Privacy Policy

This Privacy Policy govern your relationship with Shimo VPN (the “Service” or "Application") operated by Mailbutler GmbH (“us”, “we”, or “our”), Welserstraße 10-12, 10777 Berlin

By agreeing to the Terms and/or using the Websites or the Applications, you particularly agree to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. We may collect and/or you may be asked to provide us with your information (including personal information) any time you are in contact with us or use the Applications or the Websites.

We value your privacy and will never sell your information to anyone without your knowledge and consent.

Please read this Privacy Policy in order to learn more about the data we collect, what do we use it for and how we protect your privacy.

Responsible Contact

The responsible contact is Mailbutler GmbH, Belzigerstr. 69/71, 10823 Berlin. If you have any questions concerning privacy policy matters, please contact: info@shimovpn.com.io. By contacting this email address, you can inquire into privacy issues and review, change, or delete your personal information stored by us. Alternatively, you can also contact us using the above postal address.

Reasons for collection of information

We may use the information we collect from Shimo and our website to provide, maintain, protect and improve Shimo and to communicate with you about your use of the Application.

Personal data

Personal data is any individual information about the personal or material circumstances of a specified or identifiable natural person. Personal data primarily includes details such as a person’s name, postal address or e-mail address.

Processing and use of personal data

Order and payment information

In order to process orders we require all relevant personal information, such as your name, address, email address, company name, VAT ID and information concerning the payment method you have chosen. Payments are handled securely by our payment providers Paddle.com. These partner companies have their own data protection policies. We encourage you to read these policies thoroughly before using the Service, and check that you agree with them. To enable payments to be processed and invoiced, the partner company stores references to payment details. The actual payment details (including credit card and bank details) do not pass through our servers and systems.

Shimo information

In order to guarantee full functionality of all Shimo features and to deliver high level of customer service for you we may collect and store:
(a) your e-mail address. We process this type of personal data in order to sell, market our Services to you, to create an account for you and to provide you our Services. We process this type of Personal Data based on the consent you expressly grant to us at the time we collect such personal data.
(b) anonymous information about your Shimo usage, including date and time when you used Shimo. We process this type of data in order to see anonymous usage analytics. We process this type of Personal Data for our legitimate interests in providing the Services.

Cookies of third party providers and tracking

We use the services of other companies to optimize our websites and our services. You will receive an overview of the services we use in the following section.

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, text files stored on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. We use Google Analytics with the add-on “_anonymizeIP()” so that the IP addresses later transmitted to Google are shortened and modified in advance on the European servers to prevent any direct references to particular persons. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage to the website operator. Your IP address, which has been transmitted by Google Analytics, will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use all functions of this website. Furthermore, you can prohibit Google from collecting and analyzing the cookie generated data about your use of the website (including your IP address) by downloading and installing the browser plugin available [here] (http://tools.google.com/dlpage/gaoptout?hl=en).

Google Remarketing

Our websites use Google’s remarketing technology. This technology enables users who have already visited our online services and shown interest in our services to see targeted advertising on the websites of the Google partner network. Likewise users that are similar to the visitors of our websites can be addressed. The advertising will be displayed using cookies. These are small text files saved on the user’s computer. The information generated by the cookie about the website use will be transmitted to and stored on servers in the United States by Google. In the event that the IP address is transferred, it will be reduced by the last 3 digits. Using cookies, the user behavior on a website can be analyzed and subsequently utilized to provide targeted product recommendations and advertising based on the user’s interests. If you would prefer to not receive any targeted advertising, you can deactivate the use of cookies for these purposes through Google by visiting the website: https://www.google.com/settings/ads/. Alternatively, users can deactivate the use of cookies by third party providers by visiting the Network Advertising Initiative’s deactivation website (http://www.networkadvertising.org/choices/). Please note that Google has its own data protection policy which is independent of our own. We assume no responsibility or liability for their policies and procedures. Please read Google’s privacy policy before using our websites (https://www.google.com/intl/en/policies/privacy/).

Third party websites and services

Our website and service provides links to other websites and services, we do not review these sites and services, and therefore this Privacy Policy does not apply to third party websites and services. Please read their Privacy Policy before submitting any private information.

