privacy policy

Your Privacy Matters

To whom this policy applies

This privacy policy declaration applies to the following parties:

EspecialMail Inc., proprietor and administrator of the service EspecialMail as defined on the web site especialmail.com. The company EspecialMail Inc., operating under the web address especialmail.com is referred to as EspecialMail in this declaration;
Registered users of the service EspecialMail possessing a member list. These EspecialMail users are referred to as “Clients” in this declaration;
Members of the mailing list, recipients of the permission-based marketing emails by an intermediary of the EspecialMail service. These mailing lists are generated by the Clients of EspecialMail and the administration of such lists is facilitated by EspecialMail. The members of these mailing lists are referred to as ”Subscribers”.
Internet users seeking information from web sites administered by EspecialMail. The users of these sites are referred to as ”Users”.

Effective as of July 1, 2023

Personal Information

Except as provided elsewhere in this privacy policy, EspecialMail will not divulge any User’s personal information to any third party. The User can, without obligation, gather essential information regarding the EspecialMail service on the EspecialMail web site provided that the User or the Client does not reproduce the content for personal or commercial purposes.

If the User wishes to download electronic documents from the EspecialMail web site, contact customer service, subscribe to a mailing list or become a Client of the EspecialMail service, the User must consent to the collection by EspecialMail of the User’s personal information with the objective of verifying, where applicable, the identity or registration, including last and first name, physical address, phone number, email address and payment details for the purpose of opening a EspecialMail account.

All personal data will be used exclusively for administrative purposes so as to offer Clients and Users the required and requested service.

Data protection and non-divulgation of personal information

EspecialMail conforms to the rules governing Canada’s Personal Information Protection and Electronic Documents Act, Quebec’s Personal Information Protection Act, Alberta’s Personal Information Protection Act, British Columbia’s Personal Information Protection Act, and the European Union’s General Data Protection Regulation (collectively the “Applicable Privacy Laws”).

All personal data provided during registration of the EspecialMail service will be stored in a secure database and protected with SSL (Secure Socket Layers). This data, including member lists belonging to the Clients of EspecialMail, will be exclusively accessible by workstation intermediaries and protected by authentication.

Access to this data is only accessible to EspecialMail authorized personnel for maintenance and analysis purposes. This data will be stored as long as is necessary unless a formal request for its destruction is made by the person to whom it relates.

Except as provided in this section and elsewhere in this privacy policy, EspecialMail will not divulge any personal information to a third party allowing a Client or member to be identified without their prior written consent so as to avoid any damage to their personal reputation or their companies or to the intermediaries that represent them. Any and all transfers of such personal data that may be made to third parties outside of Canada will be made exclusively with service providers who comply with the General Data Protection Regulation.

EspecialMail and its Clients promise to never rent, sell or disclose their member lists with third parties without the prior consent of members except that EspecialMail may disclose personal information of its members in the rare circumstance where applicable law requires such disclosure in accordance with a court order.

Notwithstanding anything in this privacy policy to the contrary, we may share any information (whether personal information or not ) we have collected about Clients, Subscribers or Users or that has been submitted to us:

In response to subpoenas, court orders, or legal process, or to establish, protect, or exercise our legal rights or defend against legal claims or demands;
If we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, or any violation of the Terms of Use;
If we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the EspecialMail web site infrastructure or the Internet in general (such as spamming, denial of service attacks, or attempts to compromise the security of the EspecialMail web site infrastructure or the EspecialMail web site generally);
To a parent company, subsidiaries, joint ventures, or other companies under common control with EspecialMail (in which case we will require such entities to honour this privacy policy);
If EspecialMail is acquired by or merged with another entity (in which case we will require such entity to assume our obligations under this privacy policy, or inform all those affected that they are covered by a new privacy policy).

Communications with clients

We use Typeform to collect data from clients which is transferred to Freshsales to manage and communicate with these clients. Typeform is used to collect data and store them safely on their Amazon AWS services. Google Mail is also used to manage and send communications to build and manage customer relationships.

For more information, please refer to the list of processors below.

