Return Path Data Privacy Policy

Effective Date: November 17, 2014

Introduction

Thank you for taking the time to read our Privacy Policy. Your privacy is of the utmost importance to us. Our business depends on the trust of thousands of companies and millions of people. Violating that trust is simply not an option. We want you to be fully informed about the information we collect, how it is used, shared, and protected, and the choices you have with it.

The following explains the privacy and data practices at Return Path, Inc. (“Return Path”, “We”, “Us”, or “Our”). After you read it, if you have any questions please contact the Return Path Privacy Office by using this simple online form and submitting a ticket under privacy department. We’ll be glad to help.

Our Privacy Policy will tell you about:

Thank you for visiting our website and using our products and services.

Sincerely,
Matt Blumberg, CEO

TRUSTe Program and Scope

TRUSTe Certified Privacy

Return Path, Inc. has received TRUSTe’s Privacy Seal signifying that this Privacy Policy and our practices have been reviewed for compliance with the TRUSTe program viewable on the
validation page available by clicking the TRUSTe seal. The TRUSTe certification does not cover information that may be collected through downloadable software. The TRUSTe certification covers only our collection, use and disclosure of information we collect through our websites: www.motleybunch.com, www.otherinbox.com and http://context.io.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe here.

E.U. and Swiss Safe Harbor

Return Path, Inc. complies with the U.S.—E.U. Safe Harbor framework and the U.S.—Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Return Path, Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Return Path, Inc.’s certification, please visit www.export.gov/safeharbor/.

The Organization Collecting Information at This Website

The mission of Return Path and its subsidiary companies is to make email better for everyone. We build products and provide services to make your inbox a safe and manageable place filled with email you want to receive and nothing more.

Our products and services include Context.IO (a product of our subsidiary, DokDok, Inc.), OtherInbox, and Motley Bunch. We operate and own the websites (the “Sites”) located at:

Through these Sites, we provide various email management and information products and services through which users who register with us may analyze and manage email messages received and better understand relevant data such as purchase and other information from their email stored in their personal email accounts.

The Information We Collect and Use

We refer to the above products and services, as well as any of our other current or future products and services, collectively as the “Service.” Any information provided to us through the Service will be retained and used solely for the purposes of fulfilling your request for information, fulfilling a request through a Site or Service feature, performing and carrying out the Terms of the Service, performing or improving our Service, developing a new Service or communicating with you as a user of Return Path’s services.

Registration Information

Registration for the Service may not required to simply view a Site. If you elect to register for a Service, Return Path asks you for information that enables us to provide the Service. You will be registering with Return Path on the form provided and such registration may require you to provide contact information such as your name, username, password, and email address.

Service Usage Information

We collect non-personal information − data in a form that does not permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. For example, when you use our services, we may collect data from and about the commercial electronic mail messages, transactional or relationship messages that are sent to your email accounts so that we can better understand the behavior of the senders of such messages, as well as better understand our customer behavior and improve our products, services, and advertising, and if we do disclose such messages, all identifiable personal information will be removed prior to any such disclosure. If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

The services Return Path offers are:

Context.IO

Developers

Your privacy, and that of your users, is of the utmost importance to us. Both your business and ours depend on the trust of thousands of companies and millions of people. Violating that trust is simply not an option. Just as we strive to be clear, we want you to fully inform your customers and users about the information you and we collect, how it is used, shared, and protected, and the choices they have with it. Please note that the Context.IO Developer Terms of Service contain some specific obligations applicable to you regarding your privacy and data practices. These obligations include things such as ensuring that you are publishing a sufficient privacy policy to your End Users, that it is available to your users for review in a sufficient manner, and that specific disclosures exist which allow for the Context.IO Services to be utilized within your mobile or web product or service. If you are a developer and have powered your mobile or email application with Context.IO, please review your Developer Terms of Service.

