Webbula’s Privacy Vision
We are committed to the responsible use of the information we obtain through our offline data resources. We strive to protect the data we maintain through the implementation of industry standard security measures and operational controls. We strive to protect consumer privacy through product design and operational controls and remaining at the forefront of companies committed to responsible data practices. We are committed to provide services to businesses that are equally committed to responsible and secure data practices.
Privacy For Consumers
Data Collection and Use.
Data Collected Online From Our Website (“Online Data”). Webbula does not collect personal information through interactions on the website located at Webbula.com.
Data Collected Offline For Use In Our Products and Services (“Offline Data”). Webbula licenses and collects Offline Data via third party data vendor contracts, data contributor relationships, and via public records (such as the downloading of government lists, census files, etc.). The data used and collected by Webbula includes identity verification information, public records, telephone records, demographic information and a variety of other types of data content with the exclusion of any type of regulated data (social security numbers, credit card numbers, etc.). Offline Data is used in the Webbula Products and Services as defined below.
How We Use The Offline Data We License And Collect.
The Offline Data that is licensed, collected, and used by Webbula is used in a variety of Webbula products and services, including the following (“Products and Services”):
- CloudHygiene – “CloudHygiene” is a coded representation of a statistical analysis of an email address (similar in nature to industry-standard credit scores but based on non-credit data) to protect an email sender’s reputation and brand. CloudHygiene is designed to satisfy a wide variety of business objectives such as risk, hard bounce, and fraud mitigation for email marketers. When an email address is processed through our suppression list, proprietary algorithms, and processes is applied to the transaction information, and a CloudHygiene flag is created. Once calculated, the CloudHygiene flag is returned to the customer. Only the CloudHygiene flag is returned to the customer while the email address within our suppression list is not returned. CloudHygiene can be used in Webbula’s Data Enhancement and Online Audience Targeting.
- Data Enhancement – “Data Enhancement” is the process of adding or appending additional data attributes to a customer’s existing list. Through a proprietary key based linking process, attributes or personal information is added to a customer list at an individual and / or household level. Webbula does not sell “lists” or “leads” and only enhances a clients already existing contacts.
- Online Audience Targeting – ”Online Audience Targeting” is an offering where Webbula’s offline data attributes (not personal identifying information) are made available in online exchanges. Webbula does not collect, place, or maintain 1st or 3rd party cookies. The offline attributes are onboarded into the online exchanges via privacy compliant 3rd party that replaces any personal identifying information with an anonymous cookie. Utilizing a 3rd party onboarding partner ensures no personal identifying information enters into the online exchanges.
EU-U.S. Privacy Shield.
Webbula, LLC participates in and has certified their compliance with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list
Webbula is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Webbula complies with the Privacy Shield Principles for all onward transfers of personal data from the EU including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Webbula is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Webbula may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, Webbula commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Webbula at: email@example.com
Webbula has further committed to refer unresolved Privacy Shield complaints to The Data & Marketing Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://thedma.org/resources/consumer-resources/privacyshield-consumers/ for more information or to file a complaint. The services of The Data & Marketing Association are provided at no cost to you.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Webbula provides consumers with the ability to opt-out of Webbula’s Marketing Services.
- Opt Out – Upon receipt and verification of your Opt-Out request, Webbula will not use your information for Webbula’s Data Enhancement and Online Audience Targeting. By Opting-Out, Webbula will no longer use your personal information in its Marketing Services. This information will be used only to identify your record(s) in our databases for removal. The Opt-Out as described here will apply only to the information as submitted by you on your Opt-Out request (for example, prior addresses or nicknames may not be recognized by the Opt-Out process). In the event your information changes (i.e. change in address, name change), your Opt-Out will not apply to the information you changed. You can be Opted-In again if Webbula receives your information from our third party data vendor contracts, data contributor relationships, and via public records again. In these cases, you can submit a new Opt-Out request. Also note that initiating an Opt-Out will not prevent the use of your information under situations where Data Enhancement and Online Audience Targeting have already been delivered. There may also be a delay of up to 5 business days from the date of your Opt-Out request before it is implemented and active. Click the Consumer Opt-out Request tab for instructions on requesting an Opt-Out of Webbula Services.
- Upon request Webbula will provide you with information about whether we hold any of your personal information. You can review, or edit, or delete your personal information for CloudHygiene by logging into your account at https://login.cloudhygiene.com and clicking on the Change Email button. You can also close your account by sending an email request to firstname.lastname@example.org or by calling +1.888.993.2285. If you request that we close your account we will disable your account in our database but will not fully delete your personal information until we have collected any fees owed, resolved disputes, assisted with any investigations, or taken other actions as required or permitted by law. We will respond to any of these requests within a reasonable timeframe. Data Enhancement and Audience Targeting customers can review, or edit, or delete your personal information by clicking the Consumer Opt-out Request tab (preferred) or by sending an email request to email@example.com, or by calling +1.888.993.2285.
