Return Path Full Privacy Policy

Effective Date: March 12, 2018

 

Introduction

We know that your privacy is important to you. At Return Path (“Return Path”, “Company”, “We”, “Us” or “Our”), 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 is to inform you of our policies and practices and of the choices you can make about the way your information is collected and used.

This policy discloses the information practices for Return Path and our affiliates’ Web sites, from what type of information about our Web sites’ users is gathered and tracked, how the information is used, shared or otherwise processed. It also describes how cookies, web beacons and other technologies may be used in our Software-as-a-Service (SaaS) offerings and products.

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

Return Path participates in and has certified its compliance with the EU – U.S. Privacy Shield Framework. Return Path is committed to subjecting all personal data received from European Union (EU) member countries, 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 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 complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Return Path is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Return Path 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

The mission of Return Path and its subsidiary companies is to make email better for everyone. For consumers, we provide products and services to make your inboxes a safe and manageable place filled with email you want to receive and nothing more. For businesses, our deliverability analytics help you understand how to optimize your email campaigns. For Security companies using email data, our Data Feed products help identify email-based bad actors, threats and compromises.

The products and services of Return Path and its subsidiaries include Context.IO, OtherInbox, and Switch Labs, Inc. We operate and own the websites (the “Sites”) located at:

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The Information We Collect and Use

We refer to the above products and services, as well as any of our other current or future products and services, collectively as the “Service.” Any information provided to us through the Service is retained and used for the purposes of fulfilling your request for information, fulfilling a request through a Site or Service feature, performing and carrying out the terms of the Service, performing or improving our Service, developing a new Service, communicating with you as a user of Return Path’s services or as otherwise described in this Privacy Policy.

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Registration Information

Registration for a Service may not be required to simply view a Site. If you elect to register for a 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 we may require you to provide contact information such as your name, username, password, and email address.

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Service Usage Information

We collect non-personal information − data that does not permit direct association with any specific individual – and personal information when you use our Service.

Information Related to Data Collected through your use of Context.IO

  • Developers:  The Context.IO Developer Terms of Service contains specific obligations applicable to you regarding your privacy and data practices. These obligations include things such as ensuring that you are publishing a sufficient privacy policy to your End Users, that it is available to your Users for review in a sufficient manner, and that you are informing your Users about how data is shared with Return Path through the Context.IO platform. If you are a developer and have powered your mobile or email application with Context.IO, please review the Developer Terms of Service for your obligations. 
  • Service End-Users: If you are an email user using a third party mobile or email application powered by Context.IO, then with your permission at sign-up or use of the application, Return Path through Context.IO collects personal information from you and your email accounts connected to Context.IO. This includes but is not limited to your name, email address, username and password. This data is collected to provide the Context.IO-powered application access to your inbox.

Context.IO connects to your inbox over IMAP/API, and copies data from your inbox to secure, encrypted cloud instances controlled by Return Path for fulfillment of the Service.

  • For paid Context.IO-powered applications, your applicable data is retained in our secure, encrypted cloud instance only for as long as it is needed for the Context.IO-powered application to render the Service. Return Path makes no use of your data other than by providing connectivity through Context.IO.
  • If you are a free-of-charge subscriber to Context.IO-powered applications, we exercise our legitimate interest in operating the Context.IO API and retain some data from your inbox for up to six months. We are interested in understanding how you generally interact with your inbox (ex: how much time you spend in your email account, at what time you check your emails), which email campaigns (marketing, transactional, relationship-type messages) you engage with, and what that engagement was (ex: did you read/delete/mark as spam). We collect this data to help our clients adopt best email sending practices, optimize delivery of email marketing campaigns to you, help email and Internet service providers improve their spam filters, improve upon or develop a new Service, and help Internet security companies detect and stop phishing attacks. We will index and retain information from your email such as, but not limited to: Sending Domain and IP Address, Subject Line, Message Date, Message Body URLs, redacted and obfuscated non-personal message content, and engagement data points, including whether the email was opened, moved, forwarded, clicked, or marked as spam.
  • We are not interested in personal correspondence, and immediately delete personal messages from the data we might retain, along with other emails which are not identified as commercial messages. The data we retain is de-identified or pseudonymised (ex: we remove your email address, street address, phone and account numbers, along with any of your other identifying information) before being included in our products or services.
  • You may opt out of sharing information with Context.IO at any time by going to http://optout.context.io.

Context.IO may also collect personal information from visitors when you communicate with us about our services and products (ex: if you write to us with a question) or during other transactions or interactions on our websites (see more in the cookies section, below) required for the provision of the Service.

