Privacy Policy

At Email PA, we respect your privacy and are committed to protecting your personal data. This privacy policy tells you about how we look after your personal data when you visit our website or otherwise work or communicate with us and it tells you about your privacy rights and how the law protects you.

1. Important information and who we are

1.1 Purpose of this privacy policy

This privacy policy aims to give you information on how Email PA collects and processes your personal data through your use of our website, our Email PA services or otherwise when you communicate or interact with us in the course of business.

1.2 Controller

If you are a registered customer of Email PA, we act as the "data controller" of personal data about you and your use of Email PA, but as the "data processor" of personal data in the information you submit to Email PA to use Email PA's product and services (like information about your emails and email accounts). If we are the data processor of your personal data (i.e., not the data controller), please contact the controller party in the first instance to address your rights with respect to such data.

If you have any questions about this privacy policy, including any requests to exercise your legal rights referred to below, please contact us using the details set out below.

1.3 Contact details

Email PA is a service provided by Lextronica, Inc., a Delaware corporation. If you need to get hold of us for any reason in connection with your personal data, please email us at info@emailpa.com.

If you have concerns about our privacy practices, we would appreciate the chance to address them before you contact any regulatory authority. For users in the European Economic Area, you have the right to make a complaint to your local data protection supervisory authority. For users in California, you may contact the California Attorney General's office regarding privacy concerns.

1.4 Changes to the privacy policy and your duty to inform us of changes

This version was last updated on 30th September 2024. If you use our website or the Email PA services after any changes to this privacy policy have been posted, that means you agree to all of the changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. The data we collect about you

We may create aggregated, de-identified or anonymized data from the personal data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Email PA services and promote our business, provided that we will not disclose such data in a manner that could identify you.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

5. Data shared with third-party AI models

5.1 Data Shared with AI Models

In order to provide email categorization and draft reply functionalities, our service employs machine learning models using third party AI models. We require our AI service providers to use your information only for the purpose of providing our Service. We do not allow those providers to train their AI models using your data.

The following data types may be shared with these AI models:

This data is processed for the sole purpose of delivering the services described and is not used for any other functions within the AI models.

5.2 User Consent for Data Sharing with AI Models

Before sharing any of your data with our AI models, we seek explicit user consent. Upon initial setup or significant changes to this privacy policy, a prompt will appear within the app requiring users to consent to data sharing for AI processing.

5.3 Third Party Data Retention

We have a Zero Data Retention agreement with our AI service provider in which our provider does not store customer API data on their servers.

6. Disclosures of your personal data

We will need to share your personal data with the parties set out below for the purposes set out in paragraph 4 above:

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

A number of our account managers and other IT service companies processing your personal data on our behalf are based in the US or elsewhere outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that either:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, you can ask us to delete your data (see below for further information).

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

Depending on your location, you may have certain rights regarding your personal data:

For users in the European Economic Area (GDPR)

You have the right in certain circumstances to:

For California residents (CCPA/CPRA)

If you are a California resident, you have the right to:

Exercising your rights

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month (or 45 days for California residents). Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.