PRIVACY POLICY
Last Updated: May 1, 2025
1. Introduction
Welcome to IntelliReach (hereinafter – 'Service', 'we', 'us', 'our'). We are committed to protecting your privacy and respecting your personal data. This Privacy Policy explains what information we collect, how we use, transfer, and protect it when you use our Service, including the feature of connecting your Google accounts (Gmail and Google Workspace) for sending emails.
This Policy applies to all visitors and users of our Service. By using the Service, you agree to the collection and use of information in accordance with this Policy.
2. Data Controller
The controller of your personal data is FOP Mytakii Serhii Olehovych, EDRPU 2930302879.
3. What Information We Collect
We collect various types of information to provide and improve our Service:
Information obtained via Google Account connection (OAuth 2.0):
When you choose to connect your Google account (Gmail or Google Workspace) to our Service, you go through the Google OAuth 2.0 authorization process. As part of this process, with your explicit consent, we gain access to:
- Your email address: To identify the connected account.
- Basic profile information: (If you requested the relevant scope) Your name and profile picture, which we may use to personalize the Service.
- Permission to send emails on your behalf: We request permission (scope .../auth/gmail.send) so that our Service can send emails through your connected Google account according to your instructions.
- Google Refresh Token: After your consent, Google provides us with a refresh token. We securely store this token in encrypted form in our database. This token allows our Service to obtain temporary access tokens for sending emails on your behalf without needing re-authorization and without storing your Google account password.
We DO NOT collect or store your Google account password. The OAuth 2.0 process is designed so that you grant permission to our Service without transferring your password to us. We also DO NOT collect or store App Passwords as part of this process.
Information you provide directly:
- (If applicable) Registration data: name, email address, password for logging into our Service (if you have a Service-specific account system).
- Contact information if you contact customer support.
Information collected automatically:
- Log Data: When you use the Service, our servers may automatically record information such as your IP address, browser type, browser version, the pages of the Service you visit, the time and date of your visit, the time spent on those pages, and other statistics.
- Cookies and similar technologies: We may use cookies and similar tracking technologies to improve the Service and analyze its usage. See the `Cookies` section for details.
Information processed when sending emails:
Recipient email addresses, subject, and content of emails you send through our Service using the connected Google account. This information is processed temporarily to fulfill the send request via the Gmail API.
4. How We Use Your Information
We use the collected information for the following purposes:
- Providing and maintaining the Service: To ensure the core functionality – sending emails on your behalf through connected Google accounts using the Gmail API.
- Authentication and account management: To manage connected Google accounts and authenticate your requests to the Gmail API using stored refresh tokens.
- Communication with you: To send you service messages, respond to your support requests, inform you about Service updates or policy changes.
- Improving the Service: To analyze Service usage, monitor performance, diagnose technical problems, and enhance user experience.
- Security: To protect the Service from fraud, abuse, and unauthorized access.
- Compliance with legal obligations: To meet the requirements of applicable legislation, court orders, or requests from government authorities.
5. Legal Basis for Processing Data (for GDPR)
If you are located in the European Economic Area (EEA), we process your personal data on the following legal bases:
- Your consent: You consent to connecting your Google account and granting us permission to send emails on your behalf. You can withdraw your consent at any time.
- Performance of a contract: Processing is necessary to provide you with the services you have subscribed to.
- Our legitimate interests: Processing is necessary for our legitimate interests (e.g., improving the Service, ensuring security), provided these interests do not override your rights and freedoms.
- Legal obligation: Processing is necessary to comply with our legal obligations.
6. Data Transfer and Disclosure
We do not sell your personal data to third parties. We may transfer your information only in the following cases:
- Google: We transfer necessary data (e.g., email send requests) to Google to use the Gmail API according to the permissions you granted. Google's use of your information is governed by their Privacy Policy.
