This Privacy Policy describes how Cyber Risk Research LLC d/b/a Sangu Mail (“Sangu,” “we,” “our,” or “us”) collects, uses, and discloses personal information about you as well as your rights and choices regarding such information. For purposes of this Privacy Policy, unless otherwise stated, “information” or “personal information” means information relating to an identified or identifiable individual, and does not include aggregate information or information that does not identify you.
Some regions provide additional rights by law. For region-specific terms, please see below.
For our contact details, please see the “Contact Us” section below.
Data protection laws distinguish between entities that control the purposes and means of processing information and entities that process information on behalf of other entities.
This Privacy Policy applies to information where we control the purposes and means of processing, and governs any online services we control that link to this Privacy Policy (the “Service”). Please remember that your use of the Service is also subject to our Terms of Use.
A. Information You Provide.
We collect information you provide to us, such as information you provide when you register an account, use the Service, update your profile, make a purchase, sign-up for our newsletters, participate in a promotion, respond to our surveys, or contact support, or apply for a job. The categories of information we collect include:
We collect the following information if you apply for a job via the website:
Please do not provide any information that we do not request.
B. Information We Collect from Your Use of the Service.
C. Information from Your Browser or Device.
When you use the Service (including when you visit our websites or apps, or open or click on our emails), we and third parties we work with automatically collect information from your browser or device. The categories of information we automatically collect include:
The types of tracking technologies we use to automatically collect this information include:
D. Information from Other Sources.
We also collect information from other sources. The categories of sources from which we collect information include:
E. Information We Create or Generate.
We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics.
F. Google API
To access your email to be processed by us, we ask for authorization to access your Google email account(s) using Google’s OAUTH2 mechanism.
1. Who is requesting Google user data? We, Cyber Risk Research, owners of Sangu are requesting access to your Google gmail account. We hold this access token in a digital vault and always keep this information confidential.
2. What data are we requesting? We are requesting full access to your Google gmail account. This allows us to read, write, modify, and delete messages and to read, write, and modify the settings in your account. We use this access to bring your emails into Sangu, process them, and write the results back out to your mailbox.
3. Why are we requesting Google user data? We are requesting the data to be able offer our services to you. To be able to scan your emails, our software needs to be able to read the contents of your mail, run it through our system, then add banners to messages and return the modified message back to your mailbox. We also move spam and malicious emails to a Spam folder and this requires modify permission. We also ask for delete permission to be able to delete messages in your mailbox that we have modified. We will never delete a message that is not otherwise accessible. If your mailbox is a Google mailbox and we access it using IMAP, Google requires that we ask for full access permissions to use the IMAP protocol. When you use Sangu with our Google Workspace account, we access the settings of this Google Workspace account to modify the settings when you add your existing email to this account. This can be done manually but it is much easier and less error prone when we add your accounts by automation.
In all cases, the access we request are solely and explicitly used in pursuit of providing you with our service. We do not use or look at the contents of any of your mail in any way except when you report messages to us for investigation.
We collect and use information in accordance with the practices described in this Privacy Policy. Our purposes for collecting and using information include:
Notwithstanding the above, we may use non-personal information for any purpose to the extent permitted by applicable law. For details on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
Depending on the type of information, your personal data is stored either until you delete the Service or after a certain period of time.
Type of information & Length of storage:
When you delete your account any authentication credentials, passwords, or OAuth sessions are removed at the time of account deletion and the Sangu Mail Service will be unable to access any linked accounts.
Email messages synchronized to your Sangu mailbox are kept for 30 days in the event of inactivity or non-payment. If you delete your account from the service, the Email message content will be removed within 48 hours from the mailbox servers. Your linked accounts will not be further changed so any messages remaining on those accounts will remain on the linked account providers systems. If messages were deleted on the Linked account and only present on Sangu mail those messages will be unrecoverable when the Sangu mail content is expunged.
Email addresses, APNS device token, app tokens assigned by us, device info is kept for 3 months after deletion of your email account from Sangu mail on all devices.
Metadata about messages (headers, hashes, etc) processed via the security and spam analysis tools used in providing services to you is kept for 3 months.
