Privacy Policy
Last Updated May 22, 2009
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This
Privacy Policy governs your use of this Website and any content, products or
services made available from or through this website including any sub domains
thereof (“Website”). The Website is made
available by Frontline Direct, Inc. (Hereinafter referred to as “Company”).
By
visiting this Website and requesting information, products or services offered
on or through this Website, you agree to the terms of this Privacy Policy, as
they may be amended from time to time.
As Company updates or expands its Website, services or products, this
Privacy Policy may change and the changes are effective upon posting. Please
check back frequently for updates as it is your sole responsibility to be aware
of changes. Company does not provide
notice of changes in any manner other than by posting the changes at this
Website. This Privacy Policy is
incorporated into, and part of, the Website Terms and Conditions which govern
your use of this Website in general.
This
Website is intended for users who are located in the
Purpose of the Privacy
Policy.
This
Policy describes the information collection, use, and dissemination practices
of Company, its parent, subsidiaries and registered d/b/a companies
(Collectively Referred herein after as “Company”) and all related websites
owned or registered to Company. It
governs Company’s right to collect, use, store and disclose information
provided by You on its (a) this Website, (b) Company’s other Websites, (c) on
various Third Party websites, and (d) Company's other information collection
and distribution practices, including the acquisition of your information from
and to Third Parties. Company is not responsible for the information collection
or privacy practices of third party websites or applications which company does
not own or control.
By
providing us with Personal Information about yourself on our Website or in the
course of using our services, you consent to the transfer of your Personal
Information, and any other data we acquire about you from third-party service
providers for commercial use.
Information Collection, Use,
and Dissemination practices.
1.0. Collection
of Information.
1.1. User Direct Information. Each time you provide or transmit information
via the Website, Company may obtain and collect personal information about you,
including, but not limited to, your name, email address, mailing address,
social security number, credit card information, bank account information and
telephone or cell phone number (collectively referred to as "Personal
Information").
1.2. Survey Information. Company may collect Personal Information from
you when you voluntarily complete a Company survey, order form, or a
registration page either online by using the internet or offline by providing
this information through the mail, in person or using a telephone. This
information may be collected by surveys, order forms, or registration pages
operated by third parties. This method of collection is collectively known as a
“Survey.” In such Surveys, Company or a third party may ask you to provide
Personal Information including your name, email address, street address, zip
code, telephone numbers (including cell phone numbers and carriers), birth
date, gender, salary range, education and marital status, occupation, social
security number, employment information, personal and online interests, and
such other information as may be requested from time to time. Company may also
collect such information concerning you from another source and uses that
information in combination with information provided from the Website or
Surveys. Completing the Surveys is completely voluntary, and you are under no
obligation to provide Survey Information to Company or a third party.
1.3. Third Party Information. Company may collect Personal Information from
you when you provide information to a third party and Company subsequently
acquires or uses the information provided by the third party. Such information
may include, but is not limited to, your name, email address, street address,
zip code, telephone numbers (including cell phone numbers and carriers), birth
date, gender, salary range, education and marital status, occupation, industry
of employment, personal and online interests, and such other information you
may have provided to the third party. When acquiring this information, Company
seeks assurances from the third party that you agreed to provide and have such
information acquired by Company. If you
did not give express permission, or you would like to remove your permission,
you may suppress all of your information by sending notification to us at
unsubscribe@frontlinedirect.com.
1.4. Other Methods of Collecting Personal
Information. Other occasions when
Company obtains information from you include: (1) when you claim a prize or
seek to redeem an offer by Company or by a third party; (2) when you request
assistance through Company’s customer service department; and (3) when you
voluntarily subscribe to a Company service or newsletter.
1.5. Cookies, Web Beacons, and Other Info
Collected Using Technology. Company
currently uses cookie and web beacon technology to associate certain
Internet-related information about you with information about you in its
database. Additionally, Company may use other new and evolving sources of
information in the future.
(a) Cookies.
