Privacy Policy of SecureMailMerge

Simple Version

• Any spreadsheet you use to create or send a campaign will only be processed on your computer and never anywhere else. We don't have any servers that process campaigns for SecureMailMerge.
• If you add personalization tokens to your emails the data from spreadsheets will be used to generate emails and this email will be sent to your Microsoft 365 email server for sending to the recipients. Emails are sent through your own Microsoft 365 mailbox.
• If you switch off the promotional footer (i.e. you want to use a paid plan) the plugin will ask our server for a license key. The request and the response does not include any of your spreadsheet data, only your email address.
• If you buy a plan, you will use one of two marketplaces to do so and their privacy policy applies to the data you give them.
• If you purchase a license we store billing your and contact information (which includes your email).
• If someone assigns a license to you (i.e. they pay for a license and you get to use it) we will store user identifiers and your own email address to provide your license and for support purposes.
• Any data we store is deleted at most 30 days after your account is deleted, but more often than not immediately.
• Our website does not use cookies for tracking. Our company uses privacy-first (cookie-less) analytics from Fathom Analytics in strict EU isolation mode and we use Helpscout for customer support which sets technical cookies to provide their service and we use Sentry for exception logging to improve our service and we use Paddle as our Merchant of Record (payments).
• Our plugin (1) uses local storage to save campaign data on your computer; (2) uses Fathom analytics to give us insight into how many users are using the plugin and how many emails are being sent; and (3) uses Sentry to monitor for errors to help us improve the product.
• If you contact us via email or help desk we will store the information you send us to help us answer your query or any future queries.
• You can request a data processing addendum here.

Full Version

Your privacy is critically important to us. At Sol Inventum, we have a few fundamental principles:

• We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
• We store personal information for only as long as we have a reason to keep it.
• We help protect you from overreaching government demands for your personal information by keeping as little as technically possible.
• We aim for full transparency on how we gather, use, and share your personal information.

Below is our Privacy Policy, which incorporates and clarifies these principles.

This Privacy Policy applies to information that we collect about you when you use:

• Our website (www.securemailmerge.com); and
• Our licensing server (licensing.solinventum.com); and
• Our Microsoft 365 plugin ('SecureMailMerge')

Throughout this Privacy Policy we’ll refer to our website and plugin collectively as “Services.” The controller of information about you is Sol Inventum OÜ, a private limited company registered in Estonia. Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better. We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

When you use the plugin

When you turn off our promotional footer (i.e. try to use our paid plan)

In order to figure out if you have paid for a commercial license the plugin will contact our licensing server and ask for a license for your email address. If you have a paid license we will store a timestamp on our servers to show us when you last used your license.

When you buy a commercial license

The plugin will redirect you to our licensing server which will ask you to login with your Microsoft 365 account. From this point on we will store identifiers, your name and your email address in our server until your account is deleted. We also store an access token to retrieve your user information from Microsoft 365 (i.e. Microsoft Graph). This access token is only valid for read-only access to this information.

You then have the choice to buy a license via one of our marketplaces which are governed by their own privacy policies which will be linked to on the page that redirects you to them. Once a purchase has been made these services contact our licensing server and we store your billing contact and transaction number, but do not store any credit card information.

When you want to assign a license to a different user

If you want to assign licenses you have purchased to another user in your organiation you required administrative rights in your Microsoft 365 tenant. Upon first trying to assign licenses you will be asked to upgrade your access token to allow our licensing server to read the basic information of users in your Microsoft 365 directory. When you search for a user we will not store the search or any result in our database. If you assign a license we will store the user's identifiers, name and email address in our database to enable them to use the license.

When you contact us via email or helpdesk or respond to our emails

We store any communication securely in our systems in order to help you now and in the future with your request or query.

Information We Collect Automatically

We also collect some information automatically:

• Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services using a privacy aware analytics software that does not store any personal information or use cookies.
• Information from cookies & other technologies: Neither our website nor our plugin use cookies. Our plugin uses local browser storage in order to process your data. This local browser storage is not accessible to anyone but your computer. .

Information We Collect from Other Sources

We may also get information about you from other sources. For example:

• Microsoft 365 Login: If you log in to your our website account through another service (like Google) we’ll receive associated login information (e.g. a connection token, your username, your email address)
• Financial Account Info: If you buy a commercial license we may receive information relating to your payment from Microsoft or Stripe.

