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Emma’s Privacy Statement

Emma is committed to creating a safe and trusted communication platform for the modern digital marketer and their contacts. In this privacy statement, we will explain how we collect, use, and protect data pertaining to our customers and data about individuals, stored in our application by those customers.

We limit collection of customer data to things that are necessary for us to provide service and data about your use of our application to provide support, monitor compliance, and improve our services. All data stored and collected is shared only with trusted 3rd party service providers who, like Emma, are listed on the United States Department of Commerce’s Privacy Shield List, and then only for the purpose of providing service or support to you as a customer (e.g. cloud infrastructure, CRM, secure billing). It is not shared, rented or sold to any 3rd party for their own use. We may decide to use de-identified, aggregate data about our customers’ use of our application for our marketing purposes. We may also use your company name when we discuss Emma to prospects or to the press; we’re not above name-dropping. If we would like to use specific data about your use of our product, like a case study, we’ll ask.

As a recipient of our customers’ marketing messages, we will track whether you receive, open, click a link or image within, or share that message. Our customers can see this data and use it for their marketing purposes. We also store and track whether you opt out in order to promote compliance and ensure your request to discontinue contact is honored for the life of that customer’s account. Emma may use opens, clicks, opt out and other tracked data for any recipients of our customers’ messages to monitor customer compliance, provide support, and measure our service’s effectiveness. We will not share specific data about any recipient with any 3rd party, except where necessary to provide our services and never for that 3rd party’s own use.

You have the right, at any time, to request access to a copy of the data stored by a specific Emma customer pertaining to you. These requests will be referred to that customer and, upon their consent, we will disclose that data. It is necessary that we involve our customer to ensure that the request and any modifications to your data are reflected not just in the Emma account, but in all systems in which that data resides, and so that we fulfill contractual obligations to that customer regarding data disclosures. You may, without any notice to any customer, ask that we opt out your email address from one, many, or all customer lists on which it’s included. Any request for access or opt out should be sent via email to privacy@myemma.com. Requests for data will be fulfilled within two business days. Opt out requests will be processed within 10 business days.

Emma will respond to and cooperate with any lawfully issued subpoena or other legal requirement to provide any of the above data.

A note about the data you store with Emma

Contact data uploaded by Emma’s customers is stored on servers that offer reasonable protection for non-sensitive, directory information (name, email address). The application is not designed to store, nor should it be used to store, private or uniquely identifiable personally identifiable information (PII). We reserve the right to monitor customers’ contact lists, content, response data and account activity to enforce our Terms of Use. Access to customer data is restricted to only those Emma employees who need that access to support the application, enforce our Terms of Use, or perform tasks vital to ensure the stability of or improve the functionality of the application.

In the event of your account closure, Emma will retain data stored on the application’s servers for 40 days, at most, after which that data will be aggregated and deleted.

Emma and your billing data

Customers are asked to supply certain credit card and billing information in order to purchase Emma’s services. That information is collected and stored, using secure transmission technology, to a trusted, PCI compliant third party to handle billing transactions. Credit card information is not stored on the Emma website or on our servers. We do not have access to any customer’s credit card information.

Emma and Privacy Shield

Emma participates in EU-US and Swiss-US Privacy Shield Frameworks, which have replaced the EU-US and Swiss-US Safe Harbor to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring personal data from the European Union and Switzerland to the United States in support of transatlantic commerce. Emma has certified to the US Department of Commerce that it adheres to the Privacy Shield Principles regarding the collection, use, and retention of an individual’s data and is listed on the United States Department of Commerce’s Privacy Shield List, found here

In this privacy policy, we commit to upholding the Privacy Shield principles and outline our data collection, use, and disclosure practices. If any of our outlined practices are at odds with the Privacy Shield Principles, the Principles take precedence.

The collection, storage, and/or onward transfer of personal information originating in the EU, as with all personal information stored by Emma, may be accessed by that data subject by contacting privacy@myemma.com with a clear request for disclosure. We may ask the requestor to verify their identity when reasonable to do so. For any onward transfer to a third party processor related to providing Emma’s services, Emma assumes potential liability for the appropriate protection of that data. If an individual residing in the EU questions or disputes the collection, use, or disclosure of their personal information, please notify us first at:

Emma
9 Lea Avenue
Nashville, TN 37210
privacy@myemma.com

Emma will make any reasonable effort, in concert with the Emma customer(s) involved (if any), to address and correct the issue, including editing or removing any data stored pertaining to that individual. Any unresolved Privacy Shield complaints will be referred to JAMS, our chosen alternative dispute resolution provider. Should this arbitration fail, the complaint may be subject to binding arbitration before the Privacy Shield Panel, in accordance with the Privacy Shield Agreement. All of these remedies are offered at no cost to the complainant, as long as the complainant is an individual.

As stated elsewhere in this policy, Emma is required to comply with certain requests from law enforcement and the U.S. government to provide data. Further, Emma is subject to the investigatory and enforcement powers U.S. Federal Trade Commission.

The Data We Collect

1. When you visit our website

2. When you contact us as a prospect

3. When you use our application

4. When you contact us for support

5. When you receive a message from our customers



How We Use the Data You Share and Create as a User

1. To assist you as our customer. All the data outlined above can be helpful to us in resolving or diagnosing service issues. Your data and data derived from your use of our application (app logs, mailing response, requests for support, etc.) will be used to make your experience as an Emma customer a better one. Contact information you provide to us may be used to alert you to outages, changes in our policies, or other critical notices for you as a user.

2. To make our product better. Trends we see in aggregated support request information may help us identify ways to make our product better. We’ll use any data you provide or which is derived from your use of our application internally in order to improve our services.

3. To market services to you or others. We use Emma, too. Customers, prospects, and anyone who submits their contact information to us via our website, in the course of setting up an Emma trial, or as a customer via our application or a support request will be added to our marketing list. You may unsubscribe at any time.


When We Disclose Your Data

1. To Emma’s Service Providers. Emma uses a variety of service providers for key business functions. Cloud infrastructure, our CRM provider, and our billing provider all receive data you provide or which is created by your use of our application. These transfers occur only to support Emma’s business functions and do not represent Emma selling, renting, or otherwise providing that data to a 3rd party for their own purposes.

2. For legal purposes. If we are approached with a lawfully issued subpoena or other legal requirement or legal process to provide information, we will do so within the confines of that request. This may include providing your data or data about you to our legal representatives and any other parties associated with the legally binding request such as law enforcement.

3. In the event of sale or merger. If Emma is sold to or merged with another service provider, your data may be transferred to that entity.