Privacy Policy

    Introduction

    This privacy policy (“Policy”) is designed to inform users of the InboxPro tool, offered by Lashback, LLC (“LashBack” or the “Company”), about how LashBack gathers and uses Personal Information collected by us in connection with our services (“Services”). BY ACCESSING OR USING OUR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT USE THE SERVICES.

    We will take reasonable steps to protect user privacy consistent with the guidelines set forth in this Policy and with applicable U.S. laws.  

    In this Policy, “user” or “you” means any person using or otherwise benefiting from the Services or otherwise submitting Personal Information to LashBack. 

     

    1. What Information Do We Process?

    LashBack provides compliance and intelligence information to its digital marketer customers, and email inbox organization services to its consumer users, through its proprietary InboxPro tool.  Generally, based on permissions that our consumer users grant to LashBack, we collect business-to-consumer data to help us serve consumers and improve the practices of advertisers.   Our solutions range from monitoring compliance issues and email addresses, to competitive intelligence, to vetting and optimizing the practices of our partners.

    To provide these Services, LashBack locates, transmits, stores, and analyzes data provided by users.  Such data may include information that may be used to identify a natural person (“Personal Information”), as well as email content, metadata, or other information through emails that we process (“Non-Personal Information”).  In addition, we may collect data automatically through your use of our website, or through your filling out and submitting a webform.

    1. Personal Information

    We may process the following Personal Information in providing our Services, or through your submission of information to us through the use of a webform, email to us, or other communication you may provide us:

    • Name
    • Email
    • Address
    • Date of Birth
    • Social Security Number
    • Drivers’ License
    • Biometric information (such as a photo of you)
    • Race or demographic information
    • Employment data
    • Any other identifying information about you or others that may exist in the emails you allow us access to.
    • Non-Personal Information

    We may process the following Non-Personal Information in providing our Services:

    • Email content
    • Email metadata
    • Attachments in emails
    • Other User Data 

    Through your use of this website, we may capture and process Cookie and IP address information related to your device or devices.

    2. How Do We Use the Information We Collect?

    1. Personal Information

    We use the Personal Information that we receive when providing the Services in the following ways:

    • Using our proprietary algorithms, we filter out individual Personal Information to make sure we do not transmit or share any information that may be transactional or personal in nature.
    • From emails we then collect after the filtering process, we redact 
      1. addresses other than the sender’s address;
      2. clear name references;
      3. other Personal Information identified above.
    • We store all information we process, unless it is filtered out from our collection, for internal analytical purposes.
    • We separate emails that are marketing in nature from those that are non-marketing in nature.

    We only process such information if you have provided your explicit consent.

    We use Personal Information you may provide us voluntarily, such as through a webform or email you send to us, in order to communicate with you (including through marketing emails).

    1. Non-Personal Information 

    We use the Non-Personal Information that we receive when providing the Services to analyze, store, and transmit Non-Personal Information to our customers in order to report on compliance or intelligence consistent with our Services.

    1. User Data

    We collect and store User Data, such as cookies and IP address information, in order to provide the Service to you, and it may be used for the internal operational, product development, and administrative purposes of the Service.

    We use web tracking information to administer the Service and to understand how well our Service is working, to store your user preferences, and to develop statistical information on usage of the Service. This allows us to determine which features and content users like best to help us improve our Service, to personalize your user experience, and to measure overall effectiveness.

    1. Aggregate Information

    We will also create statistical, aggregated data relating to our users and the Service for analytical purposes. Aggregated data is derived from Personal Information, Non-Personal Information, and/or User Data, but in its aggregated form it does not duplicate or reveal any Personal Information or relate to or identify any individual. 

    3. What Information Do We Disclose to Third Parties?

    1. Personal Information and User Data

    We will not disclose Personal Information you provide us voluntarily, Non-Personal Data, or User Data, to any third parties except as follows:

    (i) to third party contractors engaged to provide Services on our behalf (“Contractors”), such as performing marketing, analyzing data and usage of the Service, hosting and operating the Service or providing support and maintenance services for the Service, or providing customer service. We enter into agreements with all Contractors that require Contractors to use the Personal Information they receive only to perform services for us; or

    (ii) when we have your consent to share the information, including with our digital marketing customers.

    1. Email Communications

    If you register and provide your email address, we will send you administrative and promotional emails. If you wish to opt out of these emails, you may do so by emailing privacy@lashback.com.

    1. Network Operators

    Use of the Service may involve use of third party internet or telecommunications providers. Such providers are not our contractors, and any information that a provider collects in connection with your use of the Services is not subject to this Privacy Policy. We are not responsible for the acts or omissions of these third parties.

    1. Legal Exception

    Notwithstanding the above, we may in any event use Personal Information and other information collected through the Service to the extent required by law or legal process, to resolve disputes, to enforce our agreements (including this Privacy Policy), or if in our reasonable discretion use is necessary to protect our legal rights or to protect third parties.

    1. Additional Disclosures

    We reserve the right to disclose any information we collect in connection with the Service, including Personal Information, (a) to any affiliate of Lashback or any successor to our business as a result of any merger, acquisition, asset sale or similar transaction; and (b) to any law enforcement, judicial authority, or governmental or regulatory authority, to the extent required by law or if in our reasonable discretion disclosure is necessary to enforce or protect our legal rights or to protect third parties.

    4. How Do We Secure Your Information?

    We have adopted reasonable physical, technical, and organizational safeguards against accidental, unauthorized, or unlawful destruction, loss, alteration, disclosure, access, use, or processing of Personal Information, Non-Personal Information, and User Data in accordance with this policy and applicable law. We process data in data centers located in the United States.  

    However, no internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures.

    5. Third Party Links

    During the course of using our Services or browsing our website you may encounter links to other websites or services.  LashBack is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our website and review the privacy statements of each third party website. This Privacy Policy applies solely to information collected by LashBack.

    6. Amendments to This Policy

    LashBack may modify or amend this policy from time to time. If we make any material changes in the way in which Personal Information, Non-Personal Information, and User Data is collected, used or transferred, we will notify you of these changes by modification of this Privacy Policy, which will be available for review by you at the Service. 

    7. How Long Do We Keep Your Information?

    We will only retain your Personal Information, Non-Personal Information, and User Data for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

    In some circumstances, we may anonymize your Personal Information so that it can no longer be associated with you, at which point it will no longer be treated as Personal Information.

    It is our policy to retain Personal Information, Non-Personal Information, and User Data for until such personal information is no longer necessary to deliver the Services and to delete such data thereafter.  

     

    8. Minors

     

    We do not knowingly collect, use, or disclose personal information from children under the age of 18 without prior parental consent, except as permitted by the Children’s Online Privacy Protection Act (“COPPA”). If you are a parent or guardian and believe we have collected information in a manner not permitted by COPPA, please contact us at privacy@lashback.com.

     

    9. Contact Us.

     

    If you have any questions regarding this policy or how we use your Personal Information, please contact us at privacy@lashback.com.

    EFFECTIVE: July 1, 2022

    LAST UPDATED: July 1, 2022