“Cookies” are a feature in your browser software. If enabled, we may
write cookies that may store small amounts of data on your computer about your
visit to any of the pages of this Site. Cookies assist us in tracking which of
our features appeal the most to you and what content you may have viewed on
past visits. When you visit this site again, cookies can enable us to customize
our content according to your preferences. We may use cookies to: keep track of
the number of return visits to this site; accumulate and report aggregate,
statistical information on website usage; deliver specific content to you based
on your interests or past viewing history; save your password for ease of access
to our Site. You can disable cookies,
although the Site may not function properly for you. Your browser preferences
can be modified to accept or reject all cookies, or request a notification when
a cookie is set. You may read more about cookies at http://cookiecentral.com.
In order to use all of the features and functionality of Company’s websites,
you need to accept cookies.
(b) Web Beacons. A web beacon is a programming code that can be
used to display an image on a web page, but can also be used to transfer your
unique user identification to a database and associate you with previously
acquired information about an individual in a database. This allows Company to
track certain websites you visit. Web beacons are used to track online
behavioral habits for marketing purposes to determine products or services you
may be interested in. In addition to using web beacons on web pages, Company
also uses web beacons in email messages sent to individuals listed in Company’s
database.
(c) IP Addresses. Company automatically tracks certain
information based upon your behavior on the site. We may use this information
to do internal research on our users' demographics, interests, and behavior to
better understand, protect and serve you and our community. This information
may include the URL that you just came from (whether this URL is on the site or
not), which URL you next go to (whether this URL is on the site or not), your
computer browser information, and your IP address. Your Internet Protocol
("IP") is a unique Internet "address" which is assigned to
you by your Internet Service Provider ("ISP"). For local area network
("LAN"), DSL, or cable modem users, an IP address may be permanently
assigned to a particular computer. IP addresses are automatically logged by Web
servers, collecting information about a user's traffic patterns. While the IP
address does not identify an individual by name, it may, with the cooperation
of the ISP, be used to locate and identify an individual using the Web. Your IP
address can, however, reveal what geographic area you are connecting from, or
which ISP you are using. Finally, other websites you visit have IP addresses,
and we may collect the IP addresses of those websites and their pages.
(d) Computer Profiles. Company may also collect and accumulate other
anonymous data which will help us understand and analyze the Internet
experience of our visitors. For instance, Company may accumulate visitor data
relating to referring domain names, the type of browsers used, operating system
software, screen resolutions, color capabilities, browser plug-ins, language
settings, cookie preferences, search engine keywords and JavaScript enablement.
When you provide us with Personal Identification Information, we are able to
use such visitor data to identify you.
(e) Data Analysis. Data Analysis technology may be employed from
time to time if used by a Client of Company.
(f) New Technology. The use of technology on the Internet,
including cookies and web beacons, is rapidly developing. As a result, Company
strongly encourages individuals to revisit this policy for any updates
regarding its use of new technology.
1.6. No Information Collected from Children. Company will never knowingly collect any
Personal Information about children under the age of 13. If Company obtains actual knowledge that it
has collected Personal Information about a child under the age of 13, that
information will be immediately deleted from its database. Because it does not collect such information,
Company has no such information to use or to disclose to third parties.
1.7. Credit Card Information and Bank Account
Information. Company may, in certain
instances, collect credit card numbers, bank account information and related
information when an individual places an order on Company’s Website. When the
credit card or bank account information is submitted to Company, such
information is encrypted and is protected with SSL encryption software. Company
will use the credit card information or bank account information for purposes
of processing and completing the transaction you requested on the Website, and
the credit card information or bank account information will be disclosed to
third parties as necessary to complete the requested purchase transaction.
2.0. Use of
Personal Information.
2.1. General Use. The following paragraphs describe how Company
currently uses Personal Information, but Company may change or broaden its use
at any time. As noted below, Company may
update this policy from time to time. Company may use Personal Information to
provide promotional offers to individuals by means of email advertising,
telephone marketing, direct mail marketing, mobile marketing, online banner
advertising, and package stuffers, among other possible uses.
