PRIVACY POLICY
1. WEBSITE PRIVACY POLICY
2. GENERAL SERVICES PRIVACY POLICY
3. ONLINE and DIGITAL SERVICES PRIVACY POLICY
Last
Updated Dec , 2020
1. 1. Website /
Application / Shopping cart Privacy Policy
Scope
This
Emailexpress Website Privacy Policy (the “Privacy Policy”) applies solely to
information collected by Emailexpress. (“Emailexpress”) on this Emailexpress
website (the “Site”). This Privacy Policy provides information about how and
why Emailexpress collects and uses the information provided to us on this Site.
For
information on Emailexpress’s range of services, how we use data across our
different services, and your options, please refer to the Emailexpress General
Services Privacy Policy located below.
For
information on Emailexpress’s online behavioral advertising activities and how
to opt out of having data processed for online behavioral advertising purposes,
see the Emailexpress Online and Digital Services Privacy Policy located below.
Links
to Third Party Sites
This
Privacy Policy does not apply to the information collection and use practices
of third-party sites including, but not limited to, client and affiliate
websites, applications and websites on which we may place advertisements, and
any third-party websites you may link to from our sites. Emailexpress does not
endorse or make any representations about these third-party sites or
applications, or any information, software, products or materials found there.
We encourage you to review the privacy policies of these third-party sites to
understand their data collection and use practices.
Information
Collection, Use and Sharing
Information
Collection
We
collect two types of information from and about our Site Users: personal
information (or “personal data” in the EEA) that identifies you, which is
collected when you provide it do us, and tracking data which is collected when
you navigate the website.
Tracking
data may include things like the Uniform Resource Locator (“URL”) of the Site
you visited before coming to our Site, the URL of the Site you visit after leaving
our Site, the type of browser you are using and your Internet Protocol (“IP”)
address. We, and/or our authorized third parties, may automatically collect
this information when you visit our Site through the use of electronic tools
like Cookies and Web beacons or Pixel tags, as described below.
We
use tracking data to troubleshoot, administer the Site, analyze trends, gather
demographic information, comply with applicable law, and cooperate with law
enforcement activities. We may also share this information with our authorized
third parties to measure the overall effectiveness of our online advertising
and content.
Personal
Data. Personal Data means information from which you can be identified. It does
not include anonymous or aggregated data that cannot be linked back to a specific
individual.
Information
Use
Emailexpress
uses the information we collect at this Site to fulfill your requests, respond
to your inquiries and provide Emailexpress news or updates. We may also use
your information to make our Sites easier for you to use and to inform you of
service and product updates, whitepapers, new products, market research
opportunities and other related information from Emailexpress, or to send you
promotional messages regarding various Emailexpress products and services.
Emailexpress
may use your tracking data to analyze trends, administer the Site, track users’
activities on the Site, help us understand the parts of our Sites visited most
often and gather broad demographic information for aggregate use in improving
our Site.
Emailexpress
may also obtain personal information from you if you apply for a job with us.
This data would include name, email address, mailing address, employment
history and any other information contained in your resume/C.V. that you submit
through our Site. We may use this information to send you a welcoming email, to
verify your username and password for employee recruitment purposes, and to
respond to your requests for information and correspond with you throughout the
application process.
Information
Sharing and Disclosure
Emailexpress
may share your information with our affiliate companies and service providers
for the purposes described in this policy.
We
reserve the right to disclose your information as required by law, court order
or other valid legal processes or in connection with the consolidation, sale of
or other transaction related to our business. We also reserve the right to
disclose your information if we believe in good faith that disclosure is
necessary to protect our rights, protect your safety or the safety of others,
investigate fraud, or respond to a valid government request.
Choices
Opt-Out
of Emailexpress Newletter Communications
You
may opt-out from receiving Emailexpress Newletter Communications by
clicking on the unsubscribe mechanism included in each email message we send.
Even
if you choose to opt-out of our communications, Emailexpress will retain and
use your information to comply with our legal obligations, resolve disputes,
enforce our agreements and to maintain a record of your opt-out. You may also
still receive transactional emails, such as registration confirmation, product
updates and responses to direct requests you have made.
Cookie
Policy
Cookies
are small text files that store data using your web browser to make your
browsing experience easier and faster. We, and our third-party service
providers who assist with managing our Site, use cookies, web beacons and
similar technologies on our Site to improve the performance of our Site, to
make our Site more user-friendly and to track your use of our Site.
Types
of Cookies used on our Site
Performance
Cookies: These cookies collect information about how visitors use our Sites for
web analytics purposes, for instance which pages visitors go to most often and
error messages received. These cookies are only used to improve how our Sites
work and your experience on our Sites; they do not track your browsing activity
on other websites. By using our Sites, you agree that we can place these types
of cookies on your device.
Functionality
Cookies: These cookies allow our Sites to remember choices you make (such as
remembering your username and password, language preference or the region you
are in) and provide enhanced, more personalized features. These cookies may
also be used to remember changes you have made to text size, fonts and other
personalization. They may also be used to provide services you have requested,
such as keeping you logged in to your account as you browse the internet. These
cookies do not track your browsing activity on other websites. By using our
Sites or by signing up for an account with us, you agree that we can place
these types of cookies on your device.
