Effective 23 May 2018
Information We May Collect
This information may include:
- Your name;
- Your company name;
- Your company or home address;
- Your telephone number;
- Your email address;
- Your email list details.
Whether you use good email marketing practices
Our websites offer a publicly accessible blog and a member community forum. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Our community forum provides the ability to create a personal profile which gives you the option to submit additional personal and demographic information about yourself, such as age and personal interests. To request removal of your personal information from our blog or community forum, contact us at .
In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Also available on our blog and on our forum, you can choose to use our referral feature to tell a friend about our site. We will ask you for your friend's name and email address. We will automatically send your friend a one-time email notifying him or her of the aspect of the site you wanted to share. We store this information for the sole purpose of sending this one-time. Your friend may contact us at to request that we remove this information from our database. Alternatively, if you used a third party application to post such information, you can remove it, by either logging into the said application to remove the information or by contacting the appropriate third-party application.
We also may display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us about using the information listed hereafter.
When you use or interact with our services, we may collect data, which may include but is not limited to type of Internet browser, Internet Protocol (IP addresses), geographic location (approximate), a record of how you use our services and sites, referring/exit pages, operating system, date/time stamp, and/or clickstream data and other data. We use this information to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole. We may combine this automatically collected log information with other information we collect about you. We do this to improve our services, to improve marketing, analytics, or site functionality.
We and our partners, affiliates, or analytics or service providers (i.e. Google, Yahoo, Bing, others), use technologies such as cookies or similar technologies to analyze trends, administer the website, tracking users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
We do not partner with a third-party to either display advertising on our website or do not manage our advertising on other third-party websites. Please note this does not opt you out of being served ads on and through third-party websites and you might continue to receive generic ads from or through such third-parties.
What We Do with Your Information
We may use your personal information to our Email service and to:
- Fulfil your registration;
- Send you a registration confirmation;
- Send you requested service information;
- Respond to customer service requests;
- Administer your registration for proper functionality of our tools;
- Send you a newsletter;
- Send you an Email with marketing communications;
- Send you an Email for support purposes;
- Respond to your questions and concerns through our email;
- Facilitate your communication with other users;
- List you in our member directory made available only to other members.
Period of Storage
Your personal data will be kept for no longer than is necessary for the specific purposes for which the personal data are processed. More precisely, personal data is kept as long as actions to us are necessary with regard to the purpose(s) of the processing of personal data.
Using Our Email Service
You can import contacts from various CRM systems and other email account address books to populate your email recipient lists. We collect the username and password for the account you wish to import your contacts from and will only use it for that purpose.
When sending emails via our service, we maintain strict privacy for all your data. Hence, if you upload or create an email list and store it online, and decide to purge or delete those email addresses, we do not keep them on our servers. They are gone forever, so please take note to export your data before you delete it if you may need to use it in the future.
While we may review your list when you upload it, just to make sure it's opt-in, we do not monitor or review the content beyond that first stage.
Also, when you create or upload an email list and store it with our service, we do not sell, rent or give away the data on your list. That data is yours and yours alone, we merely store it for you when you use our service.
3rd Party Data Processes through Our Email Service
We collect information under the direction of our readers and has no direct relationship with the individuals whose personal data it processes as part of providing our Email Service. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the regarding service agreements.
An individual who seeks access, who seeks to correct, amend, delete inaccurate data or withdraw consent to further contact should direct his/her query to our readers they interact with directly (the data controller). If our readers request that we remove personally identifiable information on their behalf, we will respond to their request within 30 (thirty) days.
We will retain personal data we process on behalf of our readers for as long as needed to provide services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
When and How We Share Your Information
We do not sell or market your personal information to third-parties.
We may provide your personal information to companies that provide services to help us with our business activities such as offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.
We will only disclose your data, the content of your private communications, or the contact information of your recipients if required to do so by law, or as otherwise stated in this Statement, or in the good faith belief that such action is necessary to (1) conform to the edicts of the law or comply with legal or bankruptcy process served to us; (2) protect and defend the rights or property of us and others, including among other things to enforce our Terms of Service; (3) act under exigent circumstances to protect the personal safety of its members or the public; (4) to correct technical problems and malfunctions in how we provide our service to you and to technically process your information; (5) to take precautions against liability; (6) to respond to claims that information you have submitted to us has violated the rights or interests of a third-party; (7) as permitted by law or to provide information to law enforcement agencies and federal bureaus.
