Consistent with its commitment to protect personal privacy, Validity has decided to voluntarily adhere to the principles set forth in the Data Privacy Framework. Please refer to the relevant section in the policy below.
Please refer to our California Privacy Notice here for more details on California specific privacy rights and other required information concerning our processing of Personal Information.
INFORMATION WE COLLECT
We may also collect and use non-personal information that does not and cannot be used to reveal your identity or that of another individual, such as information which has been anonymized, deidentified, or aggregated (“Other Information”). We use Other Information to facilitate our operation of our Sites and for other purposes described below.
HOW WE COLLECT YOUR INFORMATION
We and our service providers collect Personal Information and Other Information in a variety of ways, including:
- Through the Sites: We collect information when you request a free trial or demo, register for a webinar, contact us, subscribe to our email newsletter, register to use the Sites, download content (e.g. whitepapers), apply for employment (etc.);
- Offline: We collect information from you offline, such as when you attend one of our events, during phone calls with sales representatives, or when you contact a Validity representative;
- Information from Other Sources: In order to provide relevant marketing, offers, and services to you, we may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as from other third parties;
- Through Your Browser or Device: When you visit our Sites, we may collect information such as your MAC (Media Access Control) address, IP address, Internet browser type and version, your computer type (Windows or Macintosh), along with the time of visit and the pages you visited. If you use a mobile device to access our Sites, we may receive information about the location of your device. In some cases, even if you are not using a mobile device, information about your general location may be discernible from your device’s IP address or the URLs we receive. If you access or use our Sites with your mobile telephone, we may collect your telephone number;
- Through Your Use of the Sites and Offerings: We may track Site and Offering usage data, such as the date and time you use our Sites or Offerings, and what actions you perform within those Sites and Offerings;
- Through Cookies and other Similar Technologies: To the extent possible, Validity recognizes automated browser signals regarding tracking mechanisms, which may include ‘do not track’ instructions. See the section below titled “Cookies and other Similar Technologies” for more details.
- Specific to Validity’s Feedback Loop: Validity provides Feedback Loop services to you on behalf of select Internet Service Providers (“ISPs”) partnered with us. In order to provide the Service to you we will make your registration information (first name, last name, email address, along with any domain or IP data you provide) available to our ISP partners. This information is provided so that they may evaluate, approve, and administer the Service for you. We provide your registration information to these partners but they are not permitted to retain or use your information for any other purpose other than administering this Service.
- Specific to the Data Feed Services (i.e. betterbounces.net): We collect Personal Information only when you provide such information directly to us in connection with the Service Offering. We ask for Personal Information such as your name and e-mail address when you correspond with us for information or support. We may also retain any messages you send to us through the Service and may collect content and information you provide by posting to the Service Offering (“User Content”). We use this information to find malicious traffic which we provide to security companies to help them improve internet security efforts. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to betterbounces.net website or Service Offering.
- Through aggregation of email addresses when providing email validation services to our clients: we collect email addresses of individuals supplied to us by our customers using our products. This information is limited to email address only and is securely stored and encrypted, not in plain text. This information is not used for any ongoing purposes outside of validating email addresses for our customers.
HOW WE USE YOUR INFORMATION
We may use your Personal Information as follows:
- To register a customer or an interested party;
- To perform the contract that we are about to enter into or have entered into with you or our customers;
- To improve the content of our Services;
- To deliver interest-based content to you, including marketing and advertising material;
- To carry out research on customer demographics, interests and behaviors;
- To administer our Offerings, including by monitoring and analyzing traffic and usage patterns;
- To respond to inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our Services;
- To send administrative information to you, such as changes to our terms, conditions and policies, or information regarding the Services;
- To personalize your experience on the Sites by presenting products and offers tailored to you;
- To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these rules carefully.
REASONS FOR COLLECTION AND USE OF PERSONAL INFORMATION
- When necessary to perform a contract or take steps to enter into a contract with you.
