Effective Date: June 30, 2020
This Privacy Policy is governed in the manner by ExpressPigeon, an IMIMobile Company. (hereinafter, “ExpressPigeon”) at https://expresspigeon.com (collectively, its “Website”) and service at https://expresspigeon.com/access/login (“Service”) collects, uses, maintains and discloses information collected from its customers, its client’s customers and users of its Website and the Service (each, a “User”). The purpose of this Privacy Policy is to inform you about what kinds of information we, at ExpressPigeon, may gather about you, how we may use that information, whether we disclose it to anyone, and the choices you have regarding our use of the information. Some features discussed below may not apply to all services products or in all locations. In general, individuals (also referred to as “you” or “your”) may visit our website without telling us who they are or disclosing information to us.
For the purpose of the EU General Data 2016/679 (the GDPR) and any subsequent UK legislation on data protection, the data controller is ExpressPigeon. ExpressPigeon has appointed a company within the IMIMobile group of companies as its EU representative - [TEXTlocal/IMIMobile]
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions or you would like to make a request to exercise any of your legal rights, please contact the DPO using the details set out in the “Contact” section below.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This Privacy Policy is designed also for compliance with California Consumer Privacy Act of 2018 (the “CCPA”). The CCPA governs the Company’s disclosures to consumers pursuant to this Privacy Policy, or otherwise at the time any personal data is collected from consumers who are California residents for federal income tax purposes. To the extent compliance with the CCPA is required herein, such compliance shall only relate to consumers as are defined pursuant to the CCPA and for personal information as defined under the CCPA. To the extent a consumer is not a consumer as defined under the CCPA, the provisions contained herein regarding compliance with the CCPA shall not be required or applicable.
ExpressPigeon’s business is as a email service provider. In the course of its business, we collect, transmit, record, store, and otherwise handle information about individuals (personally identifiable information or “PII”). We take these activities seriously and provide appropriate procedures for the handling of PII. This Statement provides information to our website visitors, customers, and individuals communicating with or through our customers (collectively “Consumers”) about how information is collected, transmitted, stored, or otherwise handled. Any information provided by Consumers or collected from individuals who use Express Pigeion services/products is not sold or shared with unauthorized third parties, except in certain cases described below. Our customers may provide your PII to us for conducting their business and their use of your information is governed under their privacy policies/statements.
This Privacy Policy does not apply to the practices of companies that ExpressPigeon does not own or control, or to people that ExpressPigeon does not employ or manage. This includes any companies from whom you may have ordered services or products that are transmitted over ExpressPigeon’s email service and/or other platforms, and any companies from whom you may be purchasing other services.
While you interact as a visitor or user of our websites and platform services (together, "Sites and Services") we may ask, or you may volunteer, certain personal information, as follows:
With regard to each of your visits to our website we will automatically collect the following information:
We will also collect personal information from you when you voluntarily complete a customer survey or provide feedback via our customer service (including telephone, email or webform or messaging).
We do not presently share any personal information (whether provided to us or collected by us) with any third party.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data which we need to provide the service, then we may not be able to perform the contract we have with you
A “cookie” is a tiny text file that is stored on Users’ devices to customize your experience and support some necessary functions, either temporarily for that session or more persistently for repeat visits. ExpressPigeon uses cookies to better understand how Users use our website. Our cookies collect no PII and are not shared or intentionally revealed to other websites. ExpressPigeon does not look for or at other websites’ cookies on a Visitor’s computer. You have choices with respect to cookies. Visitors can modify their browser preferences, to accept all cookies, be notified when a cookie is set, or reject all cookies. If you choose to reject all cookies, you will be unable to use the services or engage in the activities that require cookies. Accepting a cookie does not give us access to your computer or PII other than the personal data you choose to share with us.
We use browser “cookies” to maintain session information and to allow for “remember me” function. None of the information in the cookies contains any personal or sensitive information about you. Please note that while most browsers will accept cookies by default, you may set your browser to reject cookies. However, disabling cookies in your browser will render our application inoperable. Specific details regarding our use of cookies can be found on the Cookie Policy page.
We use information held about you in the following ways:
If you fail to provide personal data which we need to provide the service, then we may not be able to perform the contract we have with you. you are responsible for ensuring that the personal data which you give us is accurate and up to date.
We collect your financial information so that we can be compensated for paid services. We store this information with an industry trusted third party financial institution. This prevents any potential theft of such information even in the unlikely event of a security breach. The security of your financial data while in transmission is assured through a 128-bit Secure Sockets Layer (SSL) connection between our Web server and a third party financial institution responsible for processing credit card transactions.
