1) Overview 

JetSend Inc. (“JetSend”, “We”, “Us”, or “Our”) is dedicated to establishing a trusting relationship with its users, based on respect for personal identity and information, by promoting the use of fair information practices. This privacy policy covers all web properties owned and maintained by JetSend, including but not limited to www.JetSend.com. Because JetSend wants to demonstrate its commitment to our users’ privacy, we are disclosing: 

a. What personally identifiable information JetSend collects. 
b. How JetSend uses the information. 
c. With whom JetSend may share user information. 
d. Your choices about collection, use and distribution of the information. 
e. The safeguarding procedures that are in place to protect the loss, misuse or alteration of information under JetSend’s control. 
f. How users can correct any inaccuracies in the information. If users have questions or concerns regarding this policy, they should contact JetSend Customer Support by email at support@JetSend.com. 

The TRUSTe certification covers only our collection, use and disclosure of information we collect through our Website: www.JetSend.com and our service http://app.JetSend.com/users/sign_in. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged. In order to view our relationship with TRUSTe please visit the validation page visible by clicking on the TRUSTe Seal. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe here. 

2) Information Collection 

JetSend is the sole owner of the information collected on its web properties, including http://JetSend.com. JetSend collects information from its users at several different points on our Web sites 

1) Registration 
In order to use JetSend services at any level, and to access certain information or areas of the website (including various downloads, “Test Drives”, webinars, etc.), a user must first complete the registration form. During registration a user is required to give contact information (such as name, telephone number or an email address). We use this information to contact the user about services on our sites. It is optional customer to provide demographic information (such as income level and gender), but encouraged so we can provide a more personalized experience on our sites. 

2) Order 
When a user purchases a paying service, we request information from the user on our order form. A user must provide contact information (such as name, email, and billing address) and financial information (such as credit card number, expiration date). This information is used for billing purposes and to fill customer’s orders. If we have trouble processing an order, the information is used to contact the user. 

3) Profile 
We store information that we collect through cookies and log files to create a profile of our users. A profile is stored information that we keep on individual users that details their viewing preferences. Consequently, collected information is tied to the user’s personally identifiable information to provide offers and improve the content of the site for the user. This profile is used to tailor a user’s visit to our Web sites, and to direct pertinent marketing promotions to them. We do not share personally identifiable elements of your profile with other third parties. Your profile is shared in aggregate form only. 

4) Cookies 
A cookie is a piece of data stored on the user’s computer tied to information about the user. Usage of a cookie is in no way linked to any personally identifiable information while on our site. We use both session ID cookies and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. We use session cookies to make it easier for you to navigate our Web site. A persistent cookie is a small text file stored on the user’s hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions. 

By setting a persistent cookie on our site, users would not have to log in a password more than once, thereby saving time while on our site. If users reject the cookie, they may still use our site. The only drawback to this is that the user will be limited in some areas of our site. Persistent cookies enable us to track and target the interests of our users to enhance the experience on our site. See the “Profile” section, above. 

Technologies such as tags, scripts, local shared objects and local storage are used by JetSend and our partners, affiliates or analytics or service providers. These technologies are used in analyzing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. 

5) Log Files 
Like most Web sites, our servers use log files to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information. 

6) Clear Gifs 
Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. Clear gifs are not tied to users’ personally identifiable information. 

We also use clear gifs in our HTML-based emails to let us know which emails the recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, please see the Opt-out section. 

7) Online Behavioural Advertising 
We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here. 

8) Children’s Privacy 
We do not knowingly collect personally identifiable information from children under the age of 13. If we learn that we have personally identifiable information on a child under the age of 13, we will delete that information from our systems. JetSend encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer: 

Teach kids never to give personally identifiable information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc. Know the sites your kids are visiting and which sites are appropriate. Look for Web site privacy policies. Know how your child’s information is treated. 

Check out the FTC’s site for more tips on protecting children’s privacy online. 

3) Information Use and Sharing of Information 

JetSend acts as a passive conduit for the distribution and receipt of its user’s e-mail communications and therefore will not monitor, edit, or disclose the contents of a user’s private communications unless JetSend in good faith believes that such action is necessary to: (1) conform to the edicts of the law or comply with legal process served on JetSend; (2) protect and defend the rights or property of JetSend; or (3) act under exigent circumstances to protect the personal safety of its users or the public. Users should also be aware (and hereby agree) that certain technical processing of and access to email messages and their content may be required to: (a) route the messages; (b) conform to connecting networks’ technical requirements; (c) prevent or minimize disruptions to JetSend’ services; or (d) conform to other similar requirements. 

Subject to the legal exceptions listed in the Privacy Policy, JetSend will not disclose to third parties the email addresses uploaded to our Web sites by our users for the purpose of using JetSend products or services. 

