Other Covered Entities

Otherinbox, Inc.
Return Path International, Inc.
Return Path, Inc.
Switch Labs, Inc.

Industries

  • Business and Professional Services
  • Marketing Services
  • Direct Marketing Services
  • Information and Communications Technology
  • Software
  • Analytics Software

Participation

EU-U.S. Privacy Shield Framework: Active

Original Certification Date: 11/18/2016
Next Certification Due Date: 10/19/2019
Data Collected: HR, NON-HR

Swiss-U.S. Privacy Shield Framework: Active

Original Certification Date: 10/11/2017
Next Certification Due Date: 10/19/2019
Data Collected: NON-HR

Purpose of Data Collection

We offer consumer applications (web browser plugins, etc.) that collect consumer personal data. We share the personal data only with the subprocessors needed to perform the services (ex: AWS for infrastructure hosting). We also offer a pixel tracking service for our b2b clients, which collects personal data. This data is shared with the client and with the subprocessors we need to perform the service. We collect EU citizen human resources related data through the operations of our business and share this data with the subprocessors needed to operate our business (ex: ADP for payroll, Intacct for expense reporting, and benefits providers). We collect b2b client data through the course of performing the contracted services to our clients. We collect prospect data through our sales and marketing services. We share the personal data with the subprocessors needed to perform the services (ex: SFDC for relationship management) and if the collection is co-branded with another controller, we may share the data with the other controller. We process personal data from our data partnerships (ex: ISPs and security companies) who share logfile, spam complaint and spam trap related data with us. This data is shared with the data provider/partner and with the subprocessors we need to perform the service.

Privacy Policy

HR Data

Return Path Performance Pact
Description:

Employee handbook including privacy disclosures for employees.

Effective Date: 1/1/2018

Non-HR Data

Description:

All of our Privacy Policies have been reviewed and updated with TRUSTe. They are available at the URL listed below.

Effective Date: 3/12/2018
Description:

Privacy policy for Threatwave/Bounce.IO/Betterbounces.net. Corporate entity is Switch Labs, Inc.

Effective Date: 1/1/2016

Verification Method

TRUSTe

Dispute Resolution

Questions or Complaints?

If you have a question or complaint regarding the covered data, please contact Return Path, Inc. at:

Margot Romary
Senior Director of Security and Privacy
Return Path, Inc.
3 Park Avenue, 41st Floor
New York, New York 10016

Privacy Shield organizations must respond within 45 days of receiving a complaint.

If you have not received a timely or satisfactory response from Return Path, Inc. to your question or complaint, please contact the independent recourse mechanism listed below


NON-HR RECOURSE MECHANISM



Appropriate statutory body with jurisdiction to investigate any claims against Return Path, Inc. regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy Federal Trade Commission