Gathering of information for statistical and analytical purposes

EspecialMail automatically collects certain information using Google Analytics and Postmastery, to help understand how visitors use EspecialMail website, but none of this information identifies the Users personally. For example, each time EspecialMail website is visited, EspecialMail automatically collect IP address, browser and computer type, access times, the web page from which the visitor came, and the web page(s) accessed (as applicable).

EspecialMail uses information collected in this manner only to better understand the needs of all EspecialMail website visitors. EspecialMail also makes use of information gathered for statistical purposes to keep track of the number of visits to EspecialMail website and which pages on EspecialMail website were visited, with a view to introducing improvements. For more information, please refer to the list of processors below.

Client management and secured payment processing

EspecialMail uses Quickbooks and Stripe for third-party in the purchasing process of the Service. This intermediary has the exclusive permission to store, on our behalf, the data pertaining to the executed transactions by the Clients with the goal of ensuring a secure method of payment and proof of purchase archive, allowing for the protection of Clients, and swift follow-up. This transactional data may be used for validation and registration purposes of Clients. For more information, please refer to the list of processors below.

Data storage and hosting providers

We may store and process personal data with our contracted third-party service providers (“Service Providers”) in order to provide our Products and Services. These include a variety of services with offerings across the globe. For more information, please refer to the list of processors below.

Consent and identity

Members, Clients and Users may decline at any time to make personal information available on the EspecialMail web site. However, EspecialMail reserves the right to accept or decline the registration of a Client to the EspecialMail service if the personal data is found to be incomplete, fraudulent or furnished by a User who has not attained the age of majority (18 years for a resident of a Canadian province or 21 years for a resident of a state in the U.S.). Any data not conforming to the rules detailed above will be removed from the Client database by EspecialMail within 72 hours. Similarly, permission-based marketing emails shall not be sent to Users who are minors without the prior written consent of their parents or legal guardians. In the case of any doubt regarding the registration information provided by a prospective Client, EspecialMail reserves the right to require additional proof of identity and age. EspecialMail reserves the right to cancel a EspecialMail Client’s membership without warning when regulations governing the usage policy described above are not met.

Corrections and unsubscribing

A Client of the EspecialMail service may communicate with EspecialMail via email at questions@especialmail.com regarding access to information submitted during registration and the correction thereof. Members of the Client mailing lists of the EspecialMail service are asked to communicate directly with the Client in order to correct or validate any personal information regarding their registration to all permission-based marketing emails. If the Client does not, within a period of 72 hours, respond to a member’s request for access to personal information concerning them or the correction thereof, such member may communicate with EspecialMail via email at questions@especialmail.com. If a member’s modification requests are not respected by a Client of the EspecialMail service, EspecialMail reserves the right to impose sanctions on the Client’s usage.

EspecialMail requires all Clients of the EspecialMail service to include a clearly articulated option to unsubscribe from the mailing list in all permission-based marketing emails. Clients who must comply with Canada’s Anti-Spam Law have specific requirements for their unsubscribe mechanism. Please refer to the Anti-Spam Policy for details. A Subscriber must be able to unsubscribe at any time from a member list generated by a Client of the EspecialMail service. The Subscriber may also unsubscribe at the same time from the member lists of any satellite subscriptions of a Client of the EspecialMail service by submitting a verbal or written request to the Client. Should an unsubscribe request made by a member not be met by a Client of the EspecialMail service within a period of 72 hours, the Subscriber may lodge a complaint directly with EspecialMail through the contact section of the EspecialMail web site.

EspecialMail reserves the right to impose sanctions or to suspend service to any and all EspecialMail Clients who do not conform to these requirements. A Client may, at any time, cancel use of the EspecialMail service following, where applicable, the payment of fees set out in the preauthorized agreement accepted by the Client when registering for the service. Any User invited to participate in a promotional activity organized by a EspecialMail Client (viral marketing of the “invite your friend to participate” type) retains the right to refuse the proposed promotional activity. All Clients of EspecialMail are held responsible by EspecialMail for the proper functioning of all viral marketing tools thereby avoiding an interruption of service.

