Provided for orientation only. The numbered sections set out the information required under Article 13 GDPR.
We collect as little as the service permits, and this notice states what that is. Messages and attachments are encrypted in storage and we cannot read their content. We hold what an email service must hold in order to operate and to invoice.
We do not track you and we do not sell information about you. On termination you may request deletion of your account contents.
black.com GmbH, Am Belvedere 8, 1100 Vienna, Austria is the controller within the meaning of Article 4(7) GDPR for all processing described in this notice.
Inquiries concerning this notice, including the exercise of the rights set out in section 13, should be addressed to us via email.
Our server records a log entry for each request, comprising the page requested, the browser and operating system used, the referring page, the time of the request, and the IP address. This serves the security and functioning of the site and the analysis of its use. IP addresses constitute personal data, so the legal basis is our legitimate interest in operating a secure and functioning website (Article 6(1)(f) GDPR).
Log entries are deleted after at most 30 days. We employ no cross-site analytics and no advertising trackers.
Cookies are used only where the site cannot function without them. There are no tracking cookies, no advertising cookies and no profiling. The legal basis is our legitimate interest in a functioning website (Article 6(1)(f) GDPR).
Cookies may be refused in your browser settings, in which case parts of the site will cease to function.
Registration requires your name, the address you select, your passkey and your mobile phone number. Paid plans additionally require payment details. All of it is necessary in order to provide the service, so the legal basis is performance of the contract with you (Article 6(1)(b) GDPR).
You are not obliged to provide any of it. Without it an account cannot be opened, as a mailbox can be neither operated nor invoiced.
What we cannot access. Messages and their attachments are encrypted in storage and the key is derived from your passkey. We retain no copy of that key and are therefore unable to read the content of your stored messages, attachments and files.
What we hold for the duration of the account: your account details, your phone number, payment records on paid plans, and the routing information that email carries in order to be delivered at all. Sign-in records are kept for the shorter period set out in section 12.
Free and paid accounts are treated identically in this respect. Payment affects storage and limits, never what is visible to us.
We do not upload or synchronize your device's address book. Contact access is used locally for address suggestions. Addresses you select are processed as recipients of your drafts and emails.
Where you grant our iOS or Android application access to your contacts, the application searches them on your device in order to complete email addresses in input fields as you type. Your contacts are not transmitted to our servers, and we neither import nor store them. An address you select is inserted into the message you are composing, and from that point is processed as a recipient of that draft and of the email sent from it, exactly as an address you type yourself would be.
The legal basis for access to your contacts is your consent (Article 6(1)(a) GDPR), given through the permission dialog on your device. You may withdraw it at any time in your device settings, which ends the local address suggestions. As nothing is uploaded, there is no imported contact data for us to delete.
Our applications do not access location data. The application stores may collect their own anonymous installation statistics under their respective privacy policies.
An item moved to Trash is not deleted until it leaves Trash. This occurs automatically after 30 days, or immediately if you empty Trash yourself.
Where you contact us, we process what you send in order to respond. The legal basis is our legitimate interest in operating a functioning contact channel (Article 6(1)(f) GDPR).
Correspondence is deleted once concluded, ordinarily within six months, unless you have written again in the interim.
We send email concerning your own account: security, invoicing, changes to the service, and anything you have requested. This forms part of the performance of the contract (Article 6(1)(b) GDPR).
We send occasional email informing you about new features of and changes to the service you use. These emails are informational: they do not advertise paid plans, partner offers or other products. They are turned on when your account is created, and you can turn them off at any time in your settings.
The legal basis is our legitimate interest in informing our own customers about our own service (Article 6(1)(f) GDPR). You may object at any time (Article 21 GDPR); switching the setting off gives effect to that objection.
A mobile phone number is required in order to open an account. We use it for the security of your account and to prevent abuse. It is not used for marketing, and it is not disclosed for advertising purposes.
Security codes. We send a one-time code by SMS when you register, when you change your phone number, when you set up account recovery, and when you initiate a recovery. The legal basis is performance of the contract and our legitimate interest in securing accounts (Article 6(1)(b) and (f) GDPR), or your consent where the law so requires. The codes are transmitted through the messaging provider named in section 10.
Your number is deleted together with the remainder of your account data.
How to stop SMS messages from us, and the charges your own provider may apply to them, are set out in our terms of service.
We do not sell your data and do not disclose it for advertising purposes. Disclosure occurs only in the following cases.
Third parties with whom we share personal data provide the same or an equivalent level of protection as described in this policy. We verify these protections before sharing data.