2.2. Email and Unsubscribe Policy. Company uses Personal Information to provide
third party promotional offers by email to individuals. Company may maintain separate email lists for
different purposes. If email recipients
wish to end their email subscription from a particular list, they need to
follow the instructions at the end of each email message to unsubscribe from
the particular list. To unsubscribe from
all Company’s email lists, a person must send an email to unsubscribe@frontlinedirect,
Inc. com.
Company's unsubscribe process
impacts only the future delivery of electronic mailings disseminated by Company
on its own behalf. You may still receive
electronic mailings sent on behalf of Third Parties and your Personal Information
may still be shared with Third Parties for use in offline marketing and data
appends, including email appends unless you unsubscribe as provided above.
You should also note that
unsubscribing from Company’s electronic mailings will not automatically
unsubscribe your information from any Third Party business associates and
licensees of the data. Since Third Party
associates and licensee partners maintain separate databases from Company, and
you will need to unsubscribe from each source individually, if desired. This allows you the freedom to pick and
choose which subscriptions to maintain and which to discontinue.
2.3. Content of Email Messages. You may receive certain commercial email
messages sent by third parties for products which may be of interest to
you. In such case, an Advertiser's name
will appear in the "From:" and the email will have a method at the
bottom of the email to unsubscribe from that Advertiser. Company is not responsible for third party
emails sent to you.
2.4. Solicited Email. Company only sends email to individuals who
have agreed on the Website to receive email from Company or to individuals who
have agreed on a Third Party website to receive email from Third Parties. As such, Company does not send unsolicited
email messages. As a result,
2.5. Targeted Advertising. Company may use Personal Information to target
advertising to an individual. When an
individual is using the Internet, Company uses Technology Information to
associate an individual with that person's Personal Information, and Company
attempts to show advertising for products and services in which the person has
expressed an interest in the Surveys, indicated an interest by means of
Technology Information, and otherwise. Company may, at its discretion, target
advertising by using email, direct mail, telephones, cell phones, and other
means of communication to provide promotional offers.
2.6. Telemarketing. Company may use Personal Information to
advertise, directly or indirectly, to individuals using direct mail marketing
or telemarketing using telephones and cell phones. You may have your telephone
number or cell phone number listed on a state or federal do not call registry. By registering and using this Site, you agree
that such act constitutes a purchase, an inquiry and/or an application for
purposes of the Amended Telemarketing Sales Rule, 16 CFR §310 et seq. (the
"ATSR"). Notwithstanding that your telephone number may be listed on
the Federal Trade Commission's Do-Not-Call List, you have authorized us to
contact you via telemarketing in accordance with the ATSR. Moreover, by
registering with, or requesting information from, a third-party advertiser at
or through the Website or other advertisement media made available by us (e.g.,
email marketing), you agree that such action shall constitute a purchase, an
inquiry and/or an application with the respective third-party advertiser for
purposes of the ATSR and you may be contacted via email, direct mail and/or
telemarketing by such third-party advertiser in accordance with the ATSR. Further, if
you are residing outside the United States, by registering and using this
Website, you acknowledge that the processing of your Personal Information may
involve the transfer of such Personal Information from within or outside the
European Economic Area (“EEA”) to countries within or outside the EEA whose
data protection regulation may not be as stringent as that within the European
Union. We may use Personal Information
to provide the services you've requested, including services that display
customized content and advertising.
2.7. Wireless
Addresses. If the e-mail address you
provide to Company is a wireless e-mail address, you agree to receive messages
at such address from Company or its business associates (unless and until you
have elected not to receive such messages by following the instructions in the
unsubscribe portion of this policy). You
understand that your wireless carrier's standard rates apply to these
messages. You represent that you are the
owner or authorized user of the wireless device on which messages will be
received, and that you are authorized to approve the applicable charges.