Service End-Users

If you are an email user using a mobile or email application powered by Context.IO, please review the following. With your permission at sign up or use of the application, Return Path and Context.IO collect personal information and provide and market our products and services to our users when you register with us. This includes but is not limited to your name, email address, your username, and password. Context.IO may also collect Personal Information from visitors when they communicate with us about our services and products or during other transactions or interactions. Context.IO will use Personal Information to provide services and products requested by you and to enable its vendors and contractors to provide and assist Context.IO in the marketing and provision of such services and products to you. We also use it to improve spam filters, detect and help stop phishing attacks, help companies adopt best practices, and analyze how people interact with commercial email. You may opt-out at anytime for Context.IO data collection practices at http://optout.context.io or marketing information via the opt- out link contained within the email.

Motley Bunch

With your permission, Return Path connects to your email account(s) that you choose in your sole discretion to link with the Site. Return Path then provides a service whereby our servers scan your mailbox for commercial messages and purchase- related emails from your inbox for those connected accounts and organizes them into your personal catalog. By connecting your email account(s) to our service, you grant us permission to access and use, from your email, purchase and shipping-related data and other information such as product names and identifiers, order identifiers, items purchased, tracking numbers, name, account number, as well as information regarding your shopping preferences such as product wish lists, order history, tracking number, open and clicks, what you bought, how much you paid for it, where you bought it, and marketing preferences. From this collection of commercial message data, we will then remove or replace all personal information such as recipient name, recipient email address, postal address and the other unique identifiers—specifically any Personal Information—with non-identifying data points and may share that non-personal information with third parties for purposes of performing analytics and market research.

OtherInbox

With your permission, Return Path connects to your email account(s) that you choose in your sole discretion to link with the Site. Return Path then provides a service whereby our servers scan your mailbox to inventory, organize and categorize email and/or to assist in unsubscribing from selected companies. As part of that process, we index information about commercial email companies who have sent you email. Examples like FROM domain, FROM IP Address, Message Subject line, Message Date, and Message Body URLs. We retain data from these commercial messages, about the commercial sender, including their name and reply email address, Message Subject line, and message content and unsubscribe link (if present). We also retain user usage data points, including whether the email was opened, moved, forwarded, clicked, or marked as spam. From this collection of commercial message data, we remove or replace all personal information with non-identifying data points, such as recipient name, recipient email address, postal address and the other unique identifiers—specifically any Personal Information about you—and store it. We may then share that non-personal information with third parties for purposes of performing analytics and market research.

Aggregate Information

From time to time, we may collect general, non-identifiable personal, statistical information about the use of the Sites and the Service, such as how many visitors visit a specific page on the Sites, how long they stay on that page, and which hyperlinks, if any, they “click” on. We collect this information through the use of technologies such as “cookies” and “IP addresses”, which are discussed in greater detail below. We may also group this information into aggregate visitor data in order to describe the use of the Sites and Service to our existing or potential business partners or other third parties (such as Google Analytics), or in response to a government request. However, please be assured that this aggregate data will in no way personally identify you, other list members or any other visitors to the Sites.

We may store your personal information along with your files and data on a third party server such as Amazon Web Services; or we may use a third party analytics tool to learn how you are using our Sites.

In cases where you use a mobile device to access our Sites, we will 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 discernable from your device’s IP address or the URLs we receive. If you access or use our Sites or Services with your mobile telephone, we may collect your telephone number.

Cookies and Other Tracking Technologies

Technologies such as: cookies, beacons, tags and scripts are used by Return Path, Inc. and our marketing partners, affiliates, or analytics or service providers. 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. 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 site, but your ability to use some features or areas of our site may be limited.

Log Files

As is true of most web sites, 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, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.

Behavioral Targeting / Re-Targeting

We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies 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). 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.

Retention of Personal Information

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period applicable by law. We will make good faith efforts to delete the data if you contact us by following the instructions at the beginning and at the end of this Privacy Policy, provided Return Path is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us by completing this simple online form.

Information Sharing and Disclosure

Except for the limited situations listed here in this Privacy Policy, we will not share your identifiable personal information with unapproved third parties. To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to unapproved third parties as part of legal process.