- If you have consented or requested to receive communications from us.
- If it is necessary for our legitimate interest, for example: (i) to keep our records updated; (ii) to explore how customers use our Offerings; (iii) to offer additional features to our customers; (iv) for provision of services, (v) to prevent fraud or monitor for security vulnerabilities; (vi) in the context of a business reorganization or group restructuring exercise; (vii) to keep our Sites updated and relevant; (viii) to develop our business; (ix) and to inform our marketing strategy (by delivering Sites content and advertising to you).
- For our business purposes, such as data analysis, audits, fraud and abuse monitoring and prevention, detecting security vulnerabilities, identifying technical errors, for testing products and services, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- As we believe to be necessary or appropriate: (1) under applicable law, including laws outside your country of residence; (2) to comply with legal process; (3) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (4) to enforce our terms and conditions; (5) to protect our operations or those of any of our Affiliates; (6) to protect our rights, privacy, safety or property, and/or that of our Affiliates, you or others; and (7) to allow us to pursue available remedies or limit the damages that we may sustain.
If you would like more information on the legal basis under which we have collected and/or are processing your Personal Information, please contact us at [email protected].
HOW WE SHARE THE INFORMATION WE RECEIVE
Subsidiaries and Affiliates:
We contract with other companies and people to perform tasks on our behalf and we share your Personal Information with some of them to provide products or services to you, or to otherwise communicate with you, such as to provide marketing or offers on our behalf. Examples include removing repetitive information from customer lists, analyzing data, providing marketing assistance, conducting billing, processing credit card payments, engaging technical support for our services, providing customer service, hosting our Sites and Service Offerings, and performing analysis related to our products or services. We also provide your Personal Information to Service Providers (ex: Google Analytics) to verify or compile aggregate usage data that we provide to our partners. When we share your Personal Information, we require the Service Provider to maintain the privacy, confidentiality and security of your Personal Information.
With your prior consent, we may share Personal Information with business partners or other third party sponsors of sweepstakes, contests and similar promotions from time to time.
Validity Blog, Validity Help Center, Validity Customer Community, and Social Media Pages:
Personal Information may be disclosed by you through the Sites, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including, without limitation, our Validity Blog at https://www.validity.com/blog/, Validity Help Center at https://knowledge.validity.com/hc/en-us, and Validity Customer Community at https://mycommunity.validity.com, and the Social Media Pages). This information can appear in public ways, such as through search engines or other publicly available platforms and can be “crawled” or searched by third parties. Please do not post any information that you do not want to reveal to the public at large.
In some cases, we may buy or sell assets or businesses. In these types of transactions, user information may be one of the business assets that is transferred. Validity will disclose Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Profiling and Automated Decision-making:
Validity combines data obtained by the methods described above to help us determine what products and services might be of interest to you and when you might be ready to make a purchase based on repeated interaction with Validity websites, emails, and content. Validity marketing and sales personnel are involved in this process and no automated decisions are made that would result in legal effects or similarly significantly affect an individual.
Protection of Validity and Others:
We release Personal Data as we believe necessary and appropriate to law enforcement, tax, fraud prevention, credit risk agencies and other companies and organizations, as described above.
No Sale of Personal Information:
We do not “sell” your Personal Information, as defined in CA AB 375 and NV SB 220, for consideration. We will only communicate your data to Service Providers in order to provide you with support, service, or access, or through use of our Sites, during a Business Transfer (as outlined above), as outlined in the last bullet point of the “Reasons for Use of Personal Information” section above, or at your direct request. California residents may refer to the California Privacy Notice here for more information.
COMUNICATIONS FROM THE SITES
Service Email: As someone with an active Offering account, we may send you service-related email messages, which are not promotional in nature, on occasions and when it is necessary. Similarly, if you request assistance with a Site or one of our products or services, we will communicate with you through email or other online help sessions until we have addressed your questions.
Customer Service: Based upon the information you provide us, we will communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We may communicate with you by email, through an online help forum, or by telephone.
