Legal
Please read these agreements and policies in full to ensure you are fully informed. To make it easier for you to review the parts of that apply to you, we have divided up our legal agreements into four partners; Terms of Use Agreement, Privacy Policy, Anti-spam Policy, GDPR, and our Data Processing Addendum.

Terms of Use
Last Updated: December 12, 2025
Thanks for using Alfred.
Please read these terms carefully. These Terms of Use (“Terms of Use”) constitute a legally binding agreement made between you, whether personally or on behalf of an entity (“you” or “your”) and J2 Martech Corp. (“we,” “us” or “our”), concerning your access to and use of the alfredknows.com website and email verification services, my.alfredknows.com (“Customer Portal”), api.alfredknows.com (“API”), doc.alfredknows.com (“Documentation”) as well as any other website (such as https://alfred.email), media form, media channel, mobile website or mobile application related, linked, or otherwise connected to it (collectively, the “Site”).
General Terms
You agree that by accessing the Site, you have read, understood, and agree to be bound by all of these Terms of Use. If you do not agree with all of these Terms of Use, then you are expressly prohibited from using the Site and you must discontinue use immediately.
In order to use the email verification services available on the Site, you must execute a valid statement of work (“SOW”) or click on the “Agree” button during sign-up. By clicking the “Agree” button and/or using the Site, you acknowledge that you have read the Agreement, understand it, and agree to be bound by it. If you do not execute a valid SOW or click on the “Agree” button, we will have not entered into any legal agreement with you and shall not provide or deliver the services to you.
Supplemental terms and conditions or documents that may be posted on the Site from time to time are hereby expressly incorporated herein by reference. We reserve the right, in our sole discretion, to make changes or modifications to these Terms of Use at any time and for any reason.
We will alert you about any changes by updating the “Last Updated” date of these Terms of Use, and you waive any right to receive specific notice of each change except as legally required.
It is your responsibility to periodically review these Terms of Use to stay informed of updates. You will be subject to and will be deemed to have been made aware of and to have accepted, the changes in any revised Terms of Use by your continued use of the Site after the date such revised Terms of Use are posted.
The information provided on the Site is not intended for distribution to or use by any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject us to any registration requirement within such jurisdiction or country. Accordingly, those persons who choose to access the Site from other locations do so on their own initiative and are solely responsible for compliance with local laws, if and to the extent local laws are applicable.
The Site is intended for users who are at least 18 years old. Persons under the age of 18 are not permitted to register for the Site.
Intellectual Property Rights
Unless otherwise indicated, the Site is our proprietary property and all source code, databases, functionality, software, website designs, audio, video, text, photographs, and graphics on the Site (collectively, the “Content”) and the trademarks, service marks, and logos contained therein (the “Marks”) are owned or controlled by us or licensed to us, and are protected by copyright and trademark laws and various other intellectual property rights and unfair competition laws of the United States, foreign jurisdictions, and international conventions.
The Content and the Marks are provided on the Site “as is” for your information and personal use only. Except as expressly provided in these Terms of Use, no part of the Site and no Content or Marks may be copied, reproduced, aggregated, republished, uploaded, posted, publicly displayed, encoded, translated, transmitted, distributed, sold, licensed, or otherwise exploited for any commercial purpose whatsoever, without our express prior written permission.
Provided that you are eligible to use the Site, you are granted a limited license to access and use the Site and to download or print a copy of any portion of the Content to which you have properly gained access. We reserve all rights not expressly granted to you in and to the Site, the Content, and the Marks.
User Representations
By using the Site, you represent and warrant that:
- all registration information you submit will be true, accurate, current, and complete;
- you will maintain the accuracy of such information and promptly update such registration information as necessary;
- you have the legal capacity, and you agree to comply with these Terms of Use;
- you are not a minor in the jurisdiction in which you reside;
- you will not access the Site through automated or non-human means, whether through a bot, script, or otherwise;
- you will not use the Site for any illegal or unauthorized purpose;
- your use of the Site will not violate any applicable law or regulation; and
- any personal details such as email addresses, first and last names, phone numbers, or any information that alone or when combined with other information could identify an individual (“Personal Data”) furnished to us is owned or properly obtained by you, and none of such Personal Data infringes upon the privacy or proprietary rights of any third party.
If you provide any information that is untrue, inaccurate, not current, or incomplete, we have the right to suspend or terminate your account and refuse any and all current or future use of the Site (or any portion thereof).
User Registration
You may be required to register with the Site. You agree to keep your password confidential and will be responsible for all use of your account and password. We reserve the right to remove, reclaim, or change a username you select if we determine, in our sole discretion, that such username is inappropriate, obscene, or otherwise objectionable.
Fees and Payment
You may be required to purchase or pay a fee to access some of our services. You agree to provide current, complete, and accurate purchase and account information for all purchases made via the Site. You further agree to promptly update account and payment information, including email address, payment method, and payment card expiration date, so that we can complete your transactions and contact you as needed.
We bill you through an online billing account for purchases made via the Site unless otherwise described in an SOW. Sales tax will be added to the price of purchases as deemed required by us. We may change prices at any time. All payments shall be in U.S. dollars.
You agree to pay all charges or fees at the prices then in effect for your purchases, and you authorize us to charge your chosen payment provider for any such amounts upon making your purchase. If your purchase is subject to recurring charges, then you consent to our charging your payment method on a recurring basis without requiring your prior approval for each recurring charge, until you notify us of your cancellation.
