SEND13 Privacy Policy

  1. Introduction

This privacy policy (“Privacy Policy”) is intended to provide you with the specific details about how SEND13, LLC collects and processes your personal and personally identifiable information. SEND13 provides SMTP email services and email deliverability support (“Services”) and in connection with its Services, access to certain software (“Software”) through its Website. SEND13 is the data processor and data controller of all information collected through its Services.

You understand and agree that SEND13 may store and process your Personal Information on computers located outside of the European Union, including, but not limited to, in the United States and Canada. By using the Services, you agree to the collection and processing of your Personal Information outside of the European Union.

Before using the Services or providing information to us, please carefully review this Privacy Policy. By using or accessing the Services, you agree that we may collect and use your information in accordance with this Privacy Policy, as revised from time to time. If you have any questions or suggestions regarding our Privacy Policy, or if your personal information is not accurate or complete, please contact our Data Protection Officer at:

SEND13, LLC
30 N. Gould St. #4000
Sheridan, WY 82801

By providing SEND13 with your personal or personally identifiable data and using the Services, you warrant that you are over the age of thirteen (13). If you are younger than 13, please do not use the SEND13 Services and please do not provide personal information to us.

  1. Personal Information Collected

When you use the Services, we may collect personal or personally identifiable information from you (“PII”). PII may include any information capable of identifying an individual, but it does not include anonymized data.

We may collect and process the following categories of PII about you:

  • Financial Data. Financial Data includes credit card numbers, account details, and payment information. We process this data to communicate with you, to record and receive your payment for our Services. SEND13’s lawful ground for processing this is its legitimate business interests in administering and offering the Services.
  • Communication Data. Communication data includes any communication that you may send to us through the website, email, social media, or through the SEND13 Website. We process this data to communicate with you, to record logs of our communication, and to store information to respond to legal claims. SEND13’s lawful ground for processing this communication data is to respond to communications sent by you to us, to keep records of our communication, and to pursue or defend against legal claims.
  • User Data. User data includes data about how you use the Services and any data that you post to or authorize through the Services, such as your bounce rate, open rate, and other metrics related to email deliverability. We collect and process this data to operate the Services and improve performance. SEND13’s lawful ground for processing this user data is its legitimate business interests in administering and offering the Services.
  • Technical Data. Technical data includes data about your use of the Services, such as your IP address, your login data, your phone number, your mobile phone model, your operating system, your geolocation, and your time zone. SEND13 collects this data from your use of the Services and from Google Advertising IDs. SEND13 processes this data to analyze your use of the Services, to administer and secure the Services, to allow you to login through a third party social networking service, to deliver relevant content and advertisements, and to understand the effectiveness of SEND13’s advertisements. SEND13’s lawful ground for collecting and processing this technical data is its legitimate interests in administering and offering the Services and to grow its business and marketing strategy.
  • Marketing Data. Marketing data includes data about your preferences in receiving and interacting with advertisements on the Services. SEND13 collects this data from your use of the Services and from Google Advertising IDs. SEND13’s lawful ground for collecting and processing this marketing data is its legitimate interests in administering and offering the Services and to grow its business and marketing strategy.
  • Personally Sensitive Data. Personally sensitive data includes data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, union membership, or information about your health. SEND13 does not collect or use personally sensitive data in the Services.

SEND13 will only use your PII for the purpose for which it was collected. In the event that SEND13 needs to use your PII for an unrelated new purpose, SEND13 will provide you with notice of this new use and will explain the lawful ground for such processing. SEND13 may process your PII without your knowledge or consent where required or permitted by law.

SEND13 does not use your PII to automatically make any decisions or to create an automated profile about you.

  1. Collection of Data From Third Parties

SEND13 may collect data about you through cookies and other technologies. This helps SEND13 understand how you use the Services and to understand any patterns that may be associated with your use of the Services. This aids SEND13 in developing or improving its Services in response to your needs or wants.

SEND13 may use session or persistent cookies. Session cookies are only stored on your computer or mobile device during your use of the Services and are automatically deleted when you close your web browser. Persistent cookies are stored as a file on your computer or mobile device that remain on your computer or mobile device even after you close your web browser. Persistent cookies can be read by the website that created the cookie when you revisit it again. SEND13 may use persistent cookies when it utilizes Google Analytics or other analytics providers, which is intended to track the origin and behavior of traffic to the Services.

SEND13 may also receive data from third parties including analytics providers or advertising networks such as Google, Facebook, or Apple. These third parties may be based outside of the European Union.

