CertainSource, an ewayDirect company places the highest level of importance on respecting the privacy of our clients and their customers. Each of our employees is dedicated to maintaining the security of client data. This privacy statement describes how your personal information is collected and used and applies to the CertainSource website, products and services.
Security & Privacy
Only employees, in the course of their day-to-day operations, may have access to this private information. Any employee who violates our privacy and/or security policies is subject to disciplinary action, including possible termination and civil and/or criminal prosecution.
Be aware that we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our Website.
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 third parties as part of legal process.
Information Collection and Use on our Website
CertainSource is the sole owner of the information collected at our site. We do not sell, share, or rent information to third parties. The information is used to determine the most appropriate information to send to those who request it.
The website provides users with registration forms offering the opportunity to request information, demonstrations and to join our mailing list. These forms require users to provide contact information.
We collect visitor IP addresses in log files to monitor our site. IP addresses are anonymous and are not linked to personal information.
We may share aggregated data with clients or partners. This does not include information that can identify any individual person. Nor does it disclose confidential or proprietary client information.
Cookies and Web Beacons
The CertainSource website and emails may also use web beacons. Web beacons are tiny graphic images on web pages or in emails that notify the server anonymously when that page has been visited or the email has been opened. Web beacons are used together with Cookies to let us know which pages are of interest to visitors. If Cookies are disabled, web beacons continue to send anonymous notice of a visit but cannot associate that with other information.
Opt-Out and Update
All non-transactional email sent by CertainSource, either for its own business or on behalf of its clients will contain clear and concise instructions (such as clicking on the link at the bottom of an email) for how to opt-out of receiving future communications. People clicking on this link will be opted-out of future mailings.
Any visitor to the CertainSource web site has the ability to maintain anonymity and privacy by choosing to disable Cookies in their web browser.
In addition, upon request, and after receiving proof of identity, we provide people with access to any and all information that we maintain about them individually. People then have the ability to request that we correct or remove their contact information and we will do so. All requests will be honored within 30 days of the user notification and proof of identity.
Hosting and Processing Client Data
CertainSource delivers permission-based electronic marketing campaigns on behalf of our clients. Campaigns are sent only to people who have agreed to receive these emails. In doing so:
CertainSource stores information in the form of database lists provided to it by its clients and processes that information under the direction of its clients. These lists may contain email addresses, street addresses, contact information and other information. Confidentiality of the client list is a top priority and they are never shared with other clients or third parties.
CertainSource acts as a data processor when hosting client data and sending emails on behalf of our clients. CertainSource has no direct relationship with the individuals whose personal data it processes and therefore, any individual who seeks access to, or who seeks to correct, modify, or delete inaccurate data should direct his query to the data controller, which is the CertainSource client. If the client requests CertainSource to remove the data, we will respond to their request within 30 days.
We track a recipient's ability to support HTML email, as well as whether an HTML email message has been opened or previewed. This capability is used to deliver relevant content to the recipient.
We collect information regarding the activity of email recipients, which is only reported to the client who owns the list.
If CertainSource determines a client has knowingly used our system for sending unsolicited email, we may revoke the right of this client to use our system.
CertainSource does not sell, share, or rent the mailing lists of our clients. Content Guidelines
The following content shall not be included in emails:
- Content endorsing or enticing any illegal activity or violence
- Content which is pornographic or involves the sale of "adult services", including, without limitation, massage parlors or escort services
- Content relating to the illegal sale or use of firearms
- Content which gratuitously or excessively uses the word "sex" or other sexually explicit or vulgar term or description
- Content which gratuitously or excessively uses violence
- Content which promotes any form of online gambling
- Content which may be deemed offensive to minors
CertainSource retains the right, at its reasonable sole discretion, to disallow any piece of content from being used in Client messages. All content used in Client messages shall be owned or licensed by Client and Client represents that use of such content shall not constitute copyright infringement or any other violation of a third party's proprietary rights.
The CertainSource website, or messages created with CertainSource, may contain links to other sites. CertainSource is not responsible for the privacy practices or the content of such other websites. In order to understand the practices of these linked sites, please read their privacy policies as they may differ from ours.
CertainSource is a member of several associations focused around building and maintaining the integrity of legitimate direct marketers and their email marketing initiatives. These organizations include:
- Email Service Providers Coalition (ESPC)
- The Direct Marketing Association (DMA)
- Online Trust Alliance (OTA)
Compliance and Safe Harbor
CertainSource complies with the U.S.-EU 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. CertainSource 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 CertainSource's certification, please visit http://www.export.gov/safeharbor/.
CertainSource and their clients agree to conduct their respective businesses in compliance with CAN-SPAM and other applicable federal, state, provincial and local laws, rules and regulations, including without limitation all laws, rules and regulations regarding list acquisition, email deployment, and advertising.
338 Commerce Drive, Second Floor
Fairfield, CT 06825