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PrivacyPolicy

PowerInbox Privacy Policy

We (PowerInbox Inc. and/or PowerInbox Ltd. (collectively, “POWERINBOX”)) know that you care about how your information is used and shared, and we take your privacy seriously.

This POWERINBOX Privacy Policy covers our treatment of Personal Information (i.e., information which can be used to identify you), as well as other information we gather when you access any of our websites, including, but not limited to  https://powerinbox.com/, http://rs-stripe.com/, and https://www.chameleos.com/ (collectively, the “Site”) or interact with our services, including AdServer for Email, RevenueStripe, InboxEngage, InboxChoice, and Advertiser Network (collectively, the Site and these services are the “Services”). We outline below the information collected by POWERINBOX through its Services, the purpose for collecting such information, who we share the information with, and choices that you may have with regard to your Personal Information.

The ways we use and share your information, including Personal Information, may vary depending on whether you are (i) a visitor to our Site (“Site Visitor”); (ii) a POWERINBOX customer (i.e., publisher, advertiser, or other content provider) (“Customer”); or (iii) recipients of emails from Customers (“Consumers”). We have therefore distinguished the information that relates to each of these types of individuals into three different sections below. Information that is relevant to all of these three categories is set forth in Section 1 of this Privacy Policy. Depending on how you interact with our Services, you may be part of more than one category (e.g., if you are a Customer who has also visited our Site, then Sections 1, 2, and 3 will apply to you).

For purposes of this Privacy Policy, we define “Personal Information” as personally identifiable information about an individual, such as a name and email address.

By visiting our Site, or by interacting with any of our Services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy.

  1. GENERAL INFORMATION APPLICABLE TO SITE VISITORS, CUSTOMERS, AND CONSUMERS

As described in Sections 2-4 below, the information that we collect about you depends on whether you are a Site Visitor, Customer, or Consumer. We may also use or share your information in different ways. Regardless of whether you are a Site Visitor, Customer, or Consumer, however, we will use and share your information as follows:

  • HOW WE USE YOUR INFORMATION
    • Provide Our Services. We may use your information to provide and improve our Services and to develop new Services. For instance, if you are a Consumer we might process information about your broad geographic location in order to provide you with localized email content on behalf of our Customers, who incorporate our Services into their emails.  We might also track your interaction with an advertisement that we serve on behalf of one of our Customers in an email.
    • Data Analytics. We may use your information to analyze use of our Services and understand how individuals engage with our Services. We do so at an aggregate level, in order to analyze general trends.
    • We may use your information to respond to your inquiries, fulfill your requests, complete your transactions, and for other service or support purposes.
    • Protection of POWERINBOX and Others. We may use your information to detect, prevent, investigate, and respond to potential fraud, security issues, or other threats to POWERINBOX or others.
    • Legal Compliance. We may use your information in order to comply with the law, regulation, subpoena, court order, or other legal process, or as part of an investigation or request from law enforcement or a government official.

In relation to Consumers, we convert email addresses into a random unique ID number, which we use in order to provide our Services to Customers over time (e.g., serving advertisements). Except for a limited period of time in server logs, we endeavor not to retain Consumer email addresses.

  • HOW WE SHARE YOUR INFORMATION
    • Service Providers.We may share your information with our vendors, service providers, agents, or others who perform functions on our behalf.
    • We may share your information with any current or future affiliates, parent companies, or subsidiaries.
    • We may share your information to comply with the law, regulation, subpoena, court order, or other legal process, or as part of an investigation or request from law enforcement or a government official or regulatory body.
    • Business Transfers. We may share your information with another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.
    • Protection of POWERINBOX and Others. We may share your information to detect, prevent, or otherwise address fraud, security, or technical issues; to enforce the provisions of this Privacy Policy and/or any other agreements between you and POWERINBOX, including investigation of potential violations thereof; or to protect against harm to the rights, property, or safety of POWERINBOX, its visitors, users, and/or the public.
    • Aggregate or De-identified Data. We may share aggregate or de-identified data for marketing, advertising, research, compliance, or other purposes, mainly with respect to ad performance metrics and analytics.
  • THIRD-PARTY LINKS

Our Services may contain links to third-party websites and applications provided by third parties. Any access to and use of such linked websites, applications, or third-party services is not governed by this Privacy Policy but instead is governed by the privacy statements of those third parties. We are not responsible for the information practices of such third parties, and we encourage you to read their privacy statements.

  • SECURITY

We endeavor to take security measures to guard against unauthorized access to the systems where we store your information. This includes internal reviews of our data collection, storage, and processing practices and security measures and physical security measures. However, despite the measures we take, we cannot warrant the security of any information provided to us. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of your information at any time.

  • DATA RETENTION

We will retain your information for as long as needed or permitted in light of the purpose(s) for which it was obtained and as outlined in this Privacy Policy.  When determining how long to retain your data, we consider: (i) the length of time we have an ongoing relationship with you as a Customer or, if you are a Consumer, what is reasonable and legitimate in the context of providing our Services (noting that we may retain de-identified information about your behavior in response to advertisements across successive Customer campaigns); (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our interests (e.g., to enforce any agreements between you and POWERINBOX or in light of regulator recommendations or industry best practices).