We reserve the right to correct any errors or mistakes in pricing, even if we have already requested or received payment. We also reserve the right to refuse any order placed through the Site. You shall be liable for collection costs, including, but not limited to, reasonable attorney’s fees for any fees that are not paid in accordance with this section. Email verification credits are billed in advance and are non-refundable. There will be no refunds or credits for partial service or refunds made should you not use the full volume of email credits ordered. The foregoing shall apply without exception. Credits may be expended at different rates depending on the type of verification selected.
Cancellation
All purchases are non-refundable. You can delete your account at any time by contacting us using the contact information provided below. If you are unsatisfied with our services, please email us at support@alfredknows.com.
Software
We grant you a non-exclusive, revocable, and non-transferable license to use our software and service (collectively, the “Software”) solely in connection with our services and per these Terms of Use.
Any Software and any related documentation are provided “as is” without warranty of any kind, either express or implied, including, without limitation, the implied warranties of merchantability, fitness for a particular purpose, or non-infringement. You accept any and all risk arising out of the use or performance of any Software. You may not reproduce or redistribute any software.
Prohibited Activities
You may not access or use the Site for any purpose other than that we make the Site available.
As a user of the Site, you agree NOT to;
- use the Software to enable the sending of unsolicited email messages;
- systematically retrieve data or other content from the Site to create or compile, directly or indirectly, a collection, compilation, database, or directory without written permission from us;
- make any unauthorized use of the Site, including collecting usernames and/or email addresses of users by electronic or other means for the purpose of sending unsolicited email, or creating user accounts by automated means or under false pretenses;
- use a buying agent or purchasing agent to make purchases on the Site;
- circumvent, disable, or otherwise interfere with security-related features of the Site, including features that prevent or restrict the use or copying of any Content or enforce limitations on the use of the Site and/or the Content contained therein;
- engage in unauthorized framing of or linking to the Site,
- trick, defraud, or mislead us and other users, especially in any attempt to learn sensitive account information such as user passwords;
- make improper use of our support services or submit false reports of abuse or misconduct;
- engage in any automated use of the system, such as using scripts to send comments or messages, or using any data mining, robots, or similar data gathering and extraction tools;
- interfere with, disrupt, or create an undue burden on the Site or the networks or services connected to the Site;
- attempt to impersonate another user or person or use the username of another user.
- sell or otherwise transfer your profile;
- use any information obtained from the Site to harass, abuse, or harm another person;
- use the Site as part of any effort to compete with us or otherwise use the Site and/or the Content for any revenue-generating endeavor or commercial enterprise;
- decipher, decompile, disassemble, or reverse engineer any of the software comprising or in any way making up a part of the Site;
- attempt to bypass any measures of the Site designed to prevent or restrict access to the Site, or any portion of the Site;
- harass, annoy, intimidate, or threaten any of our employees or agents engaged in providing any portion of the Site to you;
- delete the copyright or other proprietary rights notice from any Content,
- copy or adapt the Software, including but not limited to Python, HTML, CSS, JavaScript, or other code;
- upload or transmit (or attempt to upload or to transmit) viruses, Trojan horses, or other material that interferes with any party’s uninterrupted use and enjoyment of the Site or modifies, impairs, disrupts, alters, or interferes with the use, features, functions, operation, or maintenance of the Site;
- upload or transmit (or attempt to upload or to transmit) any material that acts as a passive or active information collection or transmission mechanism (sometimes referred to as “spyware” or “passive collection mechanisms” or “pcms”);
- except as may be the result of standard search engine or Internet browser usage, use, launch, develop, or distribute any automated system, including without limitation, any spider, robot, cheat utility, scraper, or offline reader that accesses the Site, or using or launching any unauthorized script or other software;
- disparage, tarnish, or otherwise harm, in our opinion, us and/or the Site or;
- use the Site in a manner inconsistent with any applicable laws or regulations.
Submissions
You acknowledge and agree that any questions, comments, suggestions, ideas, feedback, or other information regarding the Site (collectively, “Submissions”) provided by you to us are non-confidential and shall become our sole property. We shall own exclusive rights, including all intellectual property rights, and shall be entitled to the unrestricted use and dissemination of these Submissions for any lawful purpose, commercial or otherwise, without acknowledgment or compensation to you.
You hereby waive all rights to any such Submissions, and you hereby warrant that any such Submissions are original with you or that you have the right to submit such Submissions. You agree there shall be no recourse against us for any alleged or actual infringement or misappropriation of any proprietary right in your Submissions.
Third-party Websites and Content
The Site may contain (or you may be sent via the Site) links to other websites (“Third-Party Websites”) as well as articles, photographs, text, graphics, pictures, designs, music, sound, video, information, applications, software, and other content or items belonging to or originating from third parties (“Third-Party Content”).
Such Third-Party Websites and Third-Party Content are not investigated, monitored, or checked for accuracy, appropriateness, or completeness by us, and we are not responsible for any Third-Party Websites accessed through the Site or any Third-Party Content posted on, available through, or installed from the Site, including the content, accuracy, offensiveness, opinions, reliability, privacy practices, or other policies of or contained in the Third-Party Websites or the Third-Party Content.
Inclusion of, linking to, or permitting the use or installation of any Third-Party Websites or any Third-Party Content does not imply approval or endorsement thereof by us. If you decide to leave the Site and access the Third-Party Websites or to use or install any Third-Party Content, you do so at your own risk, and you should be aware these Terms of Use no longer govern.
You should review the applicable terms and policies, including privacy and data gathering practices, of any website to which you navigate from the Site or relating to any applications you use or install from the Site. Any purchases you make through Third-Party Websites will be through other websites and from other companies, and we take no responsibility whatsoever in relation to such purchases which are exclusively between you and the applicable third party.
