Personal Information We Collect

Information you give us Personal information that you may provide through the Services or otherwise communicate with us includes: • Registration and profile information. When you register or subscribe to any of the Services, you provide us with information such as your first name, last name, recovery email, username and password. You may optionally provide us, all in accordance with applicable laws, the email addresses in your mobile address book on a regular basis. You may also add other information to your account, such as a profile picture. • Email data. When you use our Services to send an email, we process your email address, recipient’s email address, subject and the encrypted content of your messages (including body and attachments). Once messages are delivered to your device, they are deleted from our servers. The same holds true for messages which you send. Your messages are permanently stored on your own device and not on our servers. If a message cannot be delivered immediately (for example, if you are offline or the device is powered off), we may keep it on our servers for up to 30 days. After the 30-day period the message is deleted from our server. We also keep email metadata (subject, date and sender email address) in order to enable certain features of the Services, such as the “unsend”, “read receipts” and “expiration” features. • Feedback and correspondence information. You provide us information in your responses to surveys, and when you participate in market research activities, report a problem with the Services, receive customer support or otherwise correspond with us. • Transaction details. When you make purchases through the Services, you provide us with billing and payment information. We use a third-party payment provider to process payment card transactions. We collect the transaction details only (e.g., the invoice ID, and the date and amount of purchase). Information automatically collected • Usage And Log Information. We may also automatically log information about your use of the Services, including the number of messages sent collectively by all users through the Services. For example, we may log how many emails are sent per day and what kind of file formats are shared in attachments. • Email Data. When a normal, unencrypted email is sent to you by a non-KiuMarketing sender, the email gets encrypted by the server with your public key and can only be decrypted by your device. The same holds true for attachments that are sent to you from non-KiuMarketing addresses. This means that your emails are always encrypted, even if the sender is not using KiuMarketing. • Device And Connection Information. We may automatically log information about you and your computer or mobile device when you access our Services. This includes information like hardware model, operating system information, battery level, signal strength, app version, browser information, and mobile network, connection information including mobile operator or ISP, language and time zone, and IP. This is to help us identify bugs and deliver better help to users who contacts us with support questions. • Cookies. We use cookies only in our Website. We may also use cookies to understand which of our FAQs are most popular and to show you relevant content related to our Services. Additionally, we may use cookies to remember your choices, like your language preferences, to provide a safer experience, and otherwise to customize our Services for you. Please refer to the Cookies and Similar Technologies section for more details. Changes to your personal information It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your account or emailing us at Cookies and Similar Technologies What are cookies? We may collect information using “cookies” only through our Website not our Services. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience with our Services. We use two broad categories of cookies: (1) first-party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Services; and (2) third-party cookies, which are served by service providers on for our Services, and can be used by such service providers to recognise your computer or mobile device when it visits other websites. Cookies we use Our Services use essential cookies. Disabling cookies You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. If you do not accept our cookies, you may experience some inconvenience in your use of our Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you use our Services. How We Use Your Personal Information To provide our Services If you have a KiuMarketing account or use our Services, we use your personal information to: • Operate, maintain, administer and improve the Services; • Manage and communicate with you regarding your KiuMarketing account, including by sending you service announcements, technical notices, updates, security alerts and support and administrative messages; • Provide support and maintenance for the Services; and • Respond to your service-related requests, questions and feedback. To communicate with you If you request information from us, register for the Services, or participate in our surveys, promotions or events, we may send you KiuMarketing-related marketing communications as permitted by law. You will have the ability to opt out of such communications. To comply with law We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities. With your consent We will request your consent to use your personal data where required by law, such as where we use certain cookies or similar technologies or would like to send you certain marketing messages. If we request your consent to use your personal data, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us. To create anonymous data for analytics We may create anonymous data from the information you provide to us through the Services. We exclude any information that may make the data personally identifiable to you. We reserve the right to use that anonymous data for our lawful business purposes. For compliance, fraud prevention and safety We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. How We Share Your Personal Information Affiliates We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy. Service providers We may employ third-party companies and individuals to administer and provide the Services on our behalf (such as training, customer support, hosting, email delivery and database management services). These third parties may use your information only as directed by Company and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose. Email recipients We disclose the content of your email message(s) to the email recipient(s) that you have designated in the email. Professional advisors We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us. Compliance with laws and law enforcement; protection and safety Company may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. Business transfers Company may sell, transfer or otherwise share some or all of its business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy. Your Choices Access, update, correct or delete your information You may review, update, correct or delete your personal information by logging into your account. If you choose not to provide your personal information to us, or limit how may process it, we may not be able to provide you with the Services and may need to close your account, if your choices are inconsistent with our legal obligations to process data or prevent us from providing Services to you. We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means. You can stop all collection of information by a KiuMarketing application by uninstalling the application. You may use the standard uninstall processes as may be available as part of your computer device, mobile device or via the mobile application marketplace or network. You may at any time opt out from further allowing us to have access to your location data by disabling the location sharing on your mobile device. Security The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information. You should take steps to protect against unauthorized access to your password and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen or compromised passwords or for any activity on your account via unauthorized password activity. Children Our Services are not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without his or her consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. International Transfer KiuMarketing is headquartered in the United States and has affiliates and service providers in other countries. Your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction. Other Sites and Services The Services may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third-party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use. Changes to this Privacy Policy We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy you will be notified via email (if you have an account where we have your contact information) or another manner through the Services that we believe reasonably likely to reach you (which may include posting a new privacy policy related to our Services). Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy. Contact Us If you have any questions or concerns at all about our Privacy Policy, please feel free to email us at
 Additional Information for European Union Users Personal information References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation. Controller KiuMarketing, Inc. is the controller of your personal information for purposes of European data protection legislation. See the Contact Us section above for contact details. Legal basis for processing We only use your personal information as permitted by law. We are required to inform you of the legal basis of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us at Sensitive personal data We do not control what information you may include in encrypted emails that you send or receive using the Services. If you send or disclose any sensitive personal data through the Services, we process such sensitive personal data in accordance with this Privacy Policy, pursuant to your consent. You may withdraw your consent at any time by deleting your account or contacting us at If you withdraw your consent, we will terminate your account. Retention We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you. Your rights European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold: • Opt-out. Stop sending you direct marketing communications. You may continue to receive service- related and other non-marketing emails. • Access. Provide you with information about our processing of your personal information and give you access to your personal information. • Correct. Update or correct inaccuracies in your personal information. • Delete. Delete your personal information. • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice. • Restrict. Restrict the processing of your personal information. • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information. You can submit these requests by email to or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.