Managing
Cookies in You Browser
You
may be able to adjust your browser settings to manage your cookie preferences,
such as setting your browser to notify you when you receive a cookie and give
you the choice to decide whether or not to accept it. If you reject cookies,
you may still use our Sites, but the functionality of some areas may be
limited.
Below
are links to information about managing your cookie preferences in common
browsers:
Content
Sharing Features
Our
Sites include social media sharing features, such as LinkedIn and Twitter
buttons, and may set a cookie to enable the feature to function properly. These
features may collect your IP address and which page you are visiting on our
Sites. Social media features are governed by that social media company’s
privacy policy.
DATA
RETENTION.
We
only retain the information we collect, including personal data, for as long as
necessary to fulfil the purposes we collected it for, including for the
purposes of satisfying any legal, accounting, or reporting requirements.
To
determine the appropriate retention period for personal data, we consider the
amount, nature, and sensitivity of the personal data, the potential risk of
harm from unauthorized use or disclosure of your personal data, the purposes
for which we process your personal data and whether we can achieve those
purposes through other means, as well as applicable legal requirements.
SECURITY.
Emailexpress
uses commercially reasonable safeguards to protect personal information against
loss, misuse or alteration and to maintain the integrity and security of all
information collected through the Site.
YOUR
RIGHTS REGARDING PERSONAL DATA.
You
may have the following rights under applicable data protection laws in relation
to your Personal Data, including:
Request
access to your personal information
(commonly known as a “data subject access request”). This enables you to
receive a copy of personal information we hold about you.
Request
correction of the personal information
that we hold about you. This enables you to have any incomplete or inaccurate
information we hold about you corrected.
Request
erasure of your personal information.
This enables you to ask us to delete personal information. There may be some
cases where, as allowed by applicable laws we may refuse to delete data. We may
also anonymize data so that it cannot be related back to you instead of
deleting it.
Object
to processing (opt out) You
also have the right to object where we are processing your personal information
for direct marketing purposes.
Request
restriction of processing of
your personal information. This enables you to ask us to suspend the processing
of personal information about you, for example if you want us to establish its
accuracy or the reason for processing it.
Request
the transfer of your personal information to
another party.
If
you want to review, verify, correct or request erasure of your personal
information, object to the processing of your personal data, or request that we
transfer a copy of your personal information to another party.
INTERNATIONAL
DATA TRANSFERS.
For
users based in the European Economic Area (EEA) we may share your personal data
within the Emailexpress Group or with external third parties. This may involve
transferring your data outside the EEA, including (but not limited to) the
United States or India.
Whenever
we transfer your personal data out of the EEA, we ensure a similar degree of
protection is afforded to it by ensuring at least one of the following
safeguards is implemented:
·
We may transfer your personal data to
countries that have been deemed to provide an adequate level of protection for
personal data by the European Commission. For further details, see European Commission: Adequacy
of the protection of personal data in non-EU countries.
·
We may transfer data subject to
specific contracts approved by the European Commission, which ensures that
personal data the same protection it has in Europe regardless of where it is
processed. For further details, see European Commission: Model
contracts for the transfer of personal data to third countries.
·
For some service providers based in
the US, we may transfer data to them if they participate in the EU-US Privacy
Shield program, which requires them to provide similar protection to personal
data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy
Shield.
Please
contact us if you want further information on the specific mechanism used by us
when transferring your personal data out of the EEA.
Do
Not Track
Currently,
various browsers – including Internet Explorer, Firefox, and Safari – offer a
“do not track” or “DNT” option that relies on a technology known as a DNT
header, which sends a signal to Web sites’ visited by the user about the user’s
browser DNT preference setting. Emailexpress does not currently commit to
responding to browsers’ DNT signals with respect to the Company’s Web sites, in
part, because no common industry standard for DNT has been adopted by industry
groups, technology companies or regulators, including no consistent standard of
interpreting user intent.
Children’s
Privacy
This
Site and the services we provide are intended for general audiences, and is not
intended for use by persons under the age of 16. If we learn that we have
inadvertently collected personal information from a child under the age of 16,
we will delete it. If you believe that we have collected personal information
from a child under 16, please contact us using the information below.
Updates
to this Privacy Policy
We
reserve the right to modify this privacy statement at any time. Note the date
of the most recent update at the top of this page. If we make material changes
to this policy, we will notify you here, by email, or by means of notice on our
home page.
Contact
Us
To ask questions about Emailexpress’s Privacy Policy or to request more information on Emailexpress’s privacy practices, email us at privacy@Emailexpress.io
Or
send correspondence via mail to:
Emailexpress
4283
Express Lane
Suite
3347-808,
Sarasota,
Florida, 34249
2. GENERAL SERVICES PRIVACY POLICY
INTRODUCTION
Emailexpress
is a marketing and advertising company that uses software and data about
consumers to help advertisers reach selected audiences via online or in-app
ads, email, direct mail, or telemarketing. Emailexpress collects and uses data
about individual consumers in order to identify or predict the types of
advertisements most likely to appeal to them. We use a lot of data, because
more data points about a person’s interests and purchase intent leads to more
accurate advertising with a higher rate of return for advertisers. Emailexpress
has various lines of service, as described below, and the way each works is
different. But in general, the sole purpose for our collection and use of data
is to match people to advertisements that are likely to interest them. That is
our mission. We use data, software, and ingenuity to help advertisers reach
people who want their products and services. Our business succeeds when we help
advertisers achieve higher-than-average rates of response to ads—that is,
people clicking on or forwarding an ad or ultimately making a purchase.
