Data processing agreement.

2.1 "UK GDPR"

means the United Kingdom General Data Protection Regulation as it forms part of the law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018, read with the Data Protection Act 2018.

"Data protection law"

means both, and any law that replaces them.

2.2 "Personal data", "processing", "controller", "processor", "data subject", "personal data breach" and "supervisory authority"

have the meanings UK GDPR gives them. The supervisory authority is the Information Commissioner's Office (ICO).

2.3 "The service"

means Mailbox MCP as described in the terms.

"Your AI client"

means the assistant or program you connect to the service.

"The account address"

means the email address on your account.

"Sub-processor"

means another organisation we use to process personal data under this agreement.

Hosting is on 365i, which is part of BSolve IT Limited, the processor: the servers are run by us, in London, so 365i is not a sub-processor. The data-centre operator behind them is a United Kingdom provider whose name we give on request, and it holds no key to any customer data.

3.1 Subject matter. Connecting a mailbox you own and, where you choose, a calendar and an address book, to your AI client, and acting on that mailbox, calendar and address book on the instructions your AI client relays from you; and, where you hold Team Access, doing the same for the AI client of each person you invite, at the level you set for them.

3.2 Duration. For as long as you hold an account. The processing of a mailbox ends when you remove it or revoke our access at your provider; the agreement ends when your account is closed, subject to clause 9.

3.3 Nature.

• Reading, searching, drafting, sending, replying to, forwarding, moving, deleting and flagging mail;
• reading the contents of attachments;
• reading and changing calendar events and availability;

• looking up and reading contacts in your address book, and creating, correcting, deleting and importing a contact in it on your instruction, each written to your own contacts server, your Outlook contacts or your Google contacts with a precondition:

  • a new or imported card can land on no existing card (on a CardDAV book, only where none sits at the address it is given; on Outlook or Google contacts, under an id Microsoft or Google mints, an imported card skipped where the book already holds its first email address), and
  • a correction or a deletion is written against the revision of the card as it was just read and refused rather than written over where the card changed in the meantime (on Google contacts a deletion is checked against that revision immediately before it is sent, because Google accepts no condition on the deletion itself).

Each action is taken on an instruction and completed against your provider in the same request. Message content, calendar content and contact content pass through our server in memory and are not stored.

A contact is held in memory for 10 minutes after it was last used and is dropped by the next sweep, which runs every minute, so it is gone within 11 minutes of its last use, whether it was read from the book or written to it. That is what lets a second question about the same person be answered without fetching the card again.

3.4 Purpose. To provide the service to you as described in the terms, and for nothing else. We do not use personal data processed under this agreement to train anything, to profile anybody, or for our own purposes.

4.1 Types of personal data.

• The content and metadata of email messages and their attachments, in transit through the service while a request is served: senders, recipients, subjects, bodies, dates, headers and files.
• Calendar entries and availability: events, times, attendees and their responses, and the free and busy blocks of people whose availability you ask about.

• Contacts in your address book, in transit while a request is served, whether read from the book or written to it on your instruction: names, email addresses, phone numbers, postal addresses, employer, job title and any note on the card.

  On a look-up the photograph is not requested and is discarded if a server sends it; on a CardDAV card you ask us to correct, the whole card, photograph included, passes through in memory for that one request and is written back exactly as it was, never shown to your assistant and never held; on an Outlook or a Google contact it is never requested.

  Where you ask us to import a contacts file, the file is read from your own mailbox as the attachment it arrived as, its cards written to your address book in small batches, and the file kept nowhere.

• Your account details: the account address, the mailbox connection settings, and a credential per mailbox and per connected calendar and address book, held encrypted.

• Routines you save on a mailbox's Routines tab: each routine's name, the name of its scheduled task in your AI client, which AI client runs it, the days, time and time zone it runs at, and the choices you made for it.

  The choices can include email addresses or @domains you list, such as people to put first or never to mention, and an instruction in your own words, which can name people. They are your own instructions, never taken from your mail.

  A routine is held so the Routines tab can show it again, let you change or remove it, and say whether it ran. It is kept until you remove it or its mailbox, and is then deleted at once; on closure it goes at once with the account (clause 9.2).