- Service Providers: We may engage third-party service providers to perform certain functions on our behalf (e.g., hosting, analytics, customer support). These providers will have access to your information only to the extent necessary to perform these functions and are obligated to maintain its confidentiality and security.
- Legal Requirements: We may disclose your information if required by law, court order, or request from an authorized government body, or if we believe in good faith that such disclosure is necessary to protect our rights, your safety or the safety of others, or investigate fraud.
- Business Transfers: In the event of a merger, acquisition, reorganization, or sale of all or a portion of our assets, your information may be transferred as part of such transaction. We will notify you of such transfer.
7. Data Security
We take appropriate technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These measures include:
- Encryption: We encrypt sensitive data, including Google refresh tokens, during storage.
- HTTPS: All traffic between your browser and our Service is transmitted over a secure HTTPS connection.
- Access Control: Access to personal data is restricted only to those employees or contractors who need it to perform their job duties.
- Regular updates of software and security systems.
Despite our efforts, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security of your data.
8. Data Retention
We retain your personal data only for as long as necessary to achieve the purposes stated in this Privacy Policy, or longer if required or permitted by law.
- Google Refresh Tokens: Stored in encrypted form until you disconnect the corresponding Google account from our Service, or until the token becomes invalid (e.g., if you revoke access in Google settings). After disconnecting the account, we delete the associated encrypted refresh token.
- Log Data: Usually retained for a limited period for security and usage analysis, except when this data is needed to investigate security incidents or is required by law.
9. Your Data Protection Rights
You have certain rights regarding your personal data, including (depending on jurisdiction):
- Right to access: You can request a copy of the personal data we hold about you.
- Right to rectification: You can request correction of inaccurate or incomplete information about you.
- Right to erasure (`right to be forgotten`): You can request the deletion of your personal data under certain conditions (e.g., if the data is no longer needed for the purposes for which it was collected, or you withdraw consent). Deleting your account in our Service (if applicable) or disconnecting your Google account will result in the deletion of related data, including the refresh token.
- Right to restriction of processing: You can request restriction of processing of your data under certain circumstances.
- Right to object to processing: You can object to the processing of your data based on our legitimate interests.
- Right to data portability: You can request to receive your data in a structured, machine-readable format.
- Right to withdraw consent: If processing is based on your consent (e.g., connecting a Google account), you can withdraw your consent at any time. You can disconnect our Service's access to your Google account through your Google account security settings (https://myaccount.google.com/permissions) or through our Service's interface (if such functionality is provided). Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
To exercise these rights, please contact us at the contact address provided below. We may ask you to verify your identity before fulfilling the request. You also have the right to lodge a complaint with a competent data protection supervisory authority.
10. Cookies
We use a small set of first-party cookies that are strictly necessary for the Service to function: (1) 'connect.sid' keeps your authenticated session active for up to 14 days; (2) 'access_token' stores an HTTP-only authentication token so you can stay signed in during your current browser session; and (3) 'NEXT_LOCALE' remembers your language preference for up to 12 months. We do not deploy advertising or analytics cookies. You can configure your browser to refuse cookies, but some features (such as logging in) may stop working if essential cookies are blocked.
11. Children's Privacy
Our Service is not intended for use by individuals under the age of 16 (`Children`). We do not knowingly collect personal data from Children. If you are a parent or guardian and you become aware that your child has provided us with personal data, please contact us. If we learn that we have collected personal data from a child without verification of parental consent, we will take steps to remove that information from our servers.
12. International Data Transfer
Your information, including personal data, may be transferred to and stored on computers located outside of your country, province, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. If you are located outside Ukraine and choose to provide information to us, please note that we transfer data, including personal data, to Ukraine and process it there. We take appropriate measures to ensure the security of your data during such transfer (e.g., using EU Standard Contractual Clauses where applicable).
13. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the `Last Updated` date at the top. You are advised to review this Privacy Policy periodically for any changes. Changes take effect when they are posted on this page.
14. Contact Information
If you have any questions about this Privacy Policy, please contact us: