Privacy Policy

1. Controller

SMail is developed and published by:

up2bo
Het Hoog 7
2288 Bouwel
Belgium

Belgian enterprise number: 0675.719.915

Privacy contact: support@smailsearch.com

2. Local processing

SMail is a local Windows desktop application designed to help you search email stored in supported versions of Microsoft Outlook.

SMail creates and uses a local search index on your computer. Depending on the information in your Outlook folders, that local index may include information such as email content, sender and recipient information, subject lines, dates, attachment names and other information required for searching and indexing.

Normal email content, the local search index, search queries and SMail's relevance-learning information are not sent to up2bo for normal indexing or searching.

We do not use your SMail search activity for advertising or marketing profiling.

3. Licensing

SMail requires an internet connection for certain licensing operations, including trial activation, paid-license activation, deactivation and license-status operations.

Depending on the licensing operation, SMail may transmit information such as a randomly generated Device ID, your License key, License or Activation ID, product and major-version information, a device label, and information necessary to determine or maintain license status.

SMail's licensing infrastructure uses Cloudflare services, including Cloudflare Workers and D1. Outlook email content and SMail search data are not sent to the licensing service.

The legal basis for processing information necessary to provide and administer your SMail trial or license is that the processing is necessary to perform a contract with you or to take steps at your request before entering into a contract. Where necessary to protect the licensing service against abuse or maintain its security, we may also process limited technical information on the basis of our legitimate interests in protecting our services and business.

4. Optional Pushover notifications

SMail can use Pushover to send optional operational notifications. This feature is not required to use SMail and only operates when it has been enabled and configured.

When Pushover notifications are enabled, SMail sends information required to generate the notification directly to Pushover. Depending on the event, this information can include the computer name, Windows user name, Outlook mailbox or account name, relevant Outlook folder name, application name and version, notification or diagnostic information, severity and source information, and timestamps.

SMail also sends the configured Pushover User Key and application/API token as required by the Pushover API.

SMail uses Pushover's standard HTTPS API. SMail's Pushover integration does not currently use Pushover's optional end-to-end encryption feature.

Pushover is a third-party service operated in the United States. Information sent to Pushover is also subject to Pushover's own privacy practices and retention rules.

If you do not want this information sent to Pushover, do not enable Pushover notifications.

5. Support requests and Support Reports

If you need technical support, SMail can prepare a support email addressed to support@smailsearch.com and attach a diagnostic .smailreport.

SMail creates and displays this email in Classic Outlook but does not send it automatically. You can review and edit the message and decide whether to send it.

The Support Report is specifically designed to provide technical information useful for investigating an SMail installation. It is not intended to contain the contents of your Outlook email and does not contain your reusable License key.

The report may nevertheless contain personal or technical information associated with your installation, such as diagnostic identifiers, licensing identifiers and technical status information.

Your License key is kept separate from the .smailreport. When necessary for support, you may be asked to enter your License key separately in the support email.

We also process any information that you choose to include in your support email.

Support email is currently handled using Cloudflare Email Routing for incoming routing, Google Gmail as the support mailbox backend, and SMTP2GO for outgoing support email.

The SMTP2GO account used for SMail is configured as Hosted in the EU, and up2bo has accepted SMTP2GO's Data Processing Agreement.

We process support information to respond to your request, diagnose problems, maintain support correspondence and protect the security and reliability of SMail. Depending on the circumstances, this processing is necessary to perform our contract with you and/or is based on our legitimate interests in providing effective customer and technical support.

We normally retain support correspondence for 24 months after the last support interaction. Information may be retained longer where reasonably necessary for an ongoing case, legal obligation, security matter, dispute, or the establishment, exercise or defence of legal claims.

6. Website and Cloudflare

The SMail website uses Cloudflare for website hosting, delivery, performance and security.

When you visit the SMail website, your request passes through Cloudflare's infrastructure. In providing and protecting the website, Cloudflare processes technical information associated with the request, which can include your IP address and other request, connection and security information.

We use this infrastructure to make the website available, maintain its performance and protect it and our services against abuse and security threats.

Where this processing involves personal data for which up2bo is responsible, we rely on our legitimate interests in operating, securing and reliably providing the SMail website and services, except where another legal basis is required.

7. Analytics

We use Cloudflare Web Analytics to obtain general information about use and performance of the SMail website.

According to Cloudflare, Web Analytics does not use cookies, localStorage or similar client-side state to track visitors, and Cloudflare states that it does not collect or use visitors' personal data for the Web Analytics service.

We do not use the SMail website for behavioral advertising and do not currently use advertising trackers.

Because the technologies used by the website may change, we will reassess our privacy and consent requirements when new website services are introduced.

8. Local logs and diagnostics

SMail and its related components maintain operational and diagnostic information locally on your computer. This information is used for purposes such as maintaining the local search index, recording application and indexing status, diagnosing problems and supporting the reliable operation of SMail.

These local records are not automatically uploaded to up2bo.

Information leaves your computer only through defined features or services that require external communication. These include licensing operations, optional Pushover notifications when you have enabled that feature, and support information that you choose to send to up2bo.

