A. Information I Collect
The Personal Information that I may collect or receive about you broadly falls into the following categories:
(i) Information I receive about Contacts from my Members
A Member may provide Personal Information about you to me through the Service. When a Member uploads their Distribution List or integrates the Service with another website or service (for example, when a Member chooses to connect their e-commerce account with Boldermail), or when you sign up for a Member’s Distribution List on a Boldermail or other signup form, the Member may provide me with certain contact information or other Personal Information about you such as your name, email address, address, or telephone number. You may have the opportunity to update some of this information by electing to update or manage your preferences via an email you receive from a Member.
(ii) Information I collect automatically
- Device information: I collect information about the device and applications you use to access emails sent through my Service, such as your IP address, your operating system, your browser ID, and other information about your system and connection.
(iii) Information I collect from other sources
From time to time, I may obtain information about you from third-party sources, such as social media platforms, and third-party data providers.
B. Use of Personal Information
I may use the Personal Information I collect or receive about you in reliance on my (and where applicable, my Members’) legitimate interests for the following purposes:
- To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
- To provide information to representatives and advisors, including attorneys and accountants, to help me comply with legal, accounting, or security requirements.
- To prosecute and defend a court, arbitration, or similar legal proceeding.
- To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- To provide, support and improve the Service. For example, this may include sharing your information with third parties in order to provide and support my Service or to make certain features of the Service available to my Members. When I share Personal Information with third parties, I take steps to protect your information in a manner that is consistent with applicable privacy laws. For further information about how I share information, refer to this article.
- To perform data analytics projects. My data analytics projects use data from Boldermail accounts, including your Personal Information, to provide and improve the Service. I use information, like your purchase history, provided to me by Members, so I can make more informed predictions, decisions, and products for my Members. For example, I use data from Boldermail accounts to enable product recommendation, audience segmentation, and predicted demographics features for my Members. If you prefer your data not to be used in this manner, you can opt out of data analytics projects at any time by emailing me at [email protected].
- To carry out other business purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which I will notify you.
C. Cookies and Tracking Technologies
I and my third-party partners may use various technologies to automatically collect and store certain device and usage information (as discussed above) when you interact with a Member’s email campaign or connected store, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, I use web beacons in the emails I send on behalf of my Members. When you receive and engage with a Member’s campaign, web beacons track certain behavior such as whether the email sent through the Boldermail platform was delivered and opened and whether links within the email were clicked. Web beacons allow me to collect information such as your IP address, browser, email client type, and other similar data as further described above. I use this information to measure the performance of my Members’ email campaigns, and to provide analytics information and enhance the effectiveness of my Service, and for the other purposes described above.
D. Your Data Protection Rights
Depending on the country in which you reside, you may have the following data protection rights:
- To access; correct; update; port; delete; restrict or object to my processing of your Personal Information.
- For more information about how you can exercise these rights, please see my Data Subject Requests form. You also have the right to complain to a data protection authority about my collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
As described above, for much of the Personal Information I collect and process about Contacts through the Service, I act as a processor on behalf of my Members. In such cases, if you are a Contact and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by Boldermail as a processor on behalf of my individual Members, you should contact the relevant Member that is using the Boldermail Service, and refer to their separate privacy policies.
If you no longer want to be contacted by one of my Members through my Service, please unsubscribe directly from that Member’s newsletter or contact the Member directly to update or delete your data. If you contact me directly, I may either forward your request to the relevant Member or provide you with the identity of the Member to enable you to contact them directly.
I respond to all requests I receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. I may ask you to verify your identity in order to help me respond efficiently to your request.
Updated July 30th, 2020