Tutanota
Tutanota is a free and open-source end-to-end encrypted email software and freemium secure email provider.
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Tutanota does not use any analytical tools.
Even if there is a reasonable delay before the data is fully deleted (as is common), the data still counts as "permanently deleted" and satisfies the parameters for this question.
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When signing up for a Tutanota account, you give consent to the processing of this data according to Art. 6 DSGVO 1. a). All textual content is encrypted for the user and its communication partners in a way that even Tutao GmbH has no access to the data. This data can be deleted by the user.
This may come in the form of outright data sharing or by using local third-party analytics software (such as Google Analytics, which collects a plethora of user information).
Note that whether the policy allows sharing aggregated user data does not affect this question.
If the personal data is encrypted when it passes through the third-party, it does not count as third-party access (as the data is inaccessible to that party).
If personal data has been made public by, for example, posting it to a blog, it does not count as private personal information (and is therefore not considered by this question).
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With the exception of payment data, we will not disclose your personal data including your email address to third parties.
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Payment is handled by Braintree.
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With the exception of payment data, we will not disclose your personal data including your email address to third parties. However, we can be legally bound to provide content data (in case of a valid German court order) and inventory data to prosecution services. There will be no sale of data.
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They have a warrant canary at https://tutanota.com/blog/posts/transparency-report/
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This is not outlined in the privacy policy, rather on a separate page: https://tutanota.com/security
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Status: May 25, 2018
Note that all companies operating in the EU are subject to Art. 33 of the GDPR, which requires companies to notify their data protection authority of a data breach within 72 hours of discovering it.
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Although their imprint describes them being based in Germany, Tutanota does not comply with Article 33 of the GDPR.
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There is no clause requiring such.
This includes the use of data brokers and independent verification authorities (such as background check providers).
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There's no examples of such in their privacy polic(ies)
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For the initiation of a contractual relationship and for service provision we collect
the newly registered email address
as inventory data.
For invoicing and determining the VAT we collect for paid product variants
the domicile of the customer (country)
the invoicing address (for private users optional)
the VAT identification number (only for business customers of some countries)
as inventory data.
For the transaction of payments we collect depending on the chosen payment method the following payment data (inventory data):
Banking details (account number and sort code and IBAN/BIC, if necessary bank name, account holder),
credit card data,
PayPal user name.
This inventory data is processed for the performance of the contract with the customer according to Art. 6 GDPR 1. b). For the execution of direct debiting we will share your banking details with the authorized credit institution. For the execution of PayPal payments we will share your PayPal data with PayPal (Europe).
Address: PayPal (Europe) S.à r.l. et Cie, S.C.A.,22-24 Boulevard Royal, L-2449 Luxembourg
Paypal privacy statement
Paypal contact for questions about privacy
For the execution of credit card payments your credit card data will be shared with our payment service provider Braintree. This includes the transfer of personal data into a third country (USA). An agreement entered into with Braintree defines appropriate safeguards and demands that the data is only processed in compliance with the GDPR and only for the purpose of execution of payments.
Tutanota provides services for saving, editing, presentation and electronic transmission of data, such as email service, contact management and data storage. This content data is voluntarily entered into Tutanota by the customer. When signing up for a Tutanota account, you give consent to the processing of this data according to Art. 6 DSGVO 1. a). All textual content is encrypted for the user and its communication partners in a way that even Tutao GmbH has no access to the data. This data can be deleted by the user.
In order to maintain email server operations, for error diagnosis and for prevention of abuse, mail server logs are stored max. 7 days. These logs contain sender and recipient email addresses and time of connection but no customer IP addresses. Storage takes place for the purposes of the legitimate interests pursued by the controller according to Art. 6 DSGVO 1. f).
In order to maintain operations, for prevention of abuse and and for visitors analysis, IP addresses of users are processed. Storage only takes place for IP addresses made anonymous which are therefore not personal data any more. This processing takes place for the purposes of the legitimate interests pursued by the controller according to Art. 6 DSGVO 1. f).
Some services allow users to opt-out or opt-in to of non-critical collection or use of personal data, such as collecting data for personalized advertisements.
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For invoicing and determining the VAT we collect for paid product variants
[...]
the invoicing address (for private users optional)
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There are certain details that are optional for certain tiers.
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For the initiation of a contractual relationship and for service provision we collect
the newly registered email address
as inventory data.
For invoicing and determining the VAT we collect for paid product variants
the domicile of the customer (country)
the invoicing address (for private users optional)
the VAT identification number (only for business customers of some countries)
as inventory data.
For the transaction of payments we collect depending on the chosen payment method the following payment data (inventory data):
Banking details (account number and sort code and IBAN/BIC, if necessary bank name, account holder),
credit card data,
PayPal user name.
This inventory data is processed for the performance of the contract with the customer according to Art. 6 GDPR 1. b). For the execution of direct debiting we will share your banking details with the authorized credit institution. For the execution of PayPal payments we will share your PayPal data with PayPal (Europe).
Address: PayPal (Europe) S.à r.l. et Cie, S.C.A.,22-24 Boulevard Royal, L-2449 Luxembourg
Paypal privacy statement
Paypal contact for questions about privacy
For the execution of credit card payments your credit card data will be shared with our payment service provider Braintree. This includes the transfer of personal data into a third country (USA). An agreement entered into with Braintree defines appropriate safeguards and demands that the data is only processed in compliance with the GDPR and only for the purpose of execution of payments.
Tutanota provides services for saving, editing, presentation and electronic transmission of data, such as email service, contact management and data storage. This content data is voluntarily entered into Tutanota by the customer. When signing up for a Tutanota account, you give consent to the processing of this data according to Art. 6 DSGVO 1. a). All textual content is encrypted for the user and its communication partners in a way that even Tutao GmbH has no access to the data. This data can be deleted by the user.
In order to maintain email server operations, for error diagnosis and for prevention of abuse, mail server logs are stored max. 7 days. These logs contain sender and recipient email addresses and time of connection but no customer IP addresses. Storage takes place for the purposes of the legitimate interests pursued by the controller according to Art. 6 DSGVO 1. f).
In order to maintain operations, for prevention of abuse and and for visitors analysis, IP addresses of users are processed. Storage only takes place for IP addresses made anonymous which are therefore not personal data any more. This processing takes place for the purposes of the legitimate interests pursued by the controller according to Art. 6 DSGVO 1. f).
Last Updated
May 26, 2021
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