SMail does not use local application logs, email-search activity or search queries for advertising or behavioral profiling.

9. Who may receive personal data?

Depending on which SMail services you use, personal data may be processed by third-party service providers involved in operating the SMail website, licensing infrastructure, optional notifications and customer support.

These currently include:

• Cloudflare — website hosting and delivery, website security, Web Analytics, licensing infrastructure and incoming support-email routing;
• Google — the Gmail service currently used as the backend mailbox for SMail support correspondence;
• SMTP2GO — delivery of outgoing SMail support email; and
• Pushover — delivery of optional operational notifications, but only when you enable and configure the Pushover functionality.

The information involved depends on the service being used and is described in the relevant sections of this Privacy Policy.

We do not sell your personal data and do not provide your Outlook email content or SMail search data to third parties for advertising or marketing purposes.

10. International data transfers

Some of the third-party services used by SMail operate internationally. As a result, personal data processed through those services may be transferred to or processed in countries outside Belgium and the European Economic Area (EEA).

Where the GDPR requires safeguards for an international transfer, the transfer must be covered by an applicable legal mechanism, such as an adequacy decision or appropriate safeguards provided for under the GDPR.

In particular, if you enable optional Pushover notifications, notification information is transmitted to Pushover in the United States.

Cloudflare and Google operate international infrastructure and may process information in countries outside the EEA in connection with the services described in this Privacy Policy.

The SMTP2GO account used for SMail support email is configured as Hosted in the EU.

Where applicable, further information about the privacy and international-transfer arrangements of these providers is available in their respective privacy documentation.

11. How long we keep information

We retain personal data only for as long as reasonably necessary for the purposes for which it is processed, taking into account applicable legal, accounting, security and dispute-resolution requirements.

Support correspondence is normally retained for 24 months after the last support interaction. It may be retained longer where reasonably necessary for an ongoing support case, legal obligation, security matter, dispute, or the establishment, exercise or defence of legal claims.

Licensing and activation information may be retained for as long as necessary to administer the applicable trial or perpetual SMail license, maintain activation and deactivation history, establish legitimate license status, and deal with related support, security or legal matters.

Cloudflare Workers operational logs associated with the SMail licensing service are used for short-term operational and diagnostic purposes. Their retention is determined by the Cloudflare service and plan in use.

Local SMail data, including the local search index, application data and local operational logs, is stored on your computer. It is not subject to up2bo's server-side retention periods and remains under your control, subject to SMail's local maintenance and retention functions.

Information processed by third-party services may also be subject to the provider's own applicable retention practices.

12. Security

We use reasonable technical and organizational measures intended to protect personal data processed through SMail and its online services against unauthorized access, loss, misuse, alteration or disclosure.

SMail is designed to limit the amount of information that needs to leave your computer. Normal Outlook email indexing, searching and relevance processing take place locally on your computer and do not require your email content or search queries to be processed by up2bo's servers.

Where SMail communicates with online services, established encrypted transport such as HTTPS/TLS is used where applicable.

Access to online systems and services used to operate SMail is restricted and protected using the security mechanisms available for those services.

No method of electronic transmission, processing or storage can be guaranteed to be completely secure.

13. Your privacy rights

Under the GDPR, you may have rights in relation to your personal data, depending on the circumstances and the processing involved. These can include:

• the right of access to personal data we process about you;
• the right to rectification of inaccurate or incomplete personal data;
• the right to erasure of personal data where the applicable legal requirements are met;
• the right to restriction of processing in certain circumstances;
• the right to object to processing based on legitimate interests;
• the right to data portability where the legal requirements for that right are met; and
• the right to withdraw consent at any time where processing is based on consent. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

To exercise a privacy right or ask a question about your personal data, contact: support@smailsearch.com

We may ask for information reasonably necessary to verify your identity before fulfilling a request where this is necessary to protect your personal data.

You also have the right to lodge a complaint with a data-protection supervisory authority. In Belgium, the supervisory authority is the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données).

14. Children

SMail is a productivity application intended for users of Microsoft Outlook and is not designed or directed specifically at children.

We do not knowingly use SMail or the SMail website to collect personal data from children for advertising or profiling purposes.

15. Automated decision-making

up2bo does not use personal data processed through SMail's online services to make decisions about you based solely on automated processing that produce legal effects or similarly significant effects.

SMail's search, indexing, Automatic Refinement and Adaptive Relevance Engine features operate to help you search and organize your own email. They are not used by up2bo to profile you or to make decisions about you.

16. Changes to this Privacy Policy

We may update this Privacy Policy when SMail, the SMail website, our service providers, our processing activities or applicable legal requirements change.

When we update this Privacy Policy, we will revise the Last updated date shown at the top of the policy. Where additional notice is required by applicable law, we will provide it as required.

17. Contact

If you have questions about this Privacy Policy, the way we process personal data, or wish to exercise a privacy right, contact:

up2bo
Het Hoog 7
2288 Bouwel
Belgium

Belgian enterprise number: 0675.719.915

Email: support@smailsearch.com