Effective Date: May 2013
ExactTarget is committed to protecting the privacy of our website visitors and clients. We strive to uphold the highest industry standards in online privacy and permission marketing. For more information on how ExactTarget enforces permission email marketing with our clients, please see our anti-spam policy.
Information We Collect
Information You Provide
You may be asked to provide information to us through one or more services we provide through our website, messages we send to you, social media, etc. The information we request may include personal information, such as name, age, email address, address, and telephone number.
Information Obtained Through Use of Our Services
We may collect information provided by you and your computer through use of our services through this website, messages to you, social media, etc. This information may include the following types of information:
Login Information. We may automatically obtain and store HTTP header information from client-side tracking objects, your device, and our server logs upon your use of our services.
Mobile Information. We may obtain information specific to mobile activity through use of our services, such as your location, mobile device type, and mobile capabilities.
Social Media Information. When interacting with our services within social media, we may obtain information stored within social media or authorized by you to be collected by us within such social media. This information may include your contact information, email address, friend information, friends and pages with whom you have an association, and other information stored within social media.
Client-Side Tracking Objects
Some areas of ExactTarget's website allow you to provide content to us directly through comments left on a “public forum” (ex. the ExactTarget blog). If you use public forums on the ExactTarget website, you expressly agree that any personal information you submit in these public forums can be read, collected, or otherwise used by anyone who reads the public forums. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
How We Use Collected Information
At times, we will use your HTTP header information to help diagnose problems with our server and to administer our website. We may also track browser types to help us understand our visitors' needs related to our website design. There is an optional section of our website where input forms require your name, phone number, company, and email address. This form provides the ability to opt in to receive future emails of any type from ExactTarget. If you opt in to receive email communications from us, we may send information to you on our products or services. This information will not be used for any other purpose. We do, however, reserve the right to disclose your personal information as required by law when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our website. You may review and change your information with us at any time by clicking on the "modify profile" link on the site (or similar), found at the bottom of emails sent via our system or by contacting us at email@example.com. To opt out from having any provided information used for email communications from us, please click on the opt-out (unsubscribe) link in any message you receive from us. This will allow you to unsubscribe or update your message preferences. Alternately, you may contact us at firstname.lastname@example.org.
Combination of Information
We may combine information collected through your use of our website and services with information that we collect from other sources, including third parties (see below).
How We Share Information
We may disclose your information to third parties in the following situations or for the following purposes:
Consent. We may disclose your information to third parties for purposes not directly related to our site in the event that you consent to such disclosure.
Service Providers and External Processing. Your information may be shared with third party service providers, affiliates, or other trusted businesses to provide certain customer services based on our instructions. We require that our third party service providers implement and maintain security measures to protect the confidentiality and security of the information you provide to us. (ex. Third party service provider for our online Live Chat service)
Law Enforcement. Your information may be shared with law enforcement officials if it relates to a criminal investigation or alleged illegal activity.
Necessary or for Safety Reasons. We may also disclose your information if required or permitted to do so by law for fraud protection and credit risk reduction purposes; protection and defense of the rights or property of ExactTarget, its customers, or other users; to act under urgent circumstances to protect the safety of ExactTarget,its employees, or a member of the public; or to comply with a judicial proceeding, court order, or legal process.
Sale or Acquisition of Assets. If ExactTarget becomes involved in a transaction involving the sale of its assets, such as a merger or acquisition, or if ExactTarget is transferred to another company, we may disclose and/or transfer your information as part of the transaction.
Security and Privacy
ExactTarget's website uses security measures to protect against the loss, misuse, and alteration of the information under our control. We store the information in a database in a secured environment at our data centers. We do not share, sell, or rent individual personal information with anyone without your advance permission or unless ordered by a court of law. Information submitted to us is only available to employees managing this information for purposes of contacting you or sending emails you agree to receive.
You will be added to ExactTarget's email newsletter list only if you register to receive newsletters via a form or checkbox on the ExactTarget website. You may opt out of receiving our eNewsletters by clicking on the opt-out link included in every email newsletter we send or by contacting email@example.com and requesting that we stop sending the eNewsletter.
If you feel that information about ExactTarget could be useful for a third party you know (e.g. your friends or family members etc.), you may use our forward-to-a-friend functionality. We will automatically send your friend a one-time email inviting him or her to visit the site. ExactTarget stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Your friend may contact us at firstname.lastname@example.org to request that we remove this information from our database.
We post video customer testimonials on our website which may contain personal information such as your name. We obtain your consent prior to posting the testimonial with your name. If you wish to update or delete your testimonial, you can contact us at email@example.com.
Links to other Websites
ExactTarget's website may contain links to websites not affiliated with us. Your use of an external website or any informational content found on an external website is subject to and governed by the terms and conditions of such website. ExactTarget does not endorse or make any representations or warranties concerning, and will not in any way be liable for any informational content, products, services, software, or other materials available on an external website, even if one or more pages of the external website are framed within a page of ExactTarget's website. ExactTarget is not responsible for the privacy practices of any external websites.
