Thanks for using Illumineto. This policy explains the what, how, and why of the information we collect when you use our Services. It also explains the specific ways we use and disclose that information. We take your privacy extremely seriously, and we never sell lists or email addresses.
We’ll start by getting a few definitions out of the way that should help you understand this policy. When we say “we,” “us,” and “Illumineto,” we’re referring to Illumineto, Inc. a State of Delaware corporation. We provide online platforms that you may use to create, send, and manage sales campaigns (the “Services”). When we say “you” or “Subscriber,” we’re referring to the person or entity that’s registered with us to use the Services. A “Recipient” is a person you contact through our Services, including persons that you may invite to a team or refer to become a Subscriber. A “Contact List” or “Distribution List” is a list of email addresses that one of our Subscribers has sent, or intends to send, emails to, and all information relating to those email addresses. We may combine information about you or your Recipients with information provided by other Subscribers or third parties to create “Aggregate Information,” which may include, but isn’t limited to, names, email addresses, demographic information, IP addresses and location.
We offer the Services on our websites www.Illumineto.com. While providing the Services, we may collect personal information, which means information about a Subscriber or Recipient.
If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter please use our contact form to get in touch. You may also contact us by postal mail or email at:
Attn. Privacy Officer
5257 Buckeystown Pike #145
Frederick MD 21704
2. List and Email Information: When you add a Recipient to a Spark Page or create an email with the Services, we have and may access the data on your list and the information in your email.
3. Information from your Use of the Service: We may get information about how and when you use the Services, store it in log files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you’ve taken within the application.
4. Cookies and Tracking: When you use Illumineto Services, we may store “cookies,” “tags,” or “scripts,” which are strings of code, on your computer. We and our analytics Service Providers (like Google) use those cookies to collect information about your visit and your use of our website or Services. You may turn off cookies that have been placed on your computer by following the instructions on your browser, but if you block cookies, it may be more difficult (and maybe even impossible) to use some aspects of the Services.
5. Web Beacons: When we send emails to Subscribers and Recipients, we may track behavior such as who opened the emails and who clicked the links. We do that to measure the performance of email campaigns and to improve our features for specific segments of Subscribers. To do this, we include single pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details. We also include Web Beacons in the emails we deliver for you. We use the data from those Web Beacons to create the reports about how your email campaign performed and what actions your Recipients took. Reports are also available to us when we send email to you, so we may collect and review that information.
6. Information from Other Sources: We may get more information about you or your Recipients, like name, age, and use of social media websites, by searching the internet or querying third parties (we’ll refer to that information as supplemental information). We use supplemental information in our recommendation engine which will assist you in providing more relevant content to your Recipients.
7. Information from the use of our Mobile Apps: When you use our mobile apps, we may collect information about the type of device and operating system you use. We may ask you if you want to receive push notifications about activity in your account. If you opt in to these notifications and no longer want to receive them, you may turn them off through your operating system. We don’t access or track any location-based information from your mobile device unless you’ve given us permission. We may use mobile analytics software (such as intercom.io) to help us better understand how people use our application. We may collect information about how often you use the application and other performance data.
We may use and disclose your Personal Information only as follows:
1. To promote use of our Services. For example, if you leave your Personal Information when you visit our website and don’t sign up for any of the Services, we may send you an email asking if you want to sign up. And if you use any of our Services and we think you might benefit from using another Service we offer, we may send you an email about it. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send.
2. To send you informational and promotional content that you may choose (or “opt in”) to receive. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email.
3. To bill and collect money owed to us. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments. To learn more about the steps we take to safeguard that data, see Section 12 below.
5. To communicate with you about your account and provide customer support.
7. To protect the rights and safety of our Members and third parties, as well as our own.
8. To meet legal requirements like complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
9. To provide information to representatives and advisors, like attorneys and accountants, to help us comply with legal, accounting, or security requirements.
10. To prosecute and defend a court, arbitration, or similar legal proceeding.
11. To provide, support, and improve the Services we offer. This includes aggregating information from your use of the Services and sharing such Aggregated Information with third parties.
12. To provide suggestions to you. This includes adding features that compare Members’ email campaigns, or using data to suggest other publishers your Subscribers may be interested in.