Data Processing (GDPR / DSGVO)

For European individuals, GDPR expands their data privacy rights and gives them more power to control their data. GDPR also requires compliance from companies that process the personal data of these European individuals. Ensuring our users’ data privacy and security has always been top priority to our's product development and business. As your service provider to enhance your email experience, we make sure to evaluate all our practices to safeguard your information as effectively as possible. As a German company, Shimo is fully GDPR compliant. If you have any questions about GDPR or our data practices generally, please contact our data protection officer Tobias Knobl (tobias@mailbutler.io).

Authorized employees

We ensure that all authorized employees who can access personal data are made aware of the confidential nature of personal data and have executed confidentiality agreements that prevent them from disclosing or otherwise processing, both during and after their engagement with Mailbutler GmbH, any personal data except in accordance with their obligations in connection with the Services.

Authorized subcontractors

We may engage authorized Subcontractors to access and process personal data in connection with the Services and from time to time engage additional third parties for the purpose of providing the Services, including without limitation the processing of personal data. A list of current authorized subcontractors (the “List”) is available at https://feingeist.freshdesk.com/support/solutions/articles/6000197860-list-of-sub-processors (such URL may be updated by us from time to time). At least ten (10) days before enabling any third party other than authorized subcontractors to access or participate in the processing of personal data, we will add such third party to the List.

Duration of Processing

We retain personal data about you for as long as you have an open account with us and for 1 years after you close your account. In some cases we retain personal data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.

Security of personal data

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we maintain appropriate technical and organizational measures to ensure a level of security appropriate to the risk of Processing Personal Data.

Access personal data

You can request more information about the personal data we hold about you and request a copy of such personal data by contacting us via email info@shimovpn.io

Erase personal data

You can request that we erase some or all of your personal data from our systems.

Portability of personal data

You can ask for a copy of your personal data in a machine-readable format. You can also request that we transmit the data to another service.

Data processing agreement

If you are using Shimo as a customer and have agreed to our terms of service, you do not need to sign an additional Data Protection Agreement. If you are a partner or a customer who needs further documentation of compliance with Mailbutler GmbH acting as a Processor, we offer Data Processing Agreements (DPAs) to users upon request. Please download a copy of our DPA (https://mailbutler-data.s3.amazonaws.com/downloads/Data-Processing-Addendum-Shimo.pdf). For documentation purposes, please email us back with your signed copy of the DPA to info@shimovpn.io. Please note that our DPA has been tailored to the way we provide service.

Protecting your information

We take the security of your personal information very seriously and have implemented policies and procedures, including technical measures, that are designed to help safeguard it. While we strive to use best practices to protect your personal information, the Internet and computer technology are not 100% secure and we cannot absolutely ensure the security of any personal information that you provide to us. In line with this philosophy, we try to get as little information from you as possible.

Reasons for information disclosure

We do not sell, rent, loan, or lease your contact information to others, unless we have your specific permission to do so or we are required by law or litigation to disclose your personal information. We may also find it necessary to disclose information about you if we determine that it is an issue concerning national security, law enforcement, or other issues of public importance.

Changes to this data protection policy

We reserves the right to adapt its security and data protection measures, provided this is necessary as a result of technical or legal developments. In these cases, we will also update our data protection information accordingly. Please make sure, therefore, that you always use the latest version of our data protection declaration.

Privacy questions and contact

If you do not want us to keep you up to date with our news, you are free to contact us at any time and have your e-mail address removed from our mailing list.
We do not target any information towards children.
If you have any comments or concerns about our Privacy Policy, please contact us (info@shimovpn.io).

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Any changes will be placed here and the amended version will supersede this version of our Privacy Policy. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected. We will take reasonable steps to draw your attention to any changes in our Privacy Policy. However, to be on the safe side, we suggest that you read this document each time you use the website to ensure that it still meets with your approval.
If we make changes in the way we use your email address, we will notify you in advance of posting by email. Such modifications will become effective on the date set forth in the email.

Please contact us if you have further questions or any concerns regarding our privacy policy. info@shimovpn.com

Last updated: June 20, 2018