You agree and acknowledge that we do not endorse the products or services offered on Third-Party Websites and you shall hold us harmless from any harm caused by your purchase of such products or services. Additionally, you shall hold us harmless from any losses sustained by you or harm caused to you relating to or resulting in any way from any Third-Party Content or any contact with Third-Party Websites.
Site Management
We reserve the right, but not the obligation, to:
- monitor the Site for violations of these Terms of Use;
- take appropriate legal action against anyone who, in our sole discretion, violates the law or these Terms of Use, including without limitation, reporting such user to law enforcement authorities;
- in our sole discretion and without limitation, refuse, restrict access to, limit the availability of, or disable (to the extent technologically feasible) any of your contributions or any portion thereof;
- in our sole discretion and without limitation, notice, or liability, to remove from the Site or otherwise disable all files and Content that are excessive in size or are in any way burdensome to our systems or;
- otherwise, manage the Site in a manner designed to protect our rights and property and to facilitate the proper functioning of the Site.
Privacy Policy
Please review our Privacy Policy posted on the Site. By using the Site, you agree to be bound by our Privacy Policy, which is incorporated into these Terms of Use. If you are a resident in the European Economic Area, please review our General Data Protection Statement and Data Processing Addendum (DPA) for more information.
Confidentiality
In the course of performing under these Terms of Use, the parties may have access to certain proprietary information and trade secrets of each other (collectively, the “Confidential Information”). Neither party may disclose or otherwise permit any person or entity access to any of the Confidential Information of the other party, except as required or anticipated in the performance of their obligations hereunder or to comply with applicable law. The parties each understand that they are not allowed to sell, license or otherwise exploit any products or services that embody in whole or in part any Confidential Information of the other party, except as set forth hereunder.
Anti Spam Policy
Please review our Anti Spam Policy posted on the Site. By using the Site, you agree to be bound by our Anti Spam Policy, which is incorporated into these Terms of Use.
Term and Termination
These Terms of Use shall remain in full force and effect while you use the Site. We may terminate any applicable SOW or your access to the Site if we, in our reasonable determination, determine that you have violated these Terms of Use, your SOW (if applicable), the Anti Spam Policy, or any other policy linked from these Terms of Use. Email verification credits automatically expire one (1) year from the date of purchase.
WITHOUT LIMITING ANY OTHER PROVISION OF THESE TERMS OF USE, WE RESERVE THE RIGHT TO, IN OUR SOLE DISCRETION AND WITHOUT NOTICE OR LIABILITY, DENY ACCESS TO AND USE OF THE SITE (INCLUDING BLOCKING CERTAIN IP ADDRESSES), TO ANY PERSON FOR ANY REASON OR NO REASON, INCLUDING WITHOUT LIMITATION FOR BREACH OF ANY REPRESENTATION, WARRANTY, OR COVENANT CONTAINED IN THESE TERMS OF USE OR OF ANY APPLICABLE LAW OR REGULATION.
WE MAY TERMINATE YOUR USE OR PARTICIPATION IN THE SITE OR DELETE YOUR ACCOUNT AT ANY TIME, WITHOUT WARNING, AT OUR SOLE DISCRETION.
If we terminate or suspend your account for any reason, you are prohibited from registering and creating a new account under your name, a fake or borrowed name, or the name of any third party, even if you may be acting on behalf of the third party.
In addition to terminating or suspending your account, we reserve the right to take appropriate legal action, including without limitation pursuing civil, criminal, and injunctive redress.
Modifications and Interruptions
We reserve the right to change, modify, or remove the contents of the Site at any time or for any reason at our sole discretion without notice. However, we have no obligation to update any information on our Site. We also reserve the right to modify or discontinue all or part of the Site without notice at any time. We will not be liable to you or any third party for any modification, price change, suspension, or discontinuance of the Site.
We cannot guarantee the Site will be available at all times. We may experience hardware, software, or other problems or need to perform maintenance related to the Site, resulting in interruptions, delays, or errors. We reserve the right to change, revise, update, suspend, discontinue, or otherwise modify the Site at any time or for any reason without notice to you.
You agree that we have no liability for any loss, damage, or inconvenience caused by your inability to access or use the Site during any downtime or discontinuance of the Site. Nothing in these Terms of Use will be construed to obligate us to maintain and support the Site or to supply any corrections, updates, or releases in connection therewith.
Governing Law
These Terms of Use and your use of the Site are governed by and construed in accordance with the laws of the state of New York, USA. The parties agree that any controversy or claim arising out of or relating to these Terms of Use or a breach hereof shall be litigated only in the appropriate courts of New York County, New York.
Corrections
There may be information on the Site that contains typographical errors, inaccuracies, or omissions, including descriptions, pricing, availability, and other details. We reserve the right to correct any errors, inaccuracies, or omissions and to change or update the information on the Site at any time, without prior notice.