Authorized content

EspecialMail cannot be used for fraudulent purposes, those of an explicit nature or any activity not respecting applicable law. Clients may not use EspecialMail for the following:

Promotion of a pornographic nature;
The sale of pirated products or those that do not conform to applicable law;
The commercial, promotional or pornographic exploitation of minors;
False advertising involving the extortion of a User;
Non-authorized publicity of an individual or business without official consent;
Promotion of web sites involving pirating, terrorism or the posting of information considered illegal in Canada, the U.S. and the European Union.

Any Clients of the EspecialMail service not conforming to the aforementioned content rules will have their service blocked without warning. EspecialMail reserves the right to pursue any EspecialMail Client not conforming to these rules so as to protect the integrity of the services offered to its Subscribers, Clients and Users. Clients who must comply with Canada’s Anti-Spam Law have specific requirements for their email content. Please refer to the Anti-Spam Policy for details.

Hyperlinks

The EspecialMail web site, as well as all electronic communications emitted by the Clients of EspecialMail are permitted to contain hyperlinks to other web sites either belonging to partners of EspecialMail or not. These websites, independent of EspecialMail, do not automatically conform to all the points of the present privacy policy. EspecialMail is not responsible for the specific practices executed on these web sites and shall only be held responsible for the usage of the EspecialMail service.

Usage of secondary information

Invisible GIFs and pixel tags are utilized in the permission-based marketing emails sent by the Clients of EspecialMail so as to permit EspecialMail to assemble general information regarding the success of transmission. Once a recipient opens an HTML email sent by a Client of the intermediary services of EspecialMail, the computer of the recipient grants access to the EspecialMail servers to transmit these invisible GIFs. This tool allows EspecialMail to assemble the following information: email addresses and the dates and times of the delivery and opening of messages. This data allows EspecialMail to optimize the email delivery and assure that the transmission rules of all permission-based marketing emails are being respected by the Clients of the EspecialMail service. EspecialMail reserves the right to gather IP addresses in its files for statistical purposes or to test the functionality of EspecialMail’s email servers. Cookies are employed in the management execution of interfaces of the EspecialMail web site. These cookies are used for the sole purpose of offering Clients of EspecialMail access to more personalized information on the products and services of the company. The User visiting the EspecialMail web site will always maintain anonymity. Cookies are also employed as part of online advertising campaigns. Third party vendors, including Google, display EspecialMail advertisements on web sites on the internet. These third party vendors, including Google, use these cookies to serve ads based on a User’s prior visits to especialmail.com. Users may opt out of Google’s use of cookies by visiting the Google advertising opt-out page.

Notification of changes

EspecialMail’s creation of new services on the EspecialMail web site or any other web site registered under EspecialMail, may contain some modifications to the present privacy policy. In such a case, EspecialMail will post a notice on the homepage of the web sites in question to inform present Clients or anyone requesting information. An archive of the previous policy will be available to Users for verification purposes. A similar process is in place regarding any updates of the EspecialMail service. Any modifications in service taking place throughout the course of a Client contract will be documented and explained so as to facilitate the understanding of all executed upgrades. This update notice will be available on the homepage of the EspecialMail web site. EspecialMail’s Privacy Officer is responsible for ensuring that all parties conform to this privacy policy whether it be EspecialMail staff or Clients of the EspecialMail service and their Subscribers.

Any person wishing to comment or lodge a complaint of non-conformity of EspecialMail’s privacy practices with the Applicable Privacy Laws is asked to communicate with EspecialMail by email at questions@especialmail.com or by mail addressed to:

Privacy Officer, EspecialMail

307 – 94 Wright

Kingston, ON K7M 1A3

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Complaints or Concerns. Alternatively, complaints may be lodged with the applicable governmental authority.

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Data processing addendum

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How Do We Process Your Information?

This Data Processing Addendum (“DPA”) is effective as of the Effective Date of any master agreement for the provision of Services (the “Agreement”) between EspecialMail Inc. (“EspecialMail“) and the Client specified in the Agreement (“Client”). Alternatively, the DPA is effective as of the date the Client enters into the EspecialMail online Terms of Use at http://especialmail.com/tou which shall also be deemed the “Agreement” under this DPA.

EspecialMail and Client shall hereafter be collectively known as the “Parties” and individually known as a “Party”. To the extent that any of the terms or conditions contained in this DPA may contradict or conflict with any terms or conditions regarding the processing of Personal Data in the Agreement, it is expressly understood and agreed that the terms of this DPA shall take precedence and supersede those other terms or conditions as it regards the subject matter.

