Privacy Policy

Last Updated: December 10, 2019

INTRODUCTION

Validity Holdings, Inc., and its subsidiaries, including Validity, Inc., Return Path, Inc., Primal Cause, Inc., Return Path International, Inc., Otherinbox, Inc., and Switch Labs, Inc., (“Validity,” “we,” “our,” “us”) respect your privacy rights and value your trust. This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Information, as well as your rights in determining what we do with the information that we collect or hold about you.

This Privacy Statement (“Privacy Policy”) governs Validity’s collection, use, storage, and transmission of Personal Information in connection with the use of Validity’s products, applications, and services (“Offerings”) or from any of the websites listed below (the “Sites”), and other services provided by us both online and offline as well as through communication, including email messages, that we send to you that link to this Privacy Policy (together with the Offerings and the Sites, the “Services”). By using the Services, you accept and agree to the practices that this Privacy Policy describes.

This Privacy Policy does not apply to the practices of third parties that Validity does not own or control, or to individuals that Validity does not employ or manage.

THE ORGANIZATION COLLECTING INFORMATION AT THIS WEBSITE 

We operate and own the Sites located at:

https://validity.com

https://briteverify.com

https://returnpath.com

https://www.getunsubscriber.com

https://getorganizer.com

https://notifierforoutlook.com

https://www.senderscore.org

https://monitor.returnpath.net

https://www.threatwave.com

https://www.betterbounces.net

https://context.io

https://emaildna.com

https://appbuddy.com

INFORMATION WE COLLECT

When you use the Services, we may collect and use Personal Information about you or that directly or indirectly identifies you or another individual (“Personal Information”), which may also include your name, email address, phone number, title, job function, postal address, browser and device information, and information collected through cookies and other similar technologies (such as IP address). If you submit any Personal Information to us or our service providers in connection with the Services, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

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.

  1. 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.

  • By Aggregating Information: Aggregated Personal Information does not personally identify you or any other user of the Sites (for example, we may aggregate Personal Information to calculate the engagement of our marketing content by region).

  • Specific to Validity’s Consumer Applications:

    • Our (1) Organizer, (2) Unsubscriber, and (3) Notifier for Outlook applications provide services such as (1 and 2) organizing and categorizing email, unsubscribing you from email campaigns, and helping you manage your preferences for commercial emails and (3) helping you keep track of your unread email message count. When you sign up for any of these applications, we’ll collect your name, email address, and password to access your email account.

    • Once access is established, we connect to your inbox over IMAP/API, and copy data from your inbox to secure, encrypted cloud instances controlled by Validity. We then programmatically parse your data, indexing information including, but not limited to, Sending Domain and IP Address, Subject line, Message Date, Message Body URLs, redacted and obfuscated non-personal message content, and engagement data points, including whether the email was opened, moved, forwarded, clicked, or marked as spam.

    • In order to provide our Consumer Applications at no cost to you, we use some of the data we parse from your inbox for our legitimate business purposes. We are interested in understanding how you generally interact with your inbox (ex: how much time you spend in your email account, at what time you check your emails), which email campaigns (marketing, transactional, relationship-type messages) you engage with, and what that engagement was (ex: did you read/delete/mark as spam). We collect this data so we can help our clients adopt best email sending practices, optimize delivery of email marketing campaigns to you, help email and Internet service providers improve their spam filters, improve upon our existing Offerings or to develop a new services, and help Internet security companies detect and stop phishing attacks.

    • We are not interested in personal correspondence, and immediately delete personal messages from the data we might retain, along with other emails which are not identified as commercial messages. The data we retain is de-identified or pseudonymised (ex: we remove your email address, street address, phone and account numbers, along with any of your other identifying information) before being included in our products or services.

    • You can opt-out of data sharing at any time by removing the corresponding app from your email account.

  • Specific to the Return Path Feedback Loop: Validity provides Return Path 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.

  1. 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 we are about to enter into or have entered into with you;

  • 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.

  1. 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].

  1. HOW WE SHARE THE INFORMATION WE RECEIVE

Subsidiaries and Affiliates:

We disclose Personal Information to our subsidiaries and affiliates for the purposes described in this Privacy Policy.

Agents and Service Providers:

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 agents and 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 agent or service provider to maintain the privacy, confidentiality and security of your Personal Information.

Sweepstakes:

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 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 Community at https://community.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.

Business Transfers:

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.

California and Nevada Residents:

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 third parties 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.

  1. 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.

  1. 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].