Disclaimer
THE SITE IS PROVIDED ON AN AS-IS AND AS-AVAILABLE BASIS. YOU AGREE THAT YOUR USE OF THE SITE AND OUR SERVICES WILL BE AT YOUR SOLE RISK. TO THE FULLEST EXTENT PERMITTED BY LAW, WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, IN CONNECTION WITH THE SITE AND YOUR USE THEREOF, INCLUDING, WITHOUT LIMITATION, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. WE MAKE NO WARRANTIES OR REPRESENTATIONS ABOUT THE ACCURACY OR COMPLETENESS OF THE SITE’S CONTENT OR THE CONTENT OF ANY WEBSITES LINKED TO THE SITE AND WE WILL ASSUME NO LIABILITY OR RESPONSIBILITY FOR ANY (1) ERRORS, MISTAKES, OR INACCURACIES OF CONTENT AND MATERIALS, (2) PERSONAL INJURY OR PROPERTY DAMAGE, OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO AND USE OF THE SITE, (3) ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SECURE SERVERS AND ANY AND ALL PERSONAL INFORMATION AND FINANCIAL INFORMATION STORED THEREIN, (4) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM THE SITE, (5) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE WHICH MAY BE TRANSMITTED TO OR THROUGH THE SITE BY ANY THIRD PARTY, AND (6) ANY ERRORS OR OMISSIONS IN ANY CONTENT AND MATERIALS OR FOR ANY LOSS OR DAMAGE OF ANY KIND INCURRED AS A RESULT OF THE USE OF ANY CONTENT POSTED, TRANSMITTED, OR OTHERWISE MADE AVAILABLE VIA THE SITE. WE DO NOT WARRANT, ENDORSE, GUARANTEE, OR ASSUME RESPONSIBILITY FOR ANY PRODUCT OR SERVICE ADVERTISED OR OFFERED BY A THIRD PARTY THROUGH THE SITE, ANY HYPERLINKED WEBSITE, OR ANY WEBSITE OR MOBILE APPLICATION FEATURED IN ANY BANNER OR OTHER ADVERTISING, AND WE WILL NOT BE A PARTY TO OR IN ANY WAY BE RESPONSIBLE FOR MONITORING ANY TRANSACTION BETWEEN YOU AND ANY THIRD-PARTY PROVIDERS OF PRODUCTS OR SERVICES. AS WITH THE PURCHASE OF A PRODUCT OR SERVICE THROUGH ANY MEDIUM OR IN ANY ENVIRONMENT, YOU SHOULD USE YOUR BEST JUDGMENT AND EXERCISE CAUTION WHERE APPROPRIATE.
Limitations of Liability
IN NO EVENT WILL WE OR OUR DIRECTORS, EMPLOYEES, OR AGENTS BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY DIRECT, INDIRECT, CONSEQUENTIAL, EXEMPLARY, INCIDENTAL, SPECIAL, OR PUNITIVE DAMAGES, INCLUDING LOST PROFIT, LOST REVENUE, LOSS OF DATA, OR OTHER DAMAGES ARISING FROM YOUR USE OF THE SITE, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. NOTWITHSTANDING ANYTHING TO THE CONTRARY CONTAINED HEREIN, OUR LIABILITY TO YOU FOR ANY CAUSE WHATSOEVER AND REGARDLESS OF THE FORM OF THE ACTION WILL AT ALL TIMES BE LIMITED TO THE GREATER OF THE AMOUNT PAID, IF ANY, BY YOU TO US DURING THE 6 MONTHS BEFORE ANY CAUSE OF ACTION ARISING OR $100.00. CERTAIN STATE LAWS DO NOT ALLOW LIMITATIONS ON IMPLIED WARRANTIES OR THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES. IF THESE LAWS APPLY TO YOU, SOME OR ALL OF THE ABOVE DISCLAIMERS OR LIMITATIONS MAY NOT APPLY TO YOU, AND YOU MAY HAVE ADDITIONAL RIGHTS.
Indemnification
You agree to defend, indemnify, and hold us harmless, including our subsidiaries, affiliates, and all of our respective officers, agents, partners, and employees, from and against any loss, damage, liability, claim, or demand, including reasonable attorneys’ fees and expenses, made by any third party due to or arising out of: (1) use of the Site; (2) breach of these Terms of Use; (3) any breach of your representations and warranties outlined in these Terms of Use; or (4) your violation of the rights of a third party, including but not limited to intellectual property or privacy rights.
Notwithstanding the foregoing, we reserve the right, at your expense, to assume the exclusive defense and control of any matter for which you are required to indemnify us, and you agree to cooperate, at your expense, with our defense of such claims. We will use reasonable efforts to notify you of any such claim, action, or proceeding subject to this indemnification upon becoming aware of it.
Electronic Communications, Transactions, and Signatures
Visiting the Site, sending us emails, and completing online forms constitute electronic communications. You consent to receive electronic communications. You agree that all agreements, notices, disclosures, and other communications we provide to you electronically, via email, and on the Site, satisfy any legal requirement that such communication is in writing.
YOU HEREBY AGREE TO THE USE OF ELECTRONIC SIGNATURES, CONTRACTS, ORDERS, AND OTHER RECORDS AND TO ELECTRONIC DELIVERY OF NOTICES, POLICIES, AND RECORDS OF TRANSACTIONS INITIATED OR COMPLETED BY US OR VIA THE SITE.
You hereby waive any rights or requirements under any statutes, regulations, rules, ordinances, or other laws in any jurisdiction which require an original signature or delivery or retention of non-electronic records, or to payments or the granting of credits by any means other than electronic means.
Miscellaneous
These Terms of Use and any policies or operating rules posted by us on the Site or in respect to the Site constitute the entire agreement and understanding between you and us. Our failure to exercise or enforce any right or provision of these Terms of Use shall not operate as a waiver of such right or provision. These Terms of Use operate to the fullest extent permissible by law. We may assign any or all of our rights and obligations to others at any time. We shall not be responsible or liable for any loss, damage, delay, or failure to act caused by any cause beyond our reasonable control.
If any provision or part of a provision of these Terms of Use is determined to be unlawful, void, or unenforceable, that provision or part of the provision is deemed severable from these Terms of Use and does not affect the validity and enforceability of any remaining provisions. The warranties, representations, confidentiality, indemnification obligations of the parties, and any provision which, by its nature should survive termination, shall survive the termination of these Terms of Use.
