Certification Privacy Policy

Effective Date: October 2, 2017

Introduction

We know that your privacy is important to you. At Return Path, we’re committed to helping you understand how we manage and protect it. We take privacy seriously, and have taken many steps to help safeguard the information we collect and manage for you.

This privacy policy (“Privacy Policy”) is provided to inform you of our policies and practices and of the choices you can make about the way your information is collected and how that information is used.

If you have questions or concerns regarding this policy, you may contact the Return Path Privacy Office by emailing us at privacy@returnpath.com.

Our privacy policy will tell you about:

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

Sincerely,
Matt Blumberg, CEO

 

TRUSTe Privacy Certification

EU – U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Return Path, Inc. participates in and has certified its compliance with the EU – U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Return Path, Inc. is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, 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.

Return Path, Inc. is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Return Path, Inc. complies 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, Return Path, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission In certain situations, Return Path, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge).

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

 

The Organization Collecting Information at This Website

Return Path (“Company” or “we”), operates the website located at www.returnpath.com (the “Site”). Through the Site, we operate Return Path Certification (including Return Path Certified and Return Path Safelist—collectively the “Service”), an email sender accreditation service, by which information submitted by applicants is evaluated for membership into the Service.

 

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, reviewing your application for the Service, fulfilling a request through a Site feature, performing and carrying out the terms of the Service, or communicating with you as an applicant or member of the Service.

 

Registration

Completion of an application for the Service is not required to simply view the Site. If you elect to apply 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 company name, your name and your 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 (such as Google Analytics), 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), tracking for marketing 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 emails 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.

 

Log Files

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.

 

Local Storage (HTML5)

We use Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

 

Behavioral Targeting / Re-Targeting

We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.

 

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.

 

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.

 

Frames

Some of our pages utilize framing techniques to serve content to/from our partners while preserving the look and feel of our site. Please be aware that you are providing your personal information to these third parties and not to www.returnpath.com.

 

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

 

Service Email

Service-related email messages are required to fulfill the Service to you. You may opt out of these communications, which are not promotional in nature. As a qualified member of the Service, we will send you Daily Performance Reports indicating your performance standing in the Service, or informational notices with regard to program standards, requirements and operations.

We will also send you service-related announcements 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. 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.

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 by following the unsubscribe instructions included in each communication.

Correcting, Updating or Removing Your Personal Information

Upon request Return Path will provide you with information about whether we hold any of your personal information. Return Path will make commercially reasonable efforts to provide you reasonable access to any of your personal information we maintain within 30 days of your access request. We provide this access so you can review it, make corrections or request deletion of your data. If we cannot honor your request within the 30-day period, we will tell you when we will provide access. In the unlikely event that we cannot provide you access to this information, we will explain why we cannot do so. To review and update your personal information to ensure it is accurate, contact the Return Path Privacy Office by emailing us at privacy@returnpath.com.

 

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. If you have any questions about security on our website, you may contact the Return Path Privacy Office by emailing us at privacy@returnpath.com.

 

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.

 

Social Media Widgets

Our website includes Social Media Features, such as the Facebook button and Twitter button or interactive mini-programs that run on our website. These Features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy policy of the company providing it.

 

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 emailing us at privacy@returnpath.com, 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

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