Updated: 5/25/2018
Bryan Millhouse
4400 N Scottsdale Rd Ste 9850
Scottsdale, AZ 85251 USA
Contact email: dpo[at]messagekey.com
General overview
The following Privacy Policy is a simple overview of what happens to your Personal Data when you visit MessageKey.com (the “Application”), Personal Data is any data with which you could be personally identified.
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law; provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof; processing is necessary for compliance with a legal obligation to which the Owner is subject; processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner; processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes:
Handling payments, Analytics, Displaying content from external platforms, User database management, Managing contacts and sending messages, Interaction with online survey platforms, Remarketing and behavioral targeting, Interaction with external social networks and platforms and Commercial affiliation.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
Facebook Ads conversion tracking (Facebook, Inc.)
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Application.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.
Google AdWords conversion tracking (Google Inc.)
Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on this Application.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
LinkedIn conversion tracking (LinkedIn Corporation)
LinkedIn conversion tracking is an analytics service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Application.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.
This type of services allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Vimeo video (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.
YouTube video widget (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Wistia Inc. (Wistia)
Wistia is a video content visualization service that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.
This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.
The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
This type of service makes it possible to manage a database of phone contacts.
Twilio (Twilio, Inc.)
Twilio is a phone numbers management and communication service provided by Twilio, Inc.
Personal Data collected: phone number.
Place of processing: United States – Privacy Policy.
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Application.
This type of service may also enable the sending of timed messages to the User, such as emails or text messages, based on specific actions performed on this Application. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Drip and Leadpages (Avenue 81, Inc.)
This type of service allows us to create landing pages, sales pages, pop-ups and other conversion pages; and automate marketing activities to send relevant communications to subscribers.
Personal Data collected: various types of Data as specified in the privacy policy of the service to include name, email, phone number.
Place of processing: US – Privacy Policy.
MailChimp (The Rocket Science Group LLC.)
This type of service allows us to create landing pages, sales pages, pop-ups and other conversion pages; and automate marketing activities to send relevant communications to subscribers.
Personal Data collected: various types of Data as specified in the privacy policy of the service to include name, email, phone number.
Place of processing: US – Privacy Policy.
Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
2Checkout (2Checkout.com, Inc.)
2Checkout is a payment service provided by 2Checkout.com, Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Stripe (Stripe Inc.)
Stripe is a payment service provided by Stripe Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments using their PayPal credentials.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity. In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.
AdWords Remarketing (Google Inc.)
AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Application with the Adwords advertising network and the Doubleclick Cookie.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Twitter Remarketing (Twitter, Inc.)
Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Application with the Twitter advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
LinkedIn Website Retargeting (LinkedIn Corporation)
LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Application with the LinkedIn advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within 30 days.
Cookie Policy
This Application uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the top of this Privacy Policy.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Transfer to Other Countries
If you are using the Services from regions with laws governing data collection and use, then please note that we may transfer your Personal information to multiple countries throughout the world, including the United States. These countries may not have the same data protection laws as the country in which you initially provided the information. By providing your Personal Information to the Service, you consent to any transfer and processing in accordance with this Policy.
If you are located in the EEA or Switzerland, we comply with applicable data protection law when transferring your Personal Information outside of this area. In particular, we may transfer your Personal Information to countries for which adequacy decisions have been issued, use contractual protections for the transfer of Personal Information to our U.S. headquarters or third parties, such as the European Commission’s Standard Contractual Clauses, or rely on third parties’ certification to the EU-U.S. or Swiss-U.S. Privacy Shield frameworks, where applicable. You may contact us to obtain a copy of the safeguards we use to transfer Personal Information outside of the EEA.
Children's Privacy
This Application does not knowingly collect, maintain, or use Personal Information from children under 18 years of age, and no part of the Application is directed to children under the age of 18. If you learn that your child has provided Personal Information without your consent, then you may alert us at the contact information included in this Privacy Policy. If we learn that we have collected any Personal Information from children under 18, then we will promptly take steps to delete such information.
Comments
Comments collect the data shown in the comments form, and also visitor’s IP address and browser user agent string to help spam detection. The comment and its metadata are retained indefinitely. After approval of your comment, your profile picture is visible to the public in the context of your comment. Visitor comments may be checked through an automated spam detection service like Akismet
Media
Users should avoid uploading images to this Application with embedded location data (EXIF GPS) included. Visitors to the Service could download, and extract any location data from the images.
GDPR
The Regulation (EU) 2016/679 (General Data Protection Regulation) will be applicable as of May 25th, 2018 in all member states to harmonize data privacy laws across Europe.
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies
Small piece of data stored in the User's device.
If you have any questions about this Privacy Policy please email us at dpo[at]messagekey.com
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