At ContactPigeon, we respect the privacy needs of our valued customers and that's why we are founded on several clear privacy principles and we created this Privacy Policy to explain how we collect, use, disclose and otherwise process personal information in connection with operating our business.

Your trust is extremely important to us and the best learning happens where there is trust.

Your private information will remain confidential.

We will never spam you, or provide your information to others who will spam you.

We aim to be transparent and clear in our explanations of what we do with your data.

We recommend that you read this Privacy Policy in full to ensure you are fully informed.

We understand internet privacy can be difficult to understand. Please don't hesitate to reach out to us at privacy@contactpigeon.com with any privacy questions or concerns.

THE BASICS

1. Definitions

These definitions should help you understand this policy.

When we say “ContactPigeon”, “we”, “us” and “our” we are referring to the Marketing Automation services offered through the url www.contactpigeon.com.

We provide online platforms that you may use to market to or stay in contact with others, including creating, sending, and managing messages and other information related to your Subscribers (the “Services”).

When we say “Member,” we are referring to the person or entity that is registered with us to use the Services.

When we say “you,” we are referring either to a Member or to some other person who visits any of our Websites.

A “Subscriber” can be a person you contact through our Services, you collect information through our Services, a person who you might choose to contact at some point in the future through the use of our Services, is anyone on your Distribution List or about whom you have given us information.

A “Distribution List” is a list of Subscribers and all associated information related to those Subscribers (for example, email addresses).

“Personal Information” means any information that identifies or can be used to identify you or a Subscriber, directly or indirectly, including, but not limited to, first and last name, date of birth, email address, gender, occupation or other demographic information.

Message is any form of communication (eg Email, Web Push Notification).

ContactPigeon provides marketing technology services to other businesses – our Members. To take advantage of our services, our Members share with us information about their individual consumers, including contact details and shopping histories. We analyze that information and develop and send communications to the Subscribers only at the direction of the Member who provided the information, and only on that Member’s behalf. We may also collect personal data for our own business purposes in connection with our business, such as business contact details of potential Members or job applicants’ resumes.

This Privacy Policy applies to:
• The contactpigeon.com website and any other websites or online services controlled by us and which display this Privacy Notice; and
• Marketing technology services that we provide to our Members.

2. Changes

We may change this Privacy Policy at any time and from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the bottom of this Privacy Policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Website. We encourage you to review this Privacy Policy often to stay informed of changes that may affect you, as your continued use of the Website signifies your continuing consent to be bound by this Privacy Policy. Our electronically or otherwise properly stored copies of this Privacy Policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy which were in effect on each respective date you visited the Website.

3. Scope

This Privacy Policy is effective with respect to any data that we have collected, or collect, about and/or from you, according to our Terms of Use.

4. Questions & Concerns

If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please use our contact form to send us a message. You may also contact us by email at privacy@contactpigeon.com

INFORMATION

5. Collected Information

a) Information we collect for ContactPigeon’s Own Business Purposes

We may collect information about individuals who interact with ContactPigeon when using our website or services (such as employees of our Members), visitors, and other individuals.

We may collect information:

• Directly from individuals;
• From third party vendors, data brokers; or
• Business partners.

The types of information we collect include:

• Personal and business contact information (such as name, business name, address, telephone number, email address, and mailing address);
• Billing information (such as VAT ID); and
• Information we collect from or on Behalf of Our Members.

b) Information we collect from or on Behalf of Our Members

We may collect information about individual Subscribers from our Members or – at Members’ request– from their service providers. Our Members determine the scope of the information transferred to us, and the information we receive may vary by Member. Typically, we may collect Members’ Subscribers’ contact details such email addresses and demographic data, shopping histories, and details about Subscribers’ interactions with marketing communications.

c) Information we collect automatically and terminology

We, our service providers, and our business partners, may collect certain information about the use of our websites by automated means, such as cookies, web beacons and other technologies. Likewise, as part of our services, we may offer our Members the ability to install these types of technologies on their websites or in the emails they send to their clients; and if a Member does so, we collect information on its behalf.

A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser.

A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server.

We and our service providers and business partners may collect information about your online activities over time and across third-party websites when you use our websites and mobile applications.