1) Communications from the Site 

1. a) Special Offers, Free Trials and Updates
   We send all new customers welcoming emails and may communicate with them to introduce and explain their new services. Visitors to our website that are not customers but provideJetSend with contact information may receive emails from JetSend that contain information about our services, special offers and other promotions. Established users will occasionally receive emails containing information about us, updates on new service features, service usage tips, information about third party services or other JetSend services that are likely to be of interest to our users, and customers satisfaction questions. Visitors and JetSend users may opt-out of such notices. Please see the Choice and Opt-out sections. We may contact former customers to gather feedback on the services. 
2. b) Invoices and Account Statements
   We send all customers regular emails summarizing usage and credit card charges. These emails are a part of theJetSend service, and users cannot opt-out of receiving them, though they can deactivate their account. Information identifying the credit card is not included in these communications 
3. c) Service Announcements
   On rare occasions it is necessary to send out a strictly service related  For instance, if our service is temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature. 
4. d) Customer Service
   We communicate with users on a regular basis to provide requested services and regarding issues relating to their accounts. We reply via email or phone, in accordance with the users wishes.
5. e) Surveys
   Periodically, our site requests information from users via surveys. Participation in these surveys is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address), and demographic information (such as zip code). Survey information will be used for purposes of monitoring or improving the use and satisfaction of JetSend’s  Users’ personally identifiable information is not shared with third parties unless we give prior notice and a choice to opt-out. Though we may use an intermediary to conduct these surveys, they may not use customers’ personally identifiable information for any secondary purposes. 
6. f) Referral Programs
   Periodically,JetSend offers referral services, asking a user to inform a friend about our service. We collect the name and email address of the friend, and will automatically send an email invitation to the friend. JetSend stores this information for the sole purpose of sending this email and tracking success of the programs. Your friend may contact us at support@JetSend.com to request that we remove this information from our database. 

2) Sharing 

We will share your personally identifiable information with third parties only in the ways that are described in this privacy policy. We do not sell your personal information to third parties. 

1. a) Legal Disclaimer
   Though we make every effort to preserve user privacy, we may need to disclose personally identifiable information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our Web site. For example,JetSend may disclose personally identifiable information to law enforcement, other government officials, or third parties in response to criminal or civil subpoenas. Sometimes, these requests come from our third party Internet, telecommunications and service providers all over the world who supply the network required for us to deliver our services. In order to maintain the integrity of our network, we often cooperate with requests from these third party providers and/or requests from law enforcement or other governmental officials directed to these providers. 
2. b) Aggregate Information (non-personally identifiable)
   We may share aggregated demographic information with our partners. This is not linked to any personally identifiable information.
3. c) Third Party Intermediaries
   We use an outside credit card processing company to bill users for goods and services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes.
4. d) Business Transitions
   In the eventJetSend goes through a business transition, such as a merger, or acquisition by another company, or selling a portion of its assets, users’ personally identifiable information will, in most instances, be part of the assets transferred. Users will be notified prior to a change of ownership or control of their personally identifiable information. If as a result of the business transition, the users’ personally identifiable information will be used in a manner different from that stated at the time of collection they will be given a choice not to have their information used in this different manner, as described in the notification of changes section, below. 
5. e) Spam
   JetSenddoes NOT share your email address externally. While we cannot be responsible for external communications received through JetSend services, if we are given notice that a JetSend Service is being used for spam, then we will deactivate that client. 

4) Choice/Opt-out 

JetSend users and visitors who do not wish to receive our promotional communications may opt-out from receiving these communications by clicking the opt-out link included at the bottom of every promotional message. 

JetSend users may not opt-out of receiving invoices and usage information, service announcements, and customer service communications, although they can deactivate their account. 

5) Links 

JetSend’ Web sites contain links to other sites. Please be aware that JetSend is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our sites and to read the privacy policies of each and every Web site that collects personally identifiable information. This privacy policy applies solely to information collected by JetSend’ Web sites. JetSend has advertising and affiliate relationships with dozens of third party sites that drive interested parties to our sites. Information that is collected on these sites does not fall within the auspices of this policy. JetSend has Co-Brand relationships with some websites. A site is a Co-Brand of JetSend if it offers JetSend technology or services to its users under a different brand. The Co-Branded sites will have their own privacy policies specific to each site, and the user should read them carefully before registration. 

6) Testimonials 

We display personal testimonials of satisfied Clients on our Web site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at support@JetSend.com. 

7) Social Media Widgets 

Our Web site includes Social Media Features, such as the Facebook and Twitter button or interactive mini-programs that run on our Web site. These Features may collect your IP address, which page you are visiting on our Web site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Web site. Your interactions with these Features are governed by the privacy policy of the company providing it. 

