Privacy Notice for Invited Recipients
Key points
- You are reading this because someone using CIBHER invited you to exchange encrypted documents.
- We hold your email address, and we got it from the person who invited you.
- You can object at any time by writing to privacy@cibher.eu, and we will stop.
Why you are reading this
Someone who uses CIBHER asked to exchange encrypted documents with you and entered your email address to send you an invitation. You are not our customer and you have no contract with us, so this notice — rather than our customer Privacy Policy — describes what we do with your data.
Who we are
CBPROJEKT sp. z o.o., Wschodnia 6/15, 20-015 Lublin, Poland (KRS 0001221768), is the controller. We have not appointed a Data Protection Officer; the route for anything to do with your data is privacy@cibher.eu.
What we hold, and where it came from
We hold your email address, obtained from the CIBHER user who invited you, together with the timing of the invitation and, if you accept, the public key card exchanged. We do not receive any document, any document content, or any private key material.
Our lawful basis, and the balance behind it
We rely on legitimate interests (Art. 6(1)(f) GDPR): enabling a person who wants to send you a document securely to do so.
We considered consent and concluded it is structurally the wrong basis here, because we would have to ask for your consent before sending you the very message that asks for it. Instead we keep the processing minimal, tell you about it at the first contact, and make objecting easy.
How long we keep it
- Your key card is deleted as soon as delivery is acknowledged.
- The invitation record has your address cleared when the invitation closes, and the record is deleted after 30 days. Invitations expire after 14 days.
- If you go on to verify a sending address of your own, that address is held in plain text until the published retention clock runs: the sender token expires after 90 days and the row is deleted within 24 hours of that expiry — about 91 days from your last verification. The pairing service is not yet in operation, so no such record exists today.
- If you decline an invitation and ask us not to allow further invitations from that sender, we keep a suppression record so the block can be enforced. It holds no address: it is a pair of salted hashes, one of the sender's address and one of yours, and we cannot read either back or list who you have blocked. It is kept for three years from the last time it stopped an invitation, and each blocked invitation restarts that clock. It is the one record that survives an objection, because it exists to enforce one.
Who else sees it
To sign the attestation that accompanies an invitation we use Google Cloud KMS in
the europe-central2 (Warsaw) region, and on that path your email address is
passed to Google as part of the message being signed. Google is a processor for that
operation, and because the region is in Poland the processing stays inside the EU.
The invitation itself is delivered by Microsoft, using Azure Communication Services in the polandcentral (Poland) region. Delivering a message to you necessarily discloses your address to the service that carries it, so Microsoft is a processor for that address too.
Those two are the whole list. We do not sell your address, we do not market to you, and we do not add you to anything.
Your rights, including the right to object
You have the right of access, rectification, erasure, restriction and portability, and — because we rely on legitimate interests — an unqualified right to object.
Write to privacy@cibher.eu. If you object, we will stop processing your address and delete what we hold, with one exception we state rather than leave you to discover: if you asked us to block further invitations from a sender, the suppression record described above stays, because deleting it would let those invitations through again. You do not need to give a reason and you do not need to be a customer.
You may also complain to Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa, or to the supervisory authority where you live.