Last updated: 1/23/2017

1. Notice

We at Persado, Inc. (“Persado,” “we,” “us,” or “our”) created this Privacy Policy (“Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy explains the conditions under which and the purposes for which we collect and use your Personal Information in connection with your use of our services through integrations with email service providers (“ESP Integrations”), the website located at (“Site”) and any client portal or any other services we offer (“Other Services”), the third parties to whom we disclose your Personal Information, and the choices and means, if any, we offer you for limiting the use and disclosure of your Personal Information. We will provide you with notice of such practices in clear and conspicuous language when you are first asked to provide Personal Information to us, or as soon as practicable thereafter, and in any event before: (a) we use your Personal Information for a purpose other than that for which it was originally collected; (b) your Personal Information is processed by a transferring organization; or (c) we disclose your Personal Information for the first time to a third party. As discussed in this Privacy Policy, we will disclose your Personal Information as described in Section 5 (“How We Disclose Your Information/Onward Transfer”).

EU-U.S. Privacy Shield.

Persado participates in and working on self-certifying in compliance with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all Personal Information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the applicable Privacy Shield Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

Persado is responsible for the processing of Personal Information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of Personal Information from the EU, including the onward transfer liability provisions.

With respect to Personal Information received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you are unable to resolve the issue directly with us, you may file, free of charge, a complaint with our independent dispute resolution provider, JAMS located in the United States. For more information about JAMS dispute resolution process or to file a complaint, please visit:

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

The procedures for modifying or changing this Privacy Policy in the future are discussed in Section 9 below.

2. Important Information for Non-U.S. Residents.

If you are located outside of the United States, please be aware that any information you provide to us may be transferred to the United States. By providing us with any information, you consent to this transfer.

3. Information We Collect.

We collect both Non-Personal Information and Personal Information from you. “Non–Personal Information” is information that, without the aid of additional information, cannot be directly associated with a specific person or entity. “Personal Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person or entity.

A. Collection of Personal Information.

We collect Personal Information from you if you voluntarily provide it to us. When you sign up to use the ESP Integrations, you will be asked to provide us with certain Personal Information, such as your name, telephone number, company name (if applicable), and email address. If you choose to pay us via credit card, our third party contractor will collect and process your credit card information subject to its policies and practices. Please see Section 11(B) for more information about our third party credit card processor’s policies and practices.

If you choose to contact us via our Site, you will provide us with your name, email address and any other Personal Information you choose to include in your message to us. We may also collect Personal Information in connection with our Other Services.

B. Collection of Non-Personal Information.

Like most web sites, we use automatic data collection technology when you use the ESP Integrations, the Site and our Other Services to record information that identifies your computer, to track your use of the ESP Integrations, our Site and our Other Services, and to collect certain basic information about you and your usage habits. This information includes information about your operating system, your IP addresses, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of the ESP Integrations or the Site you visit, and similar information concerning your use of the ESP Integrations, the Site or our Other Services (the “Usage Information”). We collect this Usage Information by using cookies and pixel tags (also called web beacons or clear gifs).

4. How We Use Your Information

A. Personal Information.

We will use your Personal Information for any purpose related to our business, including without limitation the following: (i) to respond to your requests and to provide you with the Site, the ESP Integrations and our Other Services; (ii) to respond to your inquiries and contact you about changes to the Site, the ESP Integrations or our Other Services; (iii) to send you notices (for example, in the form of e-mails, mailings, and the like) regarding products or services you are receiving; (iv) for billing and collection purposes; (v) to improve the ESP Integrations; (vi) to contact you regarding other products or services we offer; (vii) for any other purposes disclosed at the time the information is collected or to which you consent; and (viii) as otherwise specifically described in this Privacy Policy.

We may also use your information to improve our ESP Integrations, and we may use cookies and other information to enable us to customize your user experience.

B. Data Integrity.

We will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you as set forth in this Privacy Policy. We will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current.

C. Non-Personal Information.

We analyze Non–Personal Information gathered from users of the Site, the ESP Integrations and our Other Services to help us better understand how this Site, the ESP Integrations and our Other Services are being used. By identifying patterns and trends in usage, we are able to better design this Site, the ESP Integrations and our Other Services to improve your experiences, both in terms of content and ease of use. We link information gathered using Non-Personal Information to Personal Information. Automatic data collection may be performed on our behalf by our services providers.

5. How We Disclose Your Information/Onward Transfer.

A. Personal Information

As described in Section 3 (“Information We Collect”), users may, at their option, disclose their own Personal Information by any means they choose. We will disclose Personal Information in the following circumstances:

B. Choice

Users located in the EU may direct us not to disclose their Personal Information to third parties (other than our service providers). We do not use Personal Information for purposes incompatible with the purposes for which we originally collected the information without notifying the relevant individuals of such uses and offering an opportunity to opt out.

Notwithstanding the foregoing, we may disclose Personal Information without offering individuals the opportunity to opt out for the reasons described in more detail in Sections 5(A)(iv) (“By Law, to Protect Rights and to Comply with Our Policies”) and 5(A)(v) (“Business Transfers; Bankruptcy”) above.

C. Non-Personal Information

From time to time, we may also release the Non–Personal Information gathered from ESP Integrations, Site and Other Services users in the aggregate, such as by publishing a report on trends in the usage of the ESP Integrations, the Site and our Other Services.