You must comply with the Terms of Service and Use Agreement when you provide the contact details of your target audience to us. We reserve the right to monitor this information at any time in order to ensure your compliance with our Terms of Service. We also reserve the right to collect additional information about your contacts, including but not limited to IP address, browser type, email, client type and operating system. We do not presently nor will in the future share any contact information (whether provided to us or collected by us through subscription forms) with any Third Party. Contact list information is used strictly to fulfil the functionality of our systems.
Our website may collect non-personally identifiable information. This may include, for example, collecting statistical information about the type of browsers people use to visit our website, domains from which our visitors come, or number of visits to our website, etc. This non-identifiable aggregate information may be used internally for quality control or for marketing purposes as well as provided to Third Parties. We partner with a third party(ies) to either display advertising on our Website or to manage our advertising on other sites. Our third-party partner(s) may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt-out of interest-based advertising click http://preferences-mgr.truste.com (or if located in the European Union click http://www.youronlinechoices.eu/ ). Please note you will continue to receive generic ads. Moreover, third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
While we store your personal information in order to support the proper function of our applications, it is your responsibility to keep this information up to date. You may access your personal information at any time by logging into the website and navigating to My Account. ExpressPigeon respects your control over your information, and, upon request, we will confirm whether we hold or are processing information that we have collected from you. You also have the right to amend or update inaccurate or incomplete personal information, request deletion of your personal information, or request that we no longer use it. Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you an explanation. In order to make such a request of us, please email us at our support email address, support@expresspigeon.com.
Please note that for personal information about you that we have obtained or received for processing on behalf of a separate, unaffiliated entity--which determined the means and purposes of processing, all such requests should be made to that entity directly. We will honor and support any instructions they provide us with respect to your personal information.
Please refer to Section 4 of the Terms of Service and Use Agreement to review the list of prohibited content. You may not use ExpressPigeon systems to send e-mails that include or link to any prohibited content. We reserve the right to monitor the content of your emails to ensure compliance with our Terms of Service, and freeze or even permanently close your account if we deem your content inappropriate, based solely on our opinion.
This Privacy Policy places no duty upon us with respect to Confidential Information that (a) becomes generally known to the public without violation of this Policy; (b) is collected by us from a third party without a confidentiality obligation; (c) was independently developed by us without use of the Confidential Information; (d) is disclosed in response to a court or governmental order provided that we have given you prior written notice and opportunity to object; (e) to the extent that disclosure of such Confidential Information is necessary to enforce our rights under the Terms of Service and Use Agreement in connection with any litigation, arbitration or other dispute resolution procedure.
We are based outside the EEA so processing of your personal data will involve a transfer of data outside the EEA.
We use providers based in the US, therefore we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
ExpressPigeon participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce. ExpressPigeon is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list .
ExpressPigeon is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. ExpressPigeon complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, ExpressPigeon is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission and/or the U.S. Department of Transportation, as applicable. In certain situations, ExpressPigeon may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge)at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
We represent that we will use commercially reasonable measures to maintain appropriate technical and organizational structure to protect any information, including personally-identifiable information that we collect, process or access against unauthorized or illegal processing or transfer and against accidental loss, access, or destruction.
We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. We reserve the right to eliminate, delete or destroy your personal data and information at any time, in our sole discretion, and you shall have no reliance upon our storage or access to any such personal data or information.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Your contact database as well as your account data may retain for as long as you keep it on your account. If you wish to delete it, you can freely do so at any time. If you have any questions, you can always contact us.
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes to how we treat our customer’s data, we will notify you by means of a notice on this Website’s home page. The effective date the privacy policy was last revised is identified at the top of the page. We encourage you to periodically review this Website for the latest information on our privacy practices.
The ExpressPigeon, duty to protect Confidential Information shall survive the expiration or termination of the Terms of Service and Use Agreement for any reason and will extend for a period of 5(five) years from the date of disclosure by you or collection by us of Confidential Information.
This Privacy Policy is incorporated by reference into the ExpressPigeon, an IMImobile Company. Terms of Service and Use Agreement and, therefore, made part of the Agreement.
In case you have questions or suggestions regarding this policy, feel free to contact us using our Support page,
or write to:
ExpressPigeon | IMImobile North America, Inc.
750 Park of Commerce Blvd,
Suite 400
Boca Raton, Florida 33487
Attn: Data Protection Officer
Email: dpo@imimobile.com