Full message content is persisted in some of our security analysis tools for up to 3 months. While the full message content is removed from the mailbox server when you delete your account it will persist in these security analysis tools for the longer period.
Email messages you reported for additional analysis are kept in our case management system for 12 months from time of report. This retention period also applies after you remove your account.
As part of the service when messages are determined to be malicious or spam, we retain information about the content and composition of those messages. This is distilled down into cyber observable information and/or Indicators of Compromise (IOC) elements such as hashes, files names. domain names. URLs, IP addresses, malicious sender email addresses, malicious phone numbers, postal addresses, images, etc. This information is retained for 36 months.
We offer parts of our Service through websites, platforms, and services operated or controlled by third parties. In addition, we integrate technologies operated or controlled by third parties into parts of our Service. Please note that when you interact with third parties, including when you leave our Service, those third parties may independently collect information about you and solicit information from you. The information collected and stored by third parties remains subject to their own policies and practices, including what information they disclose to us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
Some examples of where you may interact with a third party include:
A. Region-Specific Rights.
In addition to these rights and choices, you may have rights based on your region. For region-specific terms, please see the relevant sections at the end of this Privacy Policy.
B. Account Management.
You may access, update, or delete certain information that you have provided to us through your account by visiting your account settings. Please note that we will retain information in accordance with our data retention practices.
C. Tracking Technology Management.
Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.
D. Analytics Management.
We use Google Analytics cookies to help us understand how you access and use the Service. Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout. Please note that opt outs only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of any opt outs offered by other entities.
E. Communications.
Please note that your opt out is limited to the email address and device used and will not affect subsequent subscriptions.
The Service is not directed toward children under 16 years old, and we do not knowingly collect personal information (as that term is defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us at privacy@sangu.io. We will delete the personal information in accordance with COPPA.
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
We retain information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
We are based in the U.S. If you are located outside the U.S., please be aware that your information may be transferred to and processed in the U.S. or another country where we operate. Where required by applicable law, we will provide appropriate safeguards for data transfers, such as through use of standard contractual clauses.
We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.
If you have any questions, or have trouble accessing this Privacy Policy, please contact us:
By email:
privacy@sangu.io
By mail:
Cyber Risk Research LLC
197 Palmer Ave, Unit 200
Falmouth MA 02536
These additional rights and disclosures apply only to California residents. Terms have the meaning ascribed to them in the California Consumer Protection Act as replaced by the California Privacy Rights Act (“CPRA”), unless otherwise stated.
A. Notice at Collection.
At or before the time of collection, you have a right to receive notice of our data practices. The “Information Collection” section above sets out the categories of personal information we have collected and the sources from which we have obtained personal information in the past 12 months.
We collect and use this personal information for the business purposes set out in the “Use of Information” section above. We disclose this personal information to the categories of persons set out in the “Disclosure of Information” section above. Please visit those sections for further details.
We do not “sell” or “share” your personal information as those terms as defined by the CPRA.
We do not knowingly sell or share the personal information of minors under 16 years old who are California residents.
B. Retention.
We retain each category of personal information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
C. Rights to Know, Correct, and Delete.
You have the right to request the following from us:
In addition, you have the right to correct or delete the personal information we have collected from you.
To exercise any of these rights, please email us at privacy@sangu.io.
D. Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the designated methods listed above. Except for opt-out requests, we will require written proof of the agent’s permission to do so and may verify your identity directly.
E. Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
F. Shine the Light.
Under California’s Shine the Light law, Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
We do not sell and will not sell your covered information (as those terms are defined by NRS 603A.340).
These additional rights and disclosures apply only to Virginia residents. Terms have the meaning ascribed to them in the Virginia Consumer Data Protection Act (“VCDPA”).
You have the following rights under the VCDPA:
If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@sangu.io and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.
These additional disclosures and rights apply only to individuals located in the European Economic Area, Switzerland, or the United Kingdom (collectively, “Europe”). Terms have the meaning ascribed to them in the General Data Protection Regulation (“GDPR”).
A. Roles.
Sangu acts as a controller with respect to personal data collected as you interact with our Service.
B. Lawful Basis for Processing.
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.
C.Your Rights.
You have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, please email us at privacy@sangu.io and specify which right you are seeking to exercise.
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