Effective Date: May 23, 2018
1. Key Privacy Points: Email Lists. Email lists (“Email Lists”) uploaded by a customer to our Services belong to that customer. We don’t use a customer’s Email List for purposes unrelated to that customer or the use of our Services. Email Lists should only contain the portion after the @ sign of the email address.
Email Submissions. Email submissions (“Email Submissions”) uploaded by a customer to our Services belong to that customer. We don’t use a customer’s Email Submissions, including any resulting email previews generated via the Services (“Email Previews”), for purposes unrelated to that customer or the use of our Services, except in limited circumstances (e.g., we are compelled by subpoena, or the customer has given us permission to do so). Email Submissions should never contain personal data.
Email Analytics. All data collected by eDataSource on behalf of a customer that elects to use our email analytics Services (“Email Analytics”) belongs to that customer. We don’t use Email Analytics data for purposes unrelated to that customer or the use of our Services, except in aggregated, de-identified form as permitted under our Terms of Service (or such other service agreement between eDataSource and the customer) or other limited circumstances (e.g., we are compelled by subpoena, or the customer has given us permission to do so). While we strongly prefer that our customers do not provide us with or collect any personal data in connection with their use of Email Analytics Services, if a customer does elect to provide or collect that information we don’t use it for any other purpose. eDataSource is merely a custodian of that data. If you use Email Analytics Services, you agree to comply with applicable privacy laws, including requirements to inform the recipients of your emails about the specific uses and disclosures of their data described herein, and to directly address any concerns they may have about your privacy policies and/or use of their information for this purpose.
User Data. Personal data provided by customers to set up user accounts is used by eDataSource only as authorized by the individual user (“User”) or as otherwise permitted by law.
Sharing. We only share your information in limited circumstances in accordance with applicable law.
Security and Storage. We hold customer data securely on servers located in the United States. We leverage Amazon’s AWS infrastructure and built-in security controls, which incorporate several modern security standards and best practices.
3. What Information Does eDataSource Collect?
Information You Provide to Us
- Account Registration Information. You need a eDataSource User account before you can use our Services. When you set up a User account, we collect personal data, such as your name, email address, browser information, company role and username. You can choose not to provide us with certain information, but then you may not be able to register with us or take advantage of some features of our Services.
- Billing Information. If you sign up for our Services and/or to attend a paid event, we require you to provide billing details, such as a name, address, email address and financial information corresponding to your applicable method of payment (e.g., payment card information). If you provide a billing address, we will regard that as the location of the customer.
- Account Settings. You can set various preferences and personal details on your account preferences page, such as your username and communication preferences (e.g. opting in or out of receiving marketing emails from eDataSource).
- Event Registration Information. If you elect to attend an event hosted by eDataSource (e.g., eDataSource Live or a webinar), we may collect personal data, such as your name, address, telephone number, email address and other information. You can choose not to provide us with certain information, but then you may not be able to register with us or take advantage of some features (e.g., receipt of emails regarding event details, electronic copies of event materials, etc.).
- Survey Data. If you elect to participate in a eDataSource survey, we may collect, store and process your survey responses.
- Other Data. We may collect your personal information or data if you submit it to us in other contexts (e.g., sales inquiries, customer support requests, etc.).
Information Collected Indirectly or Passively when You Interact with Us.
- Usage Data. We collect usage data about you whenever you interact with our Services. This may include which webpages you visit, what you click on, when you performed those actions and other related information. Additionally, like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our website (e.g., HTML pages, graphics, etc.), operating system versions and timestamps.
- Device Data. We collect data from the devices and applications you use to access our Services, such as IP address, operating system version, device type, system and performance information and browser type. We may also infer your geographic location based on your IP address.
- Information from Cookies. We employ cookies and similar tools, including through the use of third party analytics and tracking services, to collect data about individuals who access and use our website. This data includes usage and user statistics. For example, this data tells us how often individuals use parts of our websites, so that we can make our websites appealing and easy to use, and our content as relevant as possible.
- Information from Third Parties. We may collect your personal data from third parties if you give permissions to those third parties to share your information with us or where you have made that information publicly available.