Information Related to Data Collected through your use of Return Path’s Consumer Applications

Return Path’s Consumer Applications (1) Whisker Widget, (2) Organizer, (3) Unsubscriber, (4) Notifier for Outlook, and (5) Email to PDF provide services such as (1, 2 and 3) organizing and categorizing email, unsubscribing you from email campaigns, and helping you manage your preferences for commercial emails (4) helping you keep track of your unread email message count, and (5) converting emails to PDF format. When you sign up for any of these applications, we’ll collect your name, email address, and password to access your email account. 

Once access is established, we connect to your inbox over IMAP/API, and copy data from your inbox to secure, encrypted cloud instances controlled by Return Path. We then programmatically parse your data, indexing information including, but not limited to, Sending Domain and IP Address, Subject line, Message Date, Message Body URLs, redacted and obfuscated non-personal message content, and engagement data points, including whether the email was opened, moved, forwarded, clicked, or marked as spam.

Return Path previously hosted the Shopami service which received email address, correspondence metadata, and device identifying data of its users. We retired this service on May 25, 2018 and have deleted all related user data including any personal user data as it relates to this service. If you believe you were a Shopami user and need assistance or if you have any further questions, please email privacy@returnpath.com.

In order to provide our Consumer Applications at no cost to you, we use some of the data we parse from your inbox for our legitimate business purposes. We are interested in understanding how you generally interact with your inbox (ex: how much time you spend in your email account, at what time you check your emails), which email campaigns (marketing, transactional, relationship-type messages) you engage with, and what that engagement was (ex: did you read/delete/mark as spam). We collect this data so we can help our clients adopt best email sending practices, optimize delivery of email marketing campaigns to you, help email and Internet service providers improve their spam filters, improve upon our existing Service or to develop a new Service, and help Internet security companies detect and stop phishing attacks.

We are not interested in personal correspondence, and immediately delete personal messages from the data we might retain, along with other emails which are not identified as commercial messages. The data we retain is de-identified or pseudonymised (ex: we remove your email address, street address, phone and account numbers, along with any of your other identifying information) before being included in our products or services.

You can opt-out of data sharing at any time by removing the corresponding app from your email account.

Information Related to Data Collected through your use of the Return Path Solutions (Email Optimization and Intelligence Suite, and Client Services)

Return Path collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by them, please contact them directly.

We retain personal data we process on behalf of our Clients for as long as needed to provide services to our Clients, and we may transfer personal information to companies that help us provide our services. Return Path will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If a Client requests we remove data we will respond within 30 days.

Information Related to Data Collected through your use of Feedback Loop Services

Return Path provides Feedback loop services 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 (first name, last name, email address, along with any domain or IP data you provide) available to our ISP partners. This information is provided so that they may evaluate, approve, and administer the Service for you. 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.

Information related to data Collected through your use of our SenderScore Services

The data you provide to us by registering for SenderScore (first name, last name, email address, phone number), or by making requests for information about our service, is 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.

Information related to data Collected through the Data Feed Services (ie. betterbounces.net, threatwave.com)

We collect some information that can be used to identify you as an individual (“Personally Identifiable Information”) only when you provide such information directly to us in connection with the Service. We ask for Personally Identifiable Information such as your name and e-mail address when you register for an account with the Site, or if you correspond with us for information or support. We may also retain any messages you send to our through the Service, and may collect content and information you provide by posting to the Service (“User Content” ). We may receive Personally Identifiable Information about you from third parties, including, for example, information about your transactions, purchase history, or relationships with various product and service providers, and your use of certain applications. For example, if you access our website or Service through a third-party connection or log-in, for example, through Facebook Connect, by “following,” “liking,” linking your account to the Site, etc., that third party may pass certain information about your use of its service to us. This information could include, but is not limited to, the user ID associated with your account, any information you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to betterbounces.net or threatwave.com website or Service.

We also collect and use information about your interactions with the Service in a manner and format that does not identify you as an individual (“Non-Personally Identifiable Information”).

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Aggregate Information

From time to time, we may collect general, non-personally identifiable, statistical information about the use of the Sites and the Services, such as how many visitors visit a specific page on the Sites, 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 group this information into aggregate visitor data to describe the use of the Sites 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, we use industry best efforts to pseudonymize the data to prevent personally identifying you, other list members, or any other visitors to the Sites.

We may store your information on third-party servers such as Amazon Web Services; or we may use a third party analytics tool to learn how you are using our Sites.

In cases where you use a mobile device to access our Sites, we will receive information about the location of your device. In some cases, even if you are not using a mobile device, information about your general location may be discernable from your device’s IP address or the URLs we receive. If you access or use our Sites or Services with your mobile telephone, we may collect your telephone number.

