February 26th 2019 - Version 1
Skotty is a web application.
Skotty facilitates secure emailing and sharing of files. With Skotty, you can send encrypted emails and files to all your email contacts, regardless of whether they use Skotty or not. All emails and shared files are secured with advanced end-to-end encryption so that only the sender and recipient can access the content of messages sent via Skotty. Skotty has no access to the correspondence of its users.
This Privacy Statement describes the personal data that is collected or generated (processed) when you use the services of Skotty and the Skotty website.
Skotty takes your privacy very seriously and will process and use your personal data in a safe way. To safeguard your privacy, Skotty always acts in accordance with the General Data Protection Regulation ("GDPR"). In this Privacy Statement Skotty explains which data it processes, and for what purpose.
Skotty is responsible for the processing of personal data as described in this Privacy Statement. Skotty is the private limited company Skotty B.V. Skotty is located in Prinses Marijkestraat 90, (5571 GP) Bergeijk and is registered in the Trade register of the Chamber of Commerce under number 66672643.
Skotty asks you as a user to share certain personal data in order to provide its services to you. This is the case, for example, when you create your Skotty Account on the Skotty website or contact customer service and helpdesk.
You need your own Skotty Account to be able to send messages with Skotty to your desired recipients. You register your Skotty Account on the Skotty website. When you are logged into your Skotty Account, your messages (sent and received) are displayed and you can see which files have been downloaded and uploaded, which messages have been read by the recipient and which users have been added or deleted. Using the message activity, you can keep control of all your file traffic and conversations.
In order to register your Skotty Account, Skotty collects the following personal data:
When you are logged in to your Skotty Account, you can send and receive messages to any email address. To send you messages, to receive messages intended for you and to help you identify your contacts, Skotty processes the following data:
When you take out a paid subscription on the Skotty services you will be redirected to the payment environment. In order to complete the payment you must fill in your payment details.
When you contact Skotty's customer service or helpdesk, Skotty processes your contact details and your question or complaint in order to handle it correctly.
In order to make Skotty's service and website work optimally (for example, to display web pages properly, to enable the chat function and to secure Skotty's services), Skotty collects the following automatically generated information about your use of Skotty:
We do not allow minors under the age of 16 to register their own Skotty Account without parental or guardian consent. However, we cannot verify this. If you suspect that your child under the age of 16 has registered a Skotty Account, we would appreciate it if you would inform us via firstname.lastname@example.org.
Skotty uses your personal data for the following purposes:
Skotty bases its processing of personal data on the following legal bases:
When you use Skotty, we need your personal data to execute our agreement with you.
We also rely on other legal bases, such as our legitimate interests as a company and/or to comply with a legal requirement.
Skotty will share your personal data as little as possible and solely with:
Skotty's website may contain hyperlinks that allow you to leave Skotty's website and enter a third party's website. Skotty has no control over the services and/or websites of third parties to which it links. The use of services and/or websites of third parties is subject to the privacy statements and conditions of these third parties.
Skotty uses a variety of technical and organizational security measures, including encryption and authentication tools, to protect your personal information from loss or unauthorized processing. In addition, Skotty uses a data minimization principle, we never store more data than necessary for the provision of our services. Skotty stores your email address and your Skotty Account information encrypted and your password only in hashed and salted form. Your conversations and files are subject to full end-to-end encryption, to which Skotty cannot gain access.
When you create your account, you will receive a recovery key that will allow you to access your messages and files and set a new password in case you lose your password. Skotty does not store this key and has no access to it. In case you lose your recovery key there is no way for Skotty to recover your messages and files. If you change your password without a recovery key, the existing messages and files in your account will be deleted. As a Skotty user, you are responsible for keeping your password and recovery key in a secure place only accessible to you.
For technical and operational reasons it may be necessary for your (personal) data to be processed on servers of Skotty's third party service providers. In some cases, these servers are located outside the European Economic Area. Because the regulations concerning data protection may not offer the same protection as in the European Economic Area, Skotty uses third party service providers that are certified under the EU-US privacy shield or imposes EU standard contractual clauses on these service providers to protect your privacy.
Skotty will not retain your personal data longer than is strictly necessary to fulfil the purposes for which your data is collected and to provide its services to you. This means that Skotty will keep your Skotty Account information and your inbox until you delete your Skotty Account. Once you delete your Skotty Account, all data on your account, including conversations and files, will be deleted immediately and irrevocably.
You have the right to access, correct or delete your personal data. You can do this yourself via the personal settings of your Skotty account. In addition, you may request us to (i) access your personal data; (ii) provide an electronic copy of your personal data (portability); (iii) correct your personal data if incomplete or inaccurate; or (iv) delete or limit your personal data under certain circumstances as provided by applicable law. These are not absolute rights. If we have obtained your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
If you would like to request a copy of your personal data or a request to exercise your rights, please contact us at email@example.com.
In order to verify that the request was made by you, we ask you to enclose a copy of your identity document with your request. In this copy, make your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and Burgerservicenummer (BSN) black/unreadable. This is necessary to protect your privacy.
Skotty will respond to your request as soon as possible, but in any case within four weeks.
Skotty would also like to point out that you have the possibility to file a complaint with the national Data Protection Authority. This can be done via the following link: https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons.
Unsubscribe from direct marketing
You can opt-out of receiving Skotty marketing messages by changing your email settings by clicking on the opt-out link or following the opt-out instructions in the message.
You can opt out of cookies by changing the settings of your Internet browser. This may result in the website no longer functioning properly.
This Privacy Statement may be amended to reflect changes in laws and regulations and/or the way we process personal data. The most recent version can always be found on our website. If we change the way we process your personal data, we will notify you in advance, or where required by law, seek your consent before implementing such changes. This Privacy Statement was last amended in February 2019.
If you have any questions about this Privacy Statement or wish to exercise your rights, please contact us by e-mail: firstname.lastname@example.org or by post: Skotty, Klokgebouw 146, 5617 AB Eindhoven.