MarketVolt Privacy Policy

Updated May 23, 2018

Introduction

We collect information when you:

  1. Visit one of our Websites
  2. Open an Account or create a User in MarketVolt
  3. Utilize our Services
  4. Receive an email sent by our servers on behalf of a MarketVolt Customer

This Privacy Policy explains what information we collect, how we collect it, and explains how we may use and disclose the information we collect.  Your privacy is extremely important to us. We will never sell your data, nor will we ever use your lists for any purpose except as permitted by this Policy.

For our Customers, this Privacy Policy is a part of your Terms of Service.  By using any of our Services, you indicate that you have read, understand, and agree to this Policy.

A Common Understanding

MarketVolt is a Web-based email service (the “Service” or “MarketVolt” or “Website”)  owned and operated by MarketVolt LLC (“we”, “us”, or “our”).  The Service enables individuals and organizations to:

  • Upload, store and manage recipient lists
  • Upload, store and manage images and documents
  • Create and send email campaigns to those recipients
  • Track the results of those campaigns

We will refer to anyone who utilizes our Services as a “Customer”.

A MarketVolt Account (“Account”) is required to utilize any of our Services.

A “Subscriber” or “Recipient” is any person whose personal information has been added to a Customer’s MarketVolt Account.

You” and “Your” may apply to anyone who visits any of our Websites, a Customer, or a Subscriber.

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

Changes to this Policy

MarketVolt may change this Privacy Policy at any time.  We will post the revised Policy on our website and send an email to the address specified in your Account contact information.  It is your responsibility to check this website regularly for modifications to this Policy. Unless you terminate your account within ten (10) days of the publication of changes, the new Policy will be effective immediately.  Continued use of the Service will indicate your acceptance of the new Policy. The Policy revision date is shown at the top of this document.

Scope

This policy covers data we have already collected and data we collect from our Websites and Services. It also applies to data we have collected and collect for Contract, Account creation, and Billing purposes.  The policy applies to Website visitors, Customers, and Subscribers.

Questions and Concerns

If you have questions, concerns or comments about our Privacy Policy or the data we collect, please contact us by email at privacy@marketvolt.com or the postal service:

Attn: Privacy Officer
MarketVolt LLC
PO BOX 410835
Saint Louis, MO 63141

Information We Collect

Website Visitors and MarketVolt Users

When you visit our Websites we automatically collect information about how you access the sites and information about the device you use to access the sites. We use this information to enhance and personalize your user experience, to monitor and improve our websites, and for other internal purposes.

Logs

For each page that you visit, our Websites automatically collect information (“HTTP Logs”) such as IP address, date-time stamp, resource accessed (html pages, images, documents, etc), the type of device, and browser.  We do not link the information in the HTTP Logs to any other Personal Information that we collect. We use this information to display content properly on your device/browser combination, monitor for malicious behavior, and forensic purposes.

Analytics

Our Websites may use 3rd party tracking tools like Google Analytics to track traffic patterns on our Websites. We do not track what individual users read, only how often each page is visited and what links are clicked.  We do not link any of this tracking information to any Personal Information. We use this information to monitor traffic flow and to improve the Website and business.

Cookies

A cookie is a simple text file stored on your computer when you browse a website. Cookies can be used to personalize the experience when using a website, or a website can use cookies to find out if someone has visited a website before and record information (data) about what they did.

Our Websites may use cookies, from us or from 3rd parties, for analytics, content personalization, and security.

You may configure your browser to reject cookies, but this may prevent full access to our Websites.

Client-side Scripting

Our Websites may use client-side scripting like JavaScript for analytics and content personalization.

You may configure your browser to disable client-side scripting, but this may cause problems with content display and/or prevent full access to our Websites.

Prospective Customers

We collect your contact information which may include name, phone number, postal address, email address and company.  This information will be stored in our cloud-based CRM.

Customers

Account Information

For Accounts, we collect primary contact information which will include name, phone number, postal address, company and email address. We will also collect Billing Information including billing contact name, postal address, phone number, and email address. For month-to-month customers, we will also collect payment information including credit card number.  

We require this information to manage your Account, provide access to our Services, provide customer support, and to send Service related emails from time-to-time.  You may not access our Services without providing this information and you may not opt-out of Service related emails without closing your Account.

Account primary contact and billing contact information will be stored in our cloud-based CRM.  Non-payment related Account information will also be stored in our application database.

Payment Information

Payment information is stored in, and transactions are handled by a 3rd party solution that is certified by eTrust and participates in the E.U. - U.S. and Swiss - U.S. Privacy Shield Frameworks and complies with the Privacy Shield Principles.

Marketvolt Users

To create a User in your Account, we require at least your name, email address, and phone number.

Edit and Review

Customers may view and edit most of their Account and User information while logged into our Service.  To review all of your Account information, primary contact and billing information, submit a Support Request.

When you request support from us

All support requests are managed through our CRM.  Your request will be linked to your personal information that we have on file for your MarketVolt Account.

Subscriber Information (You got an email from a Customer)

We store and manage Subscriber Information on behalf of our Customers so they can manage their email campaigns and send emails.  We are a processor of this data and have no direct relationship with our Customers’ Subscribers.

Subscriber Information may include data you provide to our Customers as their Subscriber. The only Subscriber Information we require is your email address. At their own discretion, Customers may add other information such as (but not limited to) date of birth, postal address, gender, professional association membership, political beliefs, health and religion.  This additional data is subject to our Terms of Service and our Acceptable Use Policy, but are not otherwise limited or controlled by us.

Email Tracking

On behalf of our Customers, we track which emails are sent to you, which emails you open, and the links you click.  