Data Collected Through Use of Email Analytics Services
We offer Email Analytics Services that, if available through a customer’s subscription, may allow us to collect data on the customer’s behalf about the emails that the customer sends. We provide a pixel that the customer may include in the body of the emails the customer sends that enables us to collect certain data on the customer’s behalf about its email recipients. Email Analytics Services are intended to allow the email sender to measure the performance of the email message and to learn how to improve email delivery and open rates. Such data may include, as determined by our customer via its configuration of the Services, the email recipients’ IP addresses, email addresses, the browser and email clients used, geolocation information inferred from IP addresses and details about how their recipients engage with the email (e.g., whether or not the email was read, forwarded or printed). It is in our customers’ discretion as to what data is collected in connection with Email Analytics Services and, therefore, each customer is solely responsible for the collection and use of any such data, including, without limitation, ensuring that such collection and use is in accordance with the customer’s privacy policies and all applicable laws.
4. How Does eDataSource Use the Information We Collect?
We use the information we collect from you, on your behalf or related to you in connection with providing our Services to you, including as follows:
- Account Setup and Access to Services. You must have an account to use our Services. eDataSource uses the information we collect for the creation of User accounts so that you can access our Services.
- Customer Support. We must access and use your information to provide customer support services, including trouble-shooting, managing account usage, responding to billing inquiries, etc.
- Service Delivery. We perform internal evaluations and statistical analysis on the information we collect to, among other things, monitor the performance of our Services, analyze and measure visitor and User behavior and trends, to understand how our Services are used, to help us improve our Services, for market research and to develop new features and functionalities.
- Enforcement of our Terms of Service. We monitor Services to ensure that use is in accordance with our Terms of Service (or other service agreement between you and eDataSource), including to prevent fraud, as well as illegal, abusive or undesirable activities.
- Transactional Communications. We may send you transactional communications (e.g., service-related announcements, billing-related matters, updates to our Terms of Service or other policies, changes to our Services, welcome emails when you register for Services, etc.). You can’t opt out of receiving these communications since they are required to provide our Services to you.
- Marketing Purposes. We will only send marketing-related communications if you have consented to receive such communications. We may combine information about you from third party sources with information we hold about you to create a user profile, which helps us to make our marketing and sales efforts more relevant to you and to personalize and improve your experience.
- Security. We use your information to maintain the security of our systems and Services (e.g., controlling abuse, spam and DDOS attacks), including the security of your User account.
- Legal Requests. We may need inspect information we hold to determine how to respond to a subpoena or other legal request. We may also contact you, to the extent permitted, regarding such matters.
5. Will eDataSource Share Any of the Information we Receive?
We may share your personal data with third parties as follows:
- With Your Organization; Billing Contacts. If the email address under which you have registered your User account belongs to or is controlled by an organization (e.g., your employer), we may disclose that email address and other pertinent account information to that organization in order to help it understand who associated with that organization uses eDataSource, and to assist the organization with its enterprise accounts. In addition, if your User account details are different from the billing contact listed for your account, we may disclose your identity and the account details to the billing contact upon their request.
- User Profiles and Submissions. Certain User profile information, including without limitation a User’s name and location, and any email, video, image or other content that such User has uploaded to the Services, may be displayed to other Users to facilitate User interaction within the Services (e.g., to provide examples on our blog or to encourage interaction through a forum hosted on our website) or to address your request for Services and support. Your account privacy settings allow you to limit the other Users who can see the personal data in your User profile and/or what information in your User profile is visible to others. Any information you upload to your public User profile, along with any personal data or content that you voluntarily disclose online in a manner other individuals can view (e.g., on discussion boards, in forums, messages and chat areas, etc.) becomes publicly available, and can be collected and used by others. Your username may also be displayed to other Users if and when you send messages or comments or upload images or videos through public portions of our websites and other individuals can contact you through messages and comments.
- Affiliated Businesses and Third-Party Services We Do Not Control. In certain situations, businesses or Third-Party Services we are affiliated with may sell items or provide services to you through our Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your personal data with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of Third-Party Services as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated Third-Party Service, please review all such policies that may apply.
- Business Transfers. We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal data would be one of the assets transferred to or acquired by a third party.