• A record of each call your AI client makes: the tool, when, which mailbox, whether it worked, who made it, and the IP address it came from. Never the contents of a message.

• Where you hold Team Access:

  • the email address and the name you give us for each person you invite, with the level, calendar switch, cap and mailboxes you set;
  • the record of which message on a shared mailbox a person holds or has asked to have approved, naming the mailbox, the folder, the message and the person and never its contents; and,
  • from the day the tier is bought, the domains your account has written to, from any mailbox and by anybody, domains only and never addresses.

4.2 Categories of data subject.

• You, and your staff or colleagues who use the service.
• People you invite under Team Access, who use the service on your mailboxes through their own account, at your invitation.
• Your correspondents: anybody who writes to your mailbox or is written to from it, and anybody named or copied in that mail.
• People named in your calendar, and people whose availability you ask about.
• People in your address book.
• Anybody else whose personal data appears in your mail, your diary or your address book.

4.3 Special categories. The service does not need any special category data and asks for none. Where your mail contains it, it passes through in the same way as everything else and is not stored.

5.1 Instructions. We process personal data only on your documented instructions, which are the terms, this agreement, and the instructions your AI client relays to the service, unless the law of the United Kingdom requires otherwise, in which case we tell you before processing unless the law prohibits that. If we think an instruction infringes data protection law we tell you.

5.2 Confidentiality. The servers are administered only by the people who run the company, each of whom is bound to keep personal data confidential. Nobody reads your mail, your diary or your address book except where you have asked us to look at something specific, or where investigating a fault or abuse requires it.

5.3 Security. We maintain the technical and organisational measures in Schedule 2, which are described in full on the security page and in the privacy policy, and we keep them appropriate to the risk. The measure that matters most is structural: no message content is stored, so there is no archive of your mail here to protect or to lose.

5.4 Sub-processors. You authorise the sub-processors listed on the IT and security page, with what each does and where: the payment processor, the data-centre operator behind our servers, and the two that run the uptime monitor, deliver its alerts, and handle a support request sent from the control panel.

We bind each one by written terms that impose data protection obligations on it, and we remain responsible to you for its performance. We give 30 days' notice of any addition or replacement, by email to the account address.

If you object, you may close your account within that 30-day notice period; where you do, we refund the unused part of any paid period, as the terms provide when we end the agreement without cause. This clause prevails over the terms and the refunds policy on this one point.

5.5 Assistance. We help you respond to a data subject exercising their rights, so far as we can: we hold no message content, so a request about mail is answered from your own mailbox, and we can supply the account records and the call records we hold about you. We help with a data protection impact assessment, and with any prior consultation with the ICO, so far as the information is ours to give.

5.6 Deletion. When you remove a mailbox or disconnect a calendar or an address book, its credential is deleted at once.

When you close your account, your account details and every credential are deleted at once, and so are the record of each call and the audit record for every mailbox on the account at closure. An audit entry belonging to a mailbox you removed before closure is kept until it is 400 days old, since the record outlives the mailbox and no choice attaches to it.

Web server logs are deleted after 90 days. While your account is open, the audit record's retention period is 400 days unless you have chosen a shorter one for your account under Settings in the control panel, which may be any whole number of days from 90 to 400, and the record of each call is kept 90 days.

Payment records are kept as long as UK tax law requires. There is no message content to delete. Clause 9 sets the timeline out in full.

5.7 Demonstrating compliance. We make available the information needed to show that these obligations are met: this agreement, the security page, the privacy policy, the threat model, and written answers to reasonable questions.

We allow an audit by you or an auditor you appoint, on 30 days' notice, at your cost, no more than once in any 12 months unless a personal data breach affecting your data requires one, conducted at a time and in a way that does not disrupt the service and does not expose any other customer's data.

5.8 People you invite. Where you hold Team Access and invite a person to a mailbox, the invitation is your instruction to us to give that person the access you set and no more, and we act on the calls their AI client makes as we act on yours, as your processor.

