Privacy Policy
This Privacy Policy explains how OpenEmail SA ("Origin", "we", "us", or "our"), a company based in Switzerland, collects, uses, and protects your personal data when you use Origin (the "Service").
We are committed to protecting your privacy. We comply with the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR).
If you have any questions, contact us at [email protected].
1. Who we are
OpenEmail SA. Via Ernesto Bosia 5c, 6900 Paradiso, Switzerland.
For the purposes of the FADP and GDPR, we are the "controller" of your personal data.
2. What data we collect
We collect the following categories of data:
Information you give us:
- Account information: name, email address, password, and any profile details you provide.
- Content you create: messages, files, and other content you send or share through the Service.
- Communications: messages you send to our support team and any feedback you provide.
Information we collect automatically:
- Usage data: how you interact with the Service, features used, and timestamps.
- Device and technical data: IP address, browser type, operating system, and device identifiers.
- Cookies and similar technologies: see Section 8.
We do not intentionally collect special categories of data (such as health, religious, or biometric data). Please do not share such data through the Service unless necessary.
3. How we use your data
We use your data to:
- Provide, operate, and maintain the Service.
- Create and manage your account.
- Enable you to connect and communicate with other users.
- Respond to your requests and provide support.
- Improve and develop the Service.
- Send you service-related communications (for example, security alerts and account notices).
- Detect, prevent, and address fraud, abuse, and security issues.
- Comply with legal obligations.
4. Legal bases for processing
Where the GDPR applies, we rely on the following legal bases:
- Performance of a contract: to provide the Service you sign up for.
- Legitimate interests: to operate, secure, and improve the Service, where these interests are not overridden by your rights.
- Consent: for optional cookies and any marketing communications. You can withdraw consent at any time.
- Legal obligation: where we are required to process data by law.
5. How we share your data
We do not sell your personal data. We share data only in these circumstances:
- With other users: content you choose to share and your profile information are visible to users you interact with.
- With service providers (processors): third parties that help us operate the Service (for example, hosting, infrastructure, and analytics providers), under contracts that require them to protect your data.
- For legal reasons: where required by law, court order, or to protect our rights, users, or the public.
- Business transfers: in connection with a merger, acquisition, or sale of assets, subject to this Policy.
A current list of our key service providers is available on request.
6. International data transfers
We are based in Switzerland and our users are global. Your data may be transferred to and processed in countries outside your own, including outside Switzerland and the European Economic Area.
Where we transfer data internationally, we use appropriate safeguards, such as the European Commission's Standard Contractual Clauses and the Swiss Federal Data Protection and Information Commissioner's recognized transfer mechanisms.
7. Data retention
We keep your personal data only as long as necessary to provide the Service and for the purposes described in this Policy. When you delete your account, we delete or anonymize your personal data within a reasonable period, unless we are required to retain it for legal or operational reasons.
8. Cookies
We use cookies and similar technologies to operate the Service, remember your preferences, and understand how the Service is used. You can control non-essential cookies through your browser settings or any cookie controls we provide. Essential cookies are required for the Service to function.
9. Your rights
Depending on where you live, you may have the right to:
- Access the personal data we hold about you.
- Correct inaccurate or incomplete data.
- Delete your data.
- Restrict or object to certain processing.
- Receive your data in a portable format.
- Withdraw consent at any time.
- Lodge a complaint with a supervisory authority. In Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC). In the EEA, this is your local data protection authority.
To exercise any of these rights, contact us at [email protected]. We will respond within the timeframes required by law.
10. Security
We use technical and organizational measures to protect your data against unauthorized access, loss, or misuse. No system is completely secure, so we cannot guarantee absolute security.
11. Children
The Service is not intended for anyone under the age of 16. We do not knowingly collect data from children. If you believe a child has provided us with personal data, contact us and we will delete it.
12. Changes to this Policy
We may update this Policy from time to time. If we make material changes, we will notify you through the Service or by other means. The "Last updated" date at the top shows when this Policy was last revised.
13. Contact us
If you have questions or concerns about this Policy or your data, contact us at:
OpenEmail SA. Via Ernesto Bosia 5c, 6900 Paradiso, Switzerland. [email protected].