Effective Date: August 12, 2020
a. What personally identifiable information Maropost collects.
b. How Maropost uses the information.
c. With whom Maropost may share user information.
d. Your choices about collection, use and distribution of the information.
e. The safeguarding procedures that are in place to protect the loss, misuse or alteration of information under Maropost’s control.
f. How users can correct any inaccuracies in the information. If users have questions or concerns regarding this policy, they should contact Maropost Customer Support by email at firstname.lastname@example.org.
Maropost is the sole owner of the information collected on its web properties, including http://maropost.wpengine.com. Maropost collects information from its users at several different points on our Web sites
In order to use Maropost services at any level, and to access certain information or areas of the website (including various downloads, “Test Drives”, webinars, etc.), a user must first complete the registration form. During registration a user is required to give contact information (such as name, telephone number or an email address). We use this information to contact the user about services on our sites. It is optional customer to provide demographic information (such as income level and gender), but encouraged so we can provide a more personalized experience on our sites.
When a user purchases a paying service, we request information from the user on our order form. A user must provide contact information (such as name, email, and billing address) and financial information (such as credit card number, expiration date). This information is used for billing purposes and to fill customer’s orders. If we have trouble processing an order, the information is used to contact the user.
We store information that we collect through cookies and log files to create a profile of our users. A profile is stored information that we keep on individual users that details their viewing preferences. Consequently, collected information is tied to the user’s personally identifiable information to provide offers and improve the content of the site for the user. This profile is used to tailor a user’s visit to our Web sites, and to direct pertinent marketing promotions to them. We do not share personally identifiable elements of your profile with other third parties. Your profile is shared in aggregate form only.
A cookie is a piece of data stored on the user’s computer tied to information about the user. Usage of a cookie is in no way linked to any personally identifiable information while on our site. We use both session ID cookies and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. We use session cookies to make it easier for you to navigate our Web site. A persistent cookie is a small text file stored on the user’s hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions.
By setting a persistent cookie on our site, users would not have to log in a password more than once, thereby saving time while on our site. If users reject the cookie, they may still use our site. The only drawback to this is that the user will be limited in some areas of our site. Persistent cookies enable us to track and target the interests of our users to enhance the experience on our site. See the “Profile” section, above.
Technologies such as tags, scripts, local shared objects and local storage are used by Maropost and our partners, affiliates or analytics or service providers. These technologies are used in analyzing trends, administering the website, tracking users’ movements around the site, and gathering 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 and aggregated basis.
5) Log Files
Like most Web sites, our servers use log files to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information.
6) Clear Gifs
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. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. Clear gifs are not tied to users’ personally identifiable information.
We also use clear gifs in our HTML-based emails to let us know which emails the recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, please see the Opt-out section.
7) Online Behavioral Advertising
We partner with a third party to either display advertising on our website 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 website 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.
8) Children’s Privacy
We do not knowingly collect personally identifiable information from children under the age of 13. If we learn that we have personally identifiable information on a child under the age of 13, we will delete that information from our systems. Maropost encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:
Teach kids never to give personally identifiable information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc. Know the sites your kids are visiting and which sites are appropriate. Look for Web site privacy policies. Know how your child’s information is treated.
Check out the FTC’s site for more tips on protecting children’s privacy online.
Maropost acts as a passive conduit for the distribution and receipt of its user’s e-mail communications and therefore will not monitor, edit, or disclose the contents of a user’s private communications unless Maropost in good faith believes that such action is necessary to: (1) conform to the edicts of the law or comply with legal process served on Maropost; (2) protect and defend the rights or property of Maropost; or (3) act under exigent circumstances to protect the personal safety of its users or the public. Users should also be aware (and hereby agree) that certain technical processing of and access to email messages and their content may be required to: (a) route the messages; (b) conform to connecting networks’ technical requirements; (c) prevent or minimize disruptions to Maropost’ services; or (d) conform to other similar requirements.
1) Communications from the Site
a) Special Offers, Free Trials and Updates
We send all new customers welcoming emails and may communicate with them to introduce and explain their new services. Visitors to our website that are not customers but provide Maropost with contact information may receive emails from Maropost that contain information about our services, special offers and other promotions. Established users will occasionally receive emails containing information about us, updates on new service features, service usage tips, information about third party services or other Maropost services that are likely to be of interest to our users, and customers satisfaction questions. Visitors and Maropost users may opt-out of such notices. Please see the Choice and Opt-out sections. We may contact former customers to gather feedback on the services.
b) Invoices and Account Statements
We send all customers regular emails summarizing usage and credit card charges. These emails are a part of the Maropost service, and users cannot opt-out of receiving them, though they can deactivate their account. Information identifying the credit card is not included in these communications
c) Service Announcements
On rare occasions it is necessary to send out a strictly service related announcement. For instance, if our service is temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.
d) Customer Service
We communicate with users on a regular basis to provide requested services and regarding issues relating to their accounts. We reply via email or phone, in accordance with the users wishes.
