Return Path Data Privacy Policy

Effective Date: October 2, 2017


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”). 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. After you read it, if you have any questions please contact the Return Path Privacy Office by emailing us at 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.

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 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

The mission of Return Path and its subsidiary companies is to make email better for everyone. We build products and provide services to make your inbox a safe and manageable place filled with email you want to receive and nothing more.

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

Through these Sites, we provide various email management and information products and services through which users who register with us may analyze and manage email messages received and better understand relevant data such as purchase and other information from their email stored in their personal email accounts.


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 will be 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.


Registration Information

Registration for the Service may not 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 such registration may require you to provide contact information such as your name, username, password, and email address.


Service Usage Information

We collect non-personal information − data in a form that does not permit direct association with any specific individual – and personal information automatically when you access and use the Service. For example, when you use the Service, we may collect data from and about the commercial electronic mail messages, transactional or relationship messages that are sent to your email accounts so that we can better understand the behavior of the senders of such messages, develop anonymized data products from your email messages and interactions (“anonymized data products”), as well as better understand our customer behavior to improve our products, services, and advertising. If we do disclose such messages, all identifiable personal information will be removed or obfuscated prior to any such disclosure. If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined. We may collect, use, transfer, and disclose non-personal information, including anonymized data products, for any purpose.

The services Return Path offers are:



The Context.IO Developer Terms of Service contain some 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 specific disclosures exist which allow for the Context.IO Services to be utilized within your mobile or web product or service, and data to be shared with Return Path. If you are a developer and have powered your mobile or email application with Context.IO, please review your Developer Terms of Service.

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 and Context.IO collect personal information from you and your email accounts that are connected to Context.IO. This includes but is not limited to your name, email address, username and password. Context.IO may also collect personal information from visitors when they communicate with us about our services and products or during other transactions or interactions. Context.IO will use personal information to provide services and products requested by you, to enable its vendors and contractors to provide and assist Context.IO in the marketing and provision of such services and products to you, or to develop anonymized data products. We also use your information to improve spam filters, detect and help stop phishing attacks, help companies adopt best practices, and analyze how people interact with commercial email. You may opt out of sharing information with Context.IO at any time by going to or to marketing communications sent by Context.IO via the opt-out link contained in the communications.


With your permission, Return Path connects your email account(s) to one or more applications developed and operated by OtherInbox. Our OtherInbox applications provide a service whereby our servers scan your mailbox to inventory, organize and categorize email and/or to assist in unsubscribing from selected senders. As part of that process, we index information about commercial email companies who have sent you email. For example, we index information like FROM domain, FROM IP Address, Message Subject line, Message Date, and Message Body URLs. We retain data from these commercial messages, about the commercial sender, including their name and reply email address, Message Subject line, and message content and unsubscribe link (if present). We also retain user usage data points, including whether the email was opened, moved, forwarded, clicked, or marked as spam. We use this collected information, including personal information, to operate or improve the Service, to develop new services, features or applications and to develop anonymized data products.

Return Path Consumer Applications

With your permission, our Consumer Applications (Shopami, Whisker Widget, Organizer, and Unsubscriber), connect to your email account(s) that you choose in order to provide you services such as indexing coupons, offers and promotions from your inbox and helping you manage your preferences for commercial emails. When you connect your email accounts to our Consumer Applications, Our servers scan your mailbox and store information, including personal information, in order to help us provide services to you, improve or develop new services, features or applications and to develop anonymized data products. We may retain message level information (like what’s described above in our OtherInbox product) as well as your location data (e.g., when you use a location-enabled feature in Shopami, we may collect and process information about your location), device information (such as product model, operating system and the device identifier or “UDID”), log information (such as device event information, system activity, hardware settings, internet protocol address, and details of how you used our services). If you do not want us to collect or use your location for the purposes set forth above, you should turn off the location services for Shopami located in your account settings on your mobile device and or within the Shopami application itself. If you choose not to share your location information, then certain features may be limited or unavailable.


Aggregate Information

From time to time, we may collect general, non-identifiable personal, statistical information about the use of the Sites and the Service, 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 also group this information into aggregate visitor data in order 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, please be assured that this aggregate data will in no way personally identify you, other list members or any other visitors to the Sites.

We may store your personal information along with your files and data on a third party server 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.


Cookies and Other Tracking Technologies

Technologies such as: cookies, beacons, tags and scripts are used by Return Path, Inc. 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

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 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 uses 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 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.

GPS/Location services

We use GPS technology (or other similar technology) within the Shopami location to determine your current location in order to determine the city you are located within and display a location map with relevant advertisements or store location or relevant coupons. At any time, you can disable location services on your personal device (generally in your devices “account settings”), and we will no longer have access to your location information.

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.



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.


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


Information Sharing and Disclosure

Except for the limited situations listed here in this Privacy Policy, we will not share your identifiable 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.


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, 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, including to help us develop anonymized data products. These entities are not permitted to retain or use your information for any other purpose other than to perform work for us.


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, and 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.


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.



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


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 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.


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


Security and Information Protection

The security of your information is important to us. When you enter sensitive information (such as your registration information and/or geo-location data) 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, therefore, always use caution when submitting personal information online. If you have any questions about security on our website, you can contact the Return Path Privacy Office by emailing us at



Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, you may contact the Return Path Privacy Office by emailing 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.



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 may contact the Return Path Privacy Office by emailing us at


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