Privacy Policy

This Application collects some Personal Data from its Users.

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Owner and Data Controller

Owner contact email: contact@warmbox.ai

Privacy contact: contact@warmbox.ai

Roles. For data relating to visitors of our website and to the Users’ own accounts (registration, billing, support, marketing), the Owner acts as Data Controller. For Personal Data contained in or derived from the mailboxes and email accounts that customers connect to the Service, the Owner acts as Data Processor on behalf of the customer, under the terms of our Data Processing Agreement (DPA), which will be provided upon request at contact@warmbox.ai. The complete list of sub-processors is available upon request at contact@warmbox.ai. This Privacy Policy covers the processing for which the Owner is Controller; processor activities are governed by the DPA.

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Tracker; Usage Data; first name; last name; username; email address; Universally unique identifier (UUID); Data communicated while using the service; connected mailbox data (as described below).

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

Data processed to provide the Service (email warm-up)

The core functionality of the Service requires Users to connect one or more email accounts (mailboxes). In order to provide the email warm-up service, the Application processes:

Authentication credentials for the connected mailbox (OAuth tokens or SMTP/IMAP credentials), stored encrypted;
Email metadata of warm-up conversations (sender, recipient, subject, timestamps, deliverability signals such as folder placement);
The content of warm-up emails automatically generated and exchanged within the warm-up network;
Technical data on the connected mailbox necessary to monitor deliverability.

The Service only processes the warm-up emails generated by the Service and the technical signals necessary to monitor deliverability; it does not use the content of the User’s other correspondence for any purpose.

This Data is processed strictly for the purpose of providing, securing and improving the warm-up service and is never used for advertising purposes nor sold to third parties. Where this Data belongs to a corporate customer’s environment, it is processed as Processor under the DPA.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Security measures

The Owner implements technical and organizational measures appropriate to the risk, including in particular:

Encryption of Data in transit (TLS) and at rest;
Encrypted storage of mailbox credentials and OAuth tokens;
Role-based access controls, least-privilege access and authentication requirements for personnel;
Logging and monitoring of access to production systems;
Regular backups and business continuity procedures;
Regular penetration tests conducted by independent third parties;
Compliance with the SOC 2 Type II standard.

A more detailed description of our security practices is available upon request at contact@warmbox.ai and, for customers, in the DPA.

Personal Data breach

In case of a Personal Data breach, the Owner will assess the incident and, where required by applicable law, notify the competent supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of it, and inform the affected Users where the breach is likely to result in a high risk to their rights and freedoms. Breach notification obligations towards corporate customers acting as Controllers are set out in the DPA.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place of processing and international transfers

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Where Personal Data is transferred outside the European Economic Area, the Owner ensures that each transfer is covered by an appropriate safeguard within the meaning of Chapter V of the GDPR, namely: (i) an adequacy decision of the European Commission – including, for transfers to the United States, the recipient’s certification under the EU-U.S. Data Privacy Framework where applicable – or (ii) the Standard Contractual Clauses adopted by the European Commission (Decision 2021/914), supplemented where necessary by additional technical and organizational measures.

Users may obtain a copy of the safeguards in place, or information on where they have been made available, by contacting the Owner at the contact details provided in this document.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose it has been collected for, and no longer than the periods below (unless a longer retention is required by a legal obligation, litigation or upon order of an authority):

Account data (name, email address, credentials): duration of the contract, then 3 months after account closure.

Billing and invoicing data: 10 years (legal obligation – accounting records).

Connected mailbox data processed for the Service (see “Data processed to provide the Service”): duration of the mailbox connection; deleted within 30 days after disconnection or account closure.

Support conversations: 3 years after the last interaction.

System logs and security logs: 12 months.

Prospect / marketing data: 3 years after the last contact from the User.

Cookies and trackers: up to 13 months, according to the applicable CNIL / EDPB guidance and the Cookie Policy.

Once the retention period expires, Personal Data shall be deleted or irreversibly anonymized. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service (including the email warm-up functionality described above), comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Tag Management, Managing data collection and online surveys, Analytics, Remarketing and behavioral targeting, Registration and authentication, Managing contacts and sending messages and User database management.

Website vs. Application. Advertising-related trackers (remarketing, behavioral targeting, ad conversion tracking) are used on our public website only and are not deployed inside the logged-in Application. Usage data collected within the Application is used solely for providing, securing and improving the Service.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics 4 (Google Ireland Limited). Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Personal Data processed: Tracker; Usage Data. Place of processing: Ireland – Privacy Policy – Opt Out.