This
Services Privacy Policy describes each of the different types of services we
provide, which for purposes of this privacy policy are divided into two main
categories:
·
Service
Provider:
where Emailexpress handles personal data collected by another company (our
client) under the terms of its privacy policy solely to perform a service for
that company; and
·
Data
Collector:
where Emailexpress uses personal data it has collected from and about individuals
on its own behalf. The terms of this privacy policy apply to these services.
When
we act as a service provider, we follow the client’s privacy policy because the
data we process as a service provider belongs to our client and we handle the
data only at the client’s direction and acting exclusively on their behalf.
When Emailexpress collects data directly from consumers or obtains data
collected by third parties for our own business purposes we are responsible for
how such data is used and shared, and for giving effect to individuals’ privacy
legal rights.
For
all of our services the overall purpose of our data collection, use,
and sharing is the same—to match advertisements to people who have a
propensity to engage with them, and ultimately to increase sales for our advertiser
clients.
All
services may include some amount of “lookalike modeling,” where we use data
about known purchasers of a product or respondents to an ad to identify
individual attributes that indicate a propensity to buy that product or respond
to that ad. This allows us to create a profile of the attributes of a person
most likely to respond to an ad, which is used to inform who a future ad will
go to.
We do not provide services that include ads with illegal or adult
content, nor do we advertise on adult sites or collect data about what adult
sites people visit. We do not knowingly collect or sell personal information
from children under 16. In the event that we learn that we have collected
personal information from a child under the age of 16, we will delete it. We do
not knowingly facilitate any advertising that is exploitative, discriminatory,
hateful, deceptive, or abusive, and our process for doing this is audited
annually.
The
types of data we use are also the same across
all our services:
(1)
Data you have provided directly either to Emailexpress, our client (an
advertiser), or another company you authorized to share data for marketing
purposes. This data generally consists of an email address, in some cases name
and street address, and/or the answers to survey questions or questionnaires.
(2)
Data collected indirectly from you using cookies or other online or mobile
technologies that allow us to identify certain sites that you visit or apps
that you use online. Included is information about when and where you gave your
permission to receive commercial email, your IP address, and visits you made to
certain websites. We log these page views to help infer your interests in order
to determine what sort of products or services might interest you. This data
typically does not include direct identifiers (like name and address), but it
can still be linked back to you via unique identifiers like a cookie ID, mobile
ad ID, or an encrypted version of your email address.
(3)
Data we have obtained from third-party data brokers or data partners. This may
include data obtained from public records (like your street address, age, and
gender), but also data relating to purchases, interests, or likely interests
that can be derived from a wide variety of sources. In some cases, we may
obtain data from third parties in or close to real time in regard to a specific
ad placement. This “just in time” approach to obtaining data means that we
collect and aggregate less data ourselves, while still being able to draw on
third-party data sources to help make decisions about which ad to send to which
person.
Our
sources of data include:
·
You,
when you give data directly to one of our websites, clients, or data sharing
partners;
·
Advertisers
who may provide us data they have collected from or about you to use in
performing marketing and advertising services for them;
·
Data
we or others collect using cookies or other online trackers. In some cases this
data may be linkable to your directly identifying data (name & email);
·
Data
brokers who supply data obtained from public records, or who resell data
obtained from private sources. Data from private sources (like magazine
publishers, credit card companies, or retailers) typically has its directly
identifying data removed (like your name and email address) and is linked
instead via unique identifiers like a proprietary ID, encrypted email address,
or other indirect identifiers, but in some cases we are able to link this data
back to you.
·
Data
partners who supply data similar to the kinds we obtain from data brokers. The
difference between a data broker and a data partner is that we buy data from
data brokers, but we may exchange data with data partners.
Recipients
of our data include service providers who
perform services for us like web hosting, data security services, or auditing,
our advertiser clients, and companies that we may trade data with for purposes
of Online Behavioral Advertising (see below). Emailexpress is not a data broker
in the sense that we do not simply sell data. The ways in which we share data
with our clients are very limited. You will find more details on this in the
sections below describing each of our services.
SERVICES
WHERE EMAILEXPRESS ACTS ONLY AS A SERVICE PROVIDER
Where
we perform services exclusively as a service provider or data processor, the
data that we handle belongs to our advertiser client. In most cases this data
will be provided to Emailexpress by the advertiser. Advertisers may also ask us
to collect data on their behalf through various means, including direct
collection from individuals, indirect collection via cookies or other online
tracking mechanisms, or via third-party sources like data brokers. When we
collect data as a service, all of the data we collect belongs to our client and
is governed by the client’s privacy policy.
Database
Services. Emailexpress performs services
for clients that include database setup, structuring, formatting, migration,
and maintenance. In some cases, Emailexpress maintains a “database of record”
for a client, meaning that the client has outsourced the maintenance of its
primary customer database to Emailexpress. In such cases, Emailexpress will
collect data directly from individuals, but handles the associated personal
data exclusively as a service provider and does not do anything with the data
outside the scope of the services that we have been hired to perform.
