Effective Date: November 28, 2017
2. What Personal Information We Collect and How We Use It
2.1 Personally Identifiable Information. In the course of using our Services, you may provide us with personally identifiable information. This refers to information about you that can be used to contact or identify you (“Personal Information”). 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 the Services, complete your transactions, and administer your inquiries. We may also use Non-Identifying Information for more general purposes such as to plan and measure the effectiveness of our marketing efforts and to identify ways to improve or change our Services.
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 from us, please follow the unsubscribe instructions provided in any of the communications or update 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 registered user or a non-registered user just browsing (any of these, a “Valimail User”), our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer's Internet Protocol (IP) address, browser type, the webpage you were visiting before you came 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. We use 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 to better tailor the Services to our visitors' needs. For example, some of this information may be collected so that when you visit the Site again, it can recognize you and display Site content that is appropriate to your interests or needs. We also use this information to verify that visitors to the Site meet the criteria required to process their requests. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
2.5 DMARC and DNS Data Collection and Use. The Valimail email authentication service operates based on data automatically forwarded to our servers regarding email purporting to be sent from or to the Internet domains that we service. This data is primarily generated and received using common technical standards and protocols known as Domain-based Message Authentication, Reporting & Conformance (DMARC), Domain Name System (DNS), DomainKeys Identified Mail (DKIM), and Sender Policy Framework (SPF). This data includes DMARC aggregate reports, DMARC failure reports, and logs of DNS requests for DMARC, DKIM and SPF records. Reports such as DMARC failure reports, which inform us of failed email transmissions, may contain some header information or content from the affected email message (depending on the receiving domain's email system settings), but we use any such information only to provide our service to the operator of the domain from which the email purports to originate. The other DMARC and DNS-related reports and logs do not provide any information that we consider Personal Information, although some of this data does allow us to determine the originating or delivering domain, the originating IP address, and/or the service provider used to send an email message. We log this information and use it for operational and analytics purposes.
2.6 Social Media. Social Media resources are interactive tools that enable individuals to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards, 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 social media resources offered either by Valimail or a Third Party. We may also enable you to use these social media resources to post or share personal information with others. When using social media resources, you should take into careful consideration what personal 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 to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Websites, various types of communications, advertising campaigns and/or promotional activities. If an individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.
2.8 Information Submitted Via Websites. You agree that Valimail is free to use the content of any communications or other information submitted by you via the Website, including narratives, images, ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purposes including developing and/or marketing goods or services. However, Valimail does not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular 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 use 'cookies' to collect information. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes. We may link the information we store in cookies to the Personal Information you submit while on our Site.
We use session ID cookies for session management, to enable certain features of the Services, to better understand how you interact with the Services, and to monitor aggregate usage by Valimail Users and web traffic routing on the Services. We may also use persistent cookies to save your registration ID and login password for future logins to the Site. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of our Services.
3.2 Pixel Tags/Web Beacons. We also use 'web beacons,' 'pixel tags,' 'clear GIFs' or similar 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 to users. Web Beacons allow us to count the number of users who have visited certain pages of the Site, to deliver branded services and to generate statistics about how our Site is used.
3.3 Analytics Information. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Websites, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by you use of the Services by going to https://tools.google.com/dlpage/gaoptout.
3.4 Interest-Based Advertising. Through our Website, Valimail may allow Third-Party advertising 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 with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Valimail related websites within their networks. This practices is 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-based advertising by going to http://optout.aboutads.info or http://www.youronlinechoices.eu/ to limit collection through the Website or by configuring the settings on your mobile device to limit ad tracking through the mobile applications.
Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Websites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness 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
We maintain telephone “do not call” lists and “do not mail” lists as mandated by law. We process requests to be placed on do not mail, do not phone and do not contact lists within 60 days after receipt, or such shorter time as may be required by law.
Registered Valimail users may change how and when Valimail communicates with them by logging 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
6.2 Privacy Shield. With respect to onward transfers to Agents under Privacy Shield, Privacy Shield requires that Valimail remain liable should its Agents Process Personal Information in a manner inconsistent with the Privacy Shield Principles.
6.3 Aggregate Information and Non-Identifying Information. We may share aggregated information that does not include Personal Information, and we may otherwise disclose Non-Identifying Information, Log Data and DMARC and DNS data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
6.4 Service Providers. We may employ third party companies and individuals to facilitate our services, to provide our services on our behalf, to perform Site-related services (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 access to your Personal Information only to perform these tasks on our behalf and we do not authorize them to disclose or use it for any other purpose.
6.5 Compliance with Laws and Law Enforcement. Valimail cooperates with government and 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 officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Valimail or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
6.6 Business Transfers. Valimail may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
7. Other Important Information
7.1 Rights of Access, Rectification, Erasure, and Restriction. Under Privacy Shield, you may seek confirmation regarding whether Valimail is processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate or has been processed in violation of the Privacy Shield Principles.
Registered Valimail users may review, update, correct or delete the Personal Information in their registration profile by logging into their account and changing the preferences associated with their account. If you completely delete all such information, your account may be deactivated. We may retain an archived copy of your records as long as required by law or for legitimate business purposes.
7.2 Security. Valimail is very concerned with safeguarding your information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored 'personal data' (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on this Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Please note that no method of transmission over the internet, or method of electronic storage is 100% secure. Therefore, we cannot ensure or warrant the security of any information you transmit to Valimail.
7.4 Policy Toward Children. This Site is not directed to children under 18. We do not knowingly collect personally identifiable information from children under 13 (and in certain jurisdictions under the age of 16). If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at firstname.lastname@example.org. If we become aware that a child under 13 (and in certain jurisdictions under the age of 16) has provided us with Personal Information, we will delete such information from our files.
7.5 Phishing. Identity theft and the practice currently known as 'phishing' are of great concern to Valimail. Safeguarding information to help protect you from identity theft is a top 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 e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission's website.
7.6 Links to Other Sites. Our Services may contain links to other websites. If you choose to click on a third-party link, you will be directed to that third party's website. The fact 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 or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
7.8 California Privacy Rights. California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Valimail does not share Personal Information with third parties for their own marketing purposes.
8. Contacting Us
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.