Feedback Loop Service Privacy Policy

Return Path Feedback Loop Privacy Policy

Effective Date: November 17, 2014

Introduction

Thank you for taking the time to read our Privacy Policy. Your privacy is of the utmost importance to us. Our business depends on the trust of thousands of companies and millions of people. Violating that trust is simply not an option. We want you to be fully informed about the information we collect, how it is used, shared, and protected, and the choices you have with it.

The following explains the privacy and data practices at Return Path, Inc. (“Return Path”, “We”, “Us”, or “Our”). After you read it, if you have any questions please contact the Return Path Privacy Office by using this simple online form and submitting a ticket under privacy department. We’ll be glad to help.

Our Privacy Policy will tell you about:

Thank you for visiting our website and using our products and services.

Sincerely,
Matt Blumberg, CEO

TRUSTe Program and Scope

TRUSTe Certified Privacy

Return Path, Inc. has received TRUSTe’s Privacy Seal signifying that this Privacy Policy and our practices have been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal. The TRUSTe certification does not cover information that may be collected through downloadable software. The TRUSTe certification covers only our collection, use and disclosure of information we collect through our website. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe here

E.U. and Swiss Safe Harbor

Return Path, Inc. complies with the U.S.—E.U. Safe Harbor framework and the U.S.—Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Return Path, Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Return Path, Inc.’s certification, please visit www.export.gov/safeharbor/.

The Organization Collecting Information at This Website

Return Path (“Company” or “we”) operates the Feedback Loop Service (the “Service”) through various websites (the “Site”), by which it allows users who register with us to receive feedback messages from participating Internet Service Providers (“ISPs”). Return Path provides this service on behalf of select ISPs partnered with us.

The Information We Collect and Use

By information we mean information about you collected through our Service website(s), including your email address and other information you provide to us by registering for our services or making requests for information about our services. Any information provided to us will be retained and used solely for the purposes of fulfilling your request for information, fulfilling a request through a Site feature, performing and carrying out the terms of the Service, or communicating with you as a member of the Service.

Registration

Registration for the Service is not required to simply view the Site. If you elect to register for the Service, Return Path asks you for information that enables us to provide the Service. You will be registering with Return Path on the form provided and such registration may require you to provide contact information such as your name and email address.

Aggregate Information

From time to time, we may collect general, non-personal, statistical information about the use of the Site and the Service, such as how many visitors visit a specific page on the Site, how long they stay on that page, and which hyperlinks, if any, they “click” on. We collect this information through the use of technologies such as “cookies” and “IP addresses”, which are discussed in greater detail below. We may also group this information into aggregate visitor data in order to describe the use of the Site and Service to our existing or potential business partners or other third parties, or in response to a government request. However, please be assured that this aggregate data will in no way personally identify you, other list members or any other visitors to the Site.

Retention of Personal Information

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. We will make good faith efforts to delete the data if you contact us by following the instructions at the beginning and at the end of this Privacy Policy, provided Return Path is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.

IP Addresses

An IP address is a number that’s automatically assigned to your computer whenever you’re surfing the web. Web servers, the computers that “serve” web pages, automatically identify your computer by its IP address. Company collects IP addresses for purposes of system administration, to report aggregate information to third parties and to track the use of the Site. When visitors request pages from the Site or click on a link in a mailing sent through the Service our servers log the visitors’ IP addresses. We reserve the right to use IP addresses to identify a visitor or list member when it will enhance the users experience or if we feel it is necessary to enforce compliance with the Site’s policies or to protect Company, the Site, its visitors, the Service, our Internet Service Provider partners, the list members or others.

Cookies and Other Tracking Technologies

Technologies such as: cookies, beacons, tags and scripts are used by Return Path and our marketing partners, affiliates, or analytics or service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site 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 as well as aggregated basis.

We use cookies to remember users’ settings (e.g. language preference), for marketing tracking purposes and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

Clear Gifs (Web Beacons / Web Bugs)

Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly in HTML files and are about the size of the period at the end of this sentence.

We may use clear gifs in our HTML-based email to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you no longer wish to receive our newsletter or other promotional communications by email, you may opt-out of receiving them by following the instructions included in each communication.

Profile

We may store information that we collect through cookies and clear gifs to create a “profile” of your preferences. We may tie your personal information to information in the profile to provide tailored promotions and marketing offers or to improve the content of the Site for you. We do not share your profile with third parties.

