Privacy notice for third parties — Art. 14 GDPR

Knowing your data
is treated with respect.

Someone has named you as a Beneficiary, Guardian or representative on Erabox, or you appear in content they have kept. This document explains clearly who processes your data and how.

Art. 14 GDPR (EU) 2016/679 Swiss FADP Art. 28 GDPR — Controller and processor
Sections 1 · Who we are 2 · Data processed 3 · Legal basis 4 · Retention 5 · Recipients 6 · Your rights 7 · How to exercise them 8 · Supervisory authority

1

Who Erabox is and why you are receiving this document

Why are you reading this? An Erabox user, referred to below as the ‘Owner’, has named you as the recipient of a message, as a Guardian or as the representative of a minor, or your data appears in content they have kept. If you are a Guardian, the invitation you received contains the link to this document. If you are a Beneficiary, you receive it at the time chosen by the Owner: within one month of being named, if the Owner chose to let you know in advance, or at the time of delivery. In any case, the document is published on this page and anyone can read it.

Erabox SA, Via delle Fornaci 6 — 6826 Riva San Vitale (TI), Switzerland, processes your data in one of two roles, depending on your position:

  • if you are a Guardian, Erabox is the controller: Erabox uses your data to verify the event that starts the delivery;
  • if you are a Beneficiary, the representative of a Beneficiary who is a minor, or a person who appears in the content of a capsule, the controller is the Owner, who decided what content to keep and who to deliver it to; Erabox keeps it and delivers it on the Owner’s behalf as processor (Art. 28 GDPR; Art. 9 FADP).

In either case, you can contact Erabox. If your request concerns data that Erabox processes on the Owner’s behalf, Erabox forwards it to the Owner and helps them respond; if the Owner has passed away or does not respond, Erabox handles it directly.

Data Protection Officer (DPO): Massimiliano Nicotra, lawyer — privacy@erabox.ch.

EU representative: Massimiliano Nicotra, lawyer.

Erabox is a platform for memories and messages for the future: it lets people create personal messages and content to be delivered — automatically and securely — to the people they love, at the moment in life that matters most. The Owner chooses the recipient, the moment and the content. Erabox takes care of the delivery.

2

What data of yours we process

Your data was provided by the Owner: Erabox did not collect it directly from you. The categories of data depend on the role you have been given:

If you are a Beneficiary
  • First name and surname
  • Email address
  • Phone number (optional)
  • Date of birth (if provided)
  • Relationship to the Owner (e.g. child, partner)
If you are a Guardian
  • First name and surname
  • Email address
  • Phone number
  • Type of relationship with the Owner
If you are a minor’s representative

First name, surname, email, phone number and your capacity as parent or legal representative. We process only the data strictly necessary for your role as representative.

No sensitive data collected from you. Erabox does not ask you for health data, payment data, identity documents or biometric data. Capsule content is encrypted at rest and protected in transit; Erabox keeps it on the Owner’s behalf, does not use it for its own purposes, and access to the systems is restricted to authorised staff and logged.
If you appear in the content of a capsule

Content added by the Owner (texts, photos, recordings) may also concern you. Erabox keeps it on the Owner’s behalf and does not check what it contains. If you think a piece of content concerns you or breaks the law, you can report it to privacy@erabox.ch: Erabox reviews the report, tells you the outcome and gives reasons for any action taken (Art. 16 of Regulation (EU) 2022/2065).

3

Why we process your data and on what legal basis

Purpose Legal basis (GDPR) Legal basis (FADP)
Guardian — sending you the invitation, this notice and requests for confirmation; verifying the event that starts the delivery (Erabox as controller) Art. 6(1)(f) Legitimate interest of Erabox and the Owner in reliable verification of the event Art. 6 FADP; Art. 31(1) FADP
Beneficiary — keeping your contact details and delivering the content to you at the time chosen by the Owner (Erabox as processor) Processing carried out on the Owner’s behalf, on their instructions (Art. 28 GDPR). An Owner acting for personal or household purposes falls within the exemption in Art. 2(2)(c) GDPR Art. 9 FADP; Art. 2(2)(a) FADP
Beneficiary — letting you access the content you received and verifying your identity on delivery, if required (Erabox as processor) Processing carried out on the Owner’s behalf, on their instructions (Art. 28 GDPR) Art. 9 FADP
Everyone — security, abuse prevention and access logs (Erabox as controller) Art. 6(1)(f) Legitimate interest in the security of the service Art. 31(1) FADP; Art. 4 Data Protection Ordinance

Your data is never used for marketing, commercial profiling, sale to third parties or to contact you with promotional messages. Your contact details are in our system only so that the Owner can keep you reachable.

