Last updated on August 20, 2018
Boxbe, owned and operated by eDataSource, Inc. ("Boxbe") has adopted this Privacy Shield Policy ("Policy") to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that Boxbe obtains from Customers.
All Boxbe employees who handle Personal Data from Switzerland or Europe are required to comply with the Principles stated in this Policy. Capitalized terms are defined in Section 14 of this Policy.
This Policy applies to the processing of Customer Personal Data that Boxbe receives in the United States concerning Customers who reside in Europe. Boxbe provides online email management services to consumers and individuals.
This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms or anonymous email accounts are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)
Boxbe has designated an internal team to oversee its information security program, including its compliance with the Privacy Shield program. The internal team shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to email@example.com
Boxbe will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. Boxbe personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that Boxbe has undertaken to protect Personal Data.
Boxbe will renew its Privacy Shield certification annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.
Prior to the re-certification, Boxbe will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, Boxbe will undertake the following:
Ensure that this Policy continues to comply with the Privacy Shield principles
Confirm that Customers are made aware of the process for addressing complaints and any independent dispute resolution process (Boxbe may do so through its publicly posted website, Customer notices via email, or both)
Review its processes and procedures for training Employees about Boxbe's participation in the Privacy Shield program and the appropriate handling of Customer Personal Data
The Personal Data that we collect may vary based on the Customer's interaction with our website and use of our services. As a general matter, Boxbe collects and stores non-personal, or information in a form that does not permit direct association with a specific individual, and personal information automatically when you use the service. For example, the following types of Personal may be collected: contact information, including, a contact person's name, email address, and IP address. In addition, the service collects data from and about commercial electronic messages and transactional messages that are sent to your email accounts so that we can understand the behavior of such senders and messages, develop anonymized data products from your email messages and interactions, as we all to better understand our customer’s behavior and inbox placements. We may disclose such messages to trusted partners, in which case, whenever possible, identifiable information will be removed or obfuscated prior to any such disclosure. Such messages will only be disclosed to trusted partners working under strict confidentiality agreements. We may collect, use, transfer, and disclose non-personal information, including anonymized data products, for any purpose.
With your permission, Boxbe connects to your email account(s) and scans your mailbox to organize, clean and assist in receiving email from selected senders. As part of this process, we identify and index information about commercial email companies have sent to your email inbox. For example: we index information like FROM domain, FROM IP address, RETURN-PATH domain, Message Subject Line, Message Date, Message URLs, Anonymized Message Content. We retain information about these commercial messages. We also retain user usage data points, such as whether the email was opened, deleted, moved, forwarded, clicked or marked as spam. We use this collected information, including potential personal information, to operate or improve the Service and to develop anonymized data products.
Except as otherwise provided herein, Boxbe discloses Personal Data only to Third Parties who reasonably need to know such data or trusted partners who work with Boxbe under confidentiality agreements. Such recipients must agree to abide by confidentiality obligations. Examples of Third Parties that may receive personal information include analysts and third-party data analytic companies. All Third Parties receiving personal information must have a written confidentiality agreement in place between Customer and Third Party and Boxbe and Third Party that meets or exceeds Privacy Shield standards.
Boxbe may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, Boxbe may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by Boxbe and they must either: (1) comply with the Privacy Shield principles or another mechanism permitted by the applicable European data protection law(s) for transfers and processing of Personal Data; or (2) agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy. Boxbe also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure.
Boxbe may be forced to disclose an individual's personal information when compelled by a request made by a recognized public authority or where required to meet national security and or law enforcement requirements.
In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield, Boxbe is potentially liable. Boxbe's liability under this agreement will be governed by the contract in place between Customer and Boxbe.
Boxbe does not collect Sensitive Data from its Customers.
Boxbe uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. Boxbe has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to Boxbe's electronic information systems requires user authentication via password or similar means. Boxbe also employs access restrictions, limiting the scope of employees who have access to Customer Personal Data. Further, Boxbe uses secure encryption technology to protect certain categories of personal data.
Despite these precautions, no data security safeguards guarantee 100% security all of the time.
Boxbe personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
Requests for Personal Data. Boxbe will track each of the following and will provide notice, when required, to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If Boxbe receives a request for access to his/her Personal Data from a Customer's customer, then, unless otherwise required under law or by contract with such Customer, Boxbe will refer such Data Subject to Customer.
Satisfying Requests for Access, Modifications, and Corrections. Boxbe will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.
Limiting Use of Personal Data. You may request limitations on the use of your personal data specified in this agreement by contacting us at firstname.lastname@example.org.
This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.
Customers may contact Boxbe with questions or complaints concerning this Policy at the following address email@example.com.
Customers with questions or concerns about the use of their Personal Data should contact us at firstname.lastname@example.org. In compliance with the Privacy Shield Principles, Boxbe commits to resolve complaints about our collection or use of your personal information. Individuals in Switzerland or the European Union with inquiries or complaints regarding our Private Shield policy should first contact email@example.com.
As part of this agreement, Boxbe subjects itself to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.
"Employee" means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of Boxbe or any of its affiliates or subsidiaries, who is also a resident of a country within Switzerland or the European Economic Area.
"Europe" or "European" refers to a country in the European Economic Area.
"Personal Data" as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual's name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term "person" includes both a natural person and a legal entity, regardless of the form of the legal entity.
"Sensitive Data" means Personal Data that discloses a Data Subject's medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.
"Third Party" means any individual or entity that is neither Boxbe nor an Boxbe employee, agent, contractor, or representative.