Email
Services. Clients may engage Emailexpress
to send email to their existing customers on their behalf. For instance, if you
have given a retailer your email address, we might send commercial or
transactional messages from that retailer, such as an emailed receipt for a
purchase, a reminder that you have items in your shopping cart, or to deliver
an updated client privacy policy. We may also send you advertisements from that
retailer, for instance offering discounts, new products, or sales. When we
perform these services we are acting on the advertiser’s behalf, and everything
we do is at the advertiser’s direction and subject to the terms of its privacy
policy.
Call
Center Services. Clients may engage Emailexpress
to receive calls on their behalf, or to make telemarketing calls on the
client’s behalf. When we perform these activities as a service provider, we use
client-owned data and perform our services in line with the terms of the
client’s privacy policy.
CRM
Services. We may use our software and
know-how to help a client better organize and manage its own customer data, or
to use its own data to determine which ads to send to which customers.
SERVICES
WHERE EMAILEXPRESS COLLECTS AND USES DATA ON ITS OWN BEHALF
The Emailexpress
Marketing Automation Data Cloud is what we call the data related to
identified people that Emailexpress collects and uses on its own behalf. The Emailexpress
Data Cloud consists of several databases where we store data that we have
obtained from the different sources described above. It also includes
connections to other third-party sources of data (data brokers and data sharing
partners) so that we can get data at or near real time in order to inform
specific ad placements. This approach means that we are using the freshest,
most up-to-date data we can obtain, and it also reduces the amount of data we
need to gather into one place in order to provide our services.
Personal
data in the Emailexpress Marketing automation platform is collected when an
individual consents to have their data used for marketing purposes. The
permission is generally provided at a website or landing page where an
individual provides an email address and checks a box authorizing the data to
be used for marketing purposes, transferred to third parties, and augmented
with other data obtained from other sources. Once we have obtained this
consent, we supplement the data initially provided by the individual with
additional online and offline data. Our goal is to obtain the richest and most
up-to-date picture we can of individual consumers so that we can make the best
possible decisions about which ad to show to which person.
We
may also use data from the Emailexpress Marketing automation platform on a
temporary, limited basis to evaluate potential data sharing partners. When we
do one of these evaluations, it is subject to appropriate contractual terms
that include that the company we are evaluating may not do anything else with
the data and must delete any data that we share at the end of the evaluation.
Personal
data in the Emailexpress Marketing automation platform is used for the
following services:
Acquisition
Email. For this service, we send client
advertising by email to people who have consented to receive commercial email.
These emails all comply with local laws pertaining to the sending of commercial
email and include opt-out links so that recipients can request not to receive
future emails. This service does not include selling data to our clients. Our
clients obtain data when someone we have sent an ad to responds to the offer or
makes a purchase. Then we will provide the client data showing that we
advertised to that person, to show that we played a part in bringing a new
customer or a new sale to the advertiser.
Acquisition
Email services for a particular client often begin with an analysis of the
client’s existing data in order to create a profile of the type of individual
who is most likely to respond to a particular offer. We then look to the Emailexpress
Marketing automation platform to find people who share those attributes but who
are not already existing customers of our client and send the offer to those
people.
CRM
and Data Cloud Services. This
service consists of loading a Emailexpress client’s customer data onto a secure
Emailexpress-controlled server, and then using our software to compare the
client’s data with data in the Emailexpress Marketing automation platform. In
most cases, we have more data points about our client’s customers than the
client has. We can use that to generate insights that the client could not
produce on their own, like which existing customers would be most likely to
respond to a particular ad campaign. We may sell data to an advertiser
as part of this service, in the form of interest categories and
inferred purchase intent data that relates to the client’s existing customers.
In other words, we don’t sell our clients lists of people, but we might provide
the advertiser with additional information about its existing customers that it
didn’t previously have.
Online
Behavioral Advertising. The
data we use for Online Behavioral Advertising (OBA) is maintained in a separate
database from the data in the Emailexpress Marketing automation platform.
Individual profiles in the Emailexpress Marketing automation platform generally
include an associated email address or other directly identifying information,
where the data that we use for OBA does not include any directly identifying
data. Rather, the data used for OBA is tied to a cookie ID, a mobile
advertising ID, or other data related to a specific device, like a computer,
smartphone or smart TV.
When
you visit different sites on the internet, different companies place cookies on
your device, and use these to obtain information about the sites you visit, the
ads you respond to, and the online purchases you make. Through a process known
as “cookie matching” different companies (data sharing partners) can either
sell or exchange different bits of this data. By stitching together bits of
data from lots of different sources, we are able to create a rich and
up-to-date data set that enables us to make predictions about what ad is likely
to appeal to a specific person, or which person is most likely to respond to a
specific ad. Emailexpress performs cookie-matching between the data used for
OBA and the Emailexpress Marketing Automation platform to enable users of our Data
Cloud to leverage the interest and purchase intent data generated on the OBA
side of our business. This cookie-matching means that data used for OBA could
theoretically be linked to fully identifiable data, but we have internal
policies against re-identifying data used for OBA.
We
offer some more focused services within the broad sphere of OBA, including
operating a “demand side platform,” which is a means of matching specific users
to specific ads, personalizing content on a website to a users’ interests, and
placing online ads across a range of websites. Please see the Emailexpress
Online and Digital Service Privacy Policy, below, for more information on this
service. Other focused services related to OBA are described below.
