Data Processing

Data Processing

Data Processing

Effective Date: 10/06/2020

By use of The Lead Tree International Corporation services, you instruct The Lead Tree International Corporation to process any personal data you provide to The Lead Tree International Corporation in alignment with The Lead Tree International Corporation’s Service Agreement and Privacy Policy and agree to the processing of any personal data that The Lead Tree International Corporation provides to you in connection with the services. Customer also specifically authorizes the engagement of The Lead Tree International Corporation’s Advocates as Sub-processors. In addition, Customer generally authorizes the engagement of any other third parties as Sub-processors.

Customer Obligations

By use of The Lead Tree International Corporation services you agree to comply with data protection, security and other obligations with respect to any and all personal data by adhering to our Service Agreement and Anti-Spam policies, and Privacy Policy along with all local data protection laws to which you are subject. The Lead Tree International Corporation will inform you if, in The Lead Tree International Corporation’s opinion, you have violated any data processing obligation.

Details of Data Processing

Subject Matter: All The Lead Tree International Corporation services, Customer provided data, and related technical support to Customer, including all publicly available information that is transmitted or retrieved from sub-processors of The Lead Tree International Corporation.

Duration of the Processing: As identified in the Service Agreement.

Nature and Purpose of the Processing: The Lead Tree International Corporation provides an email service, automation and marketing platform and other related services as identified in our Privacy Policy.

Categories of Data: As outlined in our Privacy Policy (“I Am A The Lead Tree International Corporation Advocate.”, “I Am A Subscriber To An Email List Managed Through The Lead Tree International Corporation.”, “I Am An The Lead Tree International Corporation Customer.”)

Data Subjects: Personal data submitted, stored, sent or received via The Lead Tree International Corporation services that may concern the Customer or Subscribers of the Customer.

Data Security

The Lead Tree International Corporation takes all reasonable technical and organizational measures to commit to confidentiality of your data. The following information highlights our efforts to secure your trust in us with your data.

  • Use of encryption while data is being transmitted to or procured from our systems and while stored in our data centers
  • Continual automated and manual monitoring of the confidentiality, integrity, availability, and resilience of our systems
  • Emergency Preparedness to restore availability of our services in the event of a physical or technical incident
  • Routine backups in the event of data loss or corruption
  • Regular risk assessments of all systems both internally and externally
  • DDoS detection and mitigation in place for all data centers
  • Promoting Responsible Disclosure

Account Security

  • Continuous automated and manual monitoring for fraud and abuse on all The Lead Tree International Corporation accounts
  • Secure notifications to customers for sensitive account actions like password resets
  • Tiered account access is available to limit billing and other sensitive information disclosure

Personnel Security

  • Taking commercially reasonable steps to ensure employees and those acting on The Lead Tree International Corporation’s behalf maintain confidentiality of personal data including continual security awareness training and annual attestation
  • All The Lead Tree International Corporation employees are background checked prior to employment
  • Privacy confirmations of all sub-processors engaged in providing The Lead Tree International Corporation services to maintain and provide at least the same level of protection for the personal data and the same rights of data subject as The Lead Tree International Corporation.
  • Secured physical access to all data centers including keycards, alarms, and video camera recording

Customer Response

  • Providing written responses to all reasonable requests for information made by customers and their subscribers
  • In the event of a personal data breach, reasonably assisting customers with data security audits, including inspections, conducted by the customer, auditors, law enforcement, or other supervisory authorities
  • Providing notice to customers regarding personal data breaches without undue delay
  • Reasonably assisting customers with their obligations to Supervisory Authority Data Protection Impact Assessments and Prior Consultation taking into account the nature of processing and data involved

Security Certifications

  • Maintaining Privacy-Shield certification by completing an annual third-party review
  • Maintaining Payment Card Industry (PCI) Security certification by completing an annual compliance review
  • The Lead Tree International Corporation is currently pending membership of M3AAWG.

Data Rights

Right to be informed: You or your subscribers can ask about personal data, how it is used, and why it is being used at any time.

Right of access: As outlined in our Privacy Policy (Access to Personal Information).

Right of rectification: You or your subscribers can update (or request updates to) personal information at any time.

Right of erasure: You may cancel your The Lead Tree International Corporation account at any time and may additionally request that The Lead Tree International Corporation erase your personal data, cease further dissemination of the data, and potentially have third parties halt processing of the data. Your subscribers may also request that you or The Lead Tree International Corporation do the same for their personal data. The Lead Tree International Corporation reserves the right to keep the minimum amount of information that helps us prevent fraud to keep your deliverability the highest it can be.

Right to restrict processing: You may put your account on hold at any time which restricts the sending of email. Your data will still be processed for other actions such as billing and by our sub-processors. You may backup and deactivate a list to verify subscriber data and reactivate within 30 days. You may cancel your account to restrict all data processing of your data and your subscribers and reactivate your account as long as we have not yet deleted your information according to our retention policies.

Right to data portability: You may export any of your lists, or selected information within any list, at any time while your account is active by accessing your account manager or contacting us at info@clarkoutsourcing.com.

Right to object: You may unsubscribe from any of The Lead Tree International Corporation emails at any time. Your subscribers may unsubscribe from your emails at any time.

The Lead Tree International Corporation does not discriminate against a customer, price services differently, or reduce quality of service based on exercising the above data rights.

Sub-processors

You may opt-in to be informed of sub-processor additions excluding those on our list of sub-processors below by contacting us. If you object to any sub-processor addition, you may cancel your account within 5 days of the notification provided that such objection is based on reasonable grounds relating to data protection. You may independently contact any of these sub-processors directly to have your information erased that they store about you. This may include information you provided to The Lead Tree International Corporation or information that we procured from the sub-processor.

Sub Processor Purpose Aweber, Amazon Cloud Infrastructure, Hosting Appcues, Customer Walkthroughs and Surveys, Clearbit Customer Intelligence, eHawk Spam Prevention, First Data Customer Billing, Fullstory Customer Support, Google Business Analytics, Kissmetrics Business Analytics, LiveChatInc Customer Support, Lob Address Validation, PayPal Billing and Payments, Salesforce Customer Sales Management, Sift Science, Spam Prevention Survey, Gizmo Customer Surveys, Twilio Customer Support, VWO A/B Testing, Zendesk Customer Support, Trello, Slack, Google Drive Cloud Infrastructure, Airtable Cloud Services.

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