The Parties agree as follows:

1. Definitions

1.1 For the purposes of this DPA, the following expressions bear the following meanings unless the context otherwise requires:

“Applicable Data Protection Laws” means, in respect of a Party, any law, statute, declaration, decree, directive, legislative enactment, order, ordinance, regulation, rule or other binding instrument relating to the protection of Personal Data, including:

(a) the Directive 2002/58/EC (as amended) (the “e-Privacy Directive”), the e-Privacy Regulation 2017/003 (COD) (the “e-Privacy Regulation”), and any laws and regulations implementing these; and

(b) the Directive 95/46/EC (as amended) (the “Data Protection Directive”), the Regulation 2016/679 (the “GDPR”), and any laws and regulations implementing these;

(in each case as amended, consolidated, re-enacted or replaced from time to time).

“Data Subject”, “Personal Data”, “Process”, “Processed” and “Processing” shall each have the meaning as set out in the GDPR;

“EU Data Protection Laws” means any law, statute, declaration, decree, directive, legislative enactment, order, ordinance, regulation, rule or other binding instrument relating to the protection of personal data in force in the territory of the European Union, including the Data Protection Directive, the GDPR, the e-Privacy Directive and the e-Privacy Regulation;

“Model Clauses” mean the Standard Contractual Clauses between controllers and processors under Article 28 (7) of Regulation (EU) 2016/679 of the European Parliament and of the Council and Article 29 (7) of Regulation (EU) 2018/1725 of the European Parliament and of the Council, as adopted by the European Commission Implementing Decision of June 4, 2021; or alternatively the Standard Contractual Clauses (Controller to Processor) as set out in the European Commission Decision of 5 February 2010 (C (2010) 593), until such time as they are no longer valid on December 27, 2022;

“Regulator” means the data protection supervisory authority which has jurisdiction over a Data Controller’s Processing of Personal Data;

“Third Countries” means all countries outside of the scope of the data protection laws of the European Economic Area (“EEA”) and the United Kingdom, excluding countries approved as providing adequate protection for Personal Data by the European Commission from time to time, which at the date of this DPA include Andorra, Argentina, Canada (commercial organizations only), Faroe Islands, Guernsey, Isle of Man, Israel, Japan, Jersey, New Zealand, Switzerland, and Uruguay. Any capitalized terms used but not defined herein shall have the meaning given to them in the Agreement.

2. Processing of personal data

2.1 The Parties acknowledge and agree that with regard to the Processing of Personal Data, Client is the “Data Controller”, EspecialMail is the “Data Processor” and that EspecialMail will engage “Sub-Processors” pursuant to the requirements set forth in Section 8 below.

2.2 The duration of the Processing, the nature and purpose of the Processing, the types of Personal Data and categories of Data Subjects Processed under this DPA are further specified in Schedule 1 “Processing Details” of this DPA.

2.3 The Data Processor shall only process the Personal Data on behalf of and in accordance with documented instructions from the Data Controller. The Parties agree that this DPA is Client’s complete and final instructions to EspecialMail in relation to processing of Client Data. The Data Controller shall ensure that its instructions comply with all Applicable Data Protection Laws, and that the Processing of Personal Data in accordance with Data Controller’s instructions will not cause Data Processor to be in breach of the Applicable Data Protection Laws. The Data Controller shall have sole responsibility for the accuracy, quality, and legality of Personal Data and the means by which the Data Controller acquired Personal Data and shall establish the legal basis for Processing under Applicable Data Protection Laws.

2.4 Each Party will comply with all laws, rules and regulations applicable to it and binding on it in the performance of this DPA, including Applicable Data Protection Laws.

3. Authorized personnel

3.1 The Data Processor shall ensure that its personnel authorized to Process the Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality. The Data Processor shall ensure that such confidentiality obligations survive the termination of the personnel engagement.