Optimization
and Analytics Services. These
services help our clients (generally brands and other companies that advertise
online) manage their digital advertising programs. For example, we may help
these businesses customize your experience when you visit their website,
generate leads and manage their keyword search advertising programs. Where we
can reasonably infer that a particular computer or mobile device belong to the
same user or household, we may extend our Optimization and Analytics Services
across those devices. We undertake these activities on behalf of our customers
and subject to their respective privacy policies.
Opting-out
of Online Behavioral Advertising and Data Collection by Our Cookies
To learn more about this type of targeted advertising (also called
interest-based advertising), analytics services and your choices, including how
to opt-out of some interest based advertising,
visit https://www.youronlinechoices.com or https://youronlinechoices.eu/, the DAA Consumer Opt-Out Page, NAI Consumer Opt-Out Page
and Google’s information page.
You
can also refuse or disable cookies already stored on your browser as follows:
For Edge, click here
For Internet Explorer, click here
For Mozilla Firefox, click here
For Google Chrome, click here
For Safari, click here
Below
are links to information about managing your cookie preferences in common browsers:
YOUR
PRIVACY RIGHTS
Privacy laws around the world give individuals different versions of the
following rights. Emailexpress allows any person to exercise the following
rights no matter where they live. Emailexpress will not discriminate against
you for exercising your privacy rights. Prior to fulfilling a request for a
copy of data, Emailexpress is required to reasonably verify your identity.
Under applicable laws, you can use an authorized agent to make a request on
your behalf, but that agent must still verify your identity and demonstrate
that they have been authorized to make the request. We will only use the
personal data provided for this purpose (e.g. a copy of an identification
document) to verify the requestor’s identity or authority to make the request.
To
exercise your rights with respect to data in the Emailexpress
Data Cloud by either you or an authorized agent email to info@emailexpress.io
·
Data
Access / Portability-you
can request a copy of the data that we hold about you in an identifiable form.
Note that a lot of the data that we process is not maintained in an
identifiable form, and that privacy laws generally do not require companies to
make data identifiable for the purpose of responding to an access request. If
you make an access request, we will normally respond within 30 days if you live
in Europe or Canada, or 45 days if you live elsewhere, however, if we are
experiencing a high volume of requests we may take up to 90 days to respond if
we tell you. You can access (or delete) data used for Online Behavioral
Advertising at any time.
·
Correction-you can ask us to correct data that
we hold about you if it is inaccurate.
·
Data
Deletion-you
can ask us to delete data that relates to you. As allowed by applicable laws,
there may be some cases where we will decline requests for deletion, but these
are rare cases.
·
Objection
/ Restricting Processing-in
some countries you have a legal right to object to processing of data about
you, or to ask that such processing be restricted. To keep things simple, if
you wish to exercise these rights please request to have your data deleted.
·
Opt-Out
of Receiving Email from Emailexpress-you can ask to be added to our global email
suppression list so that we won’t send any more commercial emails to the email
address you opt out.
·
Opt-Out
of Sales of Data-you
can request that we do not make your data available to our clients for their
own use. But we may still use it for analysis, or to advertise to you.
You
also have the right in many countries to contact a privacy or data protection
authority if you believe we are not complying with privacy laws and we have not
been able to resolve the situation to your satisfaction. Many countries have a
dedicated privacy / data protection authority; in the United States you can
make a complaint to the U.S. Federal Trade Commission or your state Attorney
General.
WHERE
WE PROCESS DATA
Emailexpress is headquartered in the United States, and the majority of our
services are performed in the United States and/or India. When you provide data
to Emailexpress, you consent to its processing in the U.S., India, or any of
our other locations around the world. Emailexpress has established internal
data transfer agreements that include the EU’s Standard Contractual Clauses as
our basis for enabling EU data to be handled lawfully in non-EU countries.
Our
online services may collect data relating to residents of any country, but the
majority of the data in the Emailexpress Data Cloud relates to residents of the
United States. We may also handle client-owned data as a service provider that
originates from any country.
HOW
LONG WE KEEP DATA
We keep data only for the period of time needed in order to achieve our stated
purposes—i.e. to match people with ads that interest them. Different data is
therefore needed for different lengths of time. If you have given us data and
permission to market through one of our websites or a partner website, we will
continue to use your data for marketing purposes until you revoke your consent
/ opt out. Certain data, like your contact information, we will keep as long as
it is current. Data linked to a device like a smartphone will be maintained for
as long as we detect that device on websites or using mobile apps on a regular
basis. But data relating to your interests and purchase intent needs to be
current to be useful to us, so we are constantly refreshing such data and rely
only on the past several months’ data to inform our marketing choices.
DATA
SECURITY and PRIVACY BY DESIGN
Emailexpress
uses commercially reasonable, industry standard practices to protect data.
These include technical, physical, and organizational controls designed to
prevent loss or unauthorized access to data. Our security measures are audited
every year by an independent third party, and we are constantly evolving our
approach to security to keep pace with emerging threats.
Emailexpress
also follows the practice of “Privacy by Design,” meaning that we consider the
privacy and legal implications of our products and services and ensure that
they are built to standards that align to privacy requirements around the
world. The Emailexpress Privacy office is headed by a Chief Data or technology
Officer and includes legal and non-legal resources with significant experience
in the field. These professionals provide advice and guidance to Emailexpress’s
product designers, engineers, and other businesspeople on a regular basis.