As you use our Services, you may import into our system personal information you’ve collected from your Subscribers. We have no direct relationship with your Recipients, and you’re responsible for making sure you have the appropriate permission for us to collect and process information about those individuals. We may transfer personal information to companies that help us provide our Services (“Service Providers.”) All Service Providers enter into a contract with us that protects personal data and restricts their use of any personal data in line with this policy. As part of our Services, we may use and incorporate into features information you’ve provided or we’ve collected about Subscribers as Aggregate Information. We may share this Aggregate Information, including Subscriber email addresses, with third parties in line with the approved uses in Section 6.
We’ll retain personal data we process on behalf of our Subscribers for as long as needed to provide services to our Subscribers or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
1. Blog. We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us here. If we’re unable to remove your information, we’ll let you know why.
2. Social Media Platforms and Widgets. Our websites include social media features, like the Facebook Like button. These features may collect information about your IP address and which page you’re visiting on our site, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. We also maintain presences on social media platforms like Facebook, Twitter, and LinkedIn. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
4. Service Providers. If it’s necessary to provide you something you’ve requested, like send you a T-shirt or enable a feature, then we may share your personal information to a Service Provider for that purpose. We’ll tell you we’re working with a Service Provider whenever reasonably possible, and you may request at any time the name of our Service Providers.
We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our websites or through social media (collectively “Our Promotions”). Participation in our Promotions is completely voluntary. Information requested for entry may include personal contact information like your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer Our Promotions. We also may, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or Service Providers in line with this policy and the rules posted for the Promotion.
When you send an email sales campaign, it bounces around from server to server as it crosses the Internet. Along the way, server administrators can read what you send. Email wasn’t built for confidential information. If you have something confidential to send, please don’t use Illumineto.
Sometimes we review the content of our Subscriber’s campaigns to make sure they comply with our Acceptable Use policy. To improve that process, we have software that helps us find campaigns that may violate our policy. Our employees or independent contractors may review those particular campaigns. This benefits all Subscribers who comply with our Acceptable Use policy because, among other things, it reduces the amount of spam being sent through our servers and helps to maintain high deliverability.
Your contacts are stored on a secure Illumineto server. We don’t, under any circumstances, sell your Contact Lists. If someone on your Contact List complains or contacts us, we might then contact that person. Only authorized employees have access to view Contact Lists.
We’ll use and disclose the information in your Contacts Lists only for the reasons listed under Use of Your Personal Information.
We may derive Aggregate Information from your contacts and will use that information as described in Section 7. If we detect abusive or illegal behavior related to your Contact Lists, we may share your Contact List or portions of it with affected ISPs or anti-spam organizations.
Nobody is safe from hackers. If a security breach causes an unauthorized intrusion into our system that materially affects you or people on your Distribution Lists, then Illumineto will notify you as soon as possible and later report the action we took in response.
If you integrate with a service we will connect that service to ours.
Our credit card processing vendor uses security measures to protect your information both during the transaction and after it’s complete. Our vendor is certified as compliant with card association security initiatives, like the Visa Cardholder Information Security and Compliance (CISP), MasterCard® (SDP), and Discovery Information Security and Compliance (DISC). We also perform annual SOC II audits. If you have any questions about the security of your personal information, you may contact us at privacy@Illumineto.com.
Illumineto accounts may require a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. Because the information in your Contact Lists is so sensitive, account passwords are encrypted, which means we can’t see your passwords. We can’t resend forgotten passwords either. We’ll only reset them.
Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering a data processing agreement. By using our Websites, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this policy.
We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do that. If your data changes (like a new email address), then you’re responsible for notifying us of those changes.
We’ll retain your information for as long as your account is active or as long as needed to provide you services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Agreements.
Within 30 days of a request, we will provide a Subscriber or Recipient with disclosure of any Personal Information we hold about them. Individuals may request this information from us by contacting us at email@example.com. Unless it’s prohibited by law, we’ll remove any Personal Information about an individual, be it you or a Subscriber, from our servers at their request. There is no charge for an individual to access or update his or her personal information.
If we receive a written complaint, we’ll respond to the person who made it. You may contact our Privacy Officer at privacy@Illumineto.com or by postal mail at our address listed above.
Updated April 9, 2016