We use web beacons which are trackable single pixel images included in emails sent by our Customers. These beacons enable us to collect information about when you open an email, your IP address, your browser or email client type, and other similar details. We use the data collected from the web beacons to provide our Customers with reports about how their email campaign performed and what actions your Subscribers took.

We use link wrapping to track which links are clicked.  Link clicks also register as an email “open”.

Review and Edit

We acknowledge that a Subscriber has the right to access their personal information. An individual who seeks access to their data, or who seeks to correct or delete inaccurate data, should direct their query to our Customer (the data controller). If our Customer requests that we remove the data, we will respond to their request within 20 business days.

Right to be Forgotten

We also acknowledge the “Right to be Forgotten” per the European Union’s General Data Protection Regulation (GDPR). An individual who desires to “be forgotten” should direct their request to our Customer (the data controller).   If our Customer directs us to remove your data, we will respond within 20 business days.

Note: It is necessary that these requests come from our Customer to fulfill contractual obligations regarding data disclosures and also, to ensure that your data is removed from our Customer’s systems and from MarketVolt.  

Unsubscribing (Opting Out)

Every email delivered by our Service on behalf of a MarketVolt customer is required to contain an “Unsubscribe” link.  The link is usually at the bottom of the email. Click this link and follow instructions to unsubscribe or edit/review your account information.  Unsubscribing using this link is normally instant.

Data Usage and Sharing

We do not use any Subscriber Information for our own purposes and we do not sell Subscriber Information to anyone.  We will not share Subscriber Information unless legally compelled.

Data Retention

We will retain the personal data we process on behalf of our Customers for as long as needed in order to provide services to our Customers. We will retain and use this personal information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.

Do Not Track

DNT is a concept that has been promoted by regulatory agencies, for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites via browser settings. The World Wide Web Consortium (W3C) has been working with industry groups, Internet browsers, technology companies, and regulators to develop a DNT technology standard. No standard has been adopted to this date. As such, MarketVolt does not support “do not track” requests from browsers.

International Transfers of Information

We transfer, process and store your information we collect, to the United States for the purpose of providing the Services to our Customers.  Whenever we transfer your information, we take steps to protect it.

Data Storage and Security

Our Websites and Services are hosted by providers located in the United States.  All data collected and processed by our Websites and Services is stored in the United States.  Data uploaded by MarketVolt Customers is stored on servers that reside in a tightly controlled, secure data center in the United States.

We follow generally accepted standards to protect the personal information submitted to us and the data we collect, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is unconditionally secure. Therefore, we cannot guarantee absolute security of personal information and we make no representations or warranties as to the effectiveness of our security. We assume no liability for security breaches or any failure in the security of your computer equipment, your internet service provider or other networks and communications providers.

We utilize server, database, backup, and firewall technologies to protect our information infrastructure, offering reasonable protection for non-sensitive, directory information (name, email address, postal address). Our services are not designed to store, nor should they be used to store, private or uniquely identifiable personally identifiable information (PII) as outlined in our Acceptable Use Policy.

Documents uploaded to our Document Hosting system are publicly accessible.  Anyone with the link to the document will be able to view or download the document.   The Document Hosting System is not intended as secure, permanent storage. We do not make backups of this system. You should keep secure copies of all files you upload to your Account.

Website resources (HTML pages, images, etc) are encrypted during transit using Secure Socket Layer (SSL).

Emails are sent using Transport Layer Security (TLS) when supported by the receiving server.

We have internal policies in place for password security, data handling, data privacy, and data breach response.

Data Breach

Definition

Data Breach is defined as the unauthorized acquisition or access of unencrypted Confidential Information or Personal Data that compromises the confidentiality, integrity and availability of that information. A Data Breach can occur not only virtually through computer networks but also physically through unauthorized access into MarketVolt locations or computers. Data Breach also include any breaches that affect any third party vendors that provide MarketVolt with services or hosting.

Data Breach does not include unauthorized access to a Customer's Account by means of a hacked, stolen, or otherwise compromised password.

Breach Response

In the event of a Data Breach, MarketVolt will respond promptly to investigate, contain, and mitigate any security incident that can lead to a data breach.

Notice of Data Breaches will be provided to affected individuals and/or governmental agencies in accordance with applicable contractual and legal requirements.

MarketVolt will notify affected parties as soon as possible but not later than 72 hours of reasonable suspicion of a Data Breach.  Notification will occur via email sent to the email address for primary contact for the Account.

MarketVolt and Privacy Shield

MarketVolt has not yet self-certified with respect to the EU-US and Swiss-US Privacy Shield Frameworks, designed by the U.S. Department of Commerce, however MarketVolt is committed to the principles of the Privacy Shield Framework.

For any onward transfer of data to a third party processor related to providing MarketVolt Services, MarketVolt assumes potential liability for the appropriate protection of that data.

Direct any Privacy Shield inquiries or requests to:

Attn: Privacy Officer
MarketVolt LLC
PO BOX 410835
Saint Louis, MO 63141
privacy@marketvolt.com

Note: It is necessary for deletion requests to come from the data controller (our Customer) to fulfill contractual obligations regarding data disclosures and also, to ensure that your data is removed from our Customer’s systems and from MarketVolt.

MarketVolt will make reasonable effort, in concert with the MarketVolt Customer(s) involved, to address and correct the issue.

As stated elsewhere in this policy, MarketVolt is required to comply with certain requests for data made by law enforcement and other government agencies.

Right to Inspect

We reserve the right to inspect and monitor Customers’ data including Subscriber information, email content, uploaded images and documents, response data, and account activity to enforce our Terms of Service. Access to Customer data is restricted to only those MarketVolt employees who need that access to provide customer support, enforce our Terms of Service, or perform tasks critical to the stability of or improve the functionality of the Services.

Headers

The headers in this document are provided as visual aids only and are not to be considered legally binding in any way.