We bind the invitation to the email address you give, refuse acceptance from any other account, record every call the person makes under their name so you can see it, and end every connection they hold when you remove them, in one action.

You are responsible for choosing the people you invite, for the level, calendar access and cap you set for each, for the instructions they give their AI client on your mailboxes, and for removing them when their access should end.

For a person's own account with us we are a controller in our own right, as clause 1.4 says of yours, and the privacy policy tells them what you can see of what they do.

6.1 Where a personal data breach affects your data, we notify you without undue delay and within 72 hours of confirming it, by email to the account address, saying what was affected, what we know about how, what we have done, and what you should do. Where the law requires it, we notify the ICO within 72 hours of becoming aware.

6.2 We keep a record of every personal data breach, cooperate with you in responding to it, and give you the information you need to meet your own obligations to data subjects and to the ICO.

6.3 Because message content is never stored, a breach of our systems cannot expose an archive of your mail.

What it could expose is the encrypted credentials and the account records and, for a contact asked about or written shortly before, the card then held in memory, which lives for about 10 minutes after its last use and is then dropped (clause 3.3 states the exact period); the notification would say which, and would tell you to revoke the credentials at your provider, which you can do without us.

7.1 Personal data processed under this agreement is processed in the United Kingdom: the service, the control panel, this website, the database, its nightly backup and the off-site copy of that backup are all hosted in the UK.

7.2 The one transfer outside the UK is payment. Card details are entered on Stripe's systems and never reach ours, and Stripe processes them in the United States and the European Union under its own data processing agreement and its own transfer mechanism.

7.3 Your mail provider, your calendar provider, your contacts provider and your AI provider are your own choices and your own arrangements. Where any of them is outside the UK, that is a transfer you make, not one we make on your behalf.

8.1 The liability clause in the terms of service applies to this agreement, and nothing here limits any liability that cannot lawfully be limited.

8.2 On the subject of data protection this agreement prevails over the terms where the two conflict. On every other subject the terms prevail, with the one exception clause 5.4 states.

8.3 This agreement is governed by the law of England and Wales, and the courts of England and Wales have jurisdiction, as the terms provide.

9.1 This agreement ends when your account is closed, by you or by us under the terms. Clauses 5.6, 6 and 9 survive it for as long as we hold anything under it.

9.2 On closure, deletion runs on this timeline:

9.3 There is nothing to return: we hold no copy of your mail, your diary or your address book, and the activity record is yours to export as a CSV from the control panel at any time before closure.

Each of these is described in full, with what it does not cover, on the security page, in the privacy policy and on the IT and security page. They are summarised here so the agreement is complete on its own.

• No stored content. Message, calendar and contact content pass through the server in memory while a request is served and are not written to disk. A contact is held in memory for about 10 minutes after its last use and then discarded (clause 3.3 states the exact period); the process writes no core file, so memory cannot reach a disk that way either.
• Encryption in transit. TLS between your AI client and the service, on the control panel and on this website; Microsoft 365 and Google reached on fixed encrypted endpoints. A custom IMAP host uses the ports you give, as a desktop mail client would.
• Encryption at rest. Every stored credential encrypted with AES-256-GCM under its own key, wrapped by a master key held outside the database and the source code; each credential bound to its mailbox. Passwords stored as Argon2id hashes; client tokens stored only as hashes.
• Access control. A 12-character minimum password, two-factor authentication available and, at your option, required of every person on your account, a browser signed out after 30 minutes without activity with the session behind it expiring after 7 days idle or 30 days at most and listed under Settings until it does, a permission level per connection enforced on every call, and revocation from your own side at any time.
• Audit. Every call logged per customer for 400 days by default, or the shorter period from 90 days the customer has chosen for their account, and exportable as CSV from the control panel; never the contents of a message.
• Backups. Nightly, encrypted under a separate key, 14 nights kept, a verified copy filed off the machine each night in the UK, the restore tested every week.
• Monitoring and disclosure. An independent uptime monitor on a different provider with a public status page; a security.txt naming the disclosure address; a published threat model.
• Personnel. Servers administered only by the people who run the company, under a duty of confidentiality.