.

1.3.1. Personal Information. Such data includes individual information that identifies a specific User and that the User provides to us during Registration.

Mandatory types of Personal Information required for the use of the Service include:

  • e-mail address.

1.3.2. Anonymised Information. Anonymised Information is data that does not identify a specific User and is collected automatically during Registration and use of the Service.

Anonymised Information may include:

  • information obtained through cookies, pixel tags, web beacons, browser analysis tools and web server logs, as well as other similar technologies and tools;
  • information about the devices that the User uses to access the Service, including the type of operating system, device model, browser type, system settings, including information about the language used by the User's system, geolocation data (determination of country/region), the User's device time zone, communications service provider;
  • action logs stored on the server that record the IP addresses of the devices that the User uses to interact with the Service, access time, sequence of the User's actions in the Service, session information, including response time and loading errors;
  • information from the User's social network account (depending on the privacy settings set by the User for his/her social network account), so we may obtain information about your interests and preferences, as well as access to your photo;
  • other non-identifying information depending on the permissions you grant.

1.4. The User accepts and agrees that in certain cases we are entitled to request additional information about the User, as well as copies of documents to confirm the specified data, and to make any other requests when this is necessary based on reasonable assumptions and legitimate interests.

2. Methods of Collecting Personal Data

2.1. The legal basis for collecting Personal Data is the User's consent to the collection of data.

2.2. Personal Information is collected by us at the moment of the User's Registration in the Service.

2.3. Anonymised Information is collected by us in the course of your use of the Service.

3. Purposes of Collecting Personal Data

3.1. We use Personal Data for the following purposes:

3.1.1. Providing access to the Service and its further operation.

3.1.2. Improving the Service, enhancing ease of use and configuring necessary settings, based on general or individual preferences, user experience or difficulties encountered by Users.

3.1.3. Providing technical support and feedback, including sending notifications, requests and information related to the use of the Service (notifications about updates, information on security issues, changes to our rules and terms of use of the Service).

3.1.4. Creating aggregate statistical information, including analytics and monitoring of trends in the use of the Service and Users' actions within the Service.

3.1.5. Sending marketing communications to your e-mail address or to your mobile phone, including notifications about products, services, promotions, events and other news and information which, in our opinion, may be of interest to the User. We may send you marketing information. You can easily opt out of receiving marketing messages by using the "unsubscribe" option provided in such messages.

3.1.6. Preventing fraud or violations of applicable laws, in particular for detecting, investigating and preventing fraudulent transactions and other unlawful activities, and for protecting the rights and property of EmailMassivo, other users and third parties.

3.1.7. Complying with any applicable law.

3.2. The User's Personal Data will not be used for purposes other than those specified above.

3.3. The User confirms that the purposes of using his/her Personal Data correspond to his/her interests, and that the consent to processing of Personal Data by us, expressed by the User at the beginning of the use of the Service, is given for each processing purpose specified in clause 3.1 of the Agreement.

4. Disclosure of Personal Data

4.1. We undertake not to disclose the User's Personal Data to third parties, except in the following cases:

4.1.1. The User has given explicit and specific consent to the disclosure of his/her Personal Data.

4.1.2. Such transfer of data is necessary for the User's use of the Service or for the performance of the License Agreement or other binding documents governing the relations between us and the User.

4.1.3. When such transfer of data is necessary for the operation of the Service and its functionality (transfer of data to hosting providers, communication and content delivery networks (distribution), data protection and cybersecurity services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring of the Service status, including measurement of performance and data optimisation, marketing and advertising services), third parties (recipients of Personal Data) may receive or otherwise have access to the User's Personal Data, in full or in part, depending on the role and purposes of each such party in maintaining the operation of the Service or its improvement; furthermore, they may use the data received only for the purposes specified in this Policy.

4.1.4. The transfer of Personal Data is carried out in accordance with applicable law at the request of authorised entities entitled to receive such data (court requests and requests from law enforcement authorities), when we are obliged to disclose such data and we in good faith believe that the law requires us to act in this way.

4.1.5. There is a transfer of ownership or control over all or part of the Service to a new owner.

4.1.6. The transfer of Personal Data is carried out in order to enable the protection of our rights and legitimate interests or the rights and interests of third parties in cases where the User violates this Privacy Policy or other binding documents governing the relations between us and the User, as well as applicable laws. The above cases cannot be regarded as unauthorised disclosure of personal data, since these actions are aimed at realising the purposes of processing Personal Data.

4.2. We will never sell Users' Personal Data to third parties.

4.3. Data may be transferred only in strict accordance with this Privacy Policy and within the framework of applicable law.

5. Territory of Storage and Cross-Border Transfer of Personal Data

5.1. We store and process the Personal Data of EmailMassivo Users and of recipients of your messages in the territory of the European Union.

5.2. We strive to protect and preserve Users' Personal Data in accordance with international industry standards and do not take into consideration any legal requirements that are lower than those of the User's jurisdiction.

5.3. If we and the User are located in different jurisdictions, by accessing or using the Services or otherwise providing us with his/her Personal Data, the User consents to the processing and transfer of the data to the country of our incorporation; at the same time, we guarantee that we will take appropriate measures to protect the User's Personal Data in accordance with this Privacy Policy and applicable law.

6. Use of Tracking Technologies

6.1 We use certain monitoring and tracking technologies in order to maintain, ensure and continuously improve the operation of our Service, and to provide the User with convenient use of the Service. By default, we use several such technologies for session and User authentication, security, saving the User's preferences (for example, in relation to default language and settings), connection stability, monitoring the performance of our Service and marketing campaigns, as well as for providing and improving our Services.