4. Rights of data subjects

4.1 The Data Processor shall, to the extent legally permitted, promptly notify the Data Controller if it receives a request from a Data Subject for access to its own Personal Data, or for the rectification or erasure of such Personal Data or any other request or query from a Data Subject relating to its own Personal Data (including Data Subjects’ exercising rights under Applicable Data Protection Laws, such as rights of objection, restriction of processing, data portability or the right not to be subject to automated decision making) (a “Data Subject Request”). Taking into account the nature of the Processing, the Data Processor shall assist the Data Controller by appropriate technical and organizational measures, insofar as this is possible, for the fulfilment of the Data Controller’s obligation to respond to a Data Subject Request under Applicable Data Protection Laws. In addition, to the extent the Data Controller, in its use of the Services, does not have the ability to address a Data Subject Request, the Data Processor shall upon Data Controller’s request provide commercially reasonable efforts to assist the Data Controller in responding to such Data Subject Request, to the extent the Data Processor is legally permitted to do so and the response to such Data Subject Request is required under Applicable Data Protection Laws. To the extent legally permitted, the Data Controller shall be responsible for any costs arising from the Data Processor’s provision of such assistance.

5. Government access requests

5.1 The Data Processor shall promptly notify the Data Controller about any legally binding request for disclosure of Personal Data by a law enforcement authority, unless otherwise prohibited from doing so. The Data Controller shall have the right to defend such action in lieu of and/or on behalf of the Data Processor. The Data Processor shall reasonably cooperate with the Data Controller in such defense.

6. Security

6.1 The Data Processor shall implement and maintain appropriate technical and organizational measures for protection of the security (including protection against unauthorized or unlawful Processing and against accidental or unlawful destruction, loss or alteration or damage, unauthorized disclosure of, or access to, Personal Data), confidentiality and integrity of Personal Data.

7. Compliance

7.1 The Data Processor shall take reasonable efforts to make available to the Data Controller all information necessary to demonstrate compliance with the obligations laid down in this DPA and Applicable Data Protection Laws. Upon Data Controller’s request, the Data Processor shall provide the Data Controller with reasonable cooperation and assistance needed to fulfil Data Controller’s obligation under the GDPR to carry out a data protection impact assessment related to Data Controller’s use of the Services, to the extent the Data Controller does not otherwise have access to the relevant information, and to the extent such information is available to the Data Processor. The Data Processor shall provide reasonable assistance to the Data Controller in the cooperation or prior consultation with the Regulator in the performance of its tasks relating to Section 7 of this DPA, to the extent required under the GDPR and Applicable Data Protection Laws.

8. Sub-processing

8.1 The Data Controller agrees that the Data Processor may engage Sub-Processors to Process Personal Data. The Sub-Processors currently engaged by EspecialMail and authorized by the Client are listed in Schedule 2 “List of Sub-Processors”

8.2 The Data Processor shall ensure that such Sub-Processor has entered into a written agreement requiring the Sub-Processor to abide by terms no less protective than those provided in this DPA. The Data Processor shall be liable for the acts and omissions of any Sub-Processors to the same extent as if the acts or omissions were performed by the Data Processor.

8.3 The Data Processor shall make available to the Data Controller a list of Sub-Processors authorized to Process Personal Data (“Sub-Processor List”, currently found in Schedule 2) and provide the Data Controller with a mechanism to obtain notice of any updates to the Sub-Processor List. Notification of a new Sub-Processor shall be issued prior to such new Sub-Processor being authorised to Process Personal Data in connection with the Agreement.