2.8. Short Message Service. Company may make available a service through
which you can receive messages on your wireless device via short message
service (“SMS Service”). Data obtained
from you in connection with this SMS service may include your name, address,
cell phone number, your provider's name, and the date, time, and content of
your messages. You represent that you are 18 years of age and the owner or
authorized user of the wireless device on which messages will be received, and
that you are authorized to approve the applicable charges. In addition to any fee of which you are
notified your provider's standard messaging rates apply to our confirmation and
all subsequent SMS correspondence. All
charges are billed by and payable to your mobile service provider. Company will
not be liable for any delays in the receipt of any SMS messages, as delivery is
subject to effective transmission from your network operator. SMS message
services are provided on an AS IS basis. Company may also obtain the date, time and
content of your messages in the course of your use of the SMS Service. We will use the information we obtain in
connection with our SMS Service in accordance with this Privacy Policy. If fees are charged to your wireless account
invoice, we may provide your carrier with your applicable information in
connection therewith. Your wireless
carrier and other service providers may also collect data about your wireless
device usage, and their practices are governed by their own policies.
You acknowledge and agree that the
SMS Service is provided via wireless systems which use radios (and other means)
to transmit communications over complex networks. We do not guarantee that your use of the SMS
Service will be private or secure, and we are not liable to you for any lack of
privacy or security you may experience.
You are fully responsible for taking precautions and providing security
measures best suited for your situation and intended use of the SMS
Service. We may also access the content
of your account and wireless account with your carrier for the purpose of
identifying and resolving technical problems and service-related complaints.
You may remove your information from
Company’s database. If you remove your information from Company’s database it
will no longer be used by Company for secondary purposes, disclosed to third
parties, or used by Company or third parties to send promotional correspondence
to you. You may remove your information by sending your request in writing via
email to unsubscribe@frontlinedirect.com or by sending "STOP",
"END", "QUIT" to the SMS text message you have received.
2.9. Use of Technology Information. Company may use Technology Information (1) to
match a person's Personal Information and Third Party List Information to other
categories of Personal Information to make and improve profiles of individuals,
(2) to track a person's online browsing habits on the Internet, (3) to
determine which areas of Company's websites are most frequently visited. This
information helps Company to better understand the online habits of individuals
so that Company can target advertising and promotions to them.
2.10. Profiles of Individuals. Company may use Personal Information to make a
profile of an individual. A profile can
be created by combining Survey Information and Third Party List Information
with other sources of Personal Information such as information obtained from
public databases.
2.11. Storage of Personal Information. Company stores the Personal Information in a
database on its’ computers. Company
computers have security measures (such as a firewall and password protections)
in place to protect against the loss, misuse, and alteration of the information
under Company’s control. Not
withstanding such measures, Company cannot guarantee that its security measures
will prevent its computers from being illegally accessed, and the Personal
Information on them stolen or altered.
3.0. Other
Use of Personal Information. Company may use your Personal Information in the
following ways:
3.1. Public Forums. When you contribute to a public area or
feature of our Website, such as a chat room, bulletin board, list serve, blog,
wiki or other open forum that we may make available on or through our Website,
the information that you submit will be made available to the general public
and will not be considered “Personal Information” for purposes of this Privacy
Policy. For this reason, we recommend
that you do not submit any sensitive information, including your full name,
home address, phone number, other information that would enable other users to
locate you or your financial information on these areas of our Website. Instead, make up a username that does not
disclose your personal identity.
3.2. Third Party Offers. Company may provide your Personal Information
to third parties with whom they have a business relationship for the purposes
of securing the services and products you have requested or provide you with
additional marketing materials from which you may choose additional products or
services. Company may make your Personal
Information available to companies or other entities not affiliated with the
Company that have goods, services and offers that might be of interest to you
so that they may send you these offers.
3.3. Marketing. Company
will use your Personal Information for any marketing and survey purpose on
behalf of Company and its affiliates and subsidiaries to send information to
you about additional goods or services that may be of interest to you. In
addition, Company will disclose your Personal Information to third party agents
and independent contractors to help us conduct our marketing and survey efforts
including but not limited to direct marketing. You may have no relationship
with these other companies.