HOW
TO CONTACT EMAILEXPRESS GLOBAL
You can reach Emailexpress, including our Privacy Officer, by writing: Privacy,
Emailexpress 4283 Express Lane, Suite 3347-808,Sarasota, Florida, 34249, or
emailing privacy@Emailexpress.io.
3. ONLINE and DIGITAL SERVICES PRIVACY POLICY
Last
Modified Sept 1, 2020
Emailexpress
offers a suite of digital marketing services designed to help online
advertisers generate a higher return on their marketing and media buying
investment. In the course of providing these services, we collect, use, and disclose
data about consumers like you. We have three primary lines of business: 1)
behavioral advertising services (“Behavioral Advertising Services”) performed
through Emailexpress’s data management platform and “demand side platform” (the
“Emailexpress DSP”), 2) Optimization and Analytics Services, and 3) Audience
Management Services.
The
services described in this Online and Digital Services (“ODS”) Privacy Policy
include data and technology assets that formerly belonged to companies known as
Rocket Fuel, Boomtrain, NetMining, and Ignition One. The terms of this ODS
Privacy Policy therefore address data that may have been originally collected
by Emailexpress or any of those earlier companies.
This
ODS Privacy Policy describes our practices regarding collection, use, and
sharing of data through our online and digital services and instructions for
opting out of our use of data that relates to you for interest-based
advertising.
Understanding Online and Digital
Services
The
infrastructure of online advertising and dynamic websites is technologically
complex. We want to be as transparent as we can be by explaining the range of
things we do with data. We also don’t want to overwhelm you with technical
details, and think it is important for our privacy policy to be understandable.
We think we’ve struck the right balance, but if after reading this privacy
policy you still have questions, you may contact privacy@Emailexpress.io for more information.
Our Consumer Mission
At
Emailexpress, we want digital advertising to be a useful complement to your
online experience. We want to deliver personalized, well-chosen ads to help you
discover things that interest you—new websites, new products, new bargains. Our
advertising business also helps fund the free content and services you enjoy
across the Internet.
We
use complex technology to pick the best ads to show, based on everything we
know about the context: the ad itself, the page that needs an ad, the time of
day and other external factors, and information from your browser or mobile
device digital advertising identifier that we use to predict what advertising
would be most relevant and interesting to you.
If
we can make ads more useful and interesting for you, then we’ll also make
advertising more valuable to advertisers, and your visits will make websites
more money per ad, and power their investments in the websites, apps, online
features and content that they provide to you for free. Our Optimization and
Analytics services help websites adapt to your preferences with customized
content and functionality. Fuelling ad supported free content and services is
an endeavour that we are proud to be a part of, and we hope you’re equally
happy with the results. But if you’re not, you may learn more about opting out
of our use of your data for personalized advertisements in the section below
under “Opting Out of Personalized Advertisements.”
How We Think of You
Before
describing the kinds of data we collect, it’s important to understand how we
think of you and other web surfers and online consumers. The Emailexpress DSP
does not know you personally, and we do not need to in order to provide you
with relevant advertising. We place an identifier within a cookie on your web
browser or use an advertising ID generated by your mobile device. So to us you,
and anyone else that uses that browser or mobile device, are just “surfer82”
for example. Our cookies are called “rfihub,” “Emailexpress,” “disqus,”
“boomtrain,” or “netmng,” and you can find them if you search for cookies in
your browser settings.
So,
when we talk about “you” in this ODA policy, we are referring to information
that we have associated with one or more identifiers associated with a web
browser (such as Google Chrome or Firefox) that you might use, or with an
advertising ID associated with your mobile device.
Information We Collect
We
collect several types of information from and about you, as described in this
section. Not all of the types of data collection described below necessarily
apply to you—it depends on your browser and device settings and which online
services or content you access.
We
operate an online advertising service that helps advertisers customize, target
and report on the advertisements we purchase on their behalf across third party
websites and mobile applications. While purchasing these ads across third party
websites and mobile apps, we collect information about the sites that you and
others may visit, the mobile apps that you may use, the precise location of
your mobile device such as the GPS coordinates (based on the consent you
provided to the app), and the searches that you and others may conduct while
online in order to serve advertisements that we believe are relevant to your
interests. Where we can reasonably infer that a particular computer and mobile
device belong to the same user or household, we may extend our advertising
campaigns across those devices, serving advertising across multiple browsers or
devices (sometimes called cross-device advertising). We also work with
third-party data companies that help us tailor ads.
When
you visit one of our advertiser’s websites or mobile applications (“apps”), or
the websites or apps where we display advertisements, we collect information
about your activity on that site (such as the page viewed or the advertising
that you clicked on) or the location of your device, in order to show you
relevant advertising (e.g., for local events), control how many times you may
see the same advertisement, in addition to providing advertisers aggregate
metrics that help them pay publishers for displaying this advertising
We
collect information about your device, such as unique device identifier,
browser type and language, and about your connectivity, such as the IP address,
the server your computer is logged into, and the operating system information.
We collect information such as the URLs you visit, the date, time, and duration
of your visit to each page, and certain commercially relevant keywords
pertaining to the searches you conduct (e.g. “shoes”). When we provide Optimization
and Analytics Services to our customers, we also collect information about your
activities on our customers’ websites.
