Tutanota

Tutanota is a free and open-source end-to-end encrypted email software and freemium hosted secure email service.

This page is not published. While you can access it via its direct link, it is not yet displayed on the website.

Transparency

Does the policy require users to be notified in case of a data breach? No

0/7

Decided May 15, 2020 (revision history). This question accounts for 8% of the final score.

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.

Possible Options

No0/7
Yes, eventually5/7
Yes, within 72 hours7/7
N/A (the service collects so little personal data that notification would not be possible)7/7

Note

Although their imprint describes them being based in Germany, Tutanota does not comply with Article 33 of the GDPR.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


Is the policy's history made available? Only the date it was last modified

3/5

Decided May 15, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

No0/5
Only the date it was last modified3/5
Yes, with revisions or a change-log5/5

Citation

Status: May 25, 2018

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Will affected users be notified when the policy is meaningfully changed? No

0/5

Decided May 15, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

No0/5
Yes5/5
N/A (no personal data—or contact information—collected)5/5

Note

There is no clause requiring such.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


Does the policy outline the service's general security practices? Yes

2/3

Decided May 15, 2020 (revision history). This question accounts for 4% of the final score.

Possible Options

No0/3
Somewhat1/3
Yes2/3
Yes, including audits2.5/3
N/A (no personal data collected)3/3
Yes, including independent audits3/3

Note

This is not outlined in the privacy policy, rather on a separate page: https://tutanota.com/security

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Collection

Is it clear why the service collects the personal data that it does? Yes

10/10

Decided May 15, 2020 (revision history). This question accounts for 12% of the final score.

This question deals with transparency. Even if the service uses data for reasons that aren't ideal for privacy, provided they list all of those uses, the service can still receive full credit for this question. However, if they are not explicit about their uses (by employing language like "such as"), a lower score is assigned.

Possible Options

No0/10
Somewhat4/10
Mostly7/10
Yes10/10
No personal data is collected10/10

Citation

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).

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


Does the policy list the personal data it collects? Yes, exhaustively

10/10

Decided May 15, 2020 (revision history). This question accounts for 12% of the final score.

All types of collected personal data are listed specifically

Possible Options

No0/10
Only summarily3/10
Yes, generally7/10
Yes, exhaustively10/10
N/A (no personal information is collected)10/10

Citation

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).

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


Does the service collect personal data from third parties? No

10/10

Decided May 15, 2020 (revision history). This question accounts for 12% of the final score.

This includes the use of data brokers and independent verification authorities (such as background check providers).

Possible Options

Yes0/10
Only for critical data7/10
No10/10

Note

There's no examples of such in their privacy polic(ies)

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


Does the service allow the user to control whether personal data is used or collected for non-critical purposes? On an opt-in basis

5/5

Decided May 15, 2020 (revision history). This question accounts for 6% of the final score.

Non-critical use of personal data is not enabled by default.

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.

Possible Options

No0/5
On an opt-out basis, but only for some non-critical data/uses1.5/5
On an opt-out basis, for all non-critical data/uses3/5
N/A (no data used for non-critical purposes)5/5
On an opt-in basis5/5

Citation

For invoicing and determining the VAT we collect for paid product variants [...] the invoicing address (for private users optional)

Note

There are certain details that are optional for certain tiers.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


Handling

Does the policy allow personally-targeted or behavioral marketing? No

10/10

Decided May 15, 2020 (revision history). This question accounts for 12% of the final score.

Possible Options

Yes0/10
Yes, but you can opt-out3.5/10
Yes, but you must opt-in7/10
No10/10

Note

Tutanota does not use any analytical tools.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


Does the service allow third-party access to private personal data? Yes, all parties specified (only to critical service providers)

8/10

Decided May 15, 2020 (revision history). This question accounts for 12% of the final score.

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).

Possible Options

Yes, not all parties specified0/10
Yes, all parties specified (including non-critical service providers such as advertisers)3/10
Yes, not all parties specified (but only to critical service providers)7/10
Yes, all parties specified (only to critical service providers)8/10
No10/10

Citation

With the exception of payment data, we will not disclose your personal data including your email address to third parties.

Note

Payment is handled by Braintree.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


When does the policy allow law enforcement access to personal data? Only when required by a court order or subpoena

4/5

Decided May 15, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

Always0/5
Not specified0/5
When reasonably requested3/5
Only when required by a court order or subpoena4/5
N/A (no personal data to share)5/5
Never (special legal jurisdiction)5/5

Citation

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.

Note

They have a warrant canary at https://tutanota.com/blog/posts/transparency-report/

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


Does the service allow you to permanently delete your personal data? Yes, using an automated mechanism

5/5

Decided May 15, 2020 (revision history). This question accounts for 6% of the final score.

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.

Possible Options

No0/5
Yes, by contacting someone3/5
Yes, using an automated mechanism5/5
N/A (no personal information collected)5/5

Citation

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.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.



Warnings

Tutanota has no warnings published on PrivacySpy. PrivacySpy publishes warnings when it learns a service has announced a data breach or is found misusing user data. If you believe a warning should be published for Tutanota, submit one here.


Highlighted Policy Snapshot ALPHA

No highlighted policy snapshot has been created for this privacy policy. To view the policy at its original location, click here.

7.9/10

How we calculate ratings →


Version Added

May 15, 2020

Ratings Updated

May 15, 2020

Warnings

0

Maintained by

doamatto

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