The information we collect by automated means varies based on whether we are collecting information for our own business purposes or whether we are collecting information from or on behalf of our Members to provide our services.

d) The information collected by automated means for our own business purposes includes:

• Details about the devices that are used to access our websites (such as the IP address, and type of operating system and web browser).
• Dates and times of visits to, and use of, our websites.
• Information about how our websites are used (such as the content that is viewed on our websites and how users navigate between our webpages, and the date and time of access).
• Details about how individuals interact with our emails (such as whether the email is opened and which links are clicked in the email).
• URLs that refer visitors to our websites.
• Search terms used to reach our websites.
• Web browsers may offer users of our websites the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly.

e) The information collected by automated means on behalf of our Members may include:

• Details about the devices that are used to access our Members’ websites (such as the IP address, and type of operating system and web browser).
• Dates and times of visits to, and use of, our Members’ websites.
• Information about how our Members’ websites are used (such as the content that is viewed on our Members’ websites and how users navigate between webpages, and the date and time of access).
• Details about how individuals interact with our Members’ emails (such as whether the email is opened and which links are clicked in the email).
• URLs that refer visitors to our Members’ websites.
• Search terms used to reach our Members’ websites.
• Web browsers may offer users of our Members’ websites the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly.

f) We may use personal information for ContactPigeon’s own business purposes:

• Provide our services to our Members.
• Communicate about the products and services we offer, and respond to requests, inquiries, comments, and suggestions.
• To send you System Alert messages. For example, we may inform you of temporary or permanent changes to our Services, such as planned outages, new features, version updates, releases, abuse warnings, and changes to our Privacy Policy.
• To communicate with our Members about their account and provide customer support.
• Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read).
• Operate, evaluate and improve our business, our websites, and other products and services we offer (including to develop new products and services).
• Invoice and collect payment for our services.
• Establish and maintain an individual’s profile in our service.
• Tailor the content we display in our communications, in our services and in mobile apps.
• Administer surveys and other market research.
• Comply with legal requirements, judicial process, and our company policies (including to verify users’ identity in connection with access or correction requests).
• Protect against, identify, investigate, and respond to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide.
• Process employment applications.
• Monitor recruiting statistics, to inform our recruitment activities.
• We may aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.
• To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.

g) We use personal information we collect from or on behalf of our Members to provide services to our Members at their direction. We do not use this information for ContactPigeon’s own purposes.

We use personal information only as directed or authorized by our Member. Typically, we are directed or authorized to use personal information collected on behalf of the Member to:

• Help customize marketing strategy for our Members.
• Personalize marketing content for our Members’ clients.
• Target clients for our Members’ marketing campaigns.
• Analyze and enhance our Members’ communications and strategies (including by identifying when emails sent to you have been received and read).
• Analyze results from marketing campaigns for our Members.

6. Information from other sources

From time to time we may obtain information about you or your Subscribers from third party sources, such as public databases, social media platforms, 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, 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.

7. Combined Information

We may combine Personal Information with other information we collect or obtain about you (such as information we source from our third party partners), to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this Privacy Policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this Privacy Policy applicable to, Personal Information.

8. Information we share

We may share personal information for the purposes set out in this Privacy Policy with:

• Service providers that perform services on our behalf, such as technology providers (including providers of payment processing, technology support, web hosting, and email communications).
• Survey and market research providers.
• Advertising and marketing partners.
• Analytics organizations.

In addition, we may share your information to comply with legal and regulatory requirements, and protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities.

9. Public Information and Third Party Websites

a) 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. If your Personal Information appears on our blogs and you want it removed, contact us here. If we are unable to remove your information, we will tell you why.

b) Social media platforms and widgets

Our Websites 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 Instagram. 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.

c) Links to third-party websites and/or third-party services

Our Websites include links to other websites and services, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Website you visit.

We will retain Personal Information we process on behalf of our Members for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.

10. Contest and Sweepstakes

We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Websites or through social media (collectively “Our Promotions”). Participation in our Promotions is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer Our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or Service Providers in line with this policy and the rules posted for the Promotion.

11. Content of Email Campaigns

When you send an email marketing campaign, 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 confidential information. Please do not use ContactPigeon to send confidential information.