8) Safeguards and Data Retention 

1) User Information 
JetSend takes every precaution to protect its user’s information. When users submit sensitive information via JetSend’ Web sites, their information is protected both online and off-line. 

When our registration/order forms ask users to enter sensitive information (such as credit card number) and when you log in to our platform (such as login credentials), that information is encrypted and is protected with the best encryption software in the industry – SSL. While on a secure page, such as our paid order form, the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just ‘surfing’. 

While we use SSL encryption to protect sensitive information online, we also employ security measures to protect user- information off-line. All of our users’ information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerks or a customer service representative) are granted access to personally identifiable information. Finally, the servers that store personally identifiable information are in a secure environment. 

No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at support@JetSend.com. 

2) Message Content Handling 
We will store your personal transmissions on our servers for a limited time and will endeavor to purge old transmissions from its servers when the expiration period has run out (up to 365 days).We use industry-standard efforts to safeguard the confidentiality of your transmissions (as well as your personally identifiable information), such as firewalls and SSL technology. These are the same technologies that most websites use to safeguard credit card information and other personally identifiable information. However, that said, “perfect security” does not exist over telephone lines and the Internet and JetSend accordingly accepts only limited liability for security breaches. 

3) Data Retention 
The time period for which we keep information varies according to what the information is used for. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed. 

9) Supplementation of Information 

In order for JetSend to properly fulfill its obligations to users and understand our customer demographics it is necessary for us to supplement the information we receive with information from 3rd party sources. JetSend verifies the billing address on all credit card transactions and may obtain credit reports for some corporate customers. The information obtained from these third party sources is maintained in a manner consistent with JetSend’ Privacy Policy. 

10) Correcting/Updating/ Deleting/ Deactivating Personally Identifiable Information 

If a user’s personally identifiable information changes (such as zip code, phone, email or postal address), or if a user no longer desires our service, we provide a way to correct, update or delete/deactivate users’ personally identifiable information by contacting JetSend Customer Service at support@JetSend.com or by making the change on our member information page or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request to access within 30 days. 

11) Information Related to Data Collected through the JetSend Service 

Information Related to Data Collected for our Clients 
JetSend collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personally identifiable information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients. 

Access and Retention of Data Controlled by our Clients 
JetSend has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the JetSend’s Client (the data controller). If requested to remove data we will respond within 30 days. 

We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. JetSend will retain this personally identifiable information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. 

12) Notification of Changes 

If we decide to change our privacy policy, we will post those changes in this privacy policy, and other places we deem appropriate, so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected. 

If, however, we are going to use users’ personally identifiable information in a manner different from that stated at the time of collection we will notify users via email prior to the change becoming effective. Users will have a choice as to whether or not we use their information in this different manner. However, if users have opted out of all communication with the Web site, or deleted/deactivated their account, then they will not be contacted, nor will their personally identifiable information be used in this new manner. In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our Web site notifying users of the change. In some cases where we post a notice we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices. 

13) General Data Protection Regulation (GDPR) 

JetSend processes personal information (“Processor”) on behalf of our clients who themselves (“Controllers”) and/or their customers (“Data Subjects”) are under the jurisdiction of the European Union. GDPR requires all Controllers facilitate the exercise of Data Subjects rights under Articles 15 to 22. JetSend, as a Processor, is fully able to comply with the exercise of those rights whether through our software, or upon notification of our clients. 

JetSend is also a Controller of personal information of Data Subjects who have given us their express consent to receive promotional communications. Data Subjects wishing to exercise their Right to Erasure must submit a written request to privacy@JetSend.com and include the following information: first name, last name, and email address (and/or mobile device number). JetSend shall erase a Data Subject’s Personal Data within 30 days from receipt of the written request. In cases where compliance cannot be satisfied within this time frame, JetSend shall extend the compliance deadline an additional two months. If this extension is required, then JetSend shall inform the Data Subject within the initial 30 day period along with an explanation of the reason. In cases where Personal Data is not required for statistical purposes, it shall be purged from the system. In cases where Personal Data is required for statistical purposes, it shall be pseudonymized in accordance with Article 89 Paragraph 1. 

14) California Consumer Privacy Act (CCPA) 

Under the provisions of the CCPA, natural residents of the State of California have the right to request information regarding personal data collected about them, and to request that their personal data not be resold.   

JetSend does not resell personal data to third parties. JetSend collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a resident of the State of California wishing to exercise your rights under CCPA, and a customer of one of our Clients, please contact the Client that you interact with directly. 

We do collect site visitor data and email opt-ins for our own marketing purposes. California residents may submit a request to JetSend by following the instructions defined on the Do Not Sell My Personal Information page.