Periodically, our site requests information from users via surveys. Participation in these surveys is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address), and demographic information (such as zip code). Survey information will be used for purposes of monitoring or improving the use and satisfaction of Maropost’s services. Users’ personally identifiable information is not shared with third parties unless we give prior notice and a choice to opt-out. Though we may use an intermediary to conduct these surveys, they may not use customers’ personally identifiable information for any secondary purposes.
f) Referral Programs
Periodically, Maropost offers referral services, asking a user to inform a friend about our service. We collect the name and email address of the friend, and will automatically send an email invitation to the friend. Maropost stores this information for the sole purpose of sending this email and tracking success of the programs. Your friend may contact us at email@example.com to request that we remove this information from our database.
a) Legal Disclaimer
Though we make every effort to preserve user privacy, we may need to disclose personally identifiable information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our Web site. For example, Maropost may disclose personally identifiable information to law enforcement, other government officials, or third parties in response to criminal or civil subpoenas. Sometimes, these requests come from our third party Internet, telecommunications and service providers all over the world who supply the network required for us to deliver our services. In order to maintain the integrity of our network, we often cooperate with requests from these third party providers and/or requests from law enforcement or other governmental officials directed to these providers.
b) Aggregate Information (non-personally identifiable)
We may share aggregated demographic information with our partners. This is not linked to any personally identifiable information.
c) Third Party Intermediaries
We use an outside credit card processing company to bill users for goods and services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes.
d) Business Transitions
In the event Maropost goes through a business transition, such as a merger, or acquisition by another company, or selling a portion of its assets, users’ personally identifiable information will, in most instances, be part of the assets transferred. Users will be notified prior to a change of ownership or control of their personally identifiable information. If as a result of the business transition, the users’ personally identifiable information will be used in a manner different from that stated at the time of collection they will be given a choice not to have their information used in this different manner, as described in the notification of changes section, below.
Maropost does NOT share your email address externally. While we cannot be responsible for external communications received through Maropost services, if we are given notice that a Maropost Service is being used for spam, then we will deactivate that client.
Maropost users and visitors who do not wish to receive our promotional communications may opt-out from receiving these communications by clicking the opt-out link included at the bottom of every promotional message.
Maropost users may not opt-out of receiving invoices and usage information, service announcements, and customer service communications, although they can deactivate their account.
We display personal testimonials of satisfied Clients on our Web site 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 us at firstname.lastname@example.org.
1) User Information
Maropost takes every precaution to protect its user’s information. When users submit sensitive information via Maropost’ Web sites, their information is protected both online and off-line.
When our registration/order forms ask users to enter sensitive information (such as credit card number) and when you log in to our platform (such as login credentials), that information is encrypted and is protected with the best encryption software in the industry – SSL. While on a secure page, such as our paid order form, the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just ‘surfing’.
While we use SSL encryption to protect sensitive information online, we also employ security measures to protect user- information off-line. All of our users’ information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerks or a customer service representative) are granted access to personally identifiable information. Finally, the servers that store personally identifiable information are in a secure environment.
No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at email@example.com.
2) Message Content Handling
We will store your personal transmissions on our servers for a limited time and will endeavor to purge old transmissions from its servers when the expiration period has run out (up to 365 days).We use industry-standard efforts to safeguard the confidentiality of your transmissions (as well as your personally identifiable information), such as firewalls and SSL technology. These are the same technologies that most websites use to safeguard credit card information and other personally identifiable information. However, that said, “perfect security” does not exist over telephone lines and the Internet and Maropost accordingly accepts only limited liability for security breaches.
3) Data Retention
The time period for which we keep information varies according to what the information is used for. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed.
If a user’s personally identifiable information changes (such as zip code, phone, email or postal address), or if a user no longer desires our service, we provide a way to correct, update or delete/deactivate users’ personally identifiable information by contacting Maropost Customer Service at firstname.lastname@example.org or by making the change on our member information page or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request to access within 30 days.
Information Related to Data Collected for our Clients
Maropost 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 one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personally identifiable information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
Access and Retention of Data Controlled by our Clients
Maropost has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Maropost’s Client (the data controller). If requested to remove data we will respond within 30 days.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Maropost will retain this personally identifiable information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If, however, we are going to use users’ personally identifiable information in a manner different from that stated at the time of collection we will notify users via email prior to the change becoming effective. Users will have a choice as to whether or not we use their information in this different manner. However, if users have opted out of all communication with the Web site, or deleted/deactivated their account, then they will not be contacted, nor will their personally identifiable information be used in this new manner. In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our Web site notifying users of the change. In some cases where we post a notice we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices.
On July 16, 2020, the European Union Court of Justice invalidated the EU-US Privacy Shield framework, declaring its provisions lack adequate data protection, in particular from specified U.S. entities. Regardless of this ruling Maropost remains committed to its obligations under the agreement, which is to ensure data protection when transferring personal data from the European Union to the United States.
Maropost is responsible for the processing of personal data it receives under the Privacy Shield Frameworks. Maropost complies with the Privacy Shield Principles’ liability provisions for all onward transfers of personal data from the EU and Switzerland to third parties acting as agents on its behalf.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Maropost is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
Maropost commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Maropost Privacy Team at email@example.com.
Maropost has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland. You may have the possibility, under certain conditions, to engage in binding arbitration through the Privacy Shield panel.
Maropost processes personal information (“Processor”) on behalf of our clients who themselves (“Controllers”) and/or their customers (“Data Subjects”) are under the jurisdiction of the European Union. GDPR requires all Controllers facilitate the exercise of Data Subjects rights under Articles 15 to 22. Maropost, as a Processor, is fully able to comply with the exercise of those rights whether through our software, or upon notification of our clients.
Maropost is also a Controller of personal information of Data Subjects who have given us their express consent to receive promotional communications. Data Subjects wishing to exercise their Right to Erasure must submit a written request to firstname.lastname@example.org and include the following information: first name, last name, and email address (and/or mobile device number). Maropost shall erase a Data Subject’s Personal Data within 30 days from receipt of the written request. In cases where compliance cannot be satisfied within this time frame, Maropost shall extend the compliance deadline an additional two months. If this extension is required, then Maropost shall inform the Data Subject within the initial 30 day period along with an explanation of the reason. In cases where Personal Data is not required for statistical purposes, it shall be purged from the system. In cases where Personal Data is required for statistical purposes, it shall be pseudonymized in accordance with Article 89 Paragraph 1.