Widgets and Social Buttons
We encourage parents and guardians to be aware of and participate in their children's online activities. We adhere to the Children's Online Privacy Protection Act and do not knowingly collect, use, or disclosed personally-identifiable information from any child under the age of 13 in a manner that violates this law. If we discover that we have inadvertently collected such personally-identifiable information from a child under 13 years of age, we will promptly take reasonable measures to delete such information from our systems.
Notification of Changes
Safe Harbor Data Privacy Notice – Applicable to Persons Protected Under the Directive 95/46/EC (the EU Data Protection Directive of 1995).
ExactTarget complies with the US/EU Safe Harbor Framework and the US/Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data from the European Union member countries and Switzerland. ExactTarget 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 ExactTarget’s certification, please visit www.export.gov/safeharbor.
ExactTarget will respond to your request to access or delete personal information within 30 days, as is required under the EU Safe Harbor program. This notice outlines our general policy and practices for implementing Safe Harbor principles, including the type of information to which this notice applies, how we use personal information, and the choices individuals have regarding our use of and their ability to correct that personal information. If there is any conflict between the policies in this notice and the Safe Harbor principles, the Safe Harbor principles will govern. This notice applies to all personal information we handle, including online (except as noted below) and manually-processed data. For purposes of this notice, "personal information" means data that: is transferred from the European Union to the United States; is recorded in any form; and is about, or pertains to, a living individual who is identified in, or is identifiable from, the data. "Sensitive information" is a subcategory of personal information. Sensitive information is defined as personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or the sex life of the individual. Sensitive information also includes personal information received from a third party where the third party treats and identifies it as sensitive.
Safe Harbor Principles Regarding Personal Information Notice and Choice
We notify individuals about the personal information we collect from them, how we use it, and how to contact us with privacy concerns. We obtain personal information only as permitted by the Safe Harbor principles or with the consent of the individual affected. Consent for personal information to be collected, used, and/or disclosed in certain ways may be required in order for an individual to obtain or use our services. To the extent permitted under the Safe Harbor, we reserve the right to process personal information in the course of providing professional services to our clients without the knowledge of individuals involved.
Disclosures and Transfers
We do not disclose personal information to third parties, except when one or more of the following conditions is true: we have the individual's permission to make the disclosure; the disclosure is permitted by law or mandatory under professional standards; the disclosure is reasonably related to the sale or other disposition of all or part of our business or assets; the personal information to be disclosed is publicly available; the party to whom the disclosure is made controls, is controlled by, or is under common control with ExactTarget; the disclosure is reasonably necessary for the establishment or maintenance of legal claims; or the disclosure is to persons or entities for whom we are providing services, provided the disclosure is consistent with the purpose for which the personal information was obtained. We will comply with the Safe Harbor principles with respect to disclosures of sensitive information, including, when applicable, obtaining the explicit consent of the individual prior to disclosing sensitive information to a third party or using sensitive information for purposes other than those for which it was originally collected or subsequently authorized by the individual.
Data Security, Integrity, and Access
We employ technical and organizational measures, including education and training of our personnel, designed to provide the personal information in our possession with reasonable protection from accidental loss or destruction, improper use, alteration, or disclosure. Personal information collected or displayed through a website is protected in transit by industry standard encryption processes. However, we cannot guarantee the security of personal information accessible on or transmitted via the internet. We process personal information in ways compatible with the purpose for which the personal information was collected or as otherwise authorized by the individual. To the extent necessary for such purposes, we take reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use. If an individual becomes aware that personal information we maintain about that individual is inaccurate, or if an individual would like to update or review his or her personal information, the individual may contact us using the contact information below. As a security precaution, we may request that the individual provide identifying information such as name, address, birth date, and/or social security number. In addition, we may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor agreement. In some circumstances, we may charge a reasonable fee, where warranted, for access to personal information.
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, refer to our contact information below. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Accountability and Enforcement
We have established a program to monitor our adherence to the Safe Harbor principles and to address questions and concerns regarding our adherence. This program includes a statement verifying our adherence to the Safe Harbor principles that is signed annually by our authorized representative. We encourage interested persons to raise any concerns with us using the contact information below. With respect to any dispute relating to this notice that cannot be resolved through our internal processes, we will cooperate with competent European Union and Swiss data protection authorities and comply with the advice of such authorities. In the event that we or such authorities determine that we did not comply with this notice, we will take appropriate steps to address any adverse effects and to promote future compliance.
Information Subject to Other Policies
We are committed to following the Safe Harbor principles in processing all personal information. Other information we receive may be subject to policies that may differ in some respects from the policies set forth in this notice. Certain websites of our have their own privacy policies that apply specifically to those websites. Those policies may be accessed through the websites in question. Information relating to present or former ExactTarget personnel is subject to our policies concerning personnel data privacy, which are available to present and former ExactTarget personnel upon request. Information obtained from or relating to clients or former clients is further subject to the terms of any privacy commitment made to the client, any agreements with the client, and/or any applicable laws and professional standards.
If you wish to access your information or to have your information deleted, updated, changed, or modified, you may do so by contacting us using the below information.
For further information, please contact us.
20 North Meridian Street
Indianapolis, Indiana 46204
Phone: (317) 423-3928
Fax: (317) 396-1592