2. Information We Collect and How We Use It
2.1 Personally Information. In the course of using our Services, you may provide us with Personal Information. This refers to information about you that can be used to contact or identify you. Personal Information includes, but is not limited to, your name, phone number, billing information, email address and home and business street addresses. We use your Personal Information mainly to provide our services and administer your inquiries. For example, when you register with us through the Site, we will ask you for Personal Information to associate with your account.
2.2 Non-Identifying Information. We also collect the other information that you provide as part of registration and the administration and personalization of your account (for example, your zip code or individual preferences) (“Non-Identifying Information”). Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip
code with your street address) in a way that enables you to be identified. But the same pieces of information are not Personal Information on their own or when combined only with other Non-Identifying Information (for example, combining your zip code with your viewing preferences).
2.3 Using your Personal Information. We use your Personal Information and Non- Identifying Information (in some cases, in conjunction with one another) to provide theServices, complete your transactions, and administer your inquiries. We may also useNon-Identifying Information for more general purposes such as to plan and measure theeffectiveness of our marketing efforts and to identify ways to improve or change ourServices.We may also use your Personal Information to contact you with Valimail newsletters,marketing or promotional materials and other information that may be of interest to you.If you decide at any time that you no longer wish to receive such communications fromus, please follow the unsubscribe instructions provided in any of the communications orupdate your ‘user preferences’ information. See Section 5 below, for more detail.
2.4 Log Data Collection and Use. When you visit the Site, whether as a registereduser or a non-registered user just browsing (any of these, a “Valimail User”), ourservers automatically record information that your browser sends whenever you visit awebsite (“Log Data”). This Log Data may include information such as your computer’sInternet Protocol (IP) address, browser type, the webpage you were visiting before youcame to our Site, pages of our Site that you visit, the time spent on those pages,information you search for on our Site, access times and dates, and other statistics. Weuse this information to monitor and analyze use of the Services and for the Services’technical administration, to increase our Site’s functionality and user-friendliness, and tobetter tailor the Services to our visitors’ needs. For example, some of this informationmay be collected so that when you visit the Site again, it can recognize you and displaySite content that is appropriate to your interests or needs. We also use this informationto verify that visitors to the Site meet the criteria required to process their requests. Wedo not treat Log Data as Personal Information or use it in association with otherPersonal Information, though we may aggregate, analyze and evaluate such informationfor the same purposes as stated above regarding other Non-Identifying Information.
2.5 DMARC and DNS Data Collection and Use. The Valimail email authenticationservice operates based on data automatically forwarded to our servers regarding emailpurporting to be sent from or to the Internet domains that we service. This data isprimarily generated and received using common technical standards and protocolsknown as Domain-based Message Authentication, Reporting & Conformance (DMARC),Domain Name System (DNS), DomainKeys Identified Mail (DKIM), and Sender PolicyFramework (SPF). This data includes DMARC aggregate reports, DMARC failurereports, and logs of DNS requests for DMARC, DKIM and SPF records. Reports suchas DMARC failure reports, which contain failed email transmissions, may contain someheader information or content from the affected email message (depending on thereceiving domain’s email system settings), but we do not collect DMARC failure reports.The other DMARC and DNS-related reports and logs do not provide any informationthat we consider Personal Information, although some of this data does allow us todetermine the originating or delivering domain, the originating IP address, and/or theservice provider used to send an email message. We log this information and use it foroperational and analytics purposes.
2.6 Social Media. Social Media resources are interactive tools that enable individuals tocollaborate and share information with others. Social media resources include, but arenot limited to, social networks, discussion boards, bulletin boards, chat, blogs, wikis,and referral functions to share web site content and tools with a friend or colleague.
Valimail may collect Personal Information to enable individuals to use online socialmedia resources offered either by Valimail or a Third Party. We may also enable you touse these social media resources to post or share personal information with others.When using social media resources, you should take into careful consideration whatpersonal information you share with others.
2.7 Research/Survey Solicitations. From time to time Valimail may perform research(online and offline) via surveys. We may engage Third Party-service providers toconduct such surveys on our behalf. All survey responses are voluntary, and theinformation collected will be used for research and reporting purposes to help us betterserve Individuals by learning more about their needs and the quality of the products andservices we provide. The survey responses may be utilized to determine theeffectiveness of our Sites, various types of communications, advertising campaignsand/or promotional activities. If an individual participates in a survey, the informationgiven will be used along with that of other study participants. We may share anonymousindividual and aggregate data for research and analysis purposes.