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Where Your Information is Processed

Return Path and many of its service providers are based in the United States. Return Path and its service providers may also maintain data processing facilities outside of the United States. If you use the Service, please be aware that your information will be transferred to, processed, and used in the United States and other countries where we and our service providers maintain data processing facilities. If you are located in the European Union, Switzerland or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including your personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. By signing up for and opting in to our services, you consent to the transfer of information to the U.S. or any other country in which Return Path or its parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

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Information Sharing and Disclosure

Except for the limited situations listed here in this Privacy Policy, we will not share your personal information with unapproved 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 unapproved third parties as part of legal process.

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Agents and Third Party Service Providers

To provide the Service to you, we may sometimes use approved third-party businesses or individuals to perform certain specialized services such as data processing, hosting, analysis or other technology services. Return Path may transfer personal information that we collect about you to affiliated entities or to other trusted third parties to perform services for us. These entities are not permitted to retain or use your information for any purpose other than to perform work for us.

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Security and Information Protection

The security of your information is important to us. When you enter personal information (such as your name, email address, and other registration information) 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. You should always use caution when submitting personal information online. If you have any questions about security on our website or products, you can contact the Return Path Privacy Office by emailing us at privacy@returnpath.com.

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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.

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Retention of Personal Information

When we collect your personal information (including geo-location data), we will retain it as long as your account in the relevant Service remains enabled, unless applicable law requires otherwise. However, we will make good faith efforts to delete your personal information if you contact us by following the instructions at the beginning and at the end of this Privacy Policy, provided that we are 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. If you wish to cancel your account or request that we no longer use your information to provide you services contact the Return Path Privacy Office by emailing us at privacy@returnpath.com.

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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. We collect 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 user’s experience, is necessary to perform a contract we have with our Clients, 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.

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Cookies, Web Beacons, and Other 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. To read more about how we use cookies, click here.

Log Files

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 Objects (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.

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.

Frames

Some of our pages utilize framing techniques to serve content to from our partners while preserving the look and feel of our website. Please be aware that you are providing your personal information to these third parties and not to http://context.io.

Behavioral Targeting / Re-Targeting

We partner with a third party to either display advertising on our website or to manage our advertising on other sites (for example on social media sites). Our third party partner may use technologies such as cookies or emails 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) or by unsubscribing within the ad itself. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link this information we store within the analytics software to any personal information you submit within the mobile application.

Profile

We store information that we collect through cookies and clear gifs to create a “profile” of your preferences. We tie your personal information to information in the profile to provide tailored promotions and marketing offers or to improve the content of the Sites for you.

We do not share your personal identifiable profile with unapproved third parties. We undertake to ensure that your personal information is kept strictly confidential and is not disclosed to third parties without your permission. Details will be used only by our staff and/or approved agents to support the necessary terms and conditions for use of service such as service providers under contract who help with our business operations and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.

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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 Sites 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.

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Communications from the Sites

Service Email

As someone with an active Service account, we may send you service-related email messages, which are not promotional in nature, on occasions and when it is necessary. Similarly, if you request assistance with a Site or one of our products or services, we will communicate with you through email until we have addressed your questions.

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 instructions included in each communication.

Push Notifications

We may occasionally send you push notifications through our consumer applications to send you application updates and other service related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off in the device settings.

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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.

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Collection and Use of Third Party Personal Information

You may provide personal information about other people, such as their name and email address. This information is only used for the sole purpose of completing your request or for whatever reason it may have been provided.

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Single Sign-On

You can apply for employment at Return Path using sign-in services such as Linkedin or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal information (such as your name and email address) with us, and to pre-populate our sign up form. Services like LinkedIn give you the option to post information about your activities on this site to your profile page to share with others within your network.

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Blog

Our website offers publicly accessible blogs. Our blog is managed by a third party application that may require you to register to post a comment. We do not have access or control of the information posted to the blog. You will need to contact or login into the third party application if you want the personal information that was posted to the comments section removed. To learn how the third party application uses your information, please review their privacy policy.

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Testimonials

We display personal testimonials of satisfied customers on our website 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 the Return Path Privacy Office by emailing us at privacy@returnpath.com.

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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.

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Changes to This Policy

The terms of this Privacy Policy may change from time to time. We will notify you or our Client of any material changes to this Privacy Policy by posting a notice on the homepage of the Site for a reasonable period of time prior to the change becoming effective. 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.

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Contact Us

We value your opinions. If you have comments or questions about our privacy policy or about the collection, use, disclosure and processing of your personal data, 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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