Sometimes we review the content of our Members’ email campaigns to make sure they comply with our Terms of Use. To improve that process, we have software that helps us find email campaigns that may violate our Terms. Our employees or independent contractors may review those particular email campaigns. This benefits all Members who comply with our Terms of Use because it reduces the amount of spam being sent through our servers and helps us maintain high deliverability.

YOUR LISTS

12. Your Distribution Lists

A Distribution List can be created in a number of ways, including by importing contacts, such as through csv or directly from your email client. Your Distribution Lists are stored on a secure ContactPigeon server. We do not, under any circumstances, sell your Distribution Lists. If someone on your Distribution List complains or contacts us, we might then contact that person. Only authorized employees have access to view Distribution Lists. You may export (download) your Distribution Lists from ContactPigeon.

We will use and disclose the information in your Distribution Lists only for the reasons discussed in Sections 5-8. We will not use and disclose the information in your Distribution Lists to:

• Bill or collect money owed to us;
• send you system alert messages;
• communicate with you about your account; or
• send you informational and promotional content.

If we detect abusive or illegal behavior related to your Distribution List, we may share your Distribution List or portions of it with affected ISPs or anti-spam organizations.

SECURITY

13. Notice of Breach of Security

If a security breach causes an unauthorized intrusion into our system that materially affects you or people on your Distribution Lists, then ContactPigeon will notify you as soon as possible and later report the action we took in response.

14. Safeguarding Your Information

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 including offering our Data Processing Agreement under the European General Data Protection Regulation (GDPR).

Thus and in accordance with the GDPR, ContactPigeon undertakes to take all pertinent precautions in order to preserve the security of the data and, in particular, to protect them against any accidental or unlawful destruction, accidental loss, corruption, unauthorised circulation or access, as well as against any other form of unlawful processing or disclosure to unauthorised persons. Moreover, in order to avoid in particular all unauthorised access, to guarantee accuracy and the proper use of the data, ContactPigeon has put the appropriate electronic, physical and managerial procedures in place with a view to safeguarding and preserving the data gathered through its services.

ContactPigeon accounts require a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. Because the information in your Distribution Lists is so sensitive, account passwords are encrypted, which means we cannot see your passwords. We cannot resend forgotten passwords either. We will only reset them.

If, by some exceptional case, the direct loss incurred arose due to fault or gross negligence by ContactPigeon, you will be able to seek compensation within the limit of liability referred to in our Terms of Use.

You should keep in mind that any user, customer or hacker who discovers and takes advantage of a breach in security renders him or herself liable to criminal prosecution and that ContactPigeon will take all measures, including filing a complaint and/or bringing court action, to preserve the data and the rights of its users and of itself and to limit the impacts.

If you have any questions about the security of your Personal Information, you may contact us at privacy@contactpigeon.com

COMPLIANCE

15. We Operate in the Europe

Our servers and offices are located in the Europe, so your information may be transferred to, stored, or processed in the Europe. We take many steps to protect your privacy, including offering our Data Processing Agreement under the European General Data Protection Regulation (GDPR). By using our Websites, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the Europe and those third parties with whom we share it as described in this policy.

If you are a resident of the European Economic Area ("EEA"), you have the following data protection rights:

• If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time by emailing privacy@contactpigeon.com.
• In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information, or request portability of your personal information. Again, you can exercise these rights by emailing privacy@contactpigeon.com.
• have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you. To opt-out of other forms of marketing, please contact us by emailing privacy@contactpigeon.com.
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
• ContactPigeon does not knowingly collect information from children under the age of 18, and children under 18 are prohibited from using our Services. If you learn that a child has provided us with personal information in violation of this Privacy Policy, you can alert us at privacy@contactpigeon.com.

16. Accuracy and Retention of Data

We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information.

We will retain your information for as long as your account is active or as long as needed to provide you with our Services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Agreements (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).

17. Access

We will give an individual, either you or a Subscriber, access to any Personal Information we hold about them within 30 days of any request for that information. Individuals may request to access, correct, amend or delete information we hold about them by contacting us at privacy@contactpigeon.com. Unless it is prohibited by law, we will remove any Personal Information about an individual, either you or a Subscriber, from our servers at your or their request.

18. Marketing Emails

You may unsubscribe from receiving marketing or other commercial emails from ContactPigeon by following the instructions included in the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes to our website terms).

Updated 24th of May, 2018