There is no joint venture, partnership, employment, or agency relationship created between you and us due to these Terms of Use or use of the Site. You agree that these Terms of Use will not be construed against us by having drafted them. You hereby waive any defenses you may have based on the electronic form of these Terms of Use and the lack of signing by the parties hereto to execute these Terms of Use.
Contact Us
To resolve a complaint regarding the Site or to receive further information regarding the use of the Site, please contact us at:
J2 Martech Corp.
360 Park Ave. S., 17th Floor
New York, NY 10010
privacy@alfredknows.com
Anti-Spam Policy
We have a no-tolerance for unsolicited commercial email communications (“Spam”), which are messages sent to persons with whom you do not have a business relationship or who have not specifically requested opted-in your messages.
We monitor the Site for patterns consistent with non-opted-in email addresses. Your account will be terminated if you use the Site to hygiene non-opted-in email addresses.
To use our Site, you must agree to hygiene only permission-based email addresses. This means all email addresses must have opted-in to receive communications from you.
An opt-in can occur either via a sign-up form on a website, at a point-of-sale sign-up form, on a physical sign-up sheet, or by any mechanism that allows a recipient to knowingly and willingly provide their email address for the purposes of receiving email communication from our users. Purchased lists may not be used with the Site, regardless of the source or permission status.
Please report any suspected violation of this policy to privacy@alfredknows.com.
DATA PROCESSING ADDENDUM
This Data Processing Addendum (the “Addendum”) forms part of the written or electronic Agreement (“Agreement”) between J2 Martech Corp. and/or, to the extent provided for in such Agreement, any of its affiliates (collectively, “the Company” or “Company”), and the other party to the Agreement into which this Addendum is incorporated by reference (“Customer” or “you”). All capitalized terms not defined herein shall have the meaning set forth in the Agreement, absent a contrary definition in the applicable legislation.
- Definitions:
- Terms and expressions used herein that are not otherwise defined, including without limitation “business,” “service provider” “controller,” “processor,” “personal data,” “personal information,” “processing,” “sensitive data,” and their respective derivative terms, shall have the meanings set forth in the data privacy or data protection laws, regulations, and decisions applicable to the parties and the engagement subject to the Agreement and this Addendum (“Applicable Data Protection Law”). Applicable Data Protection Law may include, without limitation, the California Consumer Privacy Act (“CCPA”) of 2018, Cal. Civ. Code § 1798.100 et seq. and its accompanying regulations, and the EU General Data Protection Regulation (2016/679) (“GDPR”), the General Data Protection Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data for the transfer of personal data to third country as it forms part of the law of England and Wales (“UK GDPR”), and the Swiss Federal Act on Data Protection (“Swiss Data Protection Law”), in each case as amended, superseded or replaced from time to time.
- “Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored, or otherwise Processed.
- “Data Privacy Framework”, means, as applicable the EU-US, Swiss-US, or UK-US Data Privacy Framework self-certification program operated by the US Department of Commerce.
- “Data Transfer Mechanism” means a transfer mechanism that enables lawful cross-border transfer of Personal Data under the Applicable Data Protection Law, which includes transfer mechanisms that are required under the Applicable Data Protection Law in the EEA, Switzerland and the UK, such as the Data Privacy Framework, the EEA SCCs, the UK International Data Transfer Addendum and any data transfer mechanism available under the Applicable Data Protection Law that is incorporated in this Addendum.
- “Personal Data” means any personal data or personal information that the Customer shares with the Company, including personal data received or shared, and sensitive personal data where applicable.
- Standard Contractual Clauses, hereinafter referred to as “SCCs” means, where applicable, the Standard Contractual Clauses for restricted transfers of Personal Data subject to the Applicable Data Protection law, as amended or replaced.
- Jurisdiction-Specific Terms
In the event of any conflict or ambiguity between the jurisdiction-specific terms and any other terms of this DPA, the equivalent jurisdiction-specific terms will rule.
- California:
- Unless specified otherwise, the term “controller” includes “Business” as defined under the CCPA; “processor” includes “Service Provider” as defined under CCPA; “data subject” includes “Consumer” as defined under CCPA; “Personal Data” includes “Personal Information” as defined under CCPA.
- Where the governing jurisdiction is California, “Permitted Purposes” shall include processing Personal Data for the purposes described in this Addendum and/or the agreement it is integrated into, or, where applicable, as otherwise may be permitted for “Service Providers” under the CCPA.
- The parties’ obligations with regard to data subject requests, extend to consumer rights requests under the CCPA.
- The parties acknowledge and agree that the Customer is a Business and appoints Company as a Service Provider to process Personal Data on its behalf and at its direction.
- Processing Restrictions:
Except as otherwise permitted by CCPA or the purpose described in the Agreement and this Addendum, the Company will not sell or share Personal Data, retain, use or disclose Personal data for any purpose other than the purpose stated in the Agreement and the Addendum.
After receipt of a request from the Customer, Company shall promptly delete Personal Data as directed by the Customer, unless such information is necessary to maintain information in accordance with the CCPA.
If applicable, notwithstanding any use restrictions elsewhere in the Agreement, where a party shares deidentified data with another party, the receiving party agrees that it has implemented technical safeguards that prohibit reidentification of the consumer to whom the information may pertain; has implemented business processes that specifically prohibit reidentification of the information; has implemented business processes to prevent inadvertent release of deidentified data; and will make no attempt to reidentify the information.
- Roles and Purpose of Processing
The parties to the Agreement, and thereby this Addendum agree to the rights and obligations with respect to Personal Data under the relevant Applicable Data Protection Law. They shall be individually and separately responsible for complying with the requirements as set forth in this Addendum.