Facebook Ads conversion tracking (Meta Platforms Ireland Ltd). An analytics service that connects data from the Meta advertising network with actions performed on this Application. The pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network. It is only activated subject to the User’s prior consent. Personal Data processed: Tracker; Usage Data. Place of processing: Ireland – Privacy Policy.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Twilio SendGrid (Twilio Inc.). An email address management and message sending service. Personal Data processed: email address. Place of processing: United States – Privacy Policy – transfer safeguards as described in “Place of processing and international transfers”.

Managing data collection and online surveys

Hotjar surveys (Hotjar Ltd.). A survey builder and data collection platform provided by Hotjar Ltd. Hotjar may use cookies to track User behavior, subject to the User’s consent. Users can opt out of Hotjar cookie tracking via Hotjar’s opt-out page. Personal Data processed: Tracker. Place of processing: Malta – Privacy Policy – Opt Out.

Registration and authentication

Firebase Authentication (Google Ireland Limited). A registration and authentication service provided by Google Ireland Limited. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform. Personal Data processed: first name; last name; username; email address. Place of processing: Ireland – Privacy Policy.

Remarketing and behavioral targeting (website only)

This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of the public website by the User. These trackers are only set subject to the User’s prior consent, which can be withdrawn at any time via the cookie banner. In addition to any opt-out feature provided by the services below, Users may opt out via the Network Advertising Initiative opt-out page or through applicable device settings.

Facebook Remarketing (Meta Platforms Ireland Ltd). A remarketing and behavioral targeting service that connects the activity of the website with the Meta advertising network. Personal Data processed: Tracker; Usage Data. Place of processing: Ireland – Privacy Policy – Opt Out.

Tag Management

Segment (Twilio Inc.). A customer data / tag management service. This results in the Users’ Data flowing through this service, potentially resulting in the retention of this Data. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – transfer safeguards as described in “Place of processing and international transfers”.

User database management

Intercom (Intercom R&D Unlimited Company). A User database management service, also used as a medium for communications, either through email or through messages within this Application. Intercom Messenger may use Trackers to recognize and track Users’ behaviour. Personal Data processed: Data communicated while using the service; email address; Tracker; Universally unique identifier (UUID); Usage Data; various types of Data as specified in the privacy policy of the service. Place of processing: Ireland – Privacy Policy.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:

Withdraw their consent at any time, where they have previously given consent to the processing of their Personal Data;
Object to processing of their Data, if the processing is carried out on a legal basis other than consent;
Access their Data, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing;
Verify and seek rectification of the accuracy of their Data;
Restrict the processing of their Data, under certain circumstances;
Have their Personal Data deleted or otherwise removed, under certain circumstances;
Receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, have it transmitted to another controller without any hindrance (data portability);
Lodge a complaint before their competent data protection authority (in France, the CNIL – www.cnil.fr).

Requests concerning connected mailbox data of a corporate customer. Where the Owner processes Personal Data as Processor on behalf of a corporate customer, data subjects are invited to address their request to that customer (the Controller); the Owner will assist the customer in accordance with the DPA and will forward any request received directly.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner at contact@warmbox.ai. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month, extendable by two further months where necessary in view of the complexity and number of requests (in which case the User will be informed within the first month).

Additional information for Users in the United States

Depending on their State of residence (including California, under the CCPA/CPRA), Users located in the United States may have specific rights, including the right to know, correct and delete their Personal Information, the right to opt out of the “sale” or “sharing” of Personal Information for cross-context behavioral advertising, and the right to non-discrimination for exercising these rights. The Owner does not sell Personal Information in exchange for money; the use of advertising trackers on the website may qualify as “sharing”, which Users can opt out of via the cookie banner. Users in the United States may exercise these rights by contacting the Owner at contact@warmbox.ai.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) and use other Personal Data (such as the IP Address) for this purpose, for the retention period indicated in the table above.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Application does not respond to “Do Not Track” signals as such; however, all non-essential trackers are subject to the User’s prior consent via the consent banner, and Users can withdraw consent at any time. To determine whether any of the third-party services it uses honor “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Material changes affecting the processing of connected mailbox data of corporate customers will additionally be notified in accordance with the DPA.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data). Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data. Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses, the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer, the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit and the details about the path followed within the Application, and other parameters about the device operating system and/or the User’s IT environment.

User. The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject. The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor). The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner). The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application. The means by which the Personal Data of the User is collected and processed.

Service. The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU). Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie. Cookies are Trackers consisting of small sets of data stored in the User’s browser.

Tracker. Tracker indicates any technology – e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy relates solely to this Application, if not stated otherwise within this document.

Latest update: September 25, 2025

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