Information Sharing and Disclosure

Except for the limited situations listed here in this Privacy Policy, we will not share your personal information with third parties. To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.

Internet Service Provider Partners

Return Path provides this Service to you on behalf of select Internet Service Providers (“ISPs”) partnered with us. In order to provide the Service to you we will make your registration information available to our Internet Service Provider partners as necessary. This information is provided to them so that they may evaluate, approve, and otherwise administer the Service for you. In such instances, we provide your registration information to these partners but they are not permitted to retain or use your information for any other purpose other than administering this service.

Agents and Third Party Service Providers

To provide the Service to you, we may sometimes use other businesses to perform certain specialized services such as data processing or other technology services. In such instances, we may provide your personal information to those businesses but they are not permitted to retain or use your information for any other purpose.

Change of Control / Asset Transfer

As the Company develops, we may buy other businesses or their assets or sell all or parts of our business assets. Customer information is generally one of the business assets involved in such transactions. Thus, in the event that the assets of the Company in whole or in parts are acquired by a third-party, customer information, including any visitor information collected through the Site or the Service, would be one of the transferred assets. In the event of a corporate change in control or sale of all or parts of our business assets our users will be notified in accordance with the “Changes to this Policy” section of the policy if their personal information is provided to the new corporate entity or asset purchaser.

Communications from the Site

Feedback Loop Complaint Messages

In order to fulfill the Service, we will send you Feedback Loop Complaint Messages on behalf of our ISP partners.

Service Email

We will send you service-related announcements, which are not promotional in nature, on occasions when it is necessary to do so. For example, if our service is temporarily suspended for maintenance, we may send you email notification.

Customer Service

Based upon the information you provide us, we will communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We may communicate with you by email or telephone.

Newsletters and Promotions

We may provide you the opportunity to opt-in to additional newsletters or promotional communications sent by email. If you have opted in or otherwise qualify to receive these forms of communication, we will use your name and email address to communicate with you. Out of respect for your privacy, we provide you a way to unsubscribe. Please see the “Choice and Opt-out” section.

Choice/Opt-out

Service Email messages are required to fulfill the Service to you. You may opt out of these communications, which are not promotional in nature. If you do not wish to receive them you may opt-out and/or deactivate your account by following the instructions included in each communication or by contacting Return Path Support using this simple online form.

Feedback Loop Complaint Messages are required to fulfill the Service to you. These communications are not promotional in nature. If you do not wish to receive them you may deactivate your registered feedback loops in the account interface provided to you or by contacting Return Path Support using this simple online form.

We may provide you the opportunity to opt-in to additional newsletters or promotional communications sent by email. If you have opted in or otherwise qualify to receive these forms of communication, and no longer wish to receive our newsletter or other promotional communications by email, you may opt-out of receiving them by following the instructions included in each communication.

Security and Information Protection

The security of your information is important to us. When you enter sensitive information (such as a credit card number) on our payment forms, we encrypt that information using Secure Socket Layer (SSL) technology.

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Firewalls

Protecting the security of your personal information is very important to us. When we store information that you have provided to us when registering for the Service, that information is protected by security measures that include “firewalls” (a combination of computer hardware and software that helps keep unauthorized visitors from accessing information within our computer network), “intrusion detection systems” (a combination of computer hardware and software that helps detect any unauthorized visitors) and other tools such as data encryption and physical security, where appropriate.

Unfortunately, no data transmission over the Internet or data repository can be guaranteed to be 100% secure. As a result, while Company strives to protect your personal information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your personal information.

Privacy Policy for Children

We do not knowingly collect information from children under the age of 13 on the Site or through the Service. If you are under the age of 13, please do not provide any information to us. If we become aware that we have collected information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database.

Changes to This Policy

The terms of this Privacy Policy may change from time to time. We will notify you of any material changes to this Privacy Policy by posting a notice on the homepage of the Site for a reasonable period of time after such changes are made, that this Privacy Policy has been updated, and by changing the Effective Date at the top of this Privacy Policy. We encourage you to check this page periodically for any changes. Your continued use of the Site and participation in following the posting of changes to these terms will mean you accept those changes.

Contacting Us

We value your opinions. If you have comments or questions about our privacy policy, you may contact the Return Path Privacy Office by using this simple online form and submitting a ticket under privacy department, or contact:

Return Path, Inc.
3 Park Avenue, 41st Floor
New York, New York 10016
Attn: Chief Privacy Officer
Phone: (212) 905-5500
Fax: (212) 905-5501