Our Privacy Policy

Privacy Policy

This Privacy Policy was last updated: [07/12/22]

Our privacy policy tells you how Robly Digital Marketing (“we, “our” and “us”) uses personal information collected on the Robly website and through the use of the Robly services (“Services” or “Robly”). Please read this privacy policy before using the site or Services, or submitting any personal information. By using the site and/or Services, you are accepting the practices described in this privacy policy. These practices may be changed, but any changes will be posted and changes will only apply to activities and information going forward, not on a retroactive basis. Your continued use of our site signifies your continuing consent to abide and be bound by this privacy policy.

Please note that the practices set forth in this privacy policy are for us alone. If you link to other websites, please review the privacy policies posted at those sites.

Opt-out of Emails from this Sender

All email campaigns sent via Robly contain an Unsubscribe link to make it easy for you to remove yourself from a mailing list. To do so, simply click the link that says “Unsubscribe” in the footer of the email you receive.

Categories of Information We Collect

1. Information You Provide to Us: When you register to use Robly on a free or paid basis, communicate with customer service, or send us an email (collectively, “User”), you provide us with information that we collect. This information may include:

• your IP address
• name
• physical address
• email address
• phone number/cell phone number
• credit card information
• gender
• occupation
• other demographic information

By providing us with this information, you consent to your information being collected, used, disclosed and stored by us in accordance with this Privacy Policy.

1. List and Campaign Information: When you upload or create an email distribution list or put together a Robly Email Campaign, we have access to the data on your list and the information in your campaign. We may look at this data to ensure that your list and campaign content are in line with our Terms of Service.
2. Cookies: We may use cookie and tracking technology. Cookie and tracking technology are useful for gathering information such as your browser type, operating system, and IP address, which we use to track the number of visitors to our site, to  better understand how and when visitors use the site and to help secure User accounts at login. Cookies can also help us better customize our site for you. If you previously provided personally identifiable information, cookies may be tied to such information. However, only aggregate cookie and tracking information may be shared with third parties. We can also determine when you open an email we send you, and collect other data related to your interaction with the subject email.
3. Tracking Our Emails to Our Users: Occasionally we track who opened emails we’ve sent to our registered Users and who clicked on certain hyperlinks contained within. We do this to measure the performance of our Email Campaigns, and to improve what we offer to specific customer segments.

Use and Disclosure of Your Personal Information.

We will use and disclose your Personal Information only as follows:

1. To promote use, including continued use, of our Services. For example, if you leave your personal information when you visit our Website and do not sign up for any of the Services, we may send you one or more emails asking whether you wish to sign up. If you use any of our Services, and may benefit from using one or more other Services we offer, we may send you an email telling you about the other Service or Services.
2. For billing and collection. Uses for this purpose include sending you emails, invoices, receipts and notices of delinquency, to alert you if we need a different credit card number, and to otherwise try to collect money owed. We use third parties to handle secure credit card transaction processing and send billing information to such third parties, who maintain all information in confidence, to process your orders and credit card payments.
3. To send you System Alert Messages to let you know about temporary or permanent changes to our Services including planned outages, new features offered, version updates, point releases, major releases, abuse warnings, changes to our Privacy Policy and possibly other documents and agreements.
4. To help enforce compliance with our Terms of Use and applicable law including, but not limited to, helping to create white lists and black lists, to develop and test algorithms and other methods and tools for detecting violations and to apply those methods and tools.
5. To provide customer support and obtain feedback.
6. To protect the rights and safety of us and our employees, Members, owners, officers and others.
7. To meet legal requirements such as complying with court orders and valid subpoenas.
8. To provide information received to representatives and advisors such as attorneys and accountants to help us comply with legal and other requirements.
9. To prosecute and defend a court, arbitration or similar proceeding.
10. To support and improve our Services including adding features and other benchmarking comparison information derived from aggregating and analyzing data.
11. To communicate with you concerning your account for an informational, as opposed to promotional, purpose.
12. To transfer information in the event of the sale of substantially all of the assets of our business to a third-party or in the event of a merger, consolidation or acquisition. However, in such event, any acquirer will be subject to our obligations under this Privacy Policy.
13. To send you informational and promotional materials that you elect (“opt-in”) to receive.

Distribution Lists

Your recipient lists are stored on a secure server. We do not, under any circumstances, steal your lists, contact people on your lists, market to people on your lists, sell your lists, or share your lists with any other party, except as required by law or, regarding contacting, except in response to a complaint or other communication directly from an individual on one of your lists. Only carefully selected, authorized personnel have access to view Distribution Lists.

Data Collected by and for our Users

Users of Robly may collect personal information from subscribers or other individuals and import it into our system. We maintain no direct contact or relationship with your subscribers and you, as the account owner or user, are responsible for ensuring that you have collected the proper permissions for sending out email marketing to anyone on your list(s).  In addition, we may collect certain behavioral data associated with your subscribers’ interactions with the emails sent via the Robly Services on your behalf.  We will only use this data to optimize the Robly Services that we provide to you, and for no other purpose.

We will retain personal information we process on behalf of our paying subscribers for as long as needed to provide our services or to comply with legal obligations, resolve disputes, prevent abuse, and enforce our agreements.

General Data Protection Regulation (GDPR)

We process 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 that all Controllers facilitate the exercise of Data Subjects rights under Articles 15 (http://gdpr-info.eu/art-15-gdpr/) to 22 (http://gdpr-info.eu/art-22-gdpr/). We, as a Processor, are fully able to comply with the exercise of those rights upon notification from our clients. In connection with our activities as a Processor, we may collect certain behavioral data associated with Data Subjects’ interactions with the emails sent via the Robly Services on our clients’ behalf.  We will only use this data to optimize the Robly Services that we provide to our clients, and for no other purpose.  Where you, as a Controller, obtain such behavioral data Processing services from us, you represent and warrant that you have obtained all consents required by the GDPR (as well as any other applicable law, rule or regulation) to permit us to perform such Processing services on your behalf.

We are also a Controller of personal information of Data Subjects who have given us their express consent to receive promotional communications from us. Data Subjects wishing to exercise their Right to Erasure must submit a written request to support@robly.com and include the following information: first name, last name, and email address. We 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, we shall extend the compliance deadline an additional two months. If this extension is required, then we shall inform the Data Subject within the initial 30 day period along with an explanation of the reason for the extension. 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 (http://gdpr-info.eu/art-89-gdpr/) Paragraph 1.

Public Information and Third Party Websites

1. Blog. We have a public blog on our website. Any information contained in a comment you post may be read, collected, or used by anyone. If you want your personal information removed from any blog post comment, contact us at support@robly.com. If we’re not able to remove this information, we will tell you why.
2. Social media platforms and widgets. Any information or materials you share with us via a social media platform such as Facebook, Twitter, and Instagram is done at your own risk without any expectation of privacy. Certain built-in tools, such as Facebook’s Like button, may collect information such as IP address, location, or which page you’re visiting on our website via use of cookies.
3. Third party website links. Our Website includes links to other websites. The privacy policies of these third party sites may differ from our own. If you submit Personal Information to those sites, it is subject to their privacy policies.

Third Parties

We may disclose Personal Information to the following types of third parties for the purposes described in this policy:

1. Service Providers. We may share your information with our third party Service Providers, who help us provide and support our Services. For example, if it is necessary to provide something you have requested (such as a referral account), then we may share your and/or your subscribers’ Personal Information with a Service Provider solely for that purpose. Examples of Service Providers include payment processors and hosting services.

Commitment to Data Security

Your personally identifiable information is kept secure. Only authorized employees, agents and contractors (who have agreed to keep information secure and confidential) have access to this information. All emails and newsletters from this site allow you to opt out of further mailings.

• To protect your information, our credit card processing vendor uses the latest 128-bit Secure Socket Layer (SSL) technology for secure transactions. In addition, our vendor is certified as compliant with card association security initiatives, such as the Visa Cardholder Information Security and Compliance (CISP), MasterCard® (SDP), and Discovery Information Security and Compliance (DISC).
• Robly accounts require a username and password to log in. When you’re finished using our Site, please make sure you log out by clicking the link in the top right hand corner of the screen to prevent someone from using your computer to access your account. Keep your username and password secure and not disclose it to a third party.
• Due to the sensitive nature of your Distribution Lists, we do not re-send forgotten passwords. Users must follow online instructions to reset their passwords if they are forgotten.
• Account passwords are encrypted. We cannot see your passwords. We can only reset them.

Breach of Security

We will notify you as soon as possible should a breach in security result in an unauthorized intrusion into our system which materially affects you or people on your Distribution Lists, and will subsequently report the corrective action taken in response to the intrusion.

Email Campaign Content

Email marketing simply isn’t 100% confidential. As it travels through the information superhighway, different server administrators can read the content. That being said, if you have something confidential to send, don’t use the Robly Services. Occasionally we will review the content of Email Campaigns to ensure that they comply with our Terms of Use using software and algorithms. We then have employees or independent contractors review those particular Email Campaigns. This practice benefits all Members who are in compliance with our Terms of Use because, among other things, it reduces SPAM being sent through our servers which helps to ensure high deliverability.

Privacy Contact Information

If you have any questions, concerns, or comments about our privacy policy you may contact us using the information below:

By e-mail: support@robly.com We reserve the right to make changes to this policy. Any changes to this policy will be posted.

Anti Spam Policy

Credit

This document was created using a Contractology template available at http://www.freenetlaw.com.

What is spam?

In the context of electronic messaging, spam refers to unsolicited, bulk or indiscriminate messages, typically sent for a commercial purpose.

We have a zero-tolerance spam policy.

Automated spam filtering

The Robly messaging systems automatically scan all incoming email messages, and filter-out messages that appear to be spam.

Problems with spam filtering

No message filtering system is 100% accurate, and from time to time legitimate messages will be filtered-out by the Robly systems.

If you believe this has happened to a message you have sent, please advise the message recipient by another means.

You can reduce the risk of a message being caught by the spam filters by sending the message in plain text (i.e. no HTML), removing any attachments, and ensuring that your messages are scanned for malware before dispatch.

User spam

We provide a facility that enables users to send electronic mail to others. Users must not use this facility to send unsolicited, bulk or indiscriminate messages, whether or not for commercial purposes. Full terms and conditions concerning the use of the facility are set out in our Terms of Service.

Receipt of unwanted messages from Us

In the unlikely event that you receive any message from us or sent using the Robly systems that may be considered to be spam, please contact us using the details below and the matter will be investigated.

Changes to this anti-spam policy

We may amend this anti-spam policy at any time by publishing a new version on this website.

Contact us

Should you have any questions about this anti-spam policy, please contact us using the details set out below:

support@robly.com

 Provisions for California Residents

These Provisions for California Residents (“Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above. These Provisions apply solely to residents of the State of California who are Users of Robly (“CA Users”). We adopt these Provisions in compliance with the California Consumer Privacy Act (“CCPA”). Any terms defined in the CCPA have the same meaning when used in these Provisions. CA Users with disabilities who wish to access these Provisions in an alternative format can contact us by using one of the contact methods provided below. 

These Provisions do not apply when we are a service provider and process personal information on behalf of our Users’ subscribers or end users. If you are a subscriber or end user of one of our Users and you want to exercise your rights under the CCPA, we recommend you contact our User directly. 

We collect personal information from Users who have explicitly given prior opt-in consent. Categories of personal information include name, postal address, email address, and internet protocol address.

CA Users have the right:

• To know the categories and specific pieces of personal information that has been collected.
• To know the categories of sources from which the personal information is collected.
• To know the categories and specific pieces of personal information that has been collected in the preceding 12 months.
• To know the categories of personal information that have been sold in the preceding 12 months, and the categories of third parties to whom the personal information was sold.
• To know the categories of personal information that have been disclosed in the preceding 12 months for a business purpose.
• To request that any personal information that we have collected be deleted.
• To withdraw their prior consent to the resale of their personal information to third parties.

CA Users may receive, free of charge, their requested information either by calling 1-855-557-6259 or by sending an email to support@robly.com. We will respond within 45 days of receiving a verifiable request. CA Users are required to provide sufficient verification at time of request that enables us to confirm the legitimacy of the request.

The time period to provide the requested information may be extended once by an additional 45 days when reasonably necessary. If such an extension is required, we will notify the consumer of the extension within the first 45-day period.