Newsletters and Promotions: If you register for our webinars, whitepapers, and/or other educational or promotional content, or otherwise indicate your interest in our Services, we will follow up via email and telephone with recommendations for our products and services based on your likely interests. You can unsubscribe or opt/out of any or all email marketing you may receive at any time.
We may occasionally send you push notifications through our consumer applications to send you application updates and other service related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off in the device settings.
HOW WE SECURE PERSONAL INFORMATION
We have implemented appropriate organizational, technical, and administrative measures to protect Personal Information within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Information from loss, misuse, interference and unauthorized access, modification and disclosure, you should be aware no security procedures or protocols are ever guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Information online. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us at [email protected].
COOKIES AND OTHER SIMILAR TECHNOLOGIES
We and our Service Providers may collect and store your usage information in log files and by using cookies, web beacons, pixel tags, embedded scripts, and other industry standard tracking technologies (“Tracking Technologies”). Among other things, we use Tracking Technologies to better serve you with more tailored information about Validity services, to facilitate your ongoing access to and use of the Site, and to collect and store information about your use of the Sites and Offerings. These technologies are used to analyze site usage trends, administer the site, monitor your navigation of the site, and to gather demographic information about our user base. We may receive reports based on this data from these companies on an individual and on an aggregated basis.
There are four types of cookies utilized on our Sites:
Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated (and so anonymous). If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Log Files and Local Storage Objects (HTML5)
We gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you. We use Local Storage, such as HTML5, to store content information and preferences. Various browsers may offer their own management tools for removing HTML5.
Clear Gifs & Web Beacons
Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly in HTML files and are about the size of the period at the end of this sentence.
We may use clear gifs in our HTML-based email to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you no longer wish to receive our newsletter or other promotional communications by email, you may opt-out of receiving them by following the instructions included in each communication, or by writing to us at [email protected].
We partner with service providers to either display advertising on our website or to manage our content and advertising on other sites (for example, on social media sites). They may use technologies such as cookies to gather information about your activities on our Sites in order to provide you advertising based upon your browsing activities and interests.
We store information that we collect through cookies and clear gifs to create a “profile” of your preferences. We tie your Personal Information to information in the profile to provide tailored promotions and marketing offers or to improve the content of the Sites for you. We do not share your personal identifiable profile with unapproved third parties. We strive to ensure that your Personal Information is kept strictly confidential and is not disclosed to third parties without your permission. Details will be used only by our staff and/or approved agents to support the necessary terms and conditions for use of service (such as our service providers who help with our business operations and technology services). Our contracts with our service providers dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
- Google Analytics Privacy, Google Analytics Opt-out Browser Add-on, Google Ads Settings, Facebook (“Cookies Policy), LinkedIn (“Manage Cookie Preferences”)
Certain browsers like Chrome, Edge, Internet Explorer, Firefox, and Safari offer a “Do Not Track” or “DNT” option that sends a signal to websites visited by the user about the user’s browser DNT preference setting. Please click on each browser name or go directly to the provider’s webpages to obtain more information on the availability of such settings. We do not currently honor Do Not Track browser settings or signals. For information about Do Not Track, please visit: allaboutdnt.com/.
We retain the Personal Information we collect where we have an ongoing legitimate business need to do so (for example to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your Personal Information, we will either delete or aggregate it or, if this is not possible due to practical or legal requirements, then we will securely store your Personal Information. If you wish to cancel your account or request that we no longer use your information to provide you with services contact the Validity Privacy Office by emailing us at [email protected].
THIRD PARTY SITES
Validity does not knowingly collect information from children under the age of 13 on the Site or through the Service. If you are under the age of 13, please do not provide any information to us. If we become aware that we have collected information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our systems.
We ask that you not send us or disclose any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, sexual orientation, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Sites or via other means.