2.8 Information Submitted Via Sites. You agree that Valimail is free to use the contentof any communications or other information submitted by you via the Site, includingnarratives, images, ideas, inventions, concepts, techniques, or know-how disclosedtherein, for any purposes including developing and/or marketing goods or services.However, Valimail does not release your name or otherwise publicize the fact that yousubmitted materials or other information to us unless: (a) you grant us permission to doso; (b) we first send notice to you that the materials or other information you submit to aparticular part of a site will be published or otherwise used with your name on it; or (c)we are required to do so by law.
3. Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-based Advertising
3.1 Cookies. Like many websites, we and our third-party suppliers, use ‘cookies’ tocollect information. A cookie is a small data file that we transfer to your computer’s harddisk for record-keeping purposes. We may link the information we store in cookies tothe Personal Information you submit while on our Site.
We use session ID cookies for session management, to enable certain features of theServices, to better understand how you interact with the Services, and to monitoraggregate usage by Valimail Users and web traffic routing on the Services. We mayalso use persistent cookies to save your registration ID and login password for futurelogins to the Site. You can instruct your browser, by changing its options, to stopaccepting cookies or to prompt you before accepting a cookie from the websites youvisit. If you do not accept cookies, however, you may not be able to use all portions ofthe Site or all functionality of our Services.
3.2 Pixel Tags/Web Beacons. We also use ‘web beacons,’ ‘pixel tags,’ ‘clear GIFs’ orsimilar means (“Web Beacons”) on our Site. A Web Beacon is an electronic image,often a single pixel, embedded on web pages. Web Beacons are ordinarily not visible tousers. Web Beacons allow us to count the number of users who have visited certainpages of the Site, to deliver branded services and to generate statistics about how ourSite is used.
3.3 Analytics Information. We may also use Google Analytics and Google AnalyticsDemographics and Interest Reporting to collect information regarding visitor behaviorand visitor demographics on some of our Sites, and to develop website content. Thisanalytics data is not tied to any Personal Information. For more information aboutGoogle Analytics, please visit www.google.com/policies/privacy/partners/. You can optout of Google’s collection and processing of data generated by you use of the Servicesby going to https://tools.google.com/dlpage/gaoptout.
3.4 Interest-Based Advertising. Through our Site, Valimail may allow Third-Partyadvertising partners to set tracking tools (e.g., cookies) to collect anonymous, non-Personal Information regarding your activities (e.g., your IP address, page(s) visited,time of day). We may also share such de-identified information we have collected withThird-Party advertising partners. These advertising partners may use this information(and similar information collected from other websites) for purposes of deliveringtargeted advertisements to you when you visit non-Valimail related websites within theirnetworks. These practices are commonly referred to as “interest-based advertising” or“online behavioral advertising.”
You can opt out of the collection and use of your information for interest-basedadvertising by going to http://optout.aboutads.info or http://www.youronlinechoices.eu/to limit collection through the Site or by configuring the settings on your mobile device tolimit ad tracking through the mobile applications.
Even if you opt-out, we may still collect and use non-Personal Information regardingyour activities on our Sites and/or information from the advertisements on Third-Partywebsites for non-interest based advertising purposes, such as to determine theeffectiveness of the advertisements.
4. Mobile Devices
Valimail may provide websites and online resources that are specifically designed to be compatible and used on mobile devices. Valimail will collect certain information that your mobile device sends when you use such websites or online resources, like a device identifier, user settings and the operating system of your device.
5. Your Choices and Ability to Opt-Out
into their account and reviewing, updating, correcting or deleting the Personal Information, or by changing the preferences associated with their account.
6. Information Sharing and Disclosure
6.3 Aggregate Information and Non-Identifying Information. We may share aggregatedinformation that does not include Personal Information, and we may otherwise discloseNon-Identifying Information, Log Data and DMARC and DNS data with third parties forindustry analysis, demographic profiling and other purposes. Any aggregatedinformation shared in these contexts will not contain your Personal Information.
6.4 Service Providers. We may employ third party companies and individuals tofacilitate our services, to provide our services on our behalf, to perform Site-relatedservices (for example, maintenance services, database management, web analytics,improvement of the Services’ features, and communications with users of our Services)or to assist us in analyzing how our Services are used. These third parties have accessto your Personal Information only to perform these tasks on our behalf and we do notauthorize them to disclose or use it for any other purpose.