Also, certain technical processing of email messages and their content that are required for (1) sending and receiving messages and emails; (2) conforming to connecting networks technical requirements; (3) conforming to the limitations of the Email Service; or (4) other similar technical connecting requirements.
It is possible that as we continue to develop our business, we may be acquired or merged. In such a transaction, your information may be transferred to the acquiring entity. Should this happen, you will be notified via email and a prominent notice on our Website for 30 (thirty) days prior to a change of ownership or control of your personal information. If as a result of the business transition your personally identifiable information will be used in a manner materially different from that stated at the time of collection, you will be given choice consistent with our notification of changes section.
Using sign-in services such as e.g. Facebook Connect, Twitter, Google and others, as our reader you may leave comments on our blog, reviews in our websites, and our readers can integrate social media features into email campaigns. These services will authenticate your identity and may give you the option to post information about your activities on this Website and other our websites to your profile page to share with others within your social network.
Third-Party Contracts and Understandings
The following is required to be stipulated in contracts between third-parties and us in order to be compliant with Privacy Shield framework’s Onward Transfer Principle.
Contracts must be in place with all third parties to whom the company will have personal data (received under Privacy Shield) be processed.
Wherein “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automated means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction.
Contracts must be in place with all third parties to whom the company will transfer personal information received under Privacy Shield too.
Transfers to third-parties not acting as a service provider (e.g., controllers):
- Wherein, “Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of personal data, so a controller determines the purposes and means of processing personal data and (1) the contract must be in place specifying and limiting data processing purposes consistent with the Individual’s consent and (2) ensure the third-party complies with the obligations associated with the PI (privacy information), and the same level of privacy protections are in place (3) contractually require the third-party to provide notice if they are no longer to meet the obligations associated with the data, and to either cease processing or remediate.
A contract is not required if transferring data within a controlled group of entities and another mechanism such as BCRs or intra-group agreements are in place.
Transfers to third-parties who are service providers (e.g., processors):
- Wherein, “Processor” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of personal data on behalf of a controller, so a processor is responsible for processing personal data on behalf of a controller and (1) the contract must specify and limit the purposes of processing, and act only on instruction of the transferring organization (e.g., the controller) and (2) take reasonable steps to ensure service providers act only as instructed and put in place appropriate safeguards to protect information and (3) contractually require the service provider to provide notice if they are no longer to meet with the obligations associated with the data, and to either cease processing or remediate and (4) assist, as appropriate, in responding to individual’s requests around notice, choice, access, and privacy-related complaints. Specify this requirement, as appropriate, in the contract, and (5) require that the service provider require its sub-processors to comply with the obligations associated with PI they are processing.
User Access and Preferences for our Readers
Upon request, we will provide you with information about whether we hold, or process on behalf of a third-party, any of your personal information. To request this information please contact us at .
If your personal information changes, or if you no longer desire our service, you may correct, update, amend or delete/remove certain information by making the change in your user account settings portal, by emailing our support at or by postal mail at the contact information listed below on this Website. We will respond to your request to access within 30 (thirty) days.
We acknowledge that you have the right to access your personal information. We have no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the data controller. If requested to remove data we will respond within a reasonable timeframe.
We will retain your information for as long as your subscription account with us is active or as needed to provide you services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to subscribe to our newsletter, we will use your name and email address to send the newsletter to you. We may also send our customers promotional emails occasionally. Out of respect for your privacy, you may choose to stop receiving via our Email Service our newsletter or our marketing communications by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at .
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
We are committed to compliance with the EU-U.S. Privacy Shield Framework and with the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
We are committed to cooperating with the Swiss Federal Data Protection and Information Commissioner (FDPIC) and will comply with the advice given by the authority with regard to human resources data transferred from Switzerland in the context of the employment relationship.
We are committed to the processing of personal data as it receives, under the Privacy Shield Framework, and subsequently transfers to a third-party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework as a subject to the regulatory enforcement powers of the U.S. Federal Trade Commission and the U.S. Department of Transportation, in certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We have further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.