General Consumer Inquiries.
You may contact us by email at firstname.lastname@example.org or by postal mail at:Webbula, LLC ATTN: Privacy/Compliance 5000 Stonewood Drive Suite 310 Wexford, PA 15090
Copyright 2009 – 2018, Webbula, LLC. All rights reserved. DATE OF LAST MODIFICATION June 14, 2017
- OUR SERVICES
Webbula provides a variety of data services to its customers, based on data that is often conventionally referred to as “personally identifiable” information, such as name, address, and email address, and also based on data that has been de-identified. Among these services (our “Services”) are those described on our website, including
- Data verification and hygiene (generally, for marketers to apply to their databases),
- Consumer insights or data “append” (generally, for marketers to learn more about their actual and prospective customers), and
- Audience building for digital targeting (e.g., for online advertising) and other marketing.
The above list is not exhaustive, however, and we often work with customers on a custom basis to help them use our data, and their own data, to better, more accurately, and more responsibly target and tailor advertising and service their own customers.
- DATA ACCURACY AND DISCLAIMER
Webbula endeavors to maintain only true and accurate consumer information. Please note, however, that Webbula secures its information from a variety of third party sources. Neither Webbula nor its employees, directors, agents, licensors, third party information providers, or vendors warrant that the information is accurate or error free. If you have concerns regarding the accuracy of your information or use of such information, you may Opt Out.
Click the Consumer Opt-Out Request tab above for instructions on requesting an Opt Out.
- OPT OUT STATUS
If you are an individual consumer and can provide us with proper identity verification, you may request to Opt Out, which means Webbula will not use the information in its provision of Data Enhancement and Online Audience Targeting services.
Click the Consumer Opt-Out Request tab above for instructions on requesting an Opt Out.
To learn about methods of “opting out” of online advertising, including that facilitated by many of the partners we may work with, please go to Section 9 below, titled “INTEREST BASED ADVERTISING AND YOUR AD CHOICES.”
- COLLECTION OF PERSONAL INFORMATION
Webbula may collect information that identifies you as an individual, such as your name, address, email and phone number, from third party data vendor contracts, data contributor relationships, and via public records (such as the downloading of government lists, census files, etc.). Our vendors may receive this information from a variety of sources, such as their own websites, surveys, and other data collection methods.
We strive to work with trustworthy and responsible data suppliers.
- COLLECTION OF OTHER INFORMATION
Webbula also collects and aggregates other information that is connected to your specific identity or household. This information generally includes attributive, demographic, housing, financial, and automotive information.
- USE OF INFORMATION
In general, Webbula uses the information that it receives or collects to provide, improve, evaluate and maintain its Services. We may combine data from multiple sources, create new data products or models with this information, or create entirely new datasets. We may work with other companies to do any of these things.
Note that Webbula does not gather information for its Services via the website www.webbula.com; however, if you provide us information through our website (such as, to inquire about our Services, or register for a webinar or event), we will add your information to our customer relationship files and may market to you in the future, such as to send you information about product updates and future events. We may do this through various channels, including email, direct mail, and display media (the latter of which may be triggered by a pixel or “cookie” on our web pages).
- DISCLOSURE OF INFORMATION
Webbula may share, sell, and / or license information from and about you in a variety situations, including: (1) to comply in good faith with law enforcement requests, subpoenas, or other legal process, or otherwise to comply with legal requirements;; (2) to protect our interests, the website, or other users; (3) as part of the sale of Webbula or its assets, including in the course of due diligence leading up to any such sale; (4) with its parent or subsidiaries; (5) with third parties for commercial use; and (6) with our third party providers, such as attorneys, accountants, hosting services and other contractors. We may also share information that is anonymous, aggregated and/or de-identified for various business and commercial purposes, where legally permissible.
- REMOVING OR UPDATING PERSONAL INFORMATION
- INTEREST-BASED ADVERTISING AND YOUR AD CHOICES
We sometimes provide our information for us in digital advertising. When we do this, we work with a service provider (and sometimes multiple service providers) who replace personally identifiable information such as an email address with a de-identified hashed value. That or other de-identified values are then combined with other data (for instance, other identifiers, demographic or interest-based data), linked to online identifiers (such as a cookie-based identifier or mobile ad identifier), and used to target interest-based ads on web and mobile advertising platforms.
To learn more about cookies, go to http://www.allaboutcookies.org/.
