Privacy Policy Statement

This policy applies to use of PoliteMail.com and any domains utilized for cloud server hosting for the PoliteMail Service. If you license and operate the PoliteMail Server products on premise, you are in control of your own data privacy and security.

Your data is your data. We secure and protect it.
We do not use, rent, sell or otherwise provide your email address(es), database or personal data to any third party for marketing or any other purpose other than to provision and maintain the products and services we provide to you.

PoliteMail provides corporate communications software and services. We understand and respect the importance of your employee data privacy and security.

This policy statement describes the data collected by PoliteMail.com as well as data collected as a function of your utilization of our software and cloud services, and explains how PoliteMail Software and any owned and operated websites including PoliteMail.com protect and use personal information you may provide to us; or that is collected through your interactions with us as well as the use of our products and cloud services.

Summary

We will not share, sell, lease or otherwise provide your data or personal information to other parties for marketing or sales purposes. We ensure any third party vendors engaged by PoliteMail with access to systems containing your data shall be obligated to have and follow a data security and privacy program at least equivalent to our own.

We do not store your credit card information on any of our system or servers. For recurring purchases, our credit card agent (Authorize.Net) securely stores your information within a PCI compliant infrastructure .

In order to perform certain services, such as credit card processing or cloud services hosting, we disclose some of your information to third party business partners solely for the purpose of performing such transaction.

We do not operate our own network data operations center. We partner with Tier 1 public cloud providers Microsoft Azure and Amazon Web Services and manage systems security using ISO27001 standards.

PoliteMail utilizes first party cookies and web tracking devices (beacons) to measure interactive behavior, interests, activities and interactions with our business and products. The intent of this is data collection is to provide conveniences and service, while informing our communications and product development decisions.

If PoliteMail is presented with a legally binding request for disclosure of your information by a law enforcement authority, PoliteMail may disclose your information and shall provide you an opportunity to waive your rights or to seek a protective order or other appropriate remedy, unless otherwise prohibited to do so.

If our business is acquired, then your information will be transferred upon sale to the purchasing entity, without prior notice.

Privacy Shield Compliance

PoliteMail complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. PoliteMail has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/participant?id=a2zt00000004EJVAA2 .

Independent Dispute Resolution

In compliance with the Privacy Shield Principles, PoliteMail commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding PoliteMail’s Privacy Shield privacy policy should first contact PoliteMail using the point of contact information provided below in this Privacy Shield privacy policy.

PoliteMail has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint at no cost to you.

Under certain conditions, if the above recourse mechanisms have not resolved the complaint, binding arbitration may be invoked before the Privacy Shield panel to be created by the U.S. Department of Commerce and the European Commission.

Safe Harbor Compliance

PoliteMail complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. PoliteMail has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit https://safeharbor.export.gov/swisslist

In compliance with the US-Swiss Safe Harbor Principles, PoliteMail commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss citizens with inquiries or complaints regarding this privacy policy should first contact PoliteMail using the Point of contact provided below in this policy.

PoliteMail has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Data Collection Notice
Use of PoliteMail.com, and transacting business with PoliteMail Software

PoliteMail may collect personal information from visitors to our website(s), including readily available click-stream data including IP address and user-agent, page-views and duration. Any personal data, including Name and Email Address, collected shall be voluntarily provided via input form. The intended purpose of such collection shall be disclosed at time of collection. For purchase transactions, PoliteMail may collect name, email address, billing address, phone numbers, as well as banking and/or credit card information.

Data Collection Notice
Use of PoliteMail Software products and services, including cloud services

PoliteMail Software provides tools to enable our customers to measure and improve their corporate communications, and our software and/or cloud services will collect data on their behalf. All such data is segregated by account into separate databases, and appropriately secured, encrypted in transit and at rest.

PoliteMail will collect name and email address for all users of our software tools, and will collect business name, address and phone numbers of our Customer, the Company who employs such users, including Customers who reside within the EU/EEA and/or Switzerland. This data may be collected over the phone, via email, online forms, or from within our Software upon installation. This data is used to add user accounts to our software system, and provide support services to those users. Such Personal Data may include name, email address, company mailing address, phone numbers, and company billing address. If a customer purchases via credit card, PoliteMail would also collect credit card number, expiration date, security code and billing address. For purchase orders PoliteMail may also collect banking information, including account names and numbers, SWFT codes, bank name and bank address and phone number. All such data collected is used to support purchases and other financial business transactions.

The PoliteMail software tools will collect the following Personal Data: employee name (first, last), employee email address, and employee IP address and user agent from devices used to access company email sent using our software. Such data will be collected upon send of email, and upon receipt, access or interaction with email. It will be collected at the senders location (may or may not be in EU/EEA and/or Switzerland) and the recipient’s location (may or may not be in EU/EEA and/or Switzerland).

