Privacy & cookies policy

1. Data Controller and Data Protection Officer

BCD, as identified in the opening to this Privacy Notice, is the Data Controller for all Personal Data processed through the Digital Properties.

You can contact BCD’s Data Protection Officer (“DPO”) at the following address: dpo@beefree.io.

2. The Personal Data we process and source of data

As you use the Digital Properties, BCD will process your Personal Data which, depending on your decisions on how you use the Services (e.g., to create or not an account on our Websites), may consist of an identifier such as your name, an identification number, an on-line identifier (hereinafter, simply “Personal Data”).

We collect the data you provide voluntarily (for example, when you create an account, request assistance or if you decide to take part in the market research and surveys we periodically conduct through the Software and/or the Websites, or when you fill a form online such as when you report a vulnerability issue), data from analysis of your activities on the Digital Properties, certain data of other third parties (users external to the Digital Properties) when invited by BCD users and customers to collaborate with them, as well as aggregated data collected by our third-party providers on social media platforms.

We process the following types of Personal Data:

a. Name, contact details, and other Personal Data

For you to access and use one of our Software as well as to use certain features of the Websites, you must create an account. To do this we need you to provide us with your e-mail address, a password, your name, last name, and your company name (if any). In case you create an account on https://reallygoodmemails.com, you can also upload a profile picture. BCD may also collect any additional information you decide to provide through market research or surveys.

The same information may be collected in various sections of the Websites, including, particularly, areas where you request the Services or when you ask for information relating BCD’s Services.

Furthermore, BCD shall process email addresses of other third parties (users external to the Digital Properties) when BCD users and customers require their collaboration in order to allow them to carry out any activity on shared documents, as well as some information related to their activities on BCD systems (such as access and operational logs automatically collected by the systems).

This Personal Data is processed in accordance with sections 3 (a) to (i) of this Policy.

b. Special categories of Personal Data

Certain areas of the Digital Properties (e.g., the Contact form) may include open text fields, where you can provide to BCD information which may contain Personal Data.

As these fields are completely open, you may use them to disclose (inadvertently or not) more sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you insert or upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation.

BCD asks that you do not disclose this kind of Personal Data, unless you consider this to be strictly necessary. Please mind know that these sensitive categories of Personal Data can only be processed with your explicit consent, in compliance with the current legislation. BCD underlines the importance to express your explicit consent to process this sort of Personal Data, where you to decide to share them.

BCD does not process this type of Personal Data for any purpose unless the processing is considered strictly necessary according to the conditions above. In such a case, this Personal Data is processed in accordance with sections 3 (a) of this Policy.  

c. Data voluntarily provided by the Data Subject

As mentioned in the previous section, certain areas of our Digital Properties allow you to post various types of content, available to BCD which may include Personal Data related to other persons and/or other Personal Data (e.g., where included in files or images of the message content by using the e-mail editing features).

In any situation where you decide to share Personal Data related to other persons, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify BCD against any complaints, claims, or demands for compensation for damages which may arise from processing this Personal Data brought by the third parties whose information you provide through the Software and/or the Website.

In any case, if you provide or otherwise process Personal Data of third parties when using our Digital Properties, you guarantee from now on - assuming all related liability - that your particular processing hypothesis is based on the consent of the third party concerned or on another appropriate legal basis legitimising the processing of the Personal Data of third parties.

This personal data is processed in accordance with sections 3 (a) and from (f) to (i) of this Policy.

d. Data automatically collected when sending e-mails or communications

When we send e-mails or other forms of communications we use, with the explicit and freely provided consent of the user, tracking systems, such as pixel or web beacons, in order to detect the opening of a message, the clicks made on hyperlinks the IP address or the type of browser used to read the message and other similar details.

This personal data is processed in accordance with sections 3 (a) to (i) of this Policy. 

e. Browsing data

The computer systems and software procedures used to operate the Software and the Websites acquire certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information which could, by its very nature, through processing and association with data held by third parties, permit the identification of users. This category of data includes IP addresses or domain names of the computers used by users connecting to the Software, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment. This data is used only to generate anonymous statistical information on the use of the Software, to check its correct operation, and to identify anomalies and/or abuses. 