4

How long we keep your data

Situation Retention period
The Owner is active and keeps you as a recipient For as long as the Owner’s account exists
The Owner removes you from their list Deletion within 30 days
The content has been delivered For the 30 days the delivery link is valid, then deletion within 30 days
The Owner’s subscription expires without renewal 30-day grace period and 12 months of read-only suspension, then deletion. If the Owner’s passing has been reported or confirmed by the Guardian, the data is kept until delivery, up to a maximum of 10 years.
The Owner’s account is closed Deletion within 30 days of closure
You ask for deletion Within 30 days of your request

In all cases, Erabox keeps the technical logs needed for security for 12 months, as required by Art. 4(5) of the Swiss Data Protection Ordinance.

5

Who we share your data with

Your data is not sold or passed on to third parties for commercial purposes. It may be shared only with:

Technical service providers

Providers of hosting, databases and email and notification sending, which act as processors or sub-processors under a written contract. The up-to-date list, with their location and the safeguards for transfers, is in section 05 of the Privacy Policy.

Competent authorities

Only where required by law — a request from a Swiss or European judicial or police authority — and only to the extent strictly necessary.

The Owner

The Owner can see your name and the fact that you have been named, but never has access to your login details, your bank details or any other private information beyond what they entered themselves.

6

Your rights

Even if you are not directly one of our users, you have all the rights provided by the GDPR (Arts. 15–22) and the FADP (Arts. 25–32):

Right of access (Art. 15 GDPR)

You can ask us to confirm whether we process data about you and get a copy of it.

Right to rectification (Art. 16 GDPR)

You can ask us to correct inaccurate or incomplete data about you.

Right to erasure (Art. 17 GDPR)

You can ask for your data to be erased. In that case, we will tell you if removing it means you will not be able to receive the content intended for you.

Right to object (Art. 21 GDPR)

You can object to processing based on legitimate interest. We will consider your request and reply within 30 days.

Right to data portability (Art. 20 GDPR)

You can receive your data in a structured, machine-readable format.

Right to restriction (Art. 18 GDPR)

In certain circumstances, you can ask us to suspend processing while we look into your request.

7

How to exercise your rights

It’s simple. Write to us at privacy@erabox.ch with the subject ‘Exercising GDPR/FADP rights’ and your first name and surname. We’ll reply within 30 days, free of charge.

To verify your identity before replying, we may ask you for a copy of an identity document with everything except your first name, surname and date of birth blacked out. This is not mandatory, but it helps us protect your data from unauthorised requests.

If your request is complex, this period can be extended by a further 60 days — we’ll let you know within the first 30 days.

Received something and not sure what to do?

You can contact us at privacy@erabox.ch — we’re here to help, even if you just want to understand. You don’t need an account to do so.

8

Complaints to a supervisory authority

If you believe the processing of your data breaches the applicable law, you have the right to lodge a complaint with a supervisory authority:

Switzerland — FDPIC

Federal Data Protection and Information Commissioner (FDPIC)

www.edoeb.admin.ch

EU — National authority

You can contact the data protection authority of the EU country where you live.

List of EU authorities →

Want to talk to us before making a complaint?

We’re happy to help sort out any question or problem directly: privacy@erabox.ch. We care about getting this right.

notifications

Create something that stays.

The iPhone app is coming soon: leave us your email and we’ll let you know as soon as it’s available. On Android, you can already download it from Google Play.

No spam. Just one message when the iPhone app is available.

check_circle

You’re on the list.

We’ll let you know as soon as the iPhone app is available. Thank you for your trust.