Effective Date: May 16, 2017
I. Introduction & Notice
- “Personal Data” and “Personal Information” means any information relating to an individual that can be used to identify that individual either on its own or in combination with other readily available data.
II. Collection of Personal Information
SetCampaign Site collect different personal information based upon how you use them.
a. Personal Information
There are areas on the Sites where you can share information that is unique to an individual; such as your name, company name, postal addresses, e-mail addresses, phone number(s), zip code(s), and billing and payment information such as credit card information (“Personal Information”). All of the foregoing is treated as Personal Information, as described in this policy.
b. Types of Personal Information Collected
SetCampaign publishes several digital properties supporting its products and services. Depending on which Sites you visit, Personal Information collected may be different.
c. Information from Children
SetCampaign Sites and its related services are directed at adults and businesses. We do not knowingly collect or use information provided from children under the age of 16. If we become aware of any collection of personal information from children, we will delete it immediately.
As is true of most websites, 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 may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer you, and to improve marketing, analytics, and/or site functionality.
The Sites use analytical data provided by Google Analytics. You can find out more about the types of analytical data and how that data is processed by visiting https://www.google.com/policies/privacy/partners/
III. Purpose & Use of Collected Personal Information
We act as a service provider or data processor to enable delivery of your requested services. We only collect, receive and use personal information to process these services. Our contractual agreements specify the type of personal information collected based on the subscription level and type of web services implemented by the wholesale customer.
Notice of purpose and usage of data is the accountability of each Partner of our customers in its relationships with its end-users, including applicable sharing with third party service providers. We collect this personal information under the direction of our customers, and have no direct relationship with the individuals whose personal information we process.
We only collect and use personal information provided to us for the following purposes:
- To establish and maintain a responsible commercial relationship to provide ongoing service. For example, with purchased services, we process information that allows us to provide support services so that we can accurately fulfill the delivery of the services
- We may process your credit card information
- For authentication purposes to access the products and services
We only collect or process personal information when you specifically and knowingly provide it on our retail websites or to our customer service representatives via telephone, or in delivery of services requested by your communication service provider. For the purposes of fraud prevention, we may exchange information internally and among our affiliates.
IV. Information Retention & Accuracy
We take reasonable steps to ensure that personal information we receive, process, or maintain is accurate, complete, and reliable for its intended use. We rely on the accuracy of the information provided directly to us but accept responsibility for the management and confidentiality of the personal information collected.
In general, we keep personal information only as long as we need it to provide you the services you requested. We may also process data on behalf of third parties who have engaged us. We keep personal information processed on behalf of third parties for as long as needed to provide services to third party in question. However, we reserve the right to retain personal information for any period required by law or to comply with our legal obligations, resolve disputes, and enforce our agreements. We maintain procedures for the secure disposal or destruction of personal information.
V. Sharing of Personal Information &Accountability for Onward Transfer
There are a variety of circumstances where we may need to disclose personal information to:
- A person who, in the reasonable judgment of SetCampaign is seeking the information as your agent. For example, we may provide information about your account to your legal representative if we are satisfied that that individual is requesting the information on your behalf;
- Our parent company or affiliates to help us serve you better and provide you with requested services;
- A company or individual employed by us to perform functions on our behalf, such as support services, information technology development and support, customer service or data processing, and are authorized to use your Personal Information only as necessary to provide these services to us; and,
- A public authority, agent of a public authority or law enforcement agency if required by law.
We will share randomized, aggregated demographic information about our users with third parties. This information is not linked to any personal information and cannot identify any individual person.
SetCampaign may also disclose your Personal Information to any other third party with your prior consent.
Additionally, SetCampaign may share your Personal Information, without your prior consent, for the limited purposes noted below:
a. Subprocessors/Third Party Service Providers
To provide and market our services, SetCampaign uses subprocessors to perform functions such as:
- Data Storage
- Marketing & Analytics
- Credit and payment Card Transactions
We only share Personal Information with third party service providers to the extent necessary to provide the requested services.
You have the choice to limit the use and disclosure of your personal data. If you choose to limit the data to be used, simply do not disclose that information to SetCampaign or use the Sites. In certain cases, limiting the use and disclosure of your personal data may impact functionality or prevent the use of SetCampaign’s products or services.
When SetCampaign does share your Personal Information with third party service providers and/or subprocessors, SetCampaign will:
- transfer such data only for limited and specified purposes;
- ascertain that the subprocessor is obligated to provide at least the same level of privacy protection as is required by these Principles;
- take reasonable and appropriate steps to ensure that the subprocessor effectively processes the Personal Information transferred in a manner consistent with the organization’s obligations under these Principles;
- require the subprocessor to notify SetCampaign if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by these Principles;
- upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and
- provide a summary or a representative copy of the relevant privacy provisions of its contract with that subprocessor to the Department of Commerce upon request.
SetCampaign shall remain liable under the Principle of Accountability for Onward Transfer if its subprocessors process your Personal Information in a manner that is inconsistent, unless SetCampaign proves that it is not responsible for the event giving rise to the damage.
b. Legal Obligations
We cooperate with government or law enforcement officials and private parties to enforce and comply with laws applicable to our services. We will disclose information about you to government or law enforcement officials or private parties, as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process, to protect our property, and the property and rights of a third party, to protect national security, the safety of the public or any person, or to prevent or stop activity we consider illegal or unethical. We will also share your information to the extent necessary to comply with rules, regulations, and policies regarding your domain services.
If you are visiting this website from a country other than the country in which our servers are located, your communications with us will result in the transfer of information across international boundaries. By visiting this website and communicating electronically with us, you consent to such cross-border transfers.
VI. Protection of Personal Information
In order to protect your Personal Information and your right to privacy, SetCampaign:
- Takes steps to protect information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction
- Maintains physical, electronic, and management procedures to safeguard information based on its sensitivity
- Uses Secure Socket Layer (SSL) technology to protect sensitive data
- Uses servers that are protected by firewalls, which are frequently updated to enhance security
- Protects the confidentiality of personal information when dealing with third parties
- Strives to keep personal information as accurate and up-to-date as is necessary for the purposes identified above
We cannot guarantee the security of information on or transmitted via the Internet. We rely on various security procedures and systems to ensure the secure storage and transmission of data, including encryption and authentication technology licensed from third parties, to effect secure transmission of confidential information.
VII. Limits to Your Privacy
VIII. Choice Regarding Collection, Use & Distribution of Personal Information
You can choose to opt-out whether your Personal Information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. In such an event, you will be only able to access public areas of the Sites. If you do not wish to receive promotional material from us, you may choose to "opt-out" each time we ask you for Personal Information. In certain cases, limiting the use and disclosure of your personal data may impact functionality or prevent the use of SetCampaign products or services.
IX. Access & Correction
We maintain processes or mechanisms to allow you to review, update, correct or delete personal information held by us. Based on the level of services provided by us to your communication service provider, you may make changes to your account information directly, or by working with our Partner Support team. Your communication service provider may notify us to correct, amend or delete inaccurate information, based on your request to them.
Please contact our Information Administrator at firstname.lastname@example.org to:
- Change or confirm your personal information, or
- Have your information removed from our databases
We will respond to your request for access to modify or delete your information within a reasonable timeframe. We may need to contact your communication service provider to validate and coordinate your request.
X. Contacting SetCampaign, Dispute Resolution, Arbitration & Cost