We
collect information about our interactions with you, such as which ads we’ve
shown, and on which pages, and whether you responded to those ads by
interacting with them.
To
learn about the ads you might like or dislike, we may also ask you questions
directly—for example, we may provide a survey via an online ad that asks about
which ads, products, or brands you like or dislike.
We
collect information about our partners’ interactions with you—for example, by
placing pixels on an advertiser’s web page that let us know if you ultimately purchased
an item after we ran an advertising campaign that showed you an ad. We obtain
data from other companies that also use cookie or device identifiers to share
similar information that they have collected about you with us. For example, we
may partner with other companies to learn the kinds of products you like to buy
online.
As
part of our Optimization and Analytics Services and our Audience Management
Services, we may collect names, email addresses and postal addresses as part of
an online lead generation campaign or an email marketing campaign on behalf of
one of our clients. We don’t make independent use of such data, but use it only
as directed by our client, and ensure that this information is appropriately
safeguarded and segregated from data collected pursuant to our Behavioural
Advertising Services.
We
store all this information in a profile in our database.
About
Health Data. We do not use
data about you from your health care providers or insurers unless you have
consented for them to use your data to advertise to you. We may infer certain
non-sensitive health related interests from the sites you visit and the ads you
interact with. We do not use data relating to cancer, mental illness,
sexually-transmitted diseases, or children’s diseases (other than
over-the-counter ailments) to select or deliver advertising unless our client
has obtained your consent for the use of that data. (Click here for a list of our standard health segments.)
About
Political Data. We do not have
information about how you voted. We infer political interests from the sites
your browser or device visits and the ads you interact with, and we can combine
this with general geo-location data obtained from your IP address to determine,
for instance, that you are a likely voter for a particular party in a specific
congressional district, based on publicly available voter registration data. (Click here for a list of our political segments.)
Data Retention and Security
Emailexpress
DSP deletes user profiles in our database after 90 days of inactivity. This
means that if we have not had an opportunity to show a consumer an ad, observed
a visit from a consumer to a website that includes a Emailexpress DSP pixel, or
received new information from one of our partners about a consumer, we will
delete the user ID associated with that consumer. We see activity from a broad
range of different places on the Internet, and the 90-day period restarts every
time we have an interaction with you. So as a practical matter, if you want to
opt out of our cookie and device-based data collection, you should follow the
steps to opt out described below.
Data
that we compile for purposes like reporting, attribution and fraud detection
will be retained for up to 30 months.
We
use physical, administrative, and industry standard technical safeguards that
are designed to protect the information that we collect and maintain.
How We Use Information
We
use the information that we collect directly or receive from other companies to
find patterns that help us select better ads to serve you at any given moment.
For example, we might learn that an ad for mp3 downloads is attractive to
people who’ve previously clicked ads for mp3 players, or we might learn that a
coffee ad works better in the morning. Our technology can test millions of
possibilities along these lines and build models using huge amounts of data to
predict responses to advertising.
We
match information relating to devices and browsers with other companies through
a process called “cookie matching.” The “cookie matching” process synchronizes
two IDs belonging to different companies in a way that makes it easier to serve
advertising online, without the need to share other pieces of information about
the ID. In other words, this process enables two or more companies can take
coordinated action with respect to your device or browser without needing to
share with each other what each respectively knows about you.
We
perform cookie matching between the different cookies that Emailexpress uses.
By doing this we are able to stitch together all of the information that we
have across the different parts of our company to create the fullest possible
picture of a consumer. That does not mean we combine all this data into a
single database—we don’t, and there is a good reason for this: the data we use
for OBA does not include directly identifiable data, and so while cookie
matching allows us to augment what we already know about identified users with
data from their online experiences, we do not merge identifiable data into the
data we use for OBA.
We
make inferences from the data we assemble from these different sources in order
to show you advertisements for products or services that we think may interest
you. We sort your device/browser into interest or purchase intent “segments”
such as “Footwear > Sports & Fitness > Indoor Fitness”
We
also use the information we collect to measure effectiveness of ads on behalf
of our advertisers and publishers.
We
may also predict whether different identifiers associated with different
browsers and different devices, like a laptop, a phone or a tablet, may belong
to one person or household, and then link the activity we see across those
devices into a common profile. We call this a “device graph.” We believe this
helps us serve you better advertisements, control how many times you may see
the same ad and provide better service to our advertisers. We make these
predictions based on the device and cookie identifiers and associated interest
and intent information that we receive from our third-party partners, as
described above.
As
part of our Optimization services we gather information about how you interact
with different areas of a website and use this to customize website content for
you in future visits, or even the same visit.
Information Sharing
We
produce reports and analytics for our clients regarding the performance of
their advertising campaigns and regarding the characteristics of people that
were responsive to the ads, but we do not share the online profiles of
individuals that our technology generates for commercial purposes.
On
the other hand, we may share any information we hold when we believe that we
are required to do so by law (including legal processes like subpoenas,
warrants or court orders), or as we believe necessary to protect the health,
safety, or legal rights of any person.
Finally,
we may transfer information to a successor or assignee in connection with a
corporate change in control such as a merger or acquisition or other
transaction.
