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Information we gather about our customers
We get to know you primarily through the information you provide to us when signing up for, or using, one or more of our services. The information you provide ranges from basic contact information, to payment information, to the technical coordinates of your host servers. The application for account registration services found at www.registrycompliance.com is a representative illustration of the information we request of you. All of the information we request from you when purchasing our services is obligatory unless otherwise noted on the relevant form. When you purchase our services, you agree to provide and maintain accurate, complete and updated information. The information we gather about you is either required by the States of Utah and Michigan (the "States") prior to using the Registry Compliance Service or used by the States or its agents in tracking abuse of the system.
Prior to or after signing up for our services, we may be in communication with you about your account, technical questions you may have about services provided by us, or any other matter relating to those services. Those communications are essential to our relationship with you and to our ability to provide you with quality services that are responsive to your needs. At the same time, those communications give us helpful insights about you, your preferences and the ways in which we might improve our services. We therefore may maintain this information for future use.
For operational and quality assurance purposes, we take note of whether and how you use the information and services that we provide, such as by recording site traffic patterns and by maintaining log files of users' access to site files.
The information we receive from or about you is stored on systems designed to prevent the loss, misuse, unauthorized access, disclosure, alteration or destruction of that information. We also encrypt your transmission of sensitive information to us (e.g., credit card numbers, account passwords) in the interest of heightened privacy protection and information integrity. Transactions within our account manager and purchase flows use Secure Sockets Layer (SSL) encryption when transmitting data from your connection to our systems.
We do not gather or compile Personally Identifiable Information regarding those individual email addresses or other contact points that are on any list that you submit to us for "scrubbing." Our system is designed such that sensitive information contained in your mailing lists does not leave your local machine. This prevents us from being able to see your lists' contents. Prior to submission of any data to us, your address list is "salted" and then "hashed." Hashing is not two-way encryption, where the data can be retrieved with the proper keys. During the hashing process data is converted in such a way that information is lost and thus retrieval of the original unhashed version just from the hash data that we receive from you is impossible.
We define Personally Identifiable Information as any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains. This includes information that is used in a way that is personally identifiable, including linking it with identifiable information from other sources, or from which other Personally Identifiable Information can easily be derived, including, but not limited to, name, address, phone number, fax number, email address, financial profiles, social security number, and credit card information. To the extent unique information (which by itself is not Personally Identifiable Information) such as a personal profile, unique identifier, biometric information, and IP address is associated with Personally Identifiable Information, then such unique information will also be considered Personally Identifiable Information. Personally Identifiable Information does not include information that is collected anonymously (i.e., without identification of the individual user) or demographic information not connected to an identified individual. In terms of P3P attributes, Personally Identifiable Information is 1) physical contact or location information, 2) online contact or location information, 3) government issued identifier, or 4) information about an individual's finances.
Although we can and do compare those hashes with the hashes that are stored on the Protect MI Child Registry and the Utah Children's Protection Registry, we do not have access to the email addresses that are on your list. In accordance with the requirements of the States, we do track and store which hashes from your lists are "matched" in process of scrubbing your list through the service. In addition, we may use such a process of storing certain honey-pot hits to track compliance and abuse by our customers.
Information Corrections or Changes
You have the ability to correct or change certain information in our records, such as your address and contact information. You may change this information at any time and as often as necessary, provided that you are providing accurate and timely information and are not attempting to mislead us or the States.
How We Use the Information We Collect
We use information about you for purposes of monitoring and improving our internal operations, as well as to ensure we: (i) bill you properly, (ii) administer your account in accordance with your agreements with us, (iii) properly perform the services you have requested, and (iv) comply with the contractual and legal requirements that the States have requested we maintain.
We also use the information we collect to monitor and improve our internal operations, as well as to improve the experience of users in our network of sites. For example, we may correlate Web site traffic information with data about individual users. This data helps us to determine how much our customers use parts of the site, allowing us to enhance it to fit the needs of as many of our customers as possible. We may also break down overall usage statistics according to customers' domain names, browser types, and MIME types by reading this information from the browser string (information contained in every user's browser).
Finally, we use the information we collect to direct important notices and information affecting your account or services, as well as to provide general information that may be of interest to you regarding the Registry Compliance Service. You may opt-out of receiving information from us simply by notifying us of your desire in accordance with the opt-out instructions contained in any information message you receive from us. Note, however, that in order to fulfill our service obligations to you, we must continue sending you notices and other important information affecting your account or services.
With Whom We May Share Information
We may share certain information about you with the States and with those of our vendors who are responsible for handling your account or performing other services that you require. Although we may share sensitive financial information (i.e., credit card numbers, banking information), security information (e.g., account passwords) and personal communications (e.g., personal e-mail messages or message board postings) with the States and such vendors where necessary and appropriate, we will not share such information with other third parties, except in response to formal requests (e.g., subpoena or court order) made in connection with litigation, arbitration, or criminal proceedings directly relating to the services we provide.
Our Accountability to You
Notification of Changes