- Role:
For the purposes of this Addendum, the Company is the processor and Customer is the controller. Detailed specification of the Personal Data being processed by the Company, including the subject-matter, the nature and purpose of the processing, the type of personal data and categories of data subjects are provided in Annex I. The subject matter of the processing is of Personal Data as laid out in the Agreement.
- Processing of Personal Data:
The Company shall process Personal Data solely to perform the stated purpose in the Agreement. Where sub-processors are required for the performance of the Agreement, the Company ensures that it has entered into a written agreement with the sub-processor(s), and has conducted appropriate due diligence on its sub-processors.
With respect to processing Personal Data, the Company will only grant access to employees, contractors, members or similar persons of its corporate bodies on a need-to-know basis and who have committed to respecting the confidentiality of the Personal Data.
The Company shall process Personal Data for as long as is necessary to fulfill its obligations under the Agreement and this Addendum. Unless otherwise required by law, after the termination or expiration of the Agreement, Company shall, without undue delay, destroy or remove all Customer Personal Data after returning any data to the Company in accordance with the Agreement.
To the extent required by Applicable Data Protection Law, the company will inform the Customer of each request the Company receives from data subjects, or consumers (including “verifiable consumer requests”, as defined under the CCPA) exercising their rights under the Applicable Data Protection Law. Other than to request further information, identify the data subject, or consumer, and, if applicable, direct them to you as a data controller, the Company will not respond to these requests unless you instruct the Company in writing to do so. Taking into account the nature of the processing, the Company will assist Customer by appropriate technical and organizational measures, insofar as this is possible, to enable Customer to meet its obligation to respond to the data subject’s, or consumer’s, request.
To the extent required by Applicable Data Protection Law, the Company shall inform Customer of each law enforcement request Company receives from a government authority requiring Company to disclose Personal Data or participate in an investigation requiring Company to disclose Personal Data, unless prohibited by law.
To the extent required by Applicable Data Protection Law, Company will provide Customer with reasonable assistance following Customer’s written request, to help Customer with its obligations under Applicable Data Protection Laws.
- Personal Data Breaches
If the Company experiences a Breach, the Company will, where applicable, notify Customer without undue delay.
To the extent known to the Company, the notification to the Customer will describe in reasonable detail, (i) a description of the nature of the Breach, (ii) the type(s) of Personal Data that was subject to the Breach, (iii) the categories and potential number of individuals or records affected, and (iv) the status of Company’s investigation and current planned remediation. Following the notification, the Company will provide relevant updates to assist Customer in complying with Customer’s obligations under Applicable Data Protection Law.
- Sub-Processors
The Company may engage a sub-processor, or sub-processors, to perform the service. Customer consents to the Company’s use of its existing sub-processor(s) as necessary for the fulfillment of the Agreement and this Addendum.
The Company shall enter into a written agreement with each sub-processor containing data protection obligations no less protective of Personal Data than those in the Agreement and this Addendum, to the extent applicable. The Company will remain liable to Customer for any failure by any of its sub-processors to comply with such data protection obligations.
- Deletion or Return of Personal Data
At Customer’s choice, Company shall delete or return to Customer all Personal Data processed in connection with the Agreement and this Addendum, except that the Company will not be required to delete or return that Personal Data, or delete existing copies, to the extent that Company’s storage of that Personal Data or those copies is (i) required by Company to exercise its rights and perform its obligations under the Agreement and this Addendum; or (ii) required or authorized by Applicable Data Protection Law, or other applicable laws, for a longer period.
- Audits
To the extent required by Applicable Data Protection Law, following a written request by Customer and no more than once per calendar year, the Company will contribute to audits or inspections by making applicable audit reports available to Customer.
- Transfers of Personal Data
If, in connection with Company providing the services to the Customer as set forth in the Agreement, more than one Data Transfer Mechanism under Applicable Data Protection Law could apply to a transfer of Personal Data, Customer and Company agree that the transfer will be subject to one Data Transfer Mechanism only, according to the following order of precedence:
- The Data Privacy Framework;
- The EU SCCs;
- The UK International Data Transfer Addendum in Annex IV;
- Any other Data Transfer Mechanism available under the Applicable Data Protection Law that is incorporated into this Addendum.
The Company is self-certified under the Data Privacy Framework. When Customer transfers Personal Data originating from the EEA, the UK or Switzerland to Company, Company will receive the Personal Data under the Data Privacy Framework and, when processing that personal data, will comply with the data privacy principles and relevant supplement principles as set out in the Data Privacy Framework.
- EEA Data Transfers:
To the extent the Company receives Personal Data protected by the GDPR in a country outside of the EEA that is not recognized as providing adequate level of protection for personal data, the parties to the Agreement agree to abide by and process such Personal Data in compliance with the SCCs as incorporated into this Addendum.
- UK Data Transfers:
Any transfer of the Personal Data of UK data subjects by the Company to a third country (in the sense of the UK GDPR) shall be governed by the SCCs and supplemental UK Addendum in Annex IV.
With respect to transfers to where the UK is the governing jurisdiction, the SCCs shall apply and shall be deemed amended as specified by the UK Applicable Data Protection Law
- Swiss Data Transfers:
With respect to transfers where Swiss law governs, the SCCs shall apply provided that any references in the SCCs to the GDPR shall refer to the Swiss Data Protection Law, the term “member state” must not be interpreted in such a way as to exclude data subjects in Switzerland from the possibility of suing for their rights in their place of habitual residence in accordance with clause 18(c), and the clauses shall also protect the data of legal persons.
The European Union’s 2021 Standard Contractual Clauses for international transfers are hereby incorporated by reference with the following selections.
Module 2 Selections:
- Clause 7 Docking Clause – Intentionally Omitted
- Clause 9 Use of Sub-processors – Option 2 with 30 days. Refer to “Sub-processors” section above.