In addition, the Websites’ operation, as is standard with any Websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Websites’ users as part of their routine operation. While BCD does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data.

This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Websites, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and other parameters related to the operating system and user’s IT environment.

These data are used to compile statistical information on the use of the Websites, as well as to ensure its correct operation and identify any faults and/or abuse of the Websites. Save for this last purpose, these data are kept as long as they are needed for the specific purpose described above. This personal data is processed in accordance with sections 3 (d), (h) and (i) of this Policy.

f. Cookies

Definitions, characteristics, and application of the legislation.

Cookies are small text files that sites you visit send and record on your computer or mobile device, which are re-transmitted to the same sites on your next visit. Through the use of cookies, sites remember your actions and preferences (such as, for example, login data, the chosen language, font size, other display settings, etc.) to avoid having to enter them again when you return to the site or browse its pages. Cookies are used mainly for authentication purposes, session monitoring and to save information on the activities of users visiting the site and may also contain a unique identification code able to track the activities of users browsing the Software itself, for statistical or advertising purposes. While browsing a site, you may also receive cookies from sites or web servers different to the one you are currently at (known as “third-party” cookies). 

Some operations would be impossible without the use of cookies, which in certain cases are technically necessary for the Websites and/or the Software to operate. 

There are various types of cookies with different characteristics and functions, which can remain on your computer for different periods of time: session cookies, for example, are automatically deleted when the browser is closed; persistent cookies, on the other hand, remain on your device for a predetermined length of time.
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According to the applicable legislation, the use of cookies does not always require your consent. In particular, “technical cookies”, i.e. those used for the sole purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user, do not usually require this consent. In short, these cookies are either essential for the operation of the Software or necessary for the activities requested by the user.

On the other hand, “profiling cookies”, i.e. those aimed at creating user profiles and used to send advertising messages corresponding to the preferences expressed by the users while browsing the net, usually require the user’s prior consent, since they are governed by the applicable regulations.

Types of cookies used by the Platform and optional enable/disable.

Except for third-party cookies, for which you should refer directly to the corresponding disable or enable procedure available via links, the Websites and the Software uses the following cookies, which can be disabled:

• Technical browsing or session cookies, strictly necessary for the operation of the Software and the Websites or to permit use of the requested content and services.
• Analytical cookies, which allow you to understand how the Software and the Websites are used. These cookies do not collect information on your identity or any Personal Data. The information is processed in aggregate and anonymous form.
• Functionality cookies, used to enable specific functions of the Software and of the Websites and a series of selected criteria (for example, the language) to improve the service provided.
• Profiling cookies, used to send advertising messages in line with the preferences you express while surfing the net.

BCD also uses third-party cookies from websites or web servers other than BCD, for the purposes of said third parties, which also include profiling cookies. Note that these third parties, listed below with links to the relevant privacy policies, are usually independent data controllers of the data collected through the cookies they serve, or act as Data Processors for BCD (i.e. they process Personal Data on behalf of BCD).

Details of the cookies sent by BCD through the Software and the website https://beefree.io/ are listed here. 

Details of the cookies sent by BCD through the website https://reallygoodemails.com are listed here.

This personal data is processed in accordance with sections 3 (d), (e), (h) and (i) of this Policy.

Cookie settings

You can block or delete technical and functional cookies (entirely or partially) through the specific functions of your browser. However, please note that if you do not consent to the use of technical cookies, it may be impossible to use the Software and the Websites, view its contents and use the services it offers. If you disable functionality cookies, the Webistes or the Software may not be available, or some services or functions of the Websites or the Software may not work properly, and you will have to modify or enter certain information or preferences manually each time you visit the Software or the Websites.

The choices made in reference to the Software or the Websites cookies will in turn be recorded in a specific cookie. However, this cookie may not work properly in some circumstances: in this case, we recommend you delete unwanted cookies and inhibit their use through the functions of your browsers as well.