Your Personal Information may be stored and processed in any country (including the United States) where we have facilities or in which we engage service providers, and by using the Sites or disclosing information to us you consent to the transfer of information to countries outside of your country of residence, which could have different data protection rules than those of your country or the country in which you were located when you initially provided the information. Validity will take steps to ensure that your Personal Information is subject to appropriate safeguards, including, where required, by implementing appropriate transfer mechanisms such as the DPF and European Commission standard contractual clauses (as amended and approved) for the transfer of Personal Information to third countries, supported by appropriate technical and organizational measures. For additional information regarding the DPF please refer to the DPF section below.
DATA PRIVACY FRAMEWORK
Consistent with its commitment to protect personal privacy, Validity has decided to voluntarily adhere to the principles set forth in the Data Privacy Framework (DPF). As such, Validity complies with the EU-U.S. Data DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF as set forth by the U.S. Department of Commerce.
Validity has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.
Validity has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.
Independent Dispute Resolution / Binding Arbitration
In compliance with the EU-U.S. DP and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Validity commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact Validity at: [email protected]
Attention: SVP of Legal and Privacy
100 Summer Street, Suite 2900
Boston, MA 02110
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Validity commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to Judicial Arbitration and Mediation Services, Inc. (“JAMS”), an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit JAMS for more information or to file a complaint. The services of JAMS are provided at no cost to you.
If JAMS does not resolve the matter, you may be able to invoke binding arbitration when other dispute resolution procedures have been exhausted. For more information: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.
Oversight, Liability and Accountability
The Federal Trade Commission has jurisdiction over Validity’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).
Validity retains accountability for any onward transfer of the third parties. This requirement limits transfers of personal data to third parties, for only specified purposes, and the third parties must provide the same level of protection as required under the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.
Applicable data privacy laws and regulations may afford you specific privacy rights (which depend on your location and jurisdiction), which may include and are not limited to the right:
- to know what Personal Information we hold and process about you and to access it;
- to correct any inaccurate data we may have about you;
- to erase your Personal Information;
- to cease or to restrict the processing of your Personal Information;
- to request to furnish you with the Personal Information which you provide us in a structured, commonly used, and machine-readable format;
- to withdraw your consent (to the extent our processing of your Personal Information is based on your consent);
- to object to legitimate reasons for the processing of your Personal Information;
- to opt-out of targeted advertising, profiling, the sale or sharing of Personal Information;
- to receive non-discriminatory treatment for the exercise of privacy rights;
- to lodge a complaint with the appropriate data protection authority if you have any concerns with regards to the processing of your Personal Information.
Validity responds to all privacy rights requests in accordance with applicable data privacy laws and regulations, which may provide certain restrictions on the extent to which you may exercise them. When a privacy right request is submitted, Validity will respond within a reasonable time frame the length of which depends on how complex or voluminous the request is (to the extent permitted by applicable law or regulation). Validity will promptly notify you if the response time will be extended.
You may exercise applicable privacy rights by submitting your request to [email protected].
Please indicate which privacy right you are exercising in the request with the corresponding data privacy law or regulation. We also need to know your email address which is associated with Validity to initiate your request. Please note we may request additional information to verify your identity, depending on the request type.
Please refer to our California Privacy Notice here for more details on California specific privacy rights.
OPT-OUT OF COMMUNICATIONS
YOU CAN ALSO OPT-OUT OF RECEIVING MARKETING MESSAGES FROM VALIDITY OR ITS AFFILIATES BY UNSUBSCRIBING THROUGH THE UNSUBSCRIBE OR OPT-OUT LINK IN AN EMAIL. PLEASE NOTE THAT IF YOU OPT-OUT OF RECEIVING MARKETING-RELATED EMAILS FROM US, WE MAY STILL SEND YOU IMPORTANT ADMINISTRATIVE AND TRANSACTIONAL MESSAGES.
Attn: Privacy Department
100 Summer Street
Boston, MA 02110
UK Contact Location:
The Charter Building
Uxbridge, UB8 1JG
Effective Date: January 2024