Agents and Third Party Service Providers

To provide the Service to you, we may sometimes use other approved third party businesses or affiliates to perform certain specialized services such as data processing or other technology services. Your information collected through the Return Path Service may be stored and processed in the United States or any other country in which Return Path, approved third party businesses, its affiliates or service providers maintain facilities. Return Path may transfer information that we collect about you, including Personal Data, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. They are not permitted to retain or use your information for any other purposes other than what is defined as the service in our Terms of Use and this privacy policy. If you are located in the European Union, Switzerland or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including Personal Data, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which Return Path or its parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

Change of Control / Asset Transfer

As the Company develops, we may buy other businesses or their assets or sell all or parts of our business assets. Customer information is generally one of the business assets involved in such transactions. Thus, in the event that the assets of the Company in whole or in parts are acquired by a third-party, customer information, including any visitor information collected through the Sites or the Service, would be one of the transferred assets. In the event of a corporate change in control or sale of all or parts of our business assets our users will be notified in accordance with the “Changes to this Policy” section of the policy if their personal information is provided to the new corporate entity or asset purchaser.

Frames

Some of our pages utilize framing techniques to serve content to from our partners while preserving the look and feel of our website. Please be aware that you are providing your personal information to these third parties and not to http://context.io.

Communications from the Sites

Service Email

As someone with an active Service account, we may send you service-related email messages, which are not promotional in nature, on occasions 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 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 or telephone.

Newsletters and Promotions

We may provide you the opportunity to opt-in to additional newsletters or promotional communications sent by email. If you have opted in or otherwise qualify to receive these forms of communication, we will use your name and email address to communicate with you. Out of respect for your privacy, we provide you a way to unsubscribe by following the instructions included in each communication.

Correcting, Updating or Removing Your Personal Information

Return Path will make commercially reasonable efforts to provide you reasonable access to any of your personal information we maintain within 30 days of your access request. We provide this access so you can review it, make corrections or request deletion of your data. If we cannot honor your request within the 30-day period, we will tell you when we will provide access. In the unlikely event that we cannot provide you access to this information, we will explain why we cannot do so. To review and update your personal information to ensure it is accurate, contact us using this simple online form and making the change on our member information page.

Security and Information Protection

The security of your information is important to us. When you enter sensitive information (such as your registration information, we encrypt that information using Secure Socket Layer (SSL) technology. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. You should, therefore, always use caution when submitting personal information online. If you have any questions about security on our website, you can contact us using this simple online form.

Blog

Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us using this simple online form. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Testimonials

We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us using this simple online form.

Collection and Use of 3rd Party Personal Information

You may provide personal information about other people, such as their name and email address. This information is only used for the sole purpose of completing your request or for whatever reason it may have been provided.

Single Sign-On

You can apply to our open positions using sign-in services such as Login with Facebook or LinkedIn. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this website to your profile page to share with others within your network.

Privacy Policy for Children

We do not knowingly collect information from children under the age of 13 through our Sites or Services. If you are under the age of 13, please do not provide any information to us. If we receive notice that we have collected information from a child under the age of 13, we will make commercially reasonable efforts to delete such information.Simply contact the Return Path Privacy Office by using this simple online form and submitting a ticket under privacy department.

Changes to This Policy

Return Path reserves the right, at its discretion, to change, modify, add, or remove portions from this policy at any time by posting such changes here. Users should review this policy regularly for changes, and can easily see if changes have been made by checking the Effective Date above. However, if at any time in the future Return Path plans to use Identifiable Information in a way that differs from this policy, Return Path will post such changes here and provide you with the opportunity to opt-out of such differing uses prior to the change becoming effective. Your continued use following the posting of any changes to this policy means acceptance of such changes.

Contacting Us

We value your opinions. If you have comments or questions about our privacy policy, you may contact the Return Path Privacy Office by using this simple online form and submitting a ticket under privacy department, or contact:

Return Path, Inc.
3 Park Avenue, 41st Floor
New York, New York 10016
Attn: Chief Privacy Officer
Phone: (212) 905-5500
Fax: (212) 905-5501