3.4. Co-sponsored Contests, Sweepstakes and Offerings. Company may provide a contest; sweepstake and
other offering may be co-sponsored by another company. In those situations, the information we
obtain from you in connection with such contest, sweepstake or offering may be
shared with our co-sponsor. In those
situations, our co-sponsors will have the right to use your information for
their own purposes, in accordance with their own policies. If you do not wish for the information we
obtain from you to be shared with our co-sponsor, then do not enter such
contest, sweepstake or other offering or otherwise provide to us any Personal
Information in connection with such contest, sweepstake or other offering. We are not responsible for how our
co-sponsors may use your information.
3.5. Service Providers. Company may use third-party advertising
companies to serve ads when you visit our website. These third party’s may use
information (not including your name, address, email address, or telephone
number) about your visits to this and other websites in order to provide
advertisements about goods and services of interest to you. Company may also use
third parties to help operate our Website, deliver products and services, and Company may share
your Personal Information with such third parties for our business (such as
Website or database hosting companies, address list hosting companies, e-mail
service providers, analytics companies, distribution companies, fulfillment
companies, and other similar service providers that use such information on our
behalf). Unless otherwise stated, these parties
do not have any right to use the Personal Information we provide to them beyond
what is necessary for them to assist us.
When you conduct e-commerce with one of the e-commerce affiliates or
service providers to which the Website may be linked, certain Personal
Information such as your e-mail and home address may be collected by the
service provider’s server and made available to us.
3.6. Aggregate Statistics. Company may disclose aggregate statistics
regarding user behavior as a measure of interest in, and use of, our Website
and e-mails to third parties in the form of aggregate data, such as overall
patterns or demographic reports that do not describe or identify any individual
user.
3.7. Complying with Legal Process. Company will use or disclose your Personal
Information in response to subpoenas, court orders, warrants, or legal process,
or to otherwise establish or exercise our legal rights or defend against legal
claims or in the event you violate or breach an agreement with Company. Company
will use and disclose your Personal Information if we believe you will harm the
property or rights of Company , its owners, or those of Company 's other
customers. Finally, we will use or disclose your Personal Information if we
believe it is necessary to share information in order to investigate, prevent,
or take action regarding illegal activities, suspected fraud, situations
involving potential threats to the physical safety of any person, violations of
Company’s acceptable use policy, or as otherwise required by law when
responding to subpoenas, court orders and other legal processes.
3.8. Order Fulfillment. Company will transfer your Personal
Information to third parties when necessary to provide a product or service
that you order from such third party while using Company’s websites or when
responding to offers provided by Company.
3.9. Data Summary. Company may sell or transfer
non-individualized information, such as summary or aggregated anonymous
information about all persons or sub-groups of persons.
4.0. Privacy
Practices of Third Parties.
4.1. Advertiser cookies and web beacons.
Advertising agencies, advertising networks, and other companies who place
advertisements on the websites and on the internet generally may use their own
cookies, web beacons, and other technology to collect information about
individuals. Company does not control the use of such technology and Company
has no responsibility for the use of such technology to gather information
about you.
4.2. Links. The websites and email messages sometimes
contain hypertext links to the websites of third parties. Company is not
responsible for the privacy practices or the content of such other websites.
Linked websites may contain links to websites maintained by third parties. Such
links are provided for your convenience and reference only. Company does not
operate or control in any respect any information, software, products or
services available on such third party websites. The inclusion of a link to a website
does not imply any endorsement of the services or the site, its contents, or
its sponsoring organization.
4.3. Affiliations/Merger/Sale. Company further reserves the right to
disclose, transfer or sell your Personal Information to companies who are affiliated
with Company in Company’s sole discretion.
If Company changes ownership through an acquisition, merger, sale or
other change of business status, it reserves the right to transfer or assign
the right to use your Personal Information collected from the Website.
5.0. Foreign
use of the Website. To the extent that you are accessing the
Website while domiciled outside of the
6.0.
If
you have questions about this policy, please contact us at privacy@frontlinedirect.com.