7. User Rights

7.1. Within the framework of this Privacy Policy, each User has the following rights in relation to his/her Personal Data:

7.1.1. Right of access to his/her Personal Data. To ensure this right, the Service provides a special section in the Account, where all Personal Information received by us from the User is indicated. The User may go to the Personal Information section and review the Personal Information that we hold at a given point in time. At the User's request, we provide a complete list of Personal Data that we have collected about the User, the legal grounds and purposes of processing, the categories of Personal Data, a list of third parties to whom the Personal Data has been or will be disclosed, the period for which the Personal Data will be stored, as well as the measures for the protection of Personal Data. A response will be provided within a reasonable period in accordance with applicable law.

7.1.2. Right to rectification. The User has the right at any time to independently make corrections to his/her Personal Data through the Account; if, for any reason, the User experiences difficulties in rectifying Personal Data, he/she may send us an appropriate request, and we will make the corrections within a reasonable period of time. Taking into account the purposes of processing, the data subject has the right to have incomplete Personal Information by indicating only the mandatory types of Personal Data necessary to provide access to the Service.

7.1.3. Right to withdraw consent to the processing of Personal Data. The User has the right to withdraw his/her consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. The Service provides the possibility to withdraw consent as easily as it is given. Thus, the User may at any time send us a request to delete the Account, and we will delete the Account within a reasonable period of time after receiving the corresponding request.

Please note that you may correct, update or delete certain parts of Personal Data yourself.

When making corrections to Personal Data or when the User withdraws consent, we will notify all third parties having access to the User's Personal Data of the changes.

7.1.4. Right to erasure ("right to be forgotten"). The User has the right to request, and we are obliged to effect, the deletion of the User's Personal Data without undue delay if:

  • Personal Data is no longer necessary for the purposes for which it was collected;
  • the data subject withdraws consent to the processing of his/her Personal Data which constitutes the basis for its collection;
  • Personal Data has been unlawfully processed;
  • Personal Data must be erased in accordance with law.

7.1.5. Right to data portability. The User has the right to receive his/her Personal Data in a structured, commonly used and machine-readable format. The User may obtain in structured form all Personal Data ever received by us by sending an appropriate request to the technical support service. The User has the right to transmit his/her Personal Data directly from one controller to another, where technically feasible.

8. Period of Storage of Personal Data

8.1. We store your Personal Data for the entire period of use of the Service (the existence of your Account) or until such time as we no longer need these data to provide the Service, or for a longer period if so required by applicable law or if this is done for the settlement of disputes with our Users, prevention of fraud and abuse and/or protection of our legitimate interests.

9. Information Security

9.1. We hereby guarantee that we take all necessary and sufficient organisational and technical measures, in accordance with applicable legislation, to protect the User's Personal Data from unlawful or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other unlawful actions with it by third parties. In our activities, we use generally accepted industry standards to protect the User's Personal Data and strive to maximally protect and ensure the confidentiality of Personal Data. Personal Data protection is implemented by default at the design level of the Service during its development. Security measures include firewall protection, pseudonymisation, data encryption, data minimisation, resilience of processing systems to failures, the ability to timely restore availability of and access to Personal Data in the event of a physical or technical incident, control of physical access to data centres, as well as control of authorisations for access to data. We regularly monitor our systems for potential vulnerabilities and attacks, assess the effectiveness of technical and organisational measures to ensure the security of Personal Data, and constantly look for new ways and service providers to further improve the security of our Service and the protection of the privacy of our Users. All third parties that gain access to Personal Data and are involved in providing the User with access to the Service adhere to security measures for Personal Data that are no less stringent.

9.2. However, we cannot guarantee absolute protection and therefore urge you to exercise caution, set a strong password for your account and avoid providing any sensitive data, the disclosure of which may cause you significant harm.

9.3. In the event of any Personal Data breach, we take all measures within our control to eliminate or minimise possible negative consequences, and also ensure immediate notification of the relevant supervisory authorities and of the User about this incident, indicating all available information about the breach of confidentiality. The facts of such incidents are entered into a special register of incidents that we are obliged to maintain in accordance with applicable law.

9.4. For the purposes of this Policy, a Personal Data breach means a security breach leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to transmitted or processed Personal Data.

10. Amendment and Interpretation of the Privacy Policy

10.1. This Privacy Policy, its interpretation and any claims and disputes related to it shall be governed by, construed and enforced exclusively in accordance with the laws of our place of incorporation, without regard to the applicable principles of conflict of laws.

10.2. You hereby agree that any disputes arising shall be resolved exclusively by the courts at our place of incorporation.

10.3. We are entitled to amend the Privacy Policy at any time. If we consider that the amendments made are material (in our own good-faith opinion), we will notify you of this before such amendments enter into force.

10.4. We recommend that you periodically review this page to obtain up-to-date information about our Privacy Policy. Unless expressly provided otherwise, our latest edition of the Privacy Policy applies to all information that we hold about you.

11. Communication with Us and Responses to Your Questions

11.1. If you have any questions regarding this Privacy Policy, please contact us at [email protected] .

11.2. You can also send a letter to the address: 9 Vasili Michailidi, 3026, Limassol, Cyprus.

11.3. We will respond to your request within a reasonable period of time or within the period established by applicable law.

11.4. In cases where this Policy or applicable law establishes our obligation to provide you with copies of data or any documents, we provide them in a single copy free of charge; for any additional copies requested, we are entitled to charge a reasonable fee based on administrative costs. If you make a request by electronic means, and unless you request otherwise, we will provide a response in a commonly used electronic format.

11.5. If the User's requests are manifestly unfounded or excessive, in particular due to their repetitive character, we are entitled to charge a reasonable fee taking into account the administrative costs of providing the information, or to refuse to act on the request.

11.6. If we have reasonable doubts as to the identity of the person making the request, we may request additional data necessary to confirm the User's identity.