8.4 The Data Controller may object to Data Processor’s use of a new Sub-Processor where there are reasonable grounds to believe that the new Sub-Processor will be unable to comply with the terms of this DPA or the Agreement. If the Data Controller objects to Data Processor’s use of a new Sub-Processor, the Data Controller shall notify the Data Processor promptly in writing within ten (10) days after notification regarding such Sub-Processor. Data Controller’s failure to object in writing within such time period shall constitute approval to use the new Sub-Processor. The Data Controller acknowledges that the inability to use a particular new Sub-Processor may result in delay in providing the Services, inability to provide the Services or increased fees. The Data Processor will notify the Data Controller in writing (including by email) of any change to the Services or fees that would result from Data Processor’s inability to use a New Sub-Processor to which the Data Controller has objected. The Data Controller may either execute a written amendment to the Agreement implementing such change or exercise its right to terminate the Agreement in accordance with the termination provisions thereof. Such termination shall not constitute termination for breach of the Agreement. The Data Processor shall have a right to terminate the Agreement if the Data Controller unreasonably objects to a Sub-Processor, or does not agree to a written amendment to the Agreement implementing changes in fees or the Services resulting from the inability to use the Sub-Processor at issue. shall take reasonable efforts to make available to the Data Controller all information necessary to demonstrate compliance with the obligations laid down in this DPA and Applicable Data Protection Laws. Upon Data Controller’s request, the Data Processor shall provide the Data Controller with reasonable cooperation and assistance needed to fulfil Data Controller’s obligation under the GDPR to carry out a data protection impact assessment related to Data Controller’s use of the Services, to the extent the Data Controller does not otherwise have access to the relevant information, and to the extent such information is available to the Data Processor. The Data Processor shall provide reasonable assistance to the Data Controller in the cooperation or prior consultation with the Regulator in the performance of its tasks relating to Section 7 of this DPA, to the extent required under the GDPR and Applicable Data Protection Laws.

9. Return and deletion

9.1 The Data Processor shall, at the choice of the Data Controller, delete or return all the Personal Data to the Data Controller after the end of the provision of the Services relating to Processing, and delete existing copies of the Personal Data unless prohibited by law or the order of a governmental or regulatory body or it could subject the Data Processor to liability.

9.2 The Data Controller acknowledges and agrees that the Data Processor shall have no liability for any losses incurred by the Data Controller arising from or in connection with Data Processor’s inability to provide the Services as a result of Data Processor complying with a request to delete or return Personal Data made by the Data Controller pursuant to Section 9.1.

10. Data breach

10.1 In the event there is, or Data Processor reasonably believes that there is, any improper, unauthorized or unlawful access to, use of, or disclosure of, or any other compromise which affects the availability, integrity or confidentiality of Personal Data which is Processed by Data Processor under or in connection with this DPA and/or the Agreement (“Data Breach”), then upon becoming aware of such Data Breach, Data Processor shall promptly notify the Data Controller and provide the Data Controller with the following information as it becomes available:

a description of the nature of the Data Breach, including where possible the categories and approximate number of Data Subjects concerned;
the name and contact details of the Data Processor contact from whom more information can be obtained; and
a description of the measures taken or proposed to be taken to address the Data Breach, including, where appropriate, measures to mitigate its possible adverse effects.

10.2 The Parties agree to coordinate in good faith on developing the content of any related public statements and any required notices to the affected Data Subjects and/or the relevant Regulators in connection with a Data Breach, provided that nothing in this Section 10.2 shall prevent either party from complying with its obligations under Applicable Data Protection Laws.

11. International transfers

11.1 The Data Processor will only process data in, or transfer Personal Data to, a Third Country where such processing or transfer takes place based and in compliance with the Model Clauses, with the processing details that comprise Appendix 1 to the Model Clauses, and the technical and organizational security measures that comprise Appendix 2 to the Model Clauses. The Data Processor shall comply with the obligations of the data importer and Data Controller shall comply with the obligations of the data exporter as set out in the Model Clauses.

11.2 Where the Data Processor appoints an affiliate or third-party Sub-Contractor to process Personal Data in a Third Country, the Data Processor must ensure that such processing takes place in accordance with the requirements of the Applicable Data Protection Laws. The parties agree that Personal Data may be transferred to an affiliate or third-party Sub-Contractor in the United States who agrees to process Personal Data according to the Model Clauses.

Schedule 1: Processing details

Processing Activities

‍The Personal Data Processed by Data Processor will be subject to the following basic Processing activities:

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‍Provision of the Services, as outlined in the Agreement and as otherwise agreed upon by the Parties.

‍Duration

The Personal Data Processed by Data Processor will be Processed for the following duration:

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‍The length of the Term of the Agreement between Data Controller and Data Processor.

‍Data Subjects

‍The Personal Data Processed by Data Processor concern the following categories of Data Subjects:

‍Clients and their Subscribers, as those terms are defined in the Agreement or the EspecialMail Privacy Policy at https://www.especialmail.com/legal/privacy-policy, and EspecialMail website visitors.