How and Why We Use Information

Purposes for Using Information

We use information about you for the purposes listed below:

• To provide some of our services. For example, to set up and maintain your account, provide customer service, process payments and orders, and verify user information.
• To ensure quality, maintain safety, and improve our Services. For example, by providing automatic upgrades and new versions of our Services. Or, for example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy and that will help them create and manage websites more efficiently or make our Services easier to use.
• To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Sol Inventum and others, which may result in us, for example, declining a transaction or terminating Services.
• To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
• To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on Sol Inventum if you have opted in. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account.)

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that: (1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or (2) The use is necessary for compliance with a legal obligation; or (3) The use is necessary in order to protect your vital interests or those of another person; or (4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience.

Sharing Information

How We Share Information

We don't store much information we could share and the information we do store is only shared in very few cases:

• Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
• Business transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Sol Inventum goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
• With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so.
• Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.

How Long We Keep Information

We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it.

For example, we keep web server logs that record information about a visitor to one of Sol Inventum’s websites, like the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyze traffic to Sol Inventum’s websites and investigate issues if something goes wrong on one of our websites.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks.

Closing your account

If you wish to close your account (assuming you have created one on our licensing server) you can do so by contacting our support using any of the contact methods listed on our website. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

Your Rights

If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

• Request access to your personal data;
• Request correction or deletion of your personal data;
• Object to our use and processing of your personal data;
• Request that we limit our use and processing of your personal data; and
• Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority.

US Privacy Laws

Laws in some US states, including California, Colorado, Connecticut, Utah, and Virginia, require us to provide residents with additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. You’ll find that information in this section (if you are a California resident, please note that this is the Notice at Collection we are required to provide you under California law).

In the last 12 months, we collected the following categories of personal information, depending on the Services used:

• Identifiers (like your name, contact information, and user directory identifiers);
• Commercial information (your billing information and purchase history, for example);
• Internet or other electronic network activity information (such as your usage of our Services);
• Geolocation data (such as your location based on your IP address);
• Inferences we make (such as likelihood of retention or attrition).

We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section. We retain this information for the length of time described in our How Long We Keep Information section.

In some US states you have additional rights subject to any exemptions provided by your state’s respective law, including the right to:

• Request a copy of the specific pieces of information we collect about you and, if you’re in California, to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, and the categories of third parties we share it with;
• Request deletion of personal information we collect or maintain;
• Request correction of personal information we collect or maintain;
• Opt out of any sale or sharing of personal information;
• Receive a copy of your information in a readily portable format; and
• Not receive discriminatory treatment for exercising your rights.

Right to Opt Out

We never directly sell your personal information in the conventional sense (i.e., for money).

We do not collect or process your sensitive (and potentially sensitive) personal information except where it is strictly necessary to provide you with our service, where the processing is not for the purpose of inferring characteristics about you, or for other purposes that do not require an option to limit under California law. We don’t knowingly sell or share personal information of those under 16.

Contacting Us About These Rights

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, reach out to use using any of the contact methods listed on our website.

When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.

Appeals Process for Rights Requests Denials

In some circumstances we may deny your request to exercise one of these rights. For example, if we cannot verify that you are the account owner we may deny your request to access the personal information associated with your account. As another example, if we are legally required to maintain a copy of your personal information we may deny your request to delete your personal information.

In the event that we deny your request, we will communicate this fact to you in writing. You may appeal our decision by responding in writing to our denial email and stating that you would like to appeal. All appeals will be reviewed by an internal expert who was not involved in your original request. In the event that your appeal is also denied this information will be communicated to you in writing. Please note that the appeal process does not apply to job applicants.

If your appeal is denied, in some US states (Colorado, Connecticut, and Virginia) you may refer the denied appeal to the state attorney general if you believe the denial is in conflict with your legal rights. The process for how to do this will be communicated to you in writing at the same time we send you our decision about your appeal.

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned above, please contact us through any contact method listed on our website.

Privacy Policy Changes

Although most changes are likely to be minor, Sol Inventum may change its Privacy Policy from time to time. Sol Inventum encourages visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by revising the change log below, and, in some cases, we may provide additional notice (like adding a statement to our homepage. Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

Conflict with the simplified version above

In the event of a conflict between the simple version of our Privacy Policy and this full version, the full text version will control. That’s it! Thanks for reading.

Change log

• June 06, 2023: Added link to our data processing addendum
• May 25, 2023: Clarification about what data gets sent for license retrieval
• May 1, 2023: Added Sentry as our error monitoring tool
• March 6, 2023: Added Crisp as our support tool
• February 1, 2024: Added Sentry, Helpscout, Paddle as a tool we use, Removed Crisp
• February 1, 2024: First version