  • YOUR CHOICES

If you are a Site Visitor or Customer, you may verify, correct, or update the Personal Information we have about you by updating the Personal Information in your account (if you have one) or by emailing us at support@powerinbox.com. We may send periodic promotional or informational emails to Site Visitors and Customers, who may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. Site Visitors and Customers who opt out of receiving emails about recommendations or other information we think may interest them may still receive emails about their account or any Services they have requested or received from us.

If you are a Consumer, you should contact the Customer with whom you interact (i.e., the organization sending you emails that incorporate our technologies) in order to exercise any rights you might have to stop receiving those emails.

Users in certain countries have a right to communicate with their local supervisory authority / data protection regulator about our use of Personal Information.

  • CHILDREN

Our Services are not directed to individuals under the age of 13, and we do not knowingly collect any Personal Information from individuals under the age of 13. If you are the parent or guardian of an individual under the age of 13 and have a concern regarding the information we collect, please contact us at support@powerinbox.com.

  • POLICY CHANGES

This Privacy Policy is current as of the date set forth below. We may make changes to this Privacy Policy from time to time, so please be sure to check our Site back periodically. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our Site or sending you an email.

  • CONTACT US

If you have feedback, questions, or concerns contact us at:

PowerInbox Inc.

311 W. 43rd Street, 12th Floor

New York, New York, 10036

(888)-824-8494

support@powerinbox.com

  1. INFORMATION APPLICABLE TO SITE VISITORS
    • SITE VISITOR INFORMATIONWE COLLECT
      • Information You Provide. We collect any information that you enter on our Site, such as your name, user name, or email address.
      • When you visit our Site we will send your browser a cookie which is stored in your browser and allows us to uniquely identify it. The cookie may assist us in storing user preferences and product utilization information such as number of visitors, average time spent on pages, features used, and other information that helps us determine which features are most important to you and working effectively.
      • When you visit our Site, we capture and store the data that your browser sends us. This data may include your browser type, language, Internet Protocol address, the date and time of your request and the cookie that helps us identify your unique browser.
      • Usage Information. Generally, our Site automatically collects usage information, such as the numbers and frequency of visitors to our Site. We only use this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. This type of aggregate data enables us to figure out how often customers use parts of our Site or products so that we can improve our Services, products, and
      • Do Not Track Disclosure. Our Site does not respond to Do Not Track signals. You can learn more about Do Not Track signals at http://www.allaboutdnt.com/. You may, however, disable certain tracking by disabling cookies.
  • HOW WE USE SITE VISITOR INFORMATION

In addition to the purposes described above in Section 1.1, we may use your information:

  • To tailor the content and information that we display to you on our Site, and to otherwise personalize your experiences while using our Site; and
  • To provide you with newsletters, special offers, and promotions, including via email; to contact you about products or services we think may interest you; and for other marketing, advertising, and promotional purposes.
  • HOW WE SHARE SITE VISITOR INFORMATION

We share Site Visitor information as described above in Section 1.2.

  1. INFORMATION APPLICABLE TO CUSTOMERS
    • CUSTOMER INFORMATIONWE COLLECT
      • Information You Provide. We collect any information that you provide to us, such as your name, user name, password, and contact information.
      • Information We Collect Automatically. We collect high-level metrics about the emails a Customer sends, including frequency of sends and volume.
  • HOW WE USE CUSTOMER INFORMATION

In addition to the purposes described above in Section 1.1, we may use your information:

  • To provide you with newsletters, special offers, and promotions, including via email; to contact you about products or services we think may interest you; and for other marketing, advertising, and promotional purposes.
  • HOW WE SHARE CUSTOMER INFORMATION

We share Customer information as described above in Section 1.2 and as follows:

  • Consumers. We may share Customer information with Consumers as part of providing our Services. For example, if you include your contact information in an email that is sent to Consumers through our Services, then that contact information will be shared with Consumers.
  1. INFORMATION APPLICABLE TO CONSUMERS
    • CONSUMER INFORMATION WE COLLECT
      • Information You Provide. Unless you visit our Site or are a Customer, if you are a Consumer we do not collect any Personal Information from you directly. We do, however, collect information about you from Customers, such as your email address, in order to provide our Services. In the EU, we do not retain your name or email address (to the extent that we receive it from a Customer), and your email address is converted to a random unique internal ID number created by multiple levels of hashing so it cannot be identified.
      • Information We Collect Automatically. We automatically collect certain information about your activity through your interactions with messages sent using our Services, including when you open a message, when you click on an advertisement. We also collect and process your IP address.
  • HOW WE USE CONSUMER INFORMATION

In addition to the purposes described above in Section 1.1, we may use your information:

  • To tailor the content and information that we may send or display to you through our Services, and to otherwise personalize messages you receive through our Services.
  • To provide aggregated information to our Customers about how Consumers engage with their communications or advertisements.
  • HOW WE SHARE CONSUMER INFORMATION

We share Consumer information as described above in Section 1.2 and as follows:

  • POWERINBOX Customers.We share Consumer information with Customers. For example, we provide publishers with information about how Consumers view and click through to content and aggregate information numbers (e.g., traffic, revenue, etc.).
Version Date of this Privacy Policy: May 23, 2018
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