6.5 Compliance with Laws and Law Enforcement. Valimail cooperates with governmentand law enforcement officials and private parties to enforce and comply with the law.We will disclose any information about you to government or law enforcement officialsor private parties as we, in our sole discretion, believe necessary or appropriate torespond to claims and legal process (including but not limited to subpoenas), to protectthe property and rights of Valimail or a third party, to protect the safety of the public orany person, or to prevent or stop activity we may consider to be, or to pose a risk ofbeing, any illegal, unethical or legally actionable activity.
6.6 Business Transfers. Valimail may sell, transfer or otherwise share some or all of its assets, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy (“Transfer Event”). Valimail will disclose Personal Data to a third party in the event of a Transfer Event.
7. Other Important Information
7.2 Security. Valimail is very concerned with safeguarding your information. We employadministrative, physical and electronic measures designed to protect your informationfrom unauthorized access. We will make any legally required disclosures of any breachof the security, confidentiality, or integrity of your unencrypted electronically stored‘personal data’ (as defined in applicable state statutes on security breach notification) toyou via email or conspicuous posting on this Site in the most expedient time possibleand without unreasonable delay, insofar as consistent with (i) the legitimate needs oflaw enforcement or (ii) any measures necessary to determine the scope of the breachand restore the reasonable integrity of the data system.
Please note that no method of transmission over the internet, or method of electronicstorage is 100% secure. Therefore, we cannot ensure or warrant the security of anyinformation you transmit to Valimail.
7.4 Policy Toward Children. This Site is not directed to children under 18. We do notknowingly collect personally identifiable information from children under 13 (and incertain jurisdictions under the age of 16). If a parent or guardian becomes aware thathis or her child has provided us with Personal Information without their consent, he orshe should contact us at firstname.lastname@example.org. If we become aware that a child under13 (and in certain jurisdictions under the age of 16) has provided us with PersonalInformation, we will delete such information from our files.
7.5 Phishing. Identity theft and the practice currently known as ‘phishing’ are of greatconcern to Valimail. Safeguarding information to help protect you from identity theft is atop priority. We do not and will not, at any time, request your credit card information,your account ID, login password, or national identification numbers in an unsolicited emailor telephone communication. For more information about phishing, visit the FederalTrade Commission’s website.
7.6 Links to Other Sites. Our Services may contain links to other websites. If youchoose to click on a third-party link, you will be directed to that third party’s website. Thefact that we link to a third-party website or allow advertising of (or otherwise refer to)third-party products or services on our Services is not an endorsement, authorization orrepresentation of our affiliation with that third party, nor is it an endorsement of theirprivacy or information security policies or practices. We do not exercise control overthird-party websites. These other websites may place their own cookies or other files onyour computer, collect data or solicit personal information from you. Other sites followdifferent rules regarding the use or disclosure of the personal information you submit tothem. We encourage you to read the privacy policies or statements of the otherwebsites you visit.
7.8 California Privacy Rights. California law permits users who are California residentsto request and obtain from us once a year, free of charge, a list of the Third Parties towhom we have disclosed their Personal Information (if any) for their direct marketingpurposes in the prior calendar year, as well as the type of Personal Informationdisclosed to those parties. Additionally, the California Consumer Privacy Act, Cal. Civ.Code §§ 1798.100 et seq. (“CCPA”) grants consumers certain rights over their PersonalInformation, including:
• Right to Know: about any Personal Information used, collected and disclosed toThird Parties• Right to Deletion: request to delete or destroy any and all Personal Informationcollected.• Right to Non-Discrimination: the right to not be discriminated against forexercising rights under CCPA.
Valimail honors these rights for California residents. Please note that Valimail does not sell your Personal Information; however, Valimail respects and understands that you may still want to ensure your Personal Information is not sold. Therefore, if you would still like to proceed with a “Do Not Sell My Personal Information” request, please submit a request at email@example.com
8. Contacting Us
resources data, has committed to cooperate with the panel established by local data protection authorities and comply with the advice given by the panel for EU citizens and with the Swiss Federal Data Protection and Information Commissioner’s authority and advice for such data of Swiss citizens. For more information and to submit a complaint regarding Individual data to JAMS, a dispute resolution provider which has locations in
the United States and EU, visit https://www.jamsadr.com/eu-us-privacy-shield. Such independent dispute resolution mechanisms are available to citizens free of charge. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.
You may also have a right, under certain circumstances, to invoke binding arbitration under Privacy Shield. For additional information, see
https://www.privacyshield.gov/article?id=ANNEX-I-introduction. The FTC has jurisdiction over Valimail’s compliance with the Privacy Shield.