  1. COOKIES AND OTHER SIMILAR TECHNOLOGIES

We and our vendors, consultants, agents, and other service providers (collectively, “Service Providers”) may collect and store your usage information in log files as well as through the use of cookies, web beacons, pixel tags, embedded scripts, and other tracking technologies now and hereafter developed (“Tracking Technologies”). We use Tracking Technologies to, among other things, better serve you with more tailored information for our services, and for those of third parties, facilitate your ongoing access to and use of the Site, and collect and store information about your use of the Sites and Offerings. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

Cookiess

T”Cookies” include commonly used pieces of information in the form of small files that are placed on an individual’s device to enable the individual to more easily communicate and interact with the Sites. When you visit our Sites, we may send one or more cookies to your device. They enable us to store information about your device which helps us, among other things, to provide you with a good experience when you browse our Sites and enhance the level of services and functions provided. We also use third parties to serve advertisements on other websites that may be of interest to you, based on information collected about your use of our Sites and other websites. To do so, these companies may place or recognize a unique cookie or similar on your browser. We use cookies to remember users’ settings (e.g. language preference), tracking for marketing purposes, and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Sites, but your ability to use some features or areas of our site may be limited.

Log Files

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.

Local Storage Objects (HTML5)

We use Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

Clear Gifs (Web Beacons / Web Bugs)

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].

Behavioral Targeting / Re-Targeting

We partner with third parties to either display advertising on our website or to manage our advertising on other sites (for example on social media sites). Our third party partners may use technologies such as cookies or emails to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here) or by unsubscribing within the ad itself. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Profile

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 undertake 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 service providers under contract who help with our business operations and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.

Do Not Track

Certain browsers like 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. To the extent possible, Validity recognizes automated browser signals regarding tracking mechanisms, which may include DNT instructions.

  1. DATA RETENTION

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].

  1. THIRD PARTY SITES

Our Sites includes Social Media Features, such as the Facebook button and Twitter Tweet button or interactive mini-programs that run on our website (the “Features”). Your interactions with these Features are governed by the privacy policy of the company providing it.

Please be aware that when you are on the Sites, or when you receive an email message from us through the Offerings, you could be directed to other sites that are beyond our control. There may be links to other sites from the Site’s pages or from the email message we send to you that take you outside our Services. These other sites may send their own cookies to visitors, collect data, or solicit Personal Information. The privacy policies of these other sites may be significantly different from this Privacy Policy. We are not responsible for the privacy practices of these other sites and cannot guarantee the security of any of your Personal Information collected there.

  1. SENSITIVE INFORMATION

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.

  1. EU-U.S. PRIVACY SHIELD AND SWISS-U.S. PRIVACY SHIELD

We participate in and have certified compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all Personal Information received from European Union (EU) member countries, the United Kingdom, and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list

Validity is responsible for the processing of Personal Information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Validity complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, the United Kingdom, and Switzerland, including the onward transfer liability provisions.

With respect to Personal Information received or transferred pursuant to the Privacy Shield Framework, Validity is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

  1. INTERNATIONAL TRANSFERS

Your Personal Information may be stored and processed in any country 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, including the United States, Australia, Brazil, France, and the UK, 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. Where required, we put in place a solution to ensure that Personal Information transferred outside of the EEA is subject to adequate protection.

  1. REVIEW AND CORRECTION OF YOUR INFORMATION; OPT-OUT

You may access, correct, or request deletion of the Personal Information we collect about you at any time by contacting us [email protected] We will respond to your request within a reasonable timeframe.

European Union Residents
If you are a European citizen, you have the right to request that we:

  • Provide you with information regarding whether we process your data, including any details related to such processing;

  • Correct any inaccurate data we may have about you without undue delay;

  • Complete any incomplete information that we may have about you;

  • Under certain circumstances, erase your Personal Information without undue delay;

  • Under certain circumstances, be restricted from processing your data;

  • Under certain circumstances, furnish you with the personal data which you provide us within a structured commonly used and machine-readable format.

Where we process your information solely on the basis of your consent, European citizens have the right to withdraw consent to our processing at any time. This will not affect the lawfulness of our processing before the withdrawal. European citizens also have the right to lodge a complaint with their data protection supervisory authority at any time.

California Residents
If you reside in California, you have the right to ask us one (1) time each year about whether or not we have your Personal Information, the categories of Personal Information we may have about you, what Personal Information we may have about you, and whether or not you would like the Personal Information deleted.

If your information has been shared with a third party, as described elsewhere in this Privacy Policy, then that third party has received its own copy of your data. If you have been contacted by one of these third parties and wish to correct or delete your information, please contact them directly.

The exercise of any of the above rights may be subject to certain conditions and we may require further information before we can respond to your request.

  1. 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.

  1. PRIVACY POLICY UPDATES

We update the Privacy Policy from time to time, so please review it regularly. If we materially change our Privacy Policy, we will notify you by posting a notice during the log-in process. Your continued use of the Sites or Offerings will be deemed your agreement that your information may be used in accordance with the new Privacy Policy. If you do not agree with the changes, then you should stop using the Sites or Offerings and notify us that you do not want your information used in accordance with the changes.

  1. CONTACTING US

We welcome any questions, comments, or concerns you may have regarding this Privacy Policy. Please do not hesitate to contact us as follows:

Validity, Inc.
Attn: Privacy Department
200 Clarendon Street
Boston, MA 02116
(888) 724-9755
[email protected]

Validity UK Office:
The Charter Building
Uxbridge, UB8 1JG
[email protected]

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