Your preferences regarding cookies will be reset if you use different devices or browsers to access the Software. 

How to view and modify cookies through your Browser

You can authorize, block or delete cookies (entirely or in part) using the specific functions of your browser. You can get more information on how to set your cookie preferences on your Browser through the following links:

• Google Chrome
• Mozilla Firefox
• Microsoft Edge
• Safari

If you do not use any of the browsers listed above, select “cookies” in the relevant section of the guide to find out where your cookie folder is.

You can also manage your choices regarding third-party cookies using on-line Software such as AdChoice or All about cookies. 
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CAUTION: if you disable technical and/or functionality cookies, the Websites or the Software may not be available, or some services or functions of the Website or the Software may not work properly, and you will have to modify or enter certain information or preferences manually each time you visit the Software or the Websites.

Deleting Flash cookies

Click the link below to change your Flash cookie settings.

Disabling Flash cookies

Third parties Websites

The Websites contains links to other websites that have their own privacy policy. These privacy policies may be different from the one adopted by BCD, which therefore does not answer for third-party sites.BCD’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

DO NOT SELL OR SHARE MY PERSONAL INFORMATION

Certain types of cookies and related tracking tools, such as for targeted advertising, may involve a data “sale” or “sharing” under the definitions of certain US privacy laws. To opt out from these practices, update your preferences using the link “Cookie Preferences and Your Privacy Choices – √/X” in the footer of our Websites.

3. Purpose of processing

BCD will use the Personal Data collected through the Digital Properties for the following purposes:

1. to provide Services such as: registration and access to the Software and/or to certain features of the Websites; help if you lose or forget your Software/Websites login details/password (as well as to help you recover certain files or images created when you use the Software should they be stored on the BCD file system); access to all functions of the Software; to respond to requests for support sent to us through the specific section and/or handle reports for any alleged breach of copyrights; to allow you to view accesses to the Software and provide you with any other Service you request (including certain optional features, such as the AI Assistant embedded into our Software); verify your identity and assist you, in case you lose or forget your login/password details for any of the registration services; to reply to your requests for information sent through the contacts section and to provide any other Services which you may request (“Provision of the Service”);
2. to invite you to our events and/or take part in market research and surveys (both on the Software, through the Websites, and off); to send marketing communications, promotions, and advertising, by e-mail, SMS, by phone, by banner, instant messaging and through the official BCD social media pages, as well as for marketing activities in the broadest sense, including prize events and competitions, relating to products and/or services of BCD or third parties (“Marketing”);
3. to send marketing communications via e-mail regarding products and services similar to those you have purchased (“Soft Opt-in”);
4. to create your profile through the use of profiling cookies, if you accept, and by collecting and analysing information on your general activities on the Software and/or the Websites. We will use your profile to provide you with information on other products and/or services that BCD believes may be of interest to you, and to show you advertisements that may correspond to your tastes. All the algorithms involved in this automated or semi-automated process are regularly tested to ensure that you are not offered products you are not interested in (“Profiling”);
5. to create audiences who are similar to the users currently engaging with our Services, by sharing with third parties (namely, social media platforms, such as Facebook and/or Instagram) the hashed Personal Data of users signed up to certain of our Services and show them advertising through such third parties’ social media platforms (“Audience expansion”);
6. to allow users (external to the Digital Properties) to access BCD systems and carry out any collaboration activity required by BCD clients (i.e., review and/or amend a document, approve the content of a document, etc.) (“Collaboration activities”);
7. to allow us to improve the functioning of our services and systems (e.g., use of a caching system to save bandwidth and computation) and to carry out debugging activities, consisting in the detection and correction of one or more errors (bugs) detected in our systems (“Improvement and Debugging”);
8. to fulfil legal obligations that require BCD to collect and/or further process certain types of Personal Data (“Compliance”);
9. to collect information about how the Software is used (including files and/or images created when you use the Software should they be stored on the BCD file system), and to prevent or identify any abuse in the use of the Software or of the Websites or any other fraudulent activity, thereby allowing BCD to defend itself in any legal proceedings (“Abuse/Fraud”).

