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.
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.
CertainSource is the sole owner of the information collected at our site, which includes name, phone, title, and email. This excludes data our client’s upload or create in our platform. We do not sell, share, or rent information to third parties. The information is used to improve our services and communicate with prospects.
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 don’t share this data with clients or partners and use it to improve and monitor our services.
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.
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.
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.
The following content shall not be included in emails:
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:
The Federal Trade Commission has jurisdiction over eWayDirect's compliance with the Privacy Shield.
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@eWayDirect.com. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@eWayDirect.com.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
eWayDirect's accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, eWayDirect remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless eWayDirect proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, eWayDirect commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact eWayDirect at:
Chief Technology Officer
eWayDirect has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
338 Commerce Drive, Second Floor
Fairfield, CT 06825