- “Personal Information” is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Information We Collect
We collect your Personal Information in the following ways:
- Blog: We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. Social media platforms and widgets: Our Websites may include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms including Facebook, Twitter, and LinkedIn. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
- Information from other sources: We may, from time to time, obtain information about you from third party sources, such as public databases, third party data providers, and our joint marketing partners. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: demographic information, company information, device information (such as IP addresses), location, and online behavioral data (such as information about your use of social media websites, page view information, and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services.
Use and Disclosure of Your Personal Information
We may use and disclose your Personal Information only for the following purposes:
- To promote use of our services to you and others. For example, if we collect your Personal Information when you visit our Website and do not sign up for any of the Services, we may send you an email inviting you to sign up. If you use any of our Services and we think you might benefit from using another Service we offer, we may send you an email about that. You can stop receiving our promotional emails by following the unsubscribe instructions included in every promotional email we send. In addition, we may use information we collect in order to advertise our Services to you or suggest additional features of our Services that you might consider using. In addition, we may use your Personal Information to advertise our Services to potential or other users like you. To bill and collect money owed to us by our Customers. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments.
- To communicate with our Customers about their account and provide customer support.
- To protect the rights and safety of our Customers and third parties, as well as our own.
- To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
- To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
- To prosecute or defend a court, arbitration, or any other legal proceeding.
- To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- To provide, support, and improve the Services we offer. This includes our use of the data that our Customers provide us in order to enable our Customers to use the Services to communicate with their Recipients. This also includes, for example, aggregating information from your use of the Services and sharing this information with third parties to improve our Services. This might also include sharing your information or the information you provide us about your Recipients with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we do have to share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that require them to use the Personal Information we transfer to them in a manner that is consistent with this policy.
Disclosure of Personal Information to Third Parties
- Information Disclosed for our Protection and the Protection of Others. We may disclose information about you to third parties: (a) if we are required to do so by law, court order or legal process; (b) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (c) under the discovery process in litigation; (d) to enforce RDA policies or contracts; (e) to collect amounts owed to RDA; (f) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (g) if we, in good faith, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes including, for example, to detect unauthorized activity on the Services. In such cases, server log data containing Personal Information may be shared with law enforcement bodies so that they may identify users in connection with their investigation of the unauthorized activities.
Data Collected for and by our Customer
If you are a Recipient and no longer want to be contacted by one of our Customers, please unsubscribe directly from that Customer’s emails or contact the Customer directly to update or delete your data. If you contact us, we may remove or update your information within a reasonable time and after providing notice to the Customer of your request.
Content of Emails Sent
When a Customer sends an email to a Recipient, it bounces from server to server as it crosses the Internet. Along the way, server administrators can read what you send. Email was not built for sending confidential information and most emails end up in an unencrypted inbox. Please do not use the Services to send confidential information.
Anonymous and Aggregated Information
RDA may use your Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Sites or other online Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and RDA may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information within RDA and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Where you have consented to RDA’s Processing of your Personal Information, you may withdraw that consent at any time and opt out by following the instructions below. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out. Note that, due to the nature of the Services, you may have to provide the email address or other identifying value that is associated with your Personal Information in order for RDA to segregate out the use and retention of such Personal Information. Where consent of the individual for the Processing of Personal Information is otherwise required by law or contract, RDA will comply with the law or contract.
Sensitive Personal Data
“Sensitive Personal Data” is a subset of Personal Information, which due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Data includes Personal Information regarding EU-residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (a) race or ethnic origin; (b) political opinions; (c) religious or philosophical beliefs; (d) trade union membership; (e) genetic data; (f) biometric data where Processed to uniquely identify a person; (g) health information; (h) sexual orientation or information about the individual’s sex life; or (i) information relating to the commission of a criminal offense.
RDA does not collect Sensitive Personal Data from you. However, if we do ever collect it, we will, prior to disclosing it to a third party or Processing it for a purpose other than its original purpose or the purpose authorized subsequently by the individual, obtain your explicit consent. Where consent of the individual for the Processing of Personal Information is otherwise required by law or contract, RDA will comply with the law or contract.
“Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. At this time, there is no general agreement on how companies like RDA should interpret DNT signals. Therefore, RDA does not recognize or respond to browser-initiated DNT signals, whether that signal is received on a computer or a mobile device.
RDA primarily stores Personal Information sent or collected via or by RDA in the United States and the European Union (as applicable), in the cloud, our servers, the servers of our group of companies, or the servers of our Service Providers. To facilitate our global operations, we may transfer and access such information from around the world. To carry out the email delivery function of the Platform, we may need to transfer such information around the world. Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to RDA, you consent to the transfer and storage of Personal Information in these locations.
RIGHTS OF ACCESS, RECTIFICATION, PORTABILITY, ERASURE, AND RESTRICTION
Your Personal Information
You may seek confirmation regarding whether RDA 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 applicable data protection laws. Where otherwise permitted by applicable law, you may contact us to request access to, receive, port, restrict Processing, seek rectification or request erasure of Personal Information held about you by RDA. Such requests will be carried out in accordance with applicable laws. Although RDA makes good faith efforts to provide you with access to your Personal Information, there may be circumstances in which RDA is unable to provide access, including for example, where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where it is commercially proprietary. If RDA determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, RDA will take reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
Recipient Personal Information
As a data processor for our Customers, RDA Processes data, which may include Recipient Personal Information on behalf of our Customers. We will not use, share, distribute, or reference any such Recipient Personal Information except as provided in the applicable agreement between us and our Customer, or as may be required by law. If Personal Information pertaining to you as an individual has been submitted to us by a Customer as Recipient Personal Information and you wish to exercise any rights you may have to access, receive, port, restrict Processing, seek rectification, or request erasure, please inquire with the applicable Customer directly. Because RDA personnel have a limited ability to access Recipient Personal Information, if you wish to make your request directly to RDA, please provide the name of the applicable RDA customer. We will refer your request to that Customer, and will support them as needed in responding to your request within the timeframe required by applicable law.
We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the Processing and the nature of the Personal Information.
RDA accounts require a username and password to log in. You must keep your username, password, and API key(s) secure, and never disclose them to a third party.
OTHER RIGHTS AND IMPORTANT INFORMATION
Due to the nature of RDA’s business, our Services are not marketed to minors. RDA does not knowingly solicit or collect Personal Information from children under the age of 13 (and in certain jurisdictions under the age of 16). This applies to any Personal Information directly collected by us, but does not apply to the Personal Information provided to us by third party services and organizations or from our Customers regarding their Recipients (please refer to the terms of their respective privacy policies). If we learn that we have collected Personal Information from a child under the age of 13 (and in certain jurisdictions under the age of 16) in relation to the Services, we will promptly delete that information.
Links to Third Party Websites