Your Online Privacy Rights

Effective Date: June 22, 2010
Responsys, Inc. and its subsidiaries (together, “Responsys,” “us,” “our” or “we”) make the same firm commitment to privacy for our Web site visitors as for our customers using our web-hosted service, Responsys Interact®.  We created this Online Privacy Policy (“Privacy Policy”) to give you confidence as you visit and use the Responsys Web site, located at www.responsys.com (the “Web site”) and to demonstrate our commitment to the protection of your privacy.  This Privacy Policy is only applicable to the Web site, and not to any other Web sites that you may be able to access from the Web site, each of which may have data collection and use practices and policies that differ materially from this Privacy Policy.  By using the Responsys Web site, you are agreeing to the terms of the Privacy Policy.

Notification of Privacy Policy Changes
We reserve the right to change the Privacy Policy at any time. If we decide to revise the Privacy Policy, we will post a notice at least thirty days prior to making any material changes. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page. Your continued use of the Web site, including use after the posting of any changes to these terms, will be deemed acceptance by you of the Privacy Policy.

Responsys is a licensee of the TRUSTe Privacy Program, which is further described below.

For privacy questions related to an email message you may have received from a company using Responsys Interact, please see our permission marketing policy, as well as the privacy policies for the sender(s) of the email message that you received.

Notice Concerning Children
PLEASE NOTE: We are a general audience site, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a Responsys Web site visitor is under age 13, we will promptly delete any personal information regarding that visitor.

TRUSTe Privacy Program
Responsys is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, nonprofit organization whose mission is to build users' trust and confidence in the Internet by promoting the use of fair information practices. Because this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe. By displaying the TRUSTe trust mark, this Website has agreed to notify you of:

If you have questions or concerns regarding this policy, you should first contact our Privacy Advocate by email at . If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with the Web site to resolve your concerns.

Responsys abides by the principles set forth in the EU Safe Harbor framework regarding the collection, use, and retention of data from the European Union.  As part of our participation in the EU Safe Harbor framework, we have agreed to TRUSTe dispute resolution for disputes relating to our compliance with the framework. If you have any complaints regarding our compliance with the framework, you should first contact us. If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by using the contact information provided above.

Information Collection Practices

What Basic Information Does Responsys Collect? 
You can visit the Web site to read information about our company,products, and services without telling us who you are and without revealing any personal information. In operating the Web site, Responsys includes optional information request forms such as white paper or webinar request forms, newsletter subscription forms, and general contact request forms that request your name,company, title, phone number, email address, URL, address and other information to help us determine your needs related to our products and solutions and in order for you to download or view documents or other information through the Responsys Web site. We use this information to send updates about our company and to contact you if requested or necessary. Depending upon your request, Responsys may also ask for additional information, such as how you heard about us. This information is provided by you on a voluntary basis only and is not required by us in order for you to use and enjoy the Web site. Responsys uses the information that we collect on the Web site to contact you to further discuss your interest in our company and services, and to send information regarding our company or partners, such as marketing promotions and events. We also use this information to improve the way that we provide our services to our clients, to relay administrative information, and to verify login information. The information is collected and stored in a manner that is appropriate for the nature of the data that we collect, and the need to fulfill your request. Finally, we may forward to our vendors and business partners information that you provide to us, but only so they can provide us services, such as responding to your request to receive information or providing web analytics services to Responsys.

Responsys Clients
If you are a client of Responsys (or work on behalf of a Responsys client), through our secure web interface, we also collect your user ID,username and password, and any other information that you provide to us on behalf of the client that you are representing, pursuant to the terms of a license or other agreement between the applicable client and Responsys (the“Client Agreement”). You should refer to that Client Agreement in addition to this Privacy Policy with regard to your use of the Responsys Web site and Responsys’ privacy obligations.

Automatic Collection
Our servers automatically recognize visitors’ IP addresses (the number assigned to computers on the Internet), domain names, the activity of the visitor’s browser when the visitor is viewing the Web site; the site path of visitors; the time visitors come to the Web site and length of visit. No personal information about you is revealed in the process. The Web site may also gather anonymous traffic data that does not personally identify you,but that may be helpful for marketing purposes or for improving the services we offer, and Responsys reserves the right to publish such anonymous, aggregate summary information regarding its visitors for promotional purposes.

Responsys uses "cookies" and "web beacons" to collect data. A cookie is a small text file containing a random and unique identifier that either Responsys, or its third party web analytics providers on behalf of Responsys, transfers to your computer's hard drive through your web browser(unless you set your browser to reject cookies) that enables Responsys’ or its third party web analytics provider's’ systems to recognize your browser. Responsys uses cookies to track your movement through the Web site and verify the login status of clients using products or services linked directly within the Responsys Web site.  Cookies are also used to track point of entry to point of registration for those users participating in our affiliate signup programs or to track and measure the success of a particular marketing campaign. Neither Responsys nor its third party web analytics providers store any personally identifiable information in cookies. Web beacons (also known as clear gifs) are typically transparent graphic images(usually 1 pixel x 1 pixel) that are placed on a site and used by Responsys and its third party web analytics providers in combination with cookies to help us understand how you interact with the Responsys Web site.; We use web beacons to measure visitor behavior, to help us improve visitor experience, and to manage site content.

Security and Privacy
Responsys' Web site uses security measures to help protect against the loss, misuse, and alteration of the information under our control. We store the information in a database in a secure environment at our data centers.

Responsys takes care to reinforce the importance of our Web site visitors' security and privacy among our employees. Responsys requires unique usernames and passwords that must be entered each time a user logs on to Responsys’client interface. These safeguards help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of all data. The bottom line is that, because our business involves hosting application accounts, data security is paramount. We're constantly reevaluating and deploying new technologies to enhance our security.

In order to accommodate changes in our business, we may sell or buy companies or assets. In such transactions, visitor information may be one of the transferred assets. In the event assets of Responsys are sold in a transaction, our visitor information may be an asset that is reviewed and transferred. Such a transaction will be disclosed per the"Notification of Privacy Policy Changes" guidelines above. Also, as with the data we collect on behalf of our clients, we reserve the right to disclose any data we collect on our Web site if required by law or valid order of a court or other governmental authority or to protect the health and safety of Responsys’ employees or the general public.

Responsys is not responsible for the privacy practices or the content of any other web sites to which we link. We encourage our visitors to read the privacy statements of each and every web site that they visit.

Updating and Choice/Opt-Out
Visitors who request information on our Web site have the following options for reviewing, modifying and deleting any personally identifiable information that has previously been provided to Responsys, as well as updating their profiles and unsubscribing (opting out) to avoid receiving future communications from Responsys:

Note that if you wish to unsubscribe from emails sent by our clients (as opposed to emails sent by Responsys directly), you will need to follow the unsubscribe or opt-out instructions in such emails.  See our Permission Marketing Policy.