- Protection of eDataSource and Others. We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of eDataSource, our employees, our Users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
- Usage Information. We may collect usage information, such as the numbers and frequency of visitors to our websites through cookies or otherwise. We may use this information and/or data in aggregate form (as combined with information and/or data that we receive from our other Users and service providers) for our marketing or other business-related purposes. For example, usage information tells us how often visitors and Users use parts of our websites and, therefore, can be used to help us make our websites appealing as possible and our content relevant.
- With Your Consent. Except as set forth above, you will be notified when your personal data may be shared with third parties in personally identifiable form, and will be able to prevent the sharing of this information.
6. Is Personal Information About Me Secure?
- Security. We endeavor to protect the privacy of your account and other personal data we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Please remember that you control the information that you input, upload or otherwise provide in connection with your use of the Services, including Email Submissions, as well as the data that is collected in connection with your subscription to our Email Analytics Services.
- User Accounts. Your User account is protected by a username and password for your privacy and security. You must prevent unauthorized access to your account and personal data by selecting and protecting your username and password, using other sign-on mechanisms appropriately and limiting access to your device and browser by signing off after you have finished accessing your account.
- Data Location. Our Services are based in the United States, so your personal data will be hosted and processed by us in the United States. Your personal data may also be processed in countries in which eDataSource offices and personnel are located, and in which our service providers are located or have servers. By using our Services, you consent to the processing of your data in these locations.
7. What Choices Do I Have?
- Access, Edit and Delete Personal Data. You may access, and, in some cases, edit or delete certain personal data that eDataSource holds about you via your User account. Please note, however, that some information may remain in our records after deletion of such information from your account. In addition, we may use any aggregated, de-identified data derived from or incorporating your personal data after you update or delete it. If you request that any of your personal data be deleted, we reserve the right to terminate and/or limit your access to the Services to the extent Services cannot be reasonably provided without that information.
- General (non-EU) Data Privacy Requests. If you have any questions about updating information we have on file about you, please contact us at email@example.com.
- EU Data Privacy Requests. Some individuals, including those whose information is subject to European Union (EU) data privacy laws, have certain legal rights to obtain information of whether we hold personal data about them, to access personal data we hold about them, and to obtain the correction, update, amendment or deletion of such data in appropriate circumstances. For some personal data, these rights may be exercised through your User account settings, and in all cases, requests to exercise these rights may be submitted by contacting us at firstname.lastname@example.org.
- Cancel Your Account. You may cancel your account in writing, per your contract terms. In the event that your account is cancelled by you or eDataSource, or your subscription to the Services terminates or expires, following such cancellation, termination, or expiration, you will no longer be able to access any of your account information, the information that you upload or receive through your use of the Services or other personal data that we hold in our records (except as otherwise provided by applicable law).
- California Civil Code Sections 1798.83-1798.84. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal data that we share with our affiliates and/or third parties for marketing purposes, and to provide contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request by contact us at email@example.com
- Decline to Provide. You may always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of the features of our Services.
- Marketing Communications. You may opt out of receiving marketing communications at any time by clicking the “unsubscribe” link located in the footer of any marketing email you have received from eDataSource.
9. For How Long Does eDataSource Retain Data?
We generally retain data for as long as you have an account with us, or to comply with our legal obligations, resolve disputes or enforce our agreements.
10. EU-U.S. Privacy Shield
- Onward Transfers. eDataSource complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
- Enforcement. eDataSource is subject to the jurisdiction of the U.S. Federal Trade Commission regarding our compliance with the Privacy Shield Frameworks. 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 legal enforcement requirements.
- Resolution Mechanisms.
- In compliance with Privacy Shield Principles, eDataSource commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact eDataSource electronically through firstname.lastname@example.org.
- eDataSource has further committed to refer unresolved Privacy Shield complaints to the EU Data Protection Authorities, an alternative dispute resolution provider located in the EU. If you do not receive timely acknowledgement of your complaint from us, or if we have not resolved your complaint, please contact or visit The EU Data Protection Authorities for more information or to file a complaint at https://ico.org.uk/concerns/eu-us-privacy-shield/. The services are provided at no cost to you.
- You may also have the right to invoke binding arbitration under certain conditions for complaints regarding Privacy Shield compliance that is not resolved by any other Privacy Shield mechanisms. For more information, please reference https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
11. Change of Control / Asset Transfer.
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