Privacy Policy

ConnectsMail2.0 (CM2.0) is a cloud-based direct mail marketing technology platform intended to automate, report on, and enhance the effectiveness of direct mail marketing campaigns(“Services”). The primary use of information via CM2.0 is to identify for Customers when direct mail campaigns have been received, opened, and when direct mail campaigns actually generated a response from recipients. This enables Customers to have access to useful information about the effectiveness of their direct mail campaign efforts.

Third-Party Platforms. The delivery of CM2.0 Services is fulfilled through various digital technologies that are owned and operated by third parties (“Third Party Platforms”) and made accessible in one platform through CM2.0 for the benefit of CM2.0 partners and their clients (“Customers”). Users of CM2.0 should note that each Third Party Platform has its own end user license agreement (“EULA”), privacy/security policies, and terms of use (collectively “Third Party Requirements”) that apply to the Customer’s use of these Third Party Platforms through CM2.0. A complete list of current Third Party Platforms can be obtained by contacting CM2.0 at wbrennan@connects360.net.

CM2.0 has no control over Customer information maintained in Third Party Platforms. As a result, Customers should be aware of how information is collected and maintained in Third Party Platforms and the steps Customers can take to further protect their information when using CM2.0. Customers must also ensure that website privacy policies adequately describe the use of Third Party Platforms as required by applicable law.

CM2.0 Not Intended for Protected Information. Customers of CM2.0 should understand that CM2.0 is not intended to be
used to create, receive, maintain or transmit protected health information (“PHI”) governed by HIPAA, or other highly sensitive information about individuals that are afforded special protections under State and/or Federal Laws (collectively “Protected Information"). While CM2.0 and Third Party Platforms have practices and systems in place intended to protect the privacy and security of information, Customers agrees not to store Protected Information in DM2.0 or Third Party Platforms. www.connectsmail20.com

Customers that anticipate Protected Information being disclosed over the phone should not utilize the CM2.0 Call Tracking Service. Customer also agrees to ensure that each of its users is aware of the requirements of this Privacy & Security Policy. While this Privacy & Security Policy is intended to summarize the privacy and security practices related to the Services offered through CM2.0, Customers are responsible for reviewing and complying with the applicable Third Party Requirements as well.

Customer Tools for Managing Privacy & Security. In CM2.0, Customers have the ability to select and/or deactivate certain functions to further ensure the privacy and security of Customer information. Customers seeking to afford extra levels of privacy and security to their information should contact wbrennan@connects360.net for more information about these features. For example, in the CM2.0 portal, CM2.0 offers a “privacy restricted campaign” feature that users can select to add an additional layer of privacy/security for a specific mail campaign. Customers should configure their accounts based on the state laws applicable to their campaign. Customers should also ensure that users are managed by Customer to ensure that only authorized users have access to Customer information.

General Data Collection, Storage & Use. CM2.0 Services are offered to provide Customers with tracking and reporting metrics on the status of direct mail campaigns. Unlike mail houses or similar services, CM2.0 has very little interaction with actual communications between Customers and their mailing recipients. Rather, CM2.0 is intended for and configured to only collect and store postal mailing information and in limited situations, email addresses when provided by Customers. Customers should understand that if Customer or its end users choose to maintain or transmit Protected Information in CM2.0 platforms, CM2.0 cannot guarantee the privacy of such information and the information may be accessible by Third Party Platforms, whose policies shall apply.

How CM2.0 Uses Mailing Addresses. Postal mailing addresses are used by CM2.0 on behalf of Customers to initiate digital campaigns and mailings as needed to fulfill the advertising services CM2.0 has been engaged to perform.

Third-Party Platform Disclaimer. CM2.0 specifically disclaims any and all warranties related to Third
Party Platforms and makes no representations about the privacy or security of such Third Party Platforms. However, Third Party
Requirements describe a range of privacy and security controls in place that are intended to protect Customer information.

https://www.connectsmail20.com

Customer Provided Data. All data involving mailing campaign(s), including but not limited to mailing lists, designs, and customer information provided to CM2.0 as needed to receive services from CM2.0 (“Customer Data”), may be used by CM2.0 as needed to fulfill the services DM2.0 has been engaged to provide. CM2.0 does not use Customer Data to solicit new customers without prior written approval. However, CM2.0 may use de-identified aggregated data that does not specifically identify individuals or the Customer (“Aggregated Anonymous Data”). By using CM2.0, the Customer acknowledges and agrees that CM2.0 may obtain and use Aggregated Anonymous Data it captures or comes in contact with through use of its Services. CM2.0 may use the Aggregated Anonymous Data to analyze, improve, support, and operate the Services, CM2.0 may also use Aggregated Anonymous Data for any business purpose, during and after the term of any Customer agreement, including without limitation, to generate industry benchmarks or best practices guidance, recommendation or similar reports for distribution to and consumption by Customer and other CM2.0 customers and prospects. In all cases, the Customer will not be identified unless prior approval has been obtained.

Feedback & Campaign Results Utilization. If the Customer provides suggestions, comments, and feedback regarding the Services, including but not limited to usability, bug reports and usage results, (collectively, “Customer Feedback”), CM2.0 may make, use, copy, modify, sell, distribute, sub-license, and create derivative works of the Customer Feedback as part of any of CM2.0’s products, technology, services, specifications or other documentation. In addition, CM2.0 may, in its sole discretion, use Customer’s campaign results and analytics, to include the number of calls received and website visitors, for both internal product development purposes, as well as marketing materials to be published to third parties. If CM2.0 uses Customer Data or Customer Feedback for such purposes, DCM2.0 will not identify the Customer as the source of the information.

