csn-helpdesk

This policy explains what CSN Helpdesk (“the Helpdesk”), run by CSN (“we”, “us”), does with the personal data of the email mailboxes connected to it, and of the mail read and sent through them. For any question about other data the Helpdesk holds, or if anything here is unclear, write to us at no-reply@gmail.com.

1. Who is responsible

CSN is responsible for the personal data processed in the Helpdesk (the “controller”, in the terms of data protection law). You can reach us about anything in this policy at no-reply@gmail.com.

2. Connected mailboxes

An administrator of the Helpdesk can connect an email mailbox (for example a Gmail account) to read, organise and send its mail from inside the Helpdesk. The mailbox is connected with an app password: a separate password the email provider creates for one application, which you can revoke at any time without changing your normal password. We never ask for, and never see, your normal password.

For a connected mailbox we process:

The connection details: the email address, the name you choose to send under, the server settings and the app password. The app password is stored encrypted, is only ever used to log in to your provider's mail servers, and is never shown again, not even to you.
Message headers: the sender, recipients, subject, date, the first lines of the text, and whether a message is read, starred or has attachments. They are copied into our database so that your folders list and search quickly.
Message bodies and attachments: fetched from your provider only when you open a message or download an attachment. A message you open is kept in our cache for up to 60 minutes, so that it opens quickly a second time, and then removed. Attachments are not stored at all.
Mail you send: passed to your provider's server to be delivered, and filed in your Sent folder. We do not keep a separate copy.

Messages naturally contain personal data of the people you correspond with. We process it only as part of showing your mailbox to you and sending the mail you write.

3. What we use it for, and what we do not

We use the data of a connected mailbox only to show it to the administrator who connected it, and to carry out what they ask: reading, searching, moving, deleting and sending mail. Only that administrator can see the mailbox; other users of the Helpdesk, other administrators included, cannot.

We do not:

sell your data or the content of your mail to anyone;
use it for advertising or profiling;
use it to train artificial intelligence or machine learning models;
share it with third parties, except the providers that host the Helpdesk for us under a duty of confidentiality, or where the law requires it.

4. How long we keep it

Message headers are kept while the mailbox is connected. Those older than 90 days are removed from every folder but the inbox; your provider keeps them, and a search on the server finds them again.
Opened messages are removed from our cache after 60 minutes at the latest.
When you disconnect a mailbox, its app password and every header and message we hold of it are deleted at once. The record that the mailbox was connected is deleted for good 30 days later.

5. How we protect it

App passwords are encrypted with a key that is not stored in the database.
The Helpdesk talks to mail servers over encrypted connections (SSL/TLS or STARTTLS), unless an administrator turns encryption off for a server of their own. With encryption on, an app password is never sent before the connection is encrypted.
Messages are shown in an isolated frame in which they can run no code, and images from the web are not loaded until you ask for them, so that a sender cannot learn when you read their message.
Access to the mail feature is limited to administrators, and to their own mailboxes.

6. Your choices

You can disconnect a mailbox at any time, from the Mailboxes page of the Helpdesk.
You can also revoke the app password at your email provider (for Gmail, at myaccount.google.com/apppasswords), which stops the Helpdesk reaching the mailbox at once.
To have everything we hold about you deleted, or to ask what we hold, write to no-reply@gmail.com. We answer within 30 days.

7. If you are in the European Union or the EEA

The General Data Protection Regulation (GDPR) gives you specific rights. We process the data described above because it is needed to provide the service you asked for (Article 6(1)(b) GDPR), and, for keeping the service secure, on the basis of our legitimate interests (Article 6(1)(f) GDPR). You have the right to:

access the personal data we hold about you, and receive a copy of it;
have it corrected, or deleted;
restrict or object to its processing;
receive it in a portable format;
lodge a complaint with a data protection authority, in particular in the country where you live or work (in Italy, the Garante per la protezione dei dati personali).

To exercise any of these rights, write to no-reply@gmail.com. Where personal data leaves the EU/EEA, we rely on the safeguards the GDPR provides for, such as the European Commission's standard contractual clauses.

8. Children

The Helpdesk is a tool for businesses and is not meant for anyone under 16.

9. Changes to this policy

When we change this policy, we update the date at the top of this page. If a change matters to how your data is used, we will tell the users concerned before it takes effect.

10. Contact

CSN · no-reply@gmail.com