Last updated: Dec 01, 2022

This Privacy Policy describes how Mailabl OÜ (reg. no. 16400138, address Kohevpesa, Pällu village, Mustvee parish, Jõgeva county, 49314; “Mailabl”, “we”, or “us”) processes the personal data of its Clients, the representatives of its Clients, Users and all other data subjects (you) in relation to their use of the Mailabl application and services.

We confirm that when processing any data, We comply with the requirements arising from the General Data Protection Regulation (EU) 2016/679.

When you use Mailabl Services, which means any website, application, services we offer, or when you communicate with us, you’re trusting us with your information.

Please read this Privacy Policy carefully as it will help you understand what we do with the information that we collect.

  1. DEFINITIONS

    1. Client - a person or organization who uses the Mailabl Services.
    2. Client Data - any information known to Mailabl about the client (personal data, contact data, billing data, etc.), as well as information collected from public databases and public channels.
    3. Personal Data - any information relating to an identified or identifiable natural person.
    4. Client Account - the User profile connected to the Client Account for the use of the Application, which is used to identify the User, provide personal access to the Services, and to change and save the settings.
    5. Public Area - the area of the website that can be accessed both by Users and Visitors, without needing to log in.
    6. Restricted Area - the area of the website or Application that can be accessed only by Users, and where access requires logging in.
    7. User - an employee, agent, or representative of a Client, who primarily uses the restricted areas of the website for the purpose of accessing the Service in such capacity.
    8. User Account - a profile connected to a specific Client for the use of the Application used to identify the Client, provide the Users connected to the Client with access to the Services, and to change and save the settings.
    9. Visitor - an individual other than a User, who uses the public area, but has no access to the restricted areas of the website or Service.
    10. Third party - a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
    11. Authorized processor - a person who processes customer data on behalf of Mailabl.

    Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Use.

  2. WHAT DATA WE COLLECT

    1. User-provided Information
      When you use the Services, as a User or as a Client, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address, mailing address, mobile phone number, and credit card or other billing information. You may provide us with Personal Data in various ways on the Service. For example when you register for an account, use the Service, send us customer service-related requests or by the representative of the Client or another User (within your company).
    2. Information Collected by Clients
      A Client or User may store or upload into the Service Client Data. Mailabl has no direct relationship with the individuals whose Personal Data it hosts as part of Client Data. Each Client is responsible for providing notice to its customers and third persons concerning the purpose for which Client collects their Personal Data and how this Personal Data is processed in or through the Service as part of Client Data.
    3. “Automatically Collected” Information
      When you use a Service, we may automatically record certain information from your device by using various types of technology, including cookies. This information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User or Visitor views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service.
    4. Information from Other Sources
      We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.
    5. Cookies
      Cookies are small text files, given ID tags that are stored on your computer or mobile device browser directory or program data subfolders. Cookies are created when you use your browser to visit a website that uses cookies to keep track of your movements within the site, help you resume where you left off, remember your registered login, theme selection, preferences, and other customization functions.

    Cookies are important for site functionality, preference, analysis, and marketing purposes.

    Functionality cookies help us make our website usable by enabling basic functions like page navigation, authentication, and access to secure areas of the website. The website cannot function properly without these cookies.

    Preference cookies enable our website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.

    Analytics cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

    Targeting cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.

    Session cookies are valid only during a browser session on each visit, they associate activities on the website.

    Persistent cookies are stored on the website visitor’s device and do not disappear when the browser is closed. Persistent cookies record the activities or preferences of a website visitor.

    Third-party cookies originate from advertisements on other websites and are located on a website visited by a visitor. For example, Google may use their own cookies to collect information about the content of our website. Google’s cookies terms.

    The following cookies are used on our Public Area:

    Service providerCookie nameCookie typeExpirationContent
    Mailabl_cookie-policy-agreementFunctionalityPersistentHelps to remember visitor preferences for cookies
    Mailabl_languagePreferencePersistentHelps to remember preferred language selection of the visitor
    Google Analytics_gidAnalyticsPersistentRegisters a unique ID that is used to generate statistical data on how the visitor uses the website
    Google Analytics_gaAnalyticsPersistentHelps to identify sessions of visitors
    Google Analytics_ga_XXXAnalyticsPersistentUsed by Google Analytics to gather statistical information on how the website is being used

    The following cookies are used within our Restricted Area:

    Service providerCookie nameCookie typeExpirationContent
    Mailabl_verifyFunctionalityPersistentUsed to authenticate the user
    Mailabl_sessionFunctionalityPersistentUsed to authenticate the user
    Mailabl_tokenFunctionalityPersistentUsed to authenticate the user
    MailabllocalePreferencePersistentHelps to remember preferred language selection of the user
    Sentrysentry-scFunctionalityPersistentNeeded to track site performance issues
    SentrysessionFunctionalityPersistentNeeded to track site performance issues
    SentrygsIDFunctionalityPersistentNeeded to track site performance issues
    SentryAMP_XXXFunctionalityPersistentNeeded to track site performance issues
    Sentry__stripe_midFunctionalityPersistentNeeded to track site performance issues
    SentryanonIdFunctionalityPersistentNeeded to track site performance issues
    Sentryamp_XXXFunctionalityPersistentNeeded to track site performance issues
    Google Analytics_gidAnalyticsPersistentRegisters a unique ID that is used to generate statistical data on how the visitor uses the website
    Google Analytics_gaAnalyticsPersistentHelps to identify sessions of visitors
    Google Analytics_ga_XXXAnalyticsPersistentUsed by Google Analytics to gather statistical information on how the website is being used

    The storage time for cookies is different for each cookie. Each new visit to the website updates the cookies and therefore the storage period is extended.