- Clause 11 Redress – Optional language omitted.
- Clause 13 Supervision – Option 1, 2 and 3 apply in accordance with whether the exporter(s) is/are established in an EU Member State and has/have appointed a representative.
- Clause 17 Governing law – Option 2 shall apply. The parties agree that the laws of Ireland shall apply.
- Clause 18 Choice of Forum and Jurisdiction – The Company and Customer agree that any dispute arising from the SCCs shall be resolved by the of Ireland, and EU Member State.
- Appendix: Annex 1(C) Competent Supervisory Authority – If the data exporter is established in the EEA, UK or Switzerland, the designated data protection authority should be the one that is competent to oversee compliance by the exporter in accordance with the Applicable Data Protection Law. Where Company is the exporter, this is the Irish Data Protection Commission. If the data exporter is not established in the EEA, UK or Switzerland but is directly subject to the GDPR, the competent data protection authority will be:
– If the exporter has to appoint a representative (in accordance with Article 27 of the GDPR): the data protection authority of the EEA country where the representative is established;
– If the exporter does not have to appoint a representative (in accordance with Article 27 of the GDPR): the data protection authority of the/a EEA country where the data subjects whose data is transferred are located.
APPENDIX
ANNEX I
- LIST OF PARTIES
Data exporter(s): Customer
Name: as set forth in the Agreement
Address: as set forth in the Agreement
Contact person’s name, position and contact details: as set forth in the Agreement
Activities relevant to the data transferred under these Clauses: as set forth in the Agreement
Signature and date: Please refer to the Agreement.
Role (controller/processor): Controller.
Data importer(s): Company
Name: as set forth in the Agreement
Address: as set forth in the Agreement
Contact person’s name, position and contact details: as set forth in the Agreement
Activities relevant to the data transferred under these Clauses: as set forth in the Agreement
Agreement acceptance date: Please refer to the Agreement.
Role (controller/processor): Processor
- DESCRIPTION OF TRANSFER
Categories of data subjects whose personal data is transferred
Clients/customers of the Customer (third-party to Company’s customers, or customers of Company’s customers)
Categories of personal data transferred
Customers provide contact lists that include personal details including first and last name and email address. Additional information may be included in the contact lists but is not requested or required.
Sensitive data transferred (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialised training), keeping a record of access to the data, restrictions for onward transfers or additional security measures.
N/A. Email Industries requests that sensitive data is not provided.
The frequency of the transfer (e.g. whether the data is transferred on a one-off or continuous basis).
Continuous
Nature of the processing
Email Industries is an email deliverability consulting, email verification, and threat assessment services firm based in the USA, who will process the data in connection with offering verification or validation of email addresses to customers through its Services.
Purpose(s) of the data transfer and further processing
Email Industries is an email deliverability consulting, email verification, and threat assessment services firm based in the USA, who will process the data in connection with offering verification or validation of email addresses to customers through its Services.
The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period
Customer-supplied contact lists are automatically removed after ninety (90) days. Customers may manually remove files or shorten the deletion cadence by emailing support@emailindustries.com. Additionally, contact lists are automatically deleted when customers are offboarded from the Services. Log files which contain client-user IP address(es) (as well as other fraud prevention signals) will be retained for auditing and security purposes for the duration of the Agreement. Email addresses and their corresponding verification results may be stored in a cache.
For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing
Third-party personal data is received by Email Industries after being sent through Amazon Web Services (“AWS”), a highly safe and protected environment. Portions of the Email Industries products are hosted in AWS. Email Industries utilizes a number of subprocessors in the course of delivering the Services.
ANNEX II – TECHNICAL AND ORGANISATIONAL MEASURES INCLUDING TECHNICAL AND ORGANISATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA
- Security Programs and Policies
The Company maintains and enforces a security program that manages security, including security controls. The security program includes:
- Policies that the Company formally approves, internally publishes, communicates to appropriate personnel and reviews at least annually;
- Clear assignment of responsibility and authority for security program activities;
- Policies covering data classification, cryptographic controls, access controls, removable media, remove access and acceptable computer use; and
- Testing of key controls, systems and procedures.
The Company also maintains and enforces a privacy program and related policies that address how Personal Data is collected, used and shared.
- Risk And Asset Management
The Company performs risk assessments and implements and maintains controls for risk identification, monitoring, analysis, reporting and remediation. The Company also maintains and enforces an asset management program that appropriately classifies and controls hardware and software assets throughout their lifecycle.
- Personnel Controls
All Company employees, independent contractors, and freelancers who have access to Personal Data (collectively “Personnel”) acknowledge their data security and privacy responsibility under the Company’s policies.
For Personnel, the Company, either itself or through a third party:
- Implements pre-employment background checks and screening;
- Conducts security and privacy training;
- Implements disciplinary processes for violations of data security or privacy requirements; and
- Upon termination or applicable role change, promptly removes or updates Personnel access rights and requires Personnel to return or destroy Personal Data.
- The Company authenticates each Personnel’s identity through appropriate authentication credentials such as strong passwords, token devices, or biometrics
- The Company’s employees complete annual security and privacy awareness training on the Company’s data security and confidentiality policies and practices.
- Network and Operations Management
The Company implements policies and procedures for network and operations management, addressing hardening, change control, segregation of duties, separation of development and production environments, technical architecture management, network security, malware protection, protection of data in transit and at rest, data integrity, encryption, audit logs, and network segregation.
The company also performs vulnerability assessments and penetration testing on its systems and applications. Vulnerabilities are managed and remediated in accordance with the Company’s vulnerability management standards.