USPS/Informed Delivery. Processed mailing lists are shared with USPS Informed Visibility and Informed Delivery. CM2.0 only discloses IMDB digits with the USPS for these services. No personal information is disclosed. The USPS Privacy Policy can be viewed here: https://faq.usps.com/s/article/Informed-DeliveryPrivacy-Security-Concerns.

Call Tracking. CM2.0 partners with Twilio and WhitePages for call tracking. The information returned by Twilio and WhitePages is password protected and stored on the CM2.0 AWS servers. The Call Tracking services include a feature to inform callers that the call may be recorded. Customers should confirm this feature is activated and in compliance with the state laws that apply to Customer. Recorded phone calls are ONLY accessible to the client the calls were made to. CM2.0 does not have access to recorded phone calls. The Call Tracking feature is not currently offered to Customers governed by https://www.connectsmail20.com the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and/or other similar privacy laws, and Customers should not utilize the Call Tracking service for Protected Information. Compliance with all laws applicable to the recording of calls remains Customer’s sole responsibility, including obtaining all necessary consents. Customer assumes full responsibility for compliance with all applicable laws related to the recording of calls, and fully releases and holds harmless CM2.0, its affiliates, officers, and agents for all damages, costs, third party claims related to Customer’s use of the call recording service offered by CM2.0. The CM2.0 call recording service is offered through Twilio, Inc. Customers should review Twilio’s security and privacy policy here: https://www.twilio.com/legal/privacy WhitePages: https://ekata.com/security-and-privacy/. Customer must comply with Twilio and WhitePages’ Third Party Platform Requirements, and ensure that Customer, and any clients of Customer, have included required information in any applicable privacy policies related to the use of these services.

Advertising & Ads. CM2.0 deploys all ad campaigns via the following Third Party Platforms: Google Network, Facebook and LinkedIn. Customer must ensure compliance with each of these Third Party Platform’s advertising policies. CM2.0 has no special rights or access to any data going to or from each of these Third Party Platforms. CM2.0 has no control over the ads these Third Party Platforms will or will not accept. CM2.0 does not give share or receive any personal information on ad targets belonging to clients of Customers in relation to advertising and ads through the Third Party Platforms described in this paragraph. Each Third Party Platform’s Privacy Policy and advertising policies can be reviewed by clicking the respective link below. The customer is responsible for ensuring that the requirements of applicable law and complied with when using these Services, including the requirement to inform individuals about how information is used in any applicable privacy policies.

Google: https://policies.google.com/privacy?hl=en-US

Facebook: https://www.facebook.com/policy.php

LinkedIn: https://www.linkedin.com/legal/privacy-policy

LEADMatch Services. With permission and placement of the pixel by the client, the LEADMatch pixel placed returns to the DM2.0 LEADMatch vendor a Device ID (if available), IP address, cookie-based information, time of firing and page of firing. The LEADMatch Service collects postal addresses and matches them to website visitors. No names, phone numbers, email addresses, financial or medical information is retrieved or shared via the LEADMatch Service. other than a residential postal address of the website visitor. However, privacy laws are constantly evolving, so it is important for Customers to ensure they take appropriate steps when using LEADMatch Services. When utilizing LEADMatch, Customer represents that: (a) no terms of use, privacy policy, or https://www.connectsmail20.com representations made to Customer website visitors will be violated by such pixel use; (b) Customer will require each website (including websites of Customer’s clients) utilizing LEADMatch to display privacy policies that disclose applicable data collection practices, including the types of data collected and purposes for which data is collected by or transferred to third parties, plus working mechanisms that conspicuously enable consumer opt-outs and do-not sell requests in accordance with applicable laws; and (c) the use of pixels will not be used in conjunction with any website or application directed to children under the age of 16, or in any manner implicating the Children’s Online Privacy Protection Act. CM2.0 and Third Party Platforms reserve the right to exclude any use of pixels that does not comply with these terms. The current Third Party Platform used by LEADMatch is Claritas. InsiderData 360 may also be used. Customer must read and comply with the Third Party Requirements for these vendors. See: https://claritas.com/privacy-legal/;

https://insiderdata360online.com/

Data Deletion, Opt-Out Requests, and Do-Not-Sell Requests. Requests for deletion, opt-outs, and do not-sell requests should be submitted to privacy@DM2.0.com.

Data Breaches. CM2.0 will notify Customers and partners of data breaches in accordance with applicable law.

Limitation of Liability. CM2.0 is not intended for Protected Information. The maximum aggregate liability of DM2.0 for any and all claims related to the use of CM2.0 and Third Party Platforms, including without limitation, data breaches and/or claims related to state and/or federal privacy laws, whether by Customer or a third party, shall be limited to the total payment the applicable Customer made to CM2.0 in the preceding three (3) months from the date of the event giving rise to the claim. No claim, regardless of form, may be brought more than the shorter of one year or the period allowed by law after the cause of action has occurred.

Introduction ​

At Connects 360 LLC (the "Company" or "We"), we respect your privacy and are committed to protecting it through our compliance with this policy. ​

This policy describes the types of information we may collect from you or that you may provide when you visit this website (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to the information we collect: