1. Introduction

The aim of this Privacy Policy is to provide an overview of the privacy practices exercised by Apvera with respect to:
• Websites that Apvera operates, including, and
• Emails that Apvera receives, including emails to the email domain.

2. What Information Does Apvera Collect?

Personal data and information (“Personally Identifiable Information” or “PII”) refers to information that can be used to identify an individual. This may include, but is not limited to:

• Your name
• Your email address
• You billing information
• Other data which can be reasonably linked to such information by Apvera

Apvera requests and uses personal information when you create an account, authorize end users, request or operate a Apvera Service, correspond with Apvera, or engage in other activities on its websites. You are under no obligation to provide this information but you may not get the full benefit of our services without providing the requested information.

For example, if you request technical support online or via telephone, Apvera will ask you for information necessary to authenticate you as a customer or end user, and to provide the requested support. Information that may be asked for includes your name, your address, information about your computer hardware and software, and the nature of the problem you are experiencing.

Apvera uses the personal information we collect about you in a number of ways. These may include but are not limited to:

• Fulfilling your request for provision of the Apvera Services;
• Updating you with relevant information concerning the Apvera Services;
• Making important service announcements, including notification of any changes to the website and/or Apvera Services;
• Contacting you about your use of the website or about our products and services;
• Responding to your comments or requests;
• Maintaining a record of the relationship between email addresses to ensure that the relationship you are developing is maintained over time regardless of the individual employee it was established with;
• Verifying and re-verifying the identity of senders;
• Requesting feedback and to enable us to develop and improve the website and our products and services;
• Internal and Apvera specific marketing/promotional purposes including newsletters, which may include advertisements; and
• Determining whether you have received or opened an email message received from Apvera, or clicked a link within a message.

Non personally identifiable information, or non-personal information, refers to information that is recorded about users in such a way that it no longer reflects or references an individually identifiable user. This is sometimes also referred to as “anonymized” or “aggregated” data.

As is true of most websites, Apvera may also automatically collect conventional web-server logs. This information includes

• Internet protocol (IP) addresses,
• Browser type,
• Internet service provider (ISP),
• Referring/exit pages,
• Operating system,
• Date/time stamp, and
• Clickstream data (URLs).

These logs are automatically deleted after a short period of time.

3. Children’s Privacy

Apvera does not knowingly collect personal information from children under the age of 13. If it is discovered that personal information from a child under the age of 13 has been collected, it will be deleted. We encourage parents to go online with their children and to talk with their children about the dangers of communicating with strangers and disclosing personal information online.

4. Rights and Responsibilities

If you have given your personal information to Apvera, you have the right to ask us to advise you of the scope of information Apvera processes about you, the purpose and nature of the processing, and information on who we share it with.

If you have given us your personal information, you can also request to update, correct, or delete (assuming that this does not impact the services we are providing to you) it at any time. In addition, you can opt out of marketing contact upon request, as explained below. If have any questions about this policy or any of the above, please contact us.

Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort, in which case we may assess a fee. If a fee is required, we will inform you.

5. Opt Out of Direct Marketing

We always provide you with the opportunity to unsubscribe from communications you have previously requested. You may also opt-out of sharing your information with third parties. Each email communication from us explains how to do this.

6. Links to Other Companies

Through links on the Apvera website and user services portals, you may interact with a number of service partners with whom Apvera has a relationship to provide information and/or commercial e-mail services to its customers and end users.
Apvera expects that personal information provided to partners will be protected under policies at least as strict as Apvera’s own privacy policies, however Apvera does not exercise control over the partner sites. Please be aware that Apvera is not responsible for the privacy practices of such other sites. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Apvera strongly encourages you to review the privacy policies posted on these (and all) third-party sites, as they may differ from Apvera’s in some particulars.

7. Co-branded Websites

We may also link to co-branded websites that are maintained by Apvera and one or more of our business partners. Please note that these co-branded websites may have their own privacy policy, which we encourage you to read and understand.

8. Security

The security of your personal information is of critical importance to Apvera. Apvera has taken certain technical and procedural steps to try and safeguard your personal information from misuse, unauthorized disclosure, and/or loss or destruction. When you enter information on a Apvera registration or order form, Apvera encrypts that information using secure socket layer technology (SSL). Once collected, personal information is stored in secure data centers typically located in Australia, Singapore, Ireland, US or the UK, where reasonable steps are taken to protect it.

For sensitive data that has been stored, procedures are implemented with the principle of least privilege in mind, in particular through granular access control so that only the specific people who need access to a particular piece of information have that access. For example, where a CRM integration has been performed, the CRM will only display active relationship information about a particular account to the designated account manager and any additional individuals who have appropriate privileges with respect to that particular account.

Apvera’s services are delivered with the aid of multiple hosting providers worldwide. We deal exclusively with substantial, mature hosting providers who have robust and comprehensive security arrangements and operate in jurisdictions in which contractual obligations can be legally enforced.

Apvera follows generally accepted industry standards to protect the personal information submitted to it, both during transmission and once it is received. However, no method of transmission over the Internet, or method of electronic storage is totally secure. Therefore, while Apvera takes reasonable steps to protect your personal information, Apvera cannot guarantee its absolute security.

Further, access to your personal information is limited to people who need it to do their job. These people may include contractors who have been engaged by Apvera to undertake the collection, transferring, storage and processing of your information. All Apvera staff members periodically affirm their understanding of their obligations to protect personal information and are aware that they may be subject to discipline, including termination and criminal prosecution, if they fail to meet their confidentiality obligations.

Similarly, Apvera requires its service partners and contractors to keep the personal information of customers secure and confidential. Apvera also requires that these contractors and service partners use your account and personal information only on behalf of Apvera and/or to suggest enhancements to your use of its website.

Apvera adheres to M3AAWG best practices for email. As part of its ongoing commitment to leadership in online privacy, Apvera is also a member of various industry alliances. These include:

• the Messaging, Malware and Mobile Anti-Abuse Working Group (M3AAWG)
• the Singapore Infocomm Trade Federation (SiTF), and
• the Open Information Security Foundation (OISF).

9. Data Integrity and Retention

Apvera will not retain your personal information longer than is necessary for the purposes for which it was collected.

10. Do We Use Cookies or Web Beacons?

Yes, Cookies and Web Beacons are used for aggregated site analytics but not for collection of personal information. Google Analytics is used for this purpose so you are encouraged to read Google’s Privacy Policy. You may opt out of having your data by Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

Cookies or Web Beacons may also be used to link permission-based email activity with website activity to improve website and email campaign effectiveness. Cookies may also be used to track how you navigate the website during a session to optimize website design.

11. With Whom Do We Share Your Information?

Apvera will not sell (or rent) personal information to any third party. Apvera will not share personal information with other companies or individuals outside of Apvera, its parents, subsidiaries and/or affiliates other than in the following circumstances:

• Without your consent;
• If you register for services that are co-branded and/or offered in conjunction with another company, both Apvera and the other company may receive the information collected;
• If we have a good faith belief that such action is reasonably necessary to:
• Comply with any applicable law, regulation, legal process or enforceable governmental request,
• Protect any rights or property of Apvera, including the investigation of possible breaches of or enforcement of any of our agreements,
• Detect, prevent, or otherwise address fraud, security or technical issues, and/or
• Act in urgent circumstances to protect against imminent harm to the rights, property or safety of Apvera, its users or members of the public;
• If Apvera becomes involved in a merger, acquisition, any form of sale of some or all of its assets or liquidation of Apvera. Such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or receiving it from sellers. It is Apvera’s practice to seek appropriate protection for information in these types of transactions.

To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.

While Apvera may share aggregated statistical information (non-personal information) about users of the Apvera Services with third parties, including our data licensors, distributors, vendors, actual and potential customers, and third-parties that offer products or services for use with the Apvera Services, this information is not linked to any personal information (anonymized).

12. Acceptance and Changes to Privacy Policy

You acknowledge and accept that your use of the Site, email sent to Apvera or use of the Apvera Services indicates your acceptance of this Site’s Privacy Policy.

Apvera reserves the right to modify this privacy statement at any time. We will advise you of changes by posting on our website. When Apvera posts changes to this policy, the “last updated” date at the top of this policy will reflect the change.

If you have any questions regarding Apvera’s privacy policies or practices, please contact us.