    Visitors to the website can block, delete stored cookies or withdraw consent to the storage of cookies on their own devices. However, it should be borne in mind that this may affect user comfort. Below we’ve included tutorials on how to set cookies in the most common web browsers:

  3. HOW THE INFORMATION IS USED

    1. Operations
      We use the collected Client Data to perform the Agreement. This includes providing customer support and contacting you for other reasons related to the Application and the Services. We use other information (except Client Data) to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service.
    2. Improvements
      We use the information (except Client Data) to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Service, and to develop new products, services, features, and functionality.
    3. Communications
      We may use a Visitor’s or User’s email address or other information (except Client Data) to contact that Visitor or User for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Client Data or Personal Data posted on the Service.
    4. Cookies and Tracking Technologies
      We use automatically collected information and other information collected on the Service through cookies and similar technologies (cookies, tracking technology and other automated tracking methods, etc) to personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits and monitor aggregate site usage metrics such as total number of visitors and pages viewed.
    5. Analytics
      We use Google Analytics to measure and evaluate access to and traffic on the Public Area and Restricted Area of the Site, and create user navigation reports for our website administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest you review. Google may use the information collected through Google Analytics to evaluate Users’ and Visitors’ activity on our website.
  4. TO WHOM WE DISCLOSE THE INFORMATION

    1. Other Users in Your Company Account
      Certain information about your use of the Mailabl Services is available to the administrator(s) of your Mailabl Account and depending on the settings chosen by the Users of the Account, to other Users for the purposes of providing the Mailabl Services.
    2. Service Providers
      We work with third party service providers who provide website hosting and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
    3. Law Enforcement, Legal Process, and Compliance
      We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
    4. Mailabl’s rights
      We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to:
      1. take precautions against liability;
      2. protect ourselves or others from fraudulent, abusive, or unlawful uses or activity;
      3. investigate and defend ourselves against any third-party claims or allegations;
      4. protect the security or integrity of the Service or equipment used to make the Service available;
      5. or protect our other legal rights, enforce our contracts, or protect the rights, or safety of others.
  5. ACCOUNT INFORMATION

    You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

    If you wish to access or amend any other Personal Data we hold about you, or to request that we delete any information about you that we have obtained from an Integrated Service, you may contact us by writing to the email address [email protected]. At your request, we will have any reference to you deleted or blocked in our database.

    You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.

    At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law.

    This provision does not apply to Personal Data that is part of Client Data. In this case, the management of the Client Data is subject to the Client’s own Privacy Policy, and any request for access, correction or deletion should be made to the Client responsible for the uploading and storage of such data into the Service.

  6. DATA RETENTION

    We only retain the Personal Data collected from a User for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:

    • the contents of closed accounts are deleted within 30 days of the date of closure;
    • backups are kept for 1 year;
    • billing information is retained for a period of 7 years as of their provision to Mailabl in accordance with the Estonian accounting and taxation laws;
    • information on legal transactions between Client and Mailabl is retained for a period of 10 years as of their provision to Mailabl in accordance with the general limitation period set for civil claims in the Estonian General Part of the Civil Code Act.
  7. SECURITY

    Personal data is stored on servers located in the territory of a Member State of the European Union or countries that have joined the European Economic Area.

    We implement appropriate organizational, physical, and IT security measures to ensure that customer data is protected from unintentional or unauthorized processing, disclosure, or destruction.

    All the Personal Data that you provide us is stored in a secure computing environment protected by secure firewalls to prevent unauthorized access. We control access so that only people who need to access the Personal Data can. All staff are required to adhere to a comprehensive set of security policies, procedures, and standards related to their jobs.

    Where your Personal Data needs to be disclosed to our service providers, we require them to process and protect your Personal Data in a manner consistent with this Privacy Policy and applicable laws.

    If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

  8. DATA TRANSFER

    We may transfer Personal Data we collect through the Services in centralized databases and with service providers. When we transfer Personal Data, we will protect it as described in this Privacy Policy.

  9. PROTECTION OF CUSTOMER RIGHTS

    The customer has the right to apply to Mailabl, the Data Protection Inspectorate or a competent court if, in the customer’s opinion, we violate the customer’s rights when processing customer data.

    The client has the right to demand compensation for the damage caused to the client by the violation of the client’s rights on the bases and pursuant to the procedure provided for in the Law of Obligations Act.

  10. CHANGES AND UPDATES TO THIS POLICY

    Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.

CONTACT

Please contact us with any questions about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email at [email protected].

Privacy Policy valid from: 01.12.2022

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