# Privacy Policy for {{ config.mail_domain }} We want to show you in a fair and transparent way what personal data is processed by us. We follow a strict privacy-by-design approach and try to avoid processing your data in the first place, but as you may know, the internet, and in particular sending e-mail messages, does not work without data. Still, it's only fair that you know at all times what personal data is processed when you use our service. If you have any remaining questions about data protection, please contact us. ## 1. Name and contact information Responsible for the processing of your personal data is: ``` {{ config.privacy_postal }} ``` E-mail: {{ config.privacy_mail }} We have appointed a data protection officer: ``` {{ config.privacy_pdo }} ``` ## 2. Processing when using chat e-mail services We provide e-mail services optimized for the use from [Delta Chat](https://delta.chat) apps and process only the data necessary for the setup and technical execution of the e-mail dispatch. The purpose of the processing is to read, write, manage, delete, send, and receive emails. For this purpose, we operate server-side software that enables us to send and receive e-mail messages. Allowing the use of the e-mail service, we process the following data and details: - Outgoing and incoming messages (SMTP) are stored for transit on behalf of their users until the message can be delivered. - E-Mail-Messages are stored for the recipient and made accessible via IMAP protocols, until explicitly deleted by the user or until a fixed time period is exceeded, (*usually 4-8 weeks*). - IMAP and SMTP protocols are password protected with unique credentials for each account. - Users can retrieve or delete all stored messages without intervention from the operators using standard IMAP client tools. ### 3.1 Account setup Creating an account happens in one of two ways on our mail servers: - with a QR invitation token which is scanned using the Delta Chat app and then the account is created. - by letting Delta Chat otherwise create an account and register it with a {{ config.mail_domain }} mail server. In either case, we process the newly created email address. No phone numbers, other email addresses, or other identifiable data is currently required. The legal basis for the processing is Art. 6 (1) lit. b GDPR, as you have a usage contract with us by using our services. ## 3.2 Processing of E-Mail-Messages In addition, we will process data to keep the server infrastructure operational for purposes of e-mail dispatch and abuse prevention. - Therefore, it is necessary to process the content and/or metadata (e.g., headers of the email as well as smtp chatter) of E-Mail-Messages in transit. - We will keep logs of messages in transit for a limited time. These logs are used to debug delivery problems and software bugs. In addition, we process data to protect the systems from excessive use. Therefore, limits are enforced: - rate limits - storage limits - message size limits - any other limit neccessary for the whole server to function in a healthy way and to prevent abuse. The processing and use of the above permissions are performed to provide the service. The data processing is necessary for the use of our services, therefore the legal basis of the processing is Art. 6 (1) lit. b GDPR, as you have a usage contract with us by using our services. The legal basis for the data processing for the purposes of security and abuse prevention is Art. 6 (1) lit. f GDPR. Our legitimate interest results from the aforementioned purposes. We will not use the collected data for the purpose of drawing conclusions about your person. ## 3. Processing when using our Website When you visit our website, the browser used on your end device automatically sends information to the server of our website. This information is temporarily stored in a so-called log file. The following information is collected and stored until it is automatically deleted (*usually 7 days*): - used type of browser, - used operating system, - access date and time as well as - country of origin and IP address, - the requested file name or HTTP resource, - the amount of data transferred, - the access status (file transferred, file not found, etc.) and - the page from which the file was requested. This website is hosted by an external service provider (hoster). The personal data collected on this website is stored on the hoster's servers. Our hoster will process your data only to the extent necessary to fulfill its obligations to perform under our instructions. In order to ensure data protection-compliant processing, we have concluded a data processing agreement with our hoster. The aforementioned data is processed by us for the following purposes: - Ensuring a reliable connection setup of the website, - ensuring a convenient use of our website, - checking and ensuring system security and stability, and - for other administrative purposes. The legal basis for the data processing is Art. 6 (1) lit. f GDPR. Our legitimate interest results from the aforementioned purposes of data collection. We will not use the collected data for the purpose of drawing conclusions about your person. ## 4. Transfer of Data Your personal data will not be transferred to third parties for purposes other than those listed below: a) you have given your express consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR, b) the disclosure is necessary for the assertion, exercise or defence of legal claims pursuant to Art. 6 (1) sentence 1 lit. f GDPR and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data, c) in the event that there is a legal obligation to disclose your data pursuant to Art. 6 para. 1 sentence 1 lit. c GDPR, as well as d) this is legally permissible and necessary in accordance with Art. 6 Para. 1 S. 1 lit. b GDPR for the processing of contractual relationships with you, e) this is carried out by a service provider acting on our behalf and on our exclusive instructions, whom we have carefully selected (Art. 28 (1) GDPR) and with whom we have concluded a corresponding contract on commissioned processing (Art. 28 (3) GDPR), which obliges our contractor, among other things, to implement appropriate security measures and grants us comprehensive control powers. ## 5. Rights of the data subject The rights arise from Articles 12 to 23 GDPR. Since no personal data is stored on our servers, even in encrypted form, there is no need to provide information on these or possible objections. A deletion can be made directly in the Delta Chat email messenger. If you have any questions or complaints, please feel free to contact us by email: {{ config.privacy_mail }} As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our registered office for this purpose. The supervisory authority responsible for our place of business is the `{{ config.privacy_supervisor }}`. ## 6. Validity of this privacy policy This data protection declaration is valid as of *December 2023*. Due to the further development of our service and offers or due to changed legal or official requirements, it may become necessary to revise this data protection declaration from time to time.