4. Lawful basis and mandatory or optional nature of processing

‍BCD applies the following lawful bases for processing your Data for the purposes indicated in preceding paragraph 3:

• Provision of the Service: processing for this purpose is necessary in order to be able to provide the Services and allow you to use the Websites and the Software in the execution of the contract that BCD executed with you or the Company you work for and to meet your requests. You are under no obligation to provide BCD with your Personal Data for this purpose, but otherwise, it will not be possible to provide you with any Service.
• Marketing: processing for this purpose is based on our legitimate interest in carrying out activities aimed at promoting our new products and/or services, as well as events, online courses, etc. At any time, you can object to this processing activity, without any consequence (other than no longer receiving communications of this kind from BCD) by following the instructions in Paragraph 8 of this Privacy Notice.
• Soft Opt-in: processing for this purpose is based on BCD’s interest in sending you marketing communications by e-mail regarding products and services similar to those you have already purchased through the Software. You can stop receiving these communications, without any consequence (other than no longer receiving communications of this kind from BCD) using the link at the bottom of each of these e-mails.
• Profiling: processing for this purpose is based on your consent collected through the cookie banner. You are under no obligation to give consent to BCD for this purpose, and you are free to withdraw it at any time without any consequence. You can withdraw any previously given consent by following the instructions in Paragraph 8 of this Privacy Notice or, as regards cookies, the information in the Cookies section.
• Audience expansion: processing for this purpose is based on our legitimate interest in expanding our customers base by creating audiences similar to the users currently engaging with our Services and showing them advertising via social media.
• Collaboration activities: processing for this purpose is necessary to provide users (external to the Digital Properties) with our services. The e-mail address is provided by BCD clients requiring their collaboration.
• Improvement and Debugging: processing for this purpose is based on our legitimate interest in carrying out debugging and caching activities.
• Compliance: processing for this purpose is necessary for BCD to fulfil any legal obligations. When you provide BCD with Personal Data, it must be processed in accordance with the applicable legislation, which could involve its storage or disclosure to the Authorities for accounting, tax, or other obligations.
• Abuse/Fraud: information collected for this purpose will be used exclusively to prevent and/or identify any fraudulent activities or abuses in the use of the Software, thereby allowing BCD to defend itself in any legal proceedings.

5. Recipients of Personal Data

Your Personal Data may be shared with the parties listed below (the “Recipients”):

• subjects who typically act as data processors or – where appropriate – as autonomous data controllers, meaning: i) persons, companies or professional firms that provide assistance and advice to BCD in accounting, administrative, legal, tax, financial and credit recovery matters relating to the provision of the Services; ii) subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communications networks); iii) social media platforms which provide us with their services for carrying out advertising campaigns;
• subjects with whom it is necessary to interact for the provision of the Services (for example hosting providers or third-party processing site, like Stripe, to process payment);
• persons authorized by BCD to process the Personal Data necessary for conducting activities strictly related to the provision of the services, who adhere to adequate confidentiality and non-disclosure agreements (e.g., BCD employees);
• other companies within the our company Group for internal administrative purposes;
• in the event of mergers and acquisitions, natural persons authorized by target companies or acquiring companies, their consultants, investors, shareholders and third-party service providers. Such disclosure may be necessary for due diligence purposes or to enable the transition of Services and it is based on our legitimate interest in carrying out corporate activities;
• if you create a profile on reallygoodemails.com, other members can see your profile information, including a picture you’ve provided, your name and username;
• subjects, entities or authorities to whom it is mandatory to disclose your Personal Data, for Compliance, Abuse or Fraud purposes, or if provided by law (such as DMCA) or by order of the authorities.

6. Transfers of Personal Data

Since BCD is a US-based company, your Personal Data are processed in the US and may also be shared with Recipients, both internal and external to our Company Group, outside the European Economic Area. BCD ensures that the processing of your Personal Data by such recipients is conducted in compliance with the applicable legislation. The Personal Data that is shared with such Recipients is limited to the categories of Personal Data that are collected by BCD as outlined in section 2 of this Policy.

