1. Introduction

We are Soverin and Privacy is our core value! Here You can find information about how We only use the bare minimum of personal data and cookies to enable You to use the Service as agreed upon in the Terms and the Agreement. Please read this Privacy Statement carefully. If You have any questions regarding this document, please don’t hesitate to contact us. You can find our contact information in article 2.3 of the Terms.

2. Definitions

The terms used in this Privacy Statement have the meaning assigned to them in the Algemene Verordening Gegevensbescherming (hereinafter “AVG”;). This Privacy Statement qualifies as a processing agreement as referred to in Article 28 AVG. The applicability of any other processing agreements is expressly rejected.

2.1. Furthermore, the same terms as defined in the Terms apply to this Privacy Statement.

2.2. Soverin offers You the opportunity to purchase the Service, whereby Soverin may Process Personal Data for and on Your behalf in the performance of the Service. In this Processing of Personal Data, You may be designated as Controller, or if You Process the Personal Data for the benefit of a third party, as Processor. Soverin performs (depending on the capacity in which the You Process Personal Data) the role of Processor or sub-processor.

3. Purposes of the data processing

3.1. Soverin undertakes to Process (Verwerken) Personal Data (Persoonsgegevens) on Your behalf under the terms of the Agreement. The Processing shall only take place in the context of the performance of the Agreement as well as for the duration thereof, and such purposes that are reasonably related thereto or which are determined with further consent.

3.2. Soverin shall not Process Personal Data for any purpose other than as determined for You.

3.3. Soverin Processes Personal Data on Your behalf, and You and Soverin confirm that this data does not concern special Personal Data, Citizen Service Numbers or data relating to criminal convictions or criminal offences concerning criminal convictions or criminal offences.

4. Security

The security of Your data is extremely important to Soverin. Therefore, We took extensive measures to prevent theft, loss or any other abuse of Your data. We encrypt all data connections from and to our email servers. Additionally, we use a so-called recovery code, which will be sent to You when You sign up for Our Service. This recovery code can be used in case You forget Your password and don’t have access to the phone You used when You signed up for Soverin. The recovery code will enable You to sign in and subsequently alter Your password. Please store Your code safely, the code is personal and only provided to You, so Soverin does not keep a copy of the code.

5. Processed personal data

Soverin Processes the following Personal Data:

5.1. Mandatory data: this data is necessary in order to provide You with Our Service,

o You get to choose Your own email address. Depending on the email address You choose, this could be considered personal data.

o In order to provide the Service and to provide You with a Soverin email account, We offer You to keep Your recovery code safe and add Your phone number optionally.

5.2. Optional data: Soverin can supply You with a domain name, linked to Your email address. Soverin can administer this domain name for You. Depending on the domain name You choose, this can be considered personal data, for instance but not limited to a domain name that consists of Your name.

6. Data storage

6.1. At Soverin, You are in control of Your Personal Data at all times. The dashboard offers an overview of Your Personal Data. From Your dashboard You can change Your information or, if You desire, delete Your account. If You have any other questions concerning the processing of Your Personal Data, feel free to contact Us through support@soverin.net.

6.2. Soverin will store Your email, calendar and address entries for as long as You store it yourself. When You delete email it will be placed in the trash. If You empty the trash, Your email will be permanently deleted from Our servers, including Our backup servers. The backups of Our servers do contain copies of Your data, amongst which including email. However, these backups are encrypted with Your personally generated key, granting You exclusive access to Your data. This key will be erased when You delete Your account, so no one will be able to access Your backup. So to be extra clear; Soverin cannot access Your backup. Deleting Your account effectively erases all Your data from Our servers. This way You have full control of Your data at all times.

7. Obligations Soverin

7.1. Regarding the mentioned purposes in this Privacy Statement, Soverin will ensure compliance with the conditions which are, pursuant to the AVG, imposed on the Processing of Personal Data by Soverin.

7.2. Soverin shall inform You, at Your request and within a reasonable time, about the measures We have taken with regard to Our obligations.

7.3. Soverin’s obligations under this Privacy Statement shall also apply to those who Process Personal Data under the authority of Soverin.

7.4. Soverin shall notify You if, in Our opinion, Your instruction or use of the Service violates privacy laws and regulations.

7.5. Soverin ensures that all Soverin personnel required to access the Personal Data are informed of the confidential nature of the Personal Data and comply with the obligations set out in this Privacy Statement.

7.6. Soverin shall take reasonable steps at Your request and cost to assist You in meeting Your obligations taking into account the nature of the processing under this Privacy Statement, provided that Soverin reserves the right to reimbursement for the reasonable cost of any time, expenditures or fees incurred in connection with such assistance.

7.7. Soverin shall, at the end of the Agreement, upon Your request, securely destroy or return Your Personal Data.

8. Data transfer to third parties

8.1. Soverin will never share Your data with third parties, unless We are obligated to do so by law.

8.2. Soverin only Processes Personal Data in countries within the European Union. At Your request, Soverin shall inform You of the country or countries concerned.

9. Your rights

  • 9.1. You have the following rights under the AVG:

    • 9.1.1. Right of access: You can ask what Personal Data We use from You.

    • 9.1.2. Right to rectification: if Your personal data is not correct, You can ask Us to amend it.

    • 9.1.3. Right to erasure: in some cases You have the right to have Your personal data erased.

    • 9.1.4. Right to object: if You do not agree with Our decision on Your request to access Your data, you can object.

    • 9.1.5. Right to withdraw Your consent: in case You gave consent for Us to use Your personal data, You may also withdraw Your consent.

    • 9.1.6. Right to restriction of processing: You can ask Us to temporarily stop using Your personal data, for example because you want to wait for a decision on another request first.

    • 9.1.7. Right to data portability: You can ask Us to transfer Your personal data to another party.

10. Cookie Statement

Cookies are small files that the owner of a website places on a visitor’s device. For example, on a computer, laptop, smartphone or tablet. This allows the owner to collect or store information about the website visit or about (the device of) the visitor.

10.1. The only cookies We place on Your computer are so-called session cookies. These session cookies serve to remember Your session whenever You log in. These cookies are automatically erased whenever You close Your browser.

10.2. Optionally, Soverin uses a bare minimum of optional technical cookies that remember Your login credentials and settings after having logged off. You can accept these cookies by ticking the ‘remember me’ box in Your browser. These cookies can be removed by clicking ‘sign out’ on the Soverin website. We certainly do not like tracking, so We do not use tracking cookies.

11. Complaints and requests

11.1. In case You have a complaint regarding the way Soverin handles Your Privacy or if You would like to exercise any of the rights as mentioned in this Privacy Statement, please let Us know by sending an e-mail to support@soverin.net. We will get back to You within one month.

11.2. Should You have any questions after reading this Privacy Statement, feel free to contact Us through support@soverin.net.