Hosting. Our email servers are operated on our behalf by Akenes SA, Boulevard de Grancy 19A, 1006 Lausanne, Switzerland ("Exoscale"), in a data center in Zurich, Switzerland, acting on our instructions. The content held there is encrypted, and Exoscale is likewise unable to read it.
Attachments. Attachments are stored in encrypted form with Cloudflare, Inc., 101 Townsend Street, San Francisco, California 94107, USA ("Cloudflare"), using Cloudflare R2, acting on our instructions. The content is encrypted, so Cloudflare is likewise unable to read it. When you download an attachment, Cloudflare necessarily processes the connection data that any download involves: your IP address, your browser and device information, and the time of the request.
Payment. On paid plans we transmit the data a payment requires to Stripe Payments Europe Ltd, The One Building, 1 Lower Grand Canal Street, Dublin 2, Ireland: name, email address, postal address and payment details. Stripe acts in part on our instructions and in part as its own controller, under its privacy policy at https://stripe.com/privacy.
In-app purchases. Where you purchase a plan in our iOS or Android application, the payment is processed by Apple or Google as independent controllers, under their own privacy policies. We receive the status of your purchase and subscription, not your payment details.
SMS. Security codes are transmitted through Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg, acting on our instructions. Your number is used for no other purpose by that provider.
Push notifications. Where you allow notifications in our iOS or Android application, they are delivered through the Apple Push Notification service or Google's Firebase Cloud Messaging. For this purpose Apple or Google receives a device token identifying your installation of the application, together with the notification. Push providers receive delivery metadata and notification identifiers, but not the contents of your emails.
Artificial intelligence. Where you use an AI feature, the data visible in the interface for that request is transmitted to the provider performing it: the draft being composed, the sender name and the recipient addresses. The provider is Venice.ai, Inc., 1309 Coffeen Avenue, Suite 14343, Sheridan, Wyoming 82801, USA ("Venice"), acting on our instructions, under its privacy policy at https://venice.ai/legal/privacy-policy. These requests use end-to-end encrypted models, so that the content of the request is not readable by the provider.
Banks and authorities. Payments are executed through banks. Where an authority with jurisdiction over us issues a lawful and properly founded request, we comply with it and disclose the information we hold. Given the encryption described in section 4, that is generally account and routing information rather than the content of stored messages. Where the law prohibits us from informing you that a request has been made, we will not do so.
Email is stored in Switzerland, on servers operated on our behalf by Exoscale. Switzerland is the subject of a European Commission adequacy decision (Decision 2000/518/EC of 26 July 2000), whose continued validity the Commission confirmed on 15 January 2024, so that transfer requires no further safeguards.
Attachments are stored in encrypted form with Cloudflare, separately from the email servers.
Where we transfer data to a country outside the EEA and Switzerland, we do so on the basis of an adequacy decision of the European Commission, such as the EU-US Data Privacy Framework where the recipient is certified under it, or of standard contractual clauses approved by the Commission. You can request a copy of the relevant safeguards via email.
Account contents. An account is not deleted automatically for as long as a paid subscription is active, or for as long as, on a free account, the phone number is re-verified once a year.
When a paid subscription ends, we downgrade the account to a free plan where that is possible. Where the account cannot be downgraded, for example because the data stored exceeds the free allocation, the account and its contents are deleted 12 months after that condition arises.
If the yearly verification of your phone number is not completed by its due date, we give you a grace period of at least 6 months from that date before deleting the account and its contents. Re-verifying your phone number during the grace period prevents deletion for this reason.
We notify you before either of these automatic deletions, and the deletion is canceled if in the meantime the account again satisfies the conditions above.
You may request deletion of your account contents at any time. We carry it out after a security hold of 14 days, during which the request can be canceled, so that a third party who has obtained access to your account cannot destroy your data before you are able to intervene. A request for erasure under Article 17 GDPR is dealt with separately and without undue delay.
We may retain data for longer where this is necessary to establish, exercise or defend legal claims (Article 6(1)(f) GDPR).
You may exercise the following rights at any time, and we respond within one month.
These rights are subject to limitation, for instance where compliance would disclose the personal data of another person.
You are also entitled to lodge a complaint with the Austrian Data Protection Authority: Österreichische Datenschutzbehörde, Barichgasse 40-42, 1030 Vienna, dsb@dsb.gv.at, +43 1 52 152-0. Forms are available at https://www.dsb.gv.at/dokumente.
This notice may be amended. The version published at the time of your visit applies. Where an amendment is material, account holders are notified by email.