When the customer elects to use optional list management functions of our software, including integrations with HR applications or the Active Directory, PoliteMail may collect other personal data, including phone numbers, addresses, departments, title and other employee related data which our customer decides to import into our software. PoliteMail may also collect images and files uploaded to our system as communications content by users of our software.

This data is collected so that our software may provide list management and email targeting, as well as compile email metrics related to the recipient’s interactions with email communications sent by our users, including number of email opens, read times, clicks to linked content and the URLs clicked upon. This data is then compiled into reports, providing PoliteMail users the ability to monitor key metrics and determine the effectiveness of and engagement with their communications.

Choice: When collecting personal and other data on our Customers behalf, PoliteMail Software will never use the data for a purpose other than the purpose for which is was originally collected and authorized. PoliteMail Software will offer individuals the opportunity to choose whether their Personal Data is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. To limit the use and disclosure of your personal information, please submit a written request using the contact information listed below.

Use of Cookies & Web Beacons
A cookie is a small text file stored by the web browser on your device that allows a web server to determine, among other things, when that browser visits again. We use cookies to simplify and enable sign-in, store your preferences and settings, and collect usage data to analyze how our web pages and services are performing.

Web pages and email pages may contain electronic images known as web beacons or single-pixel gifs. Web beacons collect a limited set of information including IP and user agent, cookie id, time and date and an encoded description of the page on which the web beacon resides, and aree used determine page access to compile statistics.

Our software may utilize session cookies (containing encrypted information) to allow our systems to securely identify you while you are logged in to the service, and allow us to process your data transactions securely. These cookies are erased from your computer when you close your browser. You may choose whether to accept cookies by changing the settings within your browser. You are always free to decline cookies, but by doing so you may not be able to use certain features on our website or utilize our web or software services. See your browser’s help documentation for specific instructions.

Onward Transfer

PoliteMail Software requires third party service providers to enter into an agreement which requires such third party to provide at least the same level of privacy and security protection for the Personal Information as set forth in this policy and to adhere to PoliteMail Software’s privacy practices, the Principles described herein, and/or that the third party is subject to laws providing the same level of privacy protection as is required by the Principles and these privacy practices and that such third party agrees in writing to provide an adequate level of privacy protection.

PoliteMail’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, PoliteMail remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless PoliteMail proves that it is not responsible for the event giving rise to the damage.

PoliteMail also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Security

PoliteMail Software shall take commercially reasonable steps to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. PoliteMail Software has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. We utilize firewalls, secure socket layers and encryption techniques to safeguard your information. Information is submitted via secure (HTTPS) connections and stored in a database protected by a firewall and encrypted at rest. Access to your information is restricted to authorized PoliteMail Software personnel and contracted partners only. PoliteMail Software requires employees that manage Personal Data to undergo appropriate training concerning data privacy and security.

Data Integrity

PoliteMail Software shall only process Personal Data in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, PoliteMail Software shall take reasonable steps to ensure that Personal Data is accurate, complete, current and reliable for its intended use.

Access

Data subjects have the right to access Personal Data held by PoliteMail Software about them. Any data subject that desires to review or update his or her Personal Data may do so by contacting PoliteMail Software through the Contact Information described below. Upon request, PoliteMail Software will grant individuals reasonable access to their Personal Data and shall take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. In the case where PoliteMail is collecting data for our Customer, the Customer is responsible to provide such access, and PoliteMail will cooperate with Customer to provide reasonable access. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should submit a written request to the contact information listed below. If requested to remove data, we will respond within a reasonable timeframe.

Enforcement and Liability

PoliteMail Software uses a self-assessment approach for privacy shield certification. From time to time, PoliteMail Software participates in self-assessments to verify compliance with the Principles to perform Privacy Shield certification. PoliteMail Software will investigate and attempt to resolve any complaint or dispute regarding its use and disclosure of Personal Data in accordance with this policy.

PoliteMail is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. (FTC).

Contact Information

Questions or comments regarding this Privacy Statement should be submitted to PoliteMail Software by mail.

Data Privacy & Security Office
PoliteMail Software
655 Portsmouth Ave
Greenland NH 03840-2246
US

Changes to this Policy Statement

We reserve the right to change this policy statement at any time. All amended terms will automatically become effective 30 days after they are posted on this website.

Located online at: http://www.politemail.com/privacy.aspx

Last Update: 2 December 2016



©2006-2015 PoliteMail Software. All Rights Reserved.
PoliteMail is a registered trademark of Bootstrap Software Partners, LLC. Microsoft, Windows, Office, Office365, Exchange, SQL Server and Azure are registered trademarks of Microsoft Corporation. Amazon, Amazon Web Services (AWS) and EC2 are trademarks of Amazon.com Inc.