All transfers are made applying suitable guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or other guarantees considered adequate. You can get more information on these matters writing to: privacy@beefree.io. 

7. Storage of Personal Data

The Personal Data processed for Providing the Services will be kept by BCD for the time strictly necessary for the aforementioned purpose, i.e. as long as there is a license agreement in place (except for certain files or images created when you use the Software, which will be kept for a period of 90 days should they be stored on the BCD file system). In any case, given that this Personal Data is processed to provide you with the Service, BCD may store it for a longer period insofar as it may be necessary to safeguard BCD against possible complaints relating to the Services.

Personal Data processed for Profiling purposes will be stored by BCD until you withdraw your consent. If you withdraw your consent, BCD will no longer use your Personal Data for these purposes but may still store it insofar as it may be necessary to safeguard BCD against possible complaints concerning this type of processing.

The Personal Data processed for Marketing, Soft Opt-in and Audience expansion purposes will be kept by BCD until you object to such processing using, respectively, the link at the bottom of each Soft Opt-in e-mail or by writing to BCD at the email address indicated in Section 8 below.

Personal Data processed for Collaboration activities will be retained by BCD until final approval of the shared project and/or document.

Personal Data processed for Debugging purposes will be retained by BCD for one year after the collection.

Personal Data processed for Compliance purposes will be kept for the period required by the specific obligation or applicable law.

Personal Data processed to prevent Abuse/Fraud will be kept by BCD for the time strictly necessary for the aforementioned purpose and, therefore, until BCD is required to keep it for disclosure to the judicial Authorities in any legal proceedings (except for certain files or images created when you use the Software, which will be kept for a period of 90 days should they be stored on the BCD file system).

8. Rights of the Data Subject

You have the right to ask BCD at any time:

• for access to your Personal Data (or a copy of such Personal Data), and any further information on the processing currently in progress regarding it;
• the correction or updating of the Personal Data processed by BCD, if it is incomplete or out of date;
• the erasure of your Personal Data from BCD databases;
• the limitation of the processing of your Personal Data by BCD;
• to obtain the Personal Data concerning you in a structured, commonly used and machine-readable format;


You can also:


• oppose the processing of your Personal Data by BCD (e.g. Soft Opt-in);
• withdraw your consent for Marketing and Profiling purposes.

You can stop receiving Marketing and/or Soft Opt-in using the appropriate links at the bottom of each e-mail received. You can use the same procedure to stop receiving the BCD newsletter, if you previously requested it as a Service.Your consent to Profiling cookies can be withdrawn using the methods indicated in preceding Paragraph 2.e. 

In addition to the above methods, you can also exercise your rights by writing to BCD at the following address: privacy@beefree.io.  

In all cases you always have the right to lodge a complaint with the competent Supervisory if you believe the processing of your Personal Data is in breach of the current regulations.

If you are located in the United States, in certain U.S. states, you may have additional rights under applicable state privacy laws, such as the California Consumer Privacy Act as amended by the California Privacy Rights Act. If you want more information about your rights, you can contact us at privacy@beefree.io.


California residents only:

In addition to the above rights, California residents, as defined by the California Consumer Privacy Act (CCPA), have the following rights and, where applicable, are entitled to exercise the following rights before BCD, at any time: 

• Right to know what information is being collected (i.e. right to access personal information).
• Right to know what personal information is shared or sold and to whom.
• Right to delete personal information.
• Right to correct inaccurate personal information.

In addition to the above method of exercising your rights, California residents can use the form accessible at the following website address to exercise their General Right to Disclosure and their Right to Disclosure of Sales:

California Resident Request

9. Amendments

This Privacy Policy has been in effect since the 14^th of May, 2024. BCD reserves to make changes or simply to update the content of the Policy, whether entirely or in part, in the event of changes in the applicable regulations. BCD will inform you of any changes as soon as they are introduced, and they will become binding as soon as they are published on the Websites. We recommend that you consult this section regularly to view the most recently updated version of the Privacy Policy, to be fully aware of the information we collect and the use we make of it.