To opt out of interest-based advertising through web-based means, you may go to industry-wide opt-out portals operated by the Digital Advertising Alliance (http://digitaladvertisingalliance.org/) or the Network Advertising Initiative (http://optout.networkadvertising.org/#!/). Please note that when you opt-out, an opt-out cookie is placed on your browser. If you delete your cookies, or replace your browser, you will need to opt out again.
To opt out of interest-based advertising through mobile apps (also called “cross-app” advertising), you may go to the “opt out” instruction in your device settings.
- LINKS TO OTHER WEBSITES
We use various electronic, physical, technical, and procedural safeguards to protect and limit access to the information you provided to us via this online service. Unfortunately, no data transmission or storage system can be guaranteed to be 100 percent secure; you therefore should not rely on our (or any) security protocols to be foolproof. Additionally, please note that information you send to us electronically may not be secure when it is transmitted to us because we do not control the security of your delivery channel.
- CHILDREN’S PRIVACY
Our online services are not intended for children, and Webbula provides no products or service geared towards children. Our website at www.webbula.com does not knowingly solicit or collect personal information online from children under age 18.
- EU-US PRIVACY SHIELD
- Privacy Shield Certification. As a business subject to the enforcement and investigatory powers of the Federal Trade Commission, Webbula, Inc. has certified our compliance with the EU-US Privacy Shield Framework with respect to the personal client data we receive from the relevant European countries, effective as of the date our certification is posted at https://www.privacyshield.gov/list. You can learn more about the Privacy Shield program at https://www.privacyshield.gov. We may alternatively process personal data our clients in the EU submit via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses. (As to any third-party service providers we may use to process information subject to the Privacy Shield, we may certain liability under the Privacy Shield if both (i) the agent processes the information in a manner inconsistent with the Privacy Shield and (ii) we are responsible for the event giving rise to the damage.)
- Accessing Your Data: European residents may have certain legal rights to access certain personal data and to obtain its correction, amendment, or deletion. You may contact us at the contact information below to request access, correction, amendment, or deletion. Because our personnel have limited rights to identify and access an individual user’s personal data that our client has submitted to us, and because we process that data on behalf of our clients, we may first refer you to the client who submitted your data, and we will support them as needed in responding to your request.
- Resolution of Complaints. In compliance with the EU-US Privacy Shield Principles, Webbula commits to resolve complaints about your privacy and our collection or use of your personal information. If you have any concerns or complaints, please contact us as described at the end of this policy, and we will work with you to resolve your issue. Webbula has further committed to refer unresolved Privacy Shield complaints to The Data & Marketing Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://thedma.org/resources/consumer-resources/privacyshield-consumers/ for more information or to file a complaint. The services of The Data & Marketing Association are provided at no cost to you. Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
You may contact us by email at email@example.com, or postal mail at:Webbula, LLC ATTN: Privacy / Compliance 5000 Stonewood Drive Suite 310
Wexford, PA 15090 Copyright 2009 – 2018, Webbula, LLC. All rights reserved. DATE OF LAST MODIFICATION January 25, 2018
Consumer Opt-Out Request
In order for us to process an Opt-Out request, we will need additional information from you. The information you provide will be used to search our databases to determine what data, if any, is maintained in our systems that are associated with your personally identifying information. We also use the information you provide to us to ensure that we can verify your identity and to prevent consumer identity fraud. This information will be used only to identify your record(s) in our databases for removal.
Upon receipt of your request and Webbula’s proper verification of your submitted information, Webbula will process your Opt-Out and will discontinue the use of your information for Webbula’s Data Enhancement and Online Audience Targeting Services.
Please be advised that the Opt-Out as described here will apply only to the information as submitted on this request (for example, prior addresses or nicknames will not be recognized by the Opt-Out process). In the event your information changes (i.e. change in address, name change), your Opt-Out will not apply to the information you changed. You can be Opted-In again if Webbula receives your information from our third party data vendor contracts, data contributor relationships, and via public records again. In these cases, you can submit a new Opt-Out request.
Also note that initiating an Opt-Out will not prevent the use of your information under situations where Data Enhancement and Online Audience Targeting have already been delivered. There may also be a delay of up to 5 business days from the date of your Opt-Out request before it is implemented and active.
Any Opt-Out requests that are submitted with incomplete data will not be processed.
General Consumer Inquiries
You may contact us by email at firstname.lastname@example.org/, or by postal mail at:Webbula, LLC ATTN: Privacy/Compliance 5000 Stonewood Drive Suite 310 Wexford, PA 15090 Copyright 2009 – 2018, Webbula, LLC. All rights reserved. DATE OF LAST MODIFICATION February 14, 2017