Opting Out of Personalized
Advertisements
You
can click here to opt out of interest-based advertising from Emailexpress
DSP. If you opt out of interest-based advertising from Emailexpress DSP, then
we will opt you out for all the identifiers or devices that we have associated
with you at the time of the opt out request. We use a predictive process to
associate identifiers and devices and do not know definitively all devices or
browsers that you may use, so that process is not guaranteed to be error free.
If you want to be completely thorough, we recommend that you use this opt out
process for each device and browser you use.
Emailexpress
DSP complies with the Self-Regulatory Principles for Online Behavioral
Advertising as managed by the Digital Advertising Alliance (DAA). You may opt
out of receiving personalized advertisements by DAA members via the DAA
website here.
Emailexpress
DSP is integrated with the DAA’s AppChoices, which allows consumers to download
and manage their privacy preferences in a mobile environment. You may download
DAA’s AppChoices mobile app on your iOS or Android device in order to exercise
choice regarding the collection of application activity for interest-based
advertising. Links to those applications are below:
• DAA
AppChoices iOS
• DAA
AppChoices Android
• Ad Privacy Manager
iOS
• Ad
Privacy Manager Android
What happens when I opt out?
An
opt-out in any of the tools listed here will have the same effect, and you do
not need to make an opt out selection using more than one method (we have to
list them all as a condition of being members of these groups). If you opt out
of interest-based advertising, you’ll still see ads from us online, but they
may not be tailored to your interests. Note that we’ll still maintain a cookie
on your computer to note the fact that you’ve opted out. That opt-out cookie is
associated with a particular computer and browser. So, for example, if you get
a new computer, install a new browser, or clear your cookies, you’ll need to
opt-out again if you still do not want interest-based advertising. Our opt-out
cookies never expire. If you change your mind, click here to opt back
in.
Our Policy Regarding Children
Emailexpress
DSP does not knowingly collect or solicit information from anyone under 16
years of age. Our services are directed to businesses – advertisers and their
agencies – and are not directed to children under 16. If we learn that we have
collected personal information of a child under 16 without parental consent, we
will delete such information. If you believe that we might have any information
from a child younger than 16, please contact us as set forth below.
Personal Data Relating to European Union Residents
Emailexpress
utilizes the EU’s Standard Contractual Clauses as its basis for transferring EU
data to the United States for processing.
Under
certain circumstances, Emailexpress may be required to disclose personal
information in response to valid requests by public authorities, including to
meet national security or law enforcement requirements.
Emailexpress
maintains reasonable and appropriate security measures to protect personal
information from loss, misuse, unauthorized access, disclosure, alteration, or
destruction. We use physical, administrative, and industry standard technical
safeguards that are designed to protect the information that we collect and
maintain.
You
have the right to obtain our confirmation of whether we maintain personal
information relating to you. You may also may view, get a copy, or delete the
personal information we hold about you for online behavioral advertising
purposes by visiting this page.
Your
right to access your personal information may be restricted in exceptional
circumstances, including, but not limited to, when the burden or expense of
providing this access would be disproportionate to the risks to your privacy in
the case in question, or when the rights of persons other than you would be
violated by the provision of such access. If we determine that your access
should be restricted in a particular instance, we will provide you with an
explanation of our determination and respond to any inquiries you may have.
You
can direct any questions or complaints about the use or disclosure of your personal
information to the Emailexpress Privacy office by email to: privacy@Emailexpress.io. Emailexpress will investigate and attempt to
resolve any complaints or disputes regarding the use or disclosure of your
personal information within 45 days of receiving your complaint.
If
you are unsatisfied with the resolution of your complaint, you may contact your
local data protection authority here.
Contacting Emailexpress
If
you have any questions, please contact privacy@Emailexpress.io or send mail to:
Emailexpress
c/o Privacy / Legal
4283 Express Lane
Suite 3347-808,
Sarasota, Florida, 34249 USA
Changes to this Policy Statement
We
reserve the right to amend this policy statement from time to time. The
effective date of the current version will be posted at the top of this page.
Opt Out Page:
We
may also predict whether different identifiers associated with different
browsers and different devices, like a laptop, a phone or a tablet, may belong
to one person or household, and then link the activity we see across those
devices into a common profile. We call this a “device graph.” We believe this
helps us serve you better advertisements, control how many times you may see
the same ad and provide better service to our advertisers. We make these
predictions based on the device and cookie identifiers and associated interest
and intent information that we receive from our third-party partners, as
described above.
Please
click here to opt out of personalized ads based on Emailexpress DSP cookies.
Please
click here to opt out of personalized ads based on Emailexpress
DSP cookies, Click here to opt out of
data collection via our netmng cookies.
Please
click here to opt out of personalized ads based on Emailexpress
DSP cookies, or https://optout.aboutads.info/?lang=EN&c=2 to
opt out of other personalized advertising via the DAA’s opt-out page.
If
you opt out, you’ll still see ads from us online, and we’ll still do our best
to serve the most relevant ads we can, but we will know less about your
interests and purchase behavior. Note that we’ll still maintain two cookies on
your computer to track that you’ve opted out—two because we have two domains
from which we serve cookies. These opt-out cookies (like all cookies) are
associated with a particular computer and browser. So, for example, if you get
a new computer, install a new browser, or clear your cookies, you’ll need to
opt-out again. If you have your browser set to reject all cookies, then it
cannot accept our opt-out cookie.