6. Security.

We maintain generally accepted administrative, technical and physical safeguards to protect and secure your information and information processed within the ESP Integrations from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, both during transmission and once it is received. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, email sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via email.

7. Accessing and Modifying Account Information.

We acknowledge that you have the right to access to your personal information. We have no direct relationship with Consumers whose Personal Information we process. A Consumer who seeks access, or who seeks to correct, amend, or delete inaccurate Personal Information should direct his query to our client, the data controller. If requested to remove data by the data controller, we will respond within a reasonable timeframe.

Upon request, we will grant customers reasonable access to Personal Information that we hold about them for the purpose of correcting, amending, or deleting such Personal Information where it is inaccurate; provided, however, that we reserve the right to deny access or limit access in cases where the burden or cost of providing access would be disproportionate to the risks to your privacy or in the case of a vexatious or fraudulent request. We will respond to requests for access to Personal Information within a reasonable timeframe.

We will retain Personal Information and Consumer Personal Information for as long necessary to provide services, comply with our legal obligations, resolve disputes, and enforce our agreements.

ESP Integrations users may update Personal Information that is stored in their ESP Integrations user account by visiting the Settings page in the ESP Integrations. Site user may update their Personal Information by contacting our Chief Privacy Officer at the address provided in Section 13 (“How to Contact Us”) below.

8. Children

The Site and ESP Integrations are not intended for children under 13 years of age. We do not knowingly collect Personal Information from children under the age of 13. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Personal Information through the internet without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Information or any other information or content to us, please email us at, and we will endeavor to delete it from our databases. Please be advised, however, that the removal of such materials from our databases does not ensure complete or comprehensive removal of such materials from our ESP Integrations, the Site or any Other Services.

9. Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. Because of changes in technology and the growth and development of our business, or for other business reasons, we may need to change this Privacy Policy from time to time. We will alert you by email if this Privacy Policy is revised (if you have given us your email address), and we will post a copy of the new policy with its effective date on this Site. It is therefore important that you notify us if you change your email address. If you do not provide us with a current email address, you should regularly review this Privacy Policy to ensure that you are informed of any changes.

10. Online Tracking.

We currently do not process or comply with any web browser’s “do not track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit our Site or use our Other Services.

11. Collection and Use of Information by Third Parties.

A. General

The ESP Integrations, the Site and our Other Services may contain links to third party sites. We do not control or endorse such third party sites, and we are not responsible for the privacy practices of such sites. We are also not responsible for the privacy practices of Salesforce Marketing Cloud.

Third parties are under no obligation to comply with this Privacy Policy with respect to Personal Information that you provide directly to those third parties or that those third parties collect for themselves. This Privacy Policy does not apply to information provided to third-party sites or gathered by the third parties that operate them. Before visiting a third-party site, whether by means of a link on our ESP Integrations or Site or otherwise, and before providing any Personal Information to any third party, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that site, and should take those steps necessary to your discretion, to protect your privacy.

B. Third Party Collection of Your Credit Card Information

If you choose to submit materials to us, our third party credit card processor (currently Merchant e-Solutions) will process your credit card. All such transactions will be governed by the Merchant e-Solutions privacy policy at We do not receive or store credit card information on our servers. We receive a transaction “token” and a one-time use ID number so we can validate that the transaction has been successfully completed, areas of the ESP Integrations that collect your Personal Information use industry standard secure socket layer encryption; however, to take advantage of this your browser must support encryption protection.

C. Third Party Collection of Information for Analytics Purposes

We may use third party companies (currently including Google, mouseflow and mixpanel) to provide us with analytics information. These companies may collect Personal Information and Non-Personal Information from you via our Site and ESP Integrations. You can find out more information about what information Google, mouseflow and mixpanel collect and how they use and disclose that information here:;; and

13. Enforcement.

If we become aware that the security of the Site, the ESP Integrations or our Other Services has been compromised or your Personal Information has been disclosed to unrelated third parties as a result of external activity, including but not limited to security attacks or fraud, we reserve the right to take reasonable appropriate measures, including but not limited to, investigation and reporting, and notification to and cooperation with law enforcement authorities.

If we become aware that your Personal Information has been disclosed in a manner not permitted by this Privacy Policy, we will make reasonable efforts to notify you, as soon as reasonably possible and as permitted by law, of what Personal Information has been disclosed, to the extent that we know this information.

Individuals who wish to file a complaint or who take issue with our Privacy Shield Framework Principles should direct such communication to our Chief Privacy Officer via email or written communication at the address provided in Section 13 below. Our Chief Privacy Officer will explain the process to be followed when filing a complaint. Filing a complaint in English will expedite the process. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Policy.

Persado participates in the Privacy Shield Framework as set forth by the United States Department of Commerce. As part of our participation in the Privacy Shield, we have agreed to use JAMS for dispute resolution of disputes relating to our compliance with the Privacy Shield Framework.

Please click here for contact information. JAMS’s Dispute Resolution process is only available in English.

We are also subject to the jurisdiction of the US Federal Trade Commission. The Federal Trade Commission may be contacted at the following address:

Federal Trade Commission
Attn: Consumer Response Center
600 Pennsylvania Avenue NW
Washington, DC 20580

How to Contact Us.

If you have questions about this Privacy Policy, please contact us at:

Persado, Inc.
Attn: Chief Privacy Officer/
Privacy Shield Framework
11 East 26th Street
New York, NY 10010, U.S.A.