Privacy Policy
Contents
1. Overview and principles
Elitemail LLC (“Elitemail”, “we”, “us”, “our”) operates a private, end-to-end encrypted electronic mail service. We believe that the privacy of correspondence is a fundamental interest of our Members, and we have designed the Service such that the contents of Member mailboxes are not legible to us in the ordinary course of operations.
This Privacy Policy describes the limited categories of information we do process, the purposes for which we process them, and the rights you have in respect of that information.
2. Data controller
The data controller for personal information processed in connection with the Service is:
Elitemail LLC
548 Market Street, Suite 35410
San Francisco, California 94104
United States
privacy@elitemail.online
3. Information we collect
3.1 Information you provide
- Contact information submitted during expression of interest, application, or onboarding (such as name and email address);
- Verification documents provided during identity verification (where applicable to your tier);
- Billing information and tax identifiers necessary for the processing of payments;
- Correspondence with the Membership Office, custodians, or counsel of record.
3.2 Information generated through use of the Service
- Mailbox metadata necessary to deliver electronic mail, including sender, recipient, timestamps, message identifiers, and message sizes;
- Account configuration, including aliases, jurisdictional preferences, and custodial settings;
- Authentication and session information, including timestamps of access and approximate location derived from IP address;
- Service logs sufficient to operate, secure, and audit the Service.
3.3 Information we do not have
Owing to the architecture of the Service, we do not retain plaintext access to the body or attachments of Member correspondence held in encrypted mailboxes. We do not sell, rent, or share Member Content with advertisers, data brokers, or analogous third parties. We do not train artificial intelligence models on Member Content.
3.4 Information submitted through this website
If you submit an expression of interest via this website (for example, by joining the private beta waitlist), we record your email address, your submission timestamp, and the IP address from which the submission was made, for the purpose of evaluating your application, communicating with you regarding membership, and maintaining a record of submissions for fraud prevention.
4. How we use information
We use the information described above to:
- Provide and operate the Service;
- Evaluate applications for membership;
- Authenticate Members and protect the security of accounts;
- Bill for membership and process payments;
- Communicate with Members regarding the Service, including service-critical notices;
- Comply with legal obligations and respond to lawful requests;
- Detect, investigate, and prevent fraud, abuse, and security incidents;
- Conduct internal analytics on aggregated and de-identified usage of the Service.
5. Legal bases (GDPR/UK GDPR)
Where the EU or UK General Data Protection Regulation applies to our processing, we rely on the following legal bases:
- Contract — to perform our agreement with you and provide the Service;
- Legitimate interests — to operate, secure, and improve the Service, prevent fraud, and conduct our business, balanced against your rights and freedoms;
- Legal obligation — to comply with applicable law, regulation, and lawful requests;
- Consent — where we ask for your express consent (for example, certain optional features).
6. Sharing and disclosure
We share information only as set out below:
- Service providers. We engage carefully selected vendors for infrastructure, payment processing, fraud prevention, and identity verification. Such vendors are bound by written contractual obligations to process information only as instructed by us.
- Professional advisors. Our counsel, accountants, and auditors, bound by professional obligations of confidentiality.
- Compliance with law. Where we receive a lawfully binding request from a competent authority, we produce only such information as is in our possession and within the scope of the request. Where permitted by law, we notify the affected Member.
- Corporate transactions. In the context of a merger, acquisition, restructuring, or sale of assets, in which case we will require the recipient to honour the commitments of this Privacy Policy.
We do not sell personal information as “sale” is defined under the California Consumer Privacy Act, nor do we share personal information for cross-context behavioural advertising.
7. Retention
We retain personal information for as long as necessary to provide the Service, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Specific retention periods are as follows, save as otherwise required by law:
- Waitlist submissions: up to 24 months from submission, or until membership is granted or declined;
- Account configuration and mailbox metadata: for the duration of membership plus 90 days;
- Billing records: 7 years following the close of the relevant tax year;
- Security and audit logs: 18 months.
8. International transfers
Elitemail is based in the United States and operates data enclaves in Switzerland, Luxembourg, Iceland, and the Cayman Islands. Where personal information is transferred from the European Economic Area, the United Kingdom, or Switzerland to a jurisdiction not the subject of an adequacy decision, we rely on the European Commission Standard Contractual Clauses or analogous safeguards, and where appropriate, additional technical and organisational measures.
9. Security
We maintain technical and organisational measures designed to protect personal information against unauthorised or unlawful processing and against accidental loss, destruction, or damage. These include end-to-end encryption of Member Content, role-based access controls, hardware security modules for key management, independent annual audits, and a documented incident response programme. No method of transmission or storage is, however, perfectly secure; we cannot warrant the absolute security of personal information.
10. Your rights
Subject to applicable law, you may have the following rights in respect of personal information we hold about you:
- The right to access and obtain a copy of your personal information;
- The right to rectification of inaccurate personal information;
- The right to erasure in certain circumstances;
- The right to restrict or object to processing in certain circumstances;
- The right to data portability;
- The right to withdraw consent, where processing is based on consent;
- The right to lodge a complaint with a supervisory authority.
To exercise any of these rights, please contact privacy@elitemail.online. We will respond within the period required by applicable law.
11. California (CCPA/CPRA)
If you are a California resident, you have specific rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:
- To know what categories of personal information we collect, the sources, and the purposes for which we use them;
- To request a copy of personal information we have collected;
- To request deletion of personal information, subject to applicable exceptions;
- To correct inaccurate personal information;
- To limit the use of sensitive personal information;
- To be free from retaliation for exercising any of these rights.
We do not sell personal information and we do not share personal information for cross-context behavioural advertising.
12. Cookies and analytics
This website uses a small number of strictly necessary cookies for session management and security. We do not employ third-party advertising cookies and we do not embed third-party analytics scripts on member-facing surfaces. Our public website uses aggregated, privacy-preserving analytics to understand traffic patterns; no personal identifiers are recorded.
13. Children
The Service is not directed to, and we do not knowingly collect personal information from, persons under the age of eighteen. If you become aware that a person under the age of eighteen has provided us personal information, please contact us so that we may take appropriate action.
14. Changes to this policy
We may amend this Privacy Policy from time to time. Material amendments will be communicated to Members in writing at least thirty (30) days in advance of taking effect, save where a shorter period is required by law.
15. Contact
Questions concerning this Privacy Policy or our processing of personal information may be directed to:
Elitemail LLC
Office of the Privacy Officer
548 Market Street, Suite 35410
San Francisco, California 94104
United States
privacy@elitemail.online