- Technical Access Controls
The Company implements measures to prevent data processing systems from being used by unauthorized individuals. These measures include:
- User identification and authentication procedures;
- ID and password parameters and security procedures;
- System monitoring.
The Company implements measures to ensure that persons entitled to use a data processing system gain access only to the Personal Data allowed for their access rights, and that Personal Data cannot be read, copied, modified or deleted without authorization, including:
- Internal policies and procedures;
- Control authorization schemes;
- Differentiated access rights (profiles, roles, actions and objects);
- Access monitoring and logging;
- Access reports;
- Access procedures;
- Change procedure;
- Retention and deletion procedures.
- Physical Access Controls
Where needed, the Company uses reputable third-party service providers to host its production infrastructure and relies on these third parties to manage the physical access controls to the data center facilities they manage. Some of the measures provided by these third parties are physical access control systems, Global Security Operations Center that monitors security systems, alarm systems, access control roles and area zones, audit measures, and trained staff. The Company reviews measures for appropriateness through our vendor management process.
- Availability Controls
The Company implements measures to ensure the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident including:
- Backup procedures;
- Hardware redundancy; and
- A disaster recovery plan.
- Data Security Incident Management and Notification
The Company implements a data security and incident management program that addresses how the Company manages security incidents. The Company will notify customers and regulators, where applicable, of incidents in a timely manner as required by Applicable Data Protection Laws.
- System Configuration
The Company implements measures for appropriate system configuration, including default configuration measures for internal IT and IT security governance. The Company uses monitoring tools to monitor production infrastructure changes from known configuration baselines.
- Data Retention and Deletion
The Company implements and maintains data retention policies and procedures related to Personal Data and reviews these policies and procedures as appropriate.
ANNEX III
List of Sub-Processors
See Annex I, Subsection B.
ANNEX IV
UK International Data Transfers: Addendum to the EU Commission SCCs
The UK’s International Data Transfer Addendum to the EU Commission Standard Contractual Clauses is hereby incorporated by reference.
Part 1: Tables
- Table 1: Parties
|
2. Please refer to the underlying Agreement between the parties to which this document is an addendum. |
|
|
3. The Parties |
4. Exporter (who sends the Restricted Transfer) |
5. Importer (who receives the Restricted Transfer) |
|
6. Parties’ details |
Full legal name: Please refer to Annex I above. 7. Trading name (if different): 8. Main address (if a company registered address): Please refer to Annex I above. |
Full legal name: Please refer to Annex I above. 9. Trading name (if different): 10. Main address (if a company registered address): Please refer to Annex I above. |
|
11. Key Contact |
Full Name (optional): Please refer to Annex I above. 12. Job Title: Please refer to Annex I above. 13. Contact details including email: Please refer to Annex I above. |
Full Name (optional): Please refer to Annex I above. 14. Job Title: Please refer to Annex I above. 15. Contact details including email: Please refer to Annex I above. |
|
16. Signature (if required for the purposes of Section 2) |
Please refer to Annex I. A above. |
Please refer to Annex I. A above. |
- 2: Selected SCCs, Modules and Selected Clauses
|
17. Addendum EU SCCs |
☐ The version of the Approved EU SCCs which this Addendum is appended to, detailed below, including the Appendix Information: 18. Date: 19. Reference (if any): 20. Other identifier (if any): 21. Or X the Approved EU SCCs, including the Appendix Information and with only the following modules, clauses or optional provisions of the Approved EU SCCs brought into effect for the purposes of this Addendum: Module 2: Controller (Customer) to Processor (Company): Please refer to SCC Module 2 Selections above. |
- Table 3: Appendix Information
|
1. Annex 1A: List of Parties: Please see Annex I. A above. |
|
2. Annex 1B: Description of Transfer: Please see Annex I. B above. |
|
3. Annex II: Technical and organisational measures including technical and organisational measures to ensure the security of the data: Please see Annex II above. |
|
4. Annex III: List of Sub processors (Modules 2 and 3 only): N/A due to General Written Authorisation. |
- Table 4: Ending this Addendum when the Approved Addendum Changes
|
5. Ending this Addendum when the Approved Addendum changes |
6. Which Parties may end this Addendum as set out in Section 19: 7. ☐ Importer 8. ☐ Exporter 9. X neither Party 10. Only the Ziff Davis entity (whether as Importer or Exporter) may end this Addendum as set out herein. |
Part 2: Mandatory Clauses
|
Mandatory Clauses |
Part 2: Mandatory Clauses of the Approved Addendum, being the template Addendum B.1.0 issued by the ICO and laid before Parliament in accordance with s119A of the Data Protection Act 2018 on 2 February 2022, as it is revised under Section 1 8 of those Mandatory Clauses. |
General Data Protection Regulation (GDPR)
The GDPR, or General Data Protection Regulation, is a European privacy law that went into effect in May 2018. It regulates how personal data of individuals in the EU can be collected, used, and processed. The law impacts European companies and any business that targets European individuals or collects, uses, or processes the personal data of European individuals regardless of where the business is located. Essentially, this means the GDPR will apply to most organizations that process personal data of EU individuals—regardless of where they are established and regardless of where their processing activities take place.
We are proud that Alfred is GDPR compliant and private by design, but what does that mean to you and data the contact you control?
- Our data centers are located in EU territory.
- Uploaded email addresses are hashed (anonymized) in all parts of the system, except the layer from which you download your results.
- You have the ability to delete permanently the data under your control at any time. Otherwise, we will erase it from the system after 14 days.
If you are interested in your privacy, please take a look at our Privacy Policy, and if your customers’ data privacy is your priority, please review our Data Processing Addendum (DPA).