  1. Marketing Communications

As stated above, SEND13’s lawful ground for sending you marketing communications is either consent or its legitimate business interests, such as to grow its business. SEND13 may send you marketing communications if you have asked for information concerning its goods or services or if you have agreed to, and have not opted out from, receiving marketing communications. You may ask SEND13 to stop sending you marketing messages at any time by logging into the Services to adjust your marketing preferences or by following the opt-out link in any marketing message sent to you. If you opt out of receiving marketing communications, your opt-out does not extend to PII provided for other purposes.

  1. Disclosure of Personal Information

SEND13 may share your PII with the following parties:

  • Other companies within the SEND13 group of companies that provide services to SEND13;
  • Service providers that provide SEND13 with information technology or other administrative services;
  • SEND13’s accountants, auditors, insurers, or attorneys; and
  • Government bodies that require SEND13 to report its processing activities.

SEND13 may also transfer PII to third parties when it sells, transfers, or merges any part of its business or assets.

SEND13 requires all third parties that receive a transfer of PII from SEND13 to maintain the same level of respect for the protection of PII as SEND13 and SEND13 only allows third parties to process your personal data for the specific purposes listed in this privacy policy.

  1. Transfers of PII Outside of European Union

SEND13 may transfer your PII to countries outside of the European Union, which may not offer the same level of protection for your PII. Many of SEND13’s third party service processors are located in the United States and their processing of PII will involve a transfer of data outside of the EU. Whenever PII is transferred outside of the EU, SEND13 does its best to ensure a similar degree of security by transferring your personal data to countries that the European Commission has approved as providing an adequate level of protection, by utilizing contracts approved by the European Commission, or by using US-based providers that are a part of the EU-US Privacy Shield.

  1. Data You Collect

SEND13 allows its users to import certain information they have collected from their own email list subscribers into its Website, Software, or Services. This data is not accessed by, reviewed, or analyzed by SEND13 and SEND13 has no formal relationship with its user’s subscribers. Consistent with SEND13’s Terms of Use [insert link], you are solely responsible for your own compliance with applicable laws, including privacy laws, to permit SEND13 to perform its Services. If a SEND13 user has a subscriber that contacts SEND13 directly, we will refer that subscriber to you to take the appropriate action.

  1. Data Security

SEND13 has put into place data security measures to protect your PII. SEND13 allows access to your PII only by employees and service providers who have a need to know or access your PII on SEND13’s instructions. SEND13 will notify you and any regulatory body of any breach of your PII or SEND13’s security measures if it is legally required to do so.

  1. Retention of Data

SEND13 will only retain your PII for so long as necessary to fulfill the purposes for which it is collected under this Privacy Policy or for the purposes of satisfying any legal, accounting, or reporting requirements.

  1. Right to Access

Under the law, you may have a right to request access to your PII for correction, transfer, erasure, or restriction, or to object to its processing or withdraw your consent. If you wish to exercise any of these rights, please contact SEND13’s Data Protection Officer as disclosed in this Privacy Policy.

You do not need to pay a fee to access your PII or to exercise your rights. However, SEND13 may charge a reasonable fee if your request is unreasonable or excessive.

To confirm your request, SEND13 may need to request specific information from you as a security measure to ensure that PII is not disclosed to an unauthorized third party. SEND13 will attempt to respond to all legitimate requests within thirty days.

  1. Third Party Links

SEND13’s Services may include links to third party websites and applications. By clicking on third party links, you may allow third parties to collect or share data about you. SEND13 does not control these third-party links and you are advised their respective privacy policies.

  1. Responding to Do Not Track Signals

You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website. Our websites are not currently set up to respond to browser do-not-track signals, but you can configure your browser settings to reject all cookies or prompt you before a cookie is set.

  1. California Privacy Rights

California residents have the right to receive information that identifies any third-party companies or individuals that SEND13 has shared your Personal Information with in the previous calendar year, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information once a year and free of charge by contacting SEND13 at admin@SEND13.com.

  1. Notification of Changes

Whenever SEND13 Ltd changes its Privacy Policy, we will post those changes to this Privacy Policy and other places that we deem appropriate. Your use of the SEND13 Services following these changes indicates your consent to the practices described in the revised Privacy Policy.

  1. Contact Us

If you have any questions about this Privacy Policy or the manner by which we collect or use Personal Information about you, email us at admin@SEND13.com.

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