ResponsePath has created this privacy policy ("Privacy Policy") to describe and explain to you, the user of the ResponsePath Hosted Partner Page ("you"), how your submitted consumer Information will be used by us. As part of our business, we collect and, in some instances, may disclose information about you - but only as set forth in this Privacy Policy. To better protect your privacy we provide this notice explaining our information collection and use practices and the choices you can make concerning the use of your personal information.

Information Collected

For each visitor to the ResponsePath Hosted Partner Page, our servers automatically recognize only the visitor's domain name, but not the e-mail address (unless requested and supplied by the visitor as a part of registration in connection with a program offered or made available on the Website).

Certain information, such as your e-mail address, may be collected, among other purposes as set forth in this Privacy Policy, in order to verify your identity in the future within our database.

We may also collect other information such as your IP address, browser type, domain names, access times and referring third party website addresses. This information is used for the operation of our ResponsePath Hosted Partner Page, to maintain the quality of offerings, and to provide general aggregate statistics regarding the use of the ResponsePath Hosted Partner Page. Such information is not personally identifiable. When you obtain any product or service directly from a Partner Website, the Partner Website may share with us certain financial information, such as your credit card number, credit card expiration date and billing address. Financial Information that you disclose is used to confirm your identity and market third party Advertiser's products and services. This information is disclosed only as set forth below. In addition, we may receive personal information about you from outside sources and add it to your existing information on file at the ResponsePath Hosted Partner Page. We do this to improve personalization of our services (for example, providing more relevant content, advertising and/or special offers that we think may be of interest you).

We also collect information such as the identification of the server that your computer is logged onto and whether you opened an e-mail message delivered to you from the ResponsePath Hosted Partner Page. We also may compare our member list to various lists received from other third party companies, in an effort to avoid sending identical or similar e-mail messages to our members.


Information Collection Processes

In addition to the information collected by us and information submitted by you, we may employ "cookies" to help customize your access to the ResponsePath Hosted Partner Page. A "cookie" is a small data file that a website can send to your browser, which may then be stored on your computer to help the ResponsePath Hosted Partner Page "remember" information about you to make it easier and more efficient for you to use the ResponsePath Hosted Partner Page. Cookies have many benefits to enhance your experience at the ResponsePath Hosted Partner Page. For instance, by setting a cookie, a consumer would not have to log in a password more than once, thereby saving time while on a Website. The ResponsePath Hosted Partner Page employs session cookies. A session cookie does not remain on your computer after you close your web browser window. Our session cookies contain none of your personal information and cannot be used to track you around the internet. Our session cookies can only be used by this ResponsePath Hosted Partner Page and they only exist for the duration of your visit. Depending on the settings in your browser, you may have the option to deny the session cookie; however, doing so may negatively impact upon the performance of the ResponsePath Hosted Partner Page or restrict your ability to use the ResponsePath Hosted Partner Page.

We occasionally use cookies to anonymously track and target the interests of consumers to further enhance the experience on ResponsePath Hosted Partner Page or for advertising tracking purposes. To find out more about cookies, please visit www.cookiecentral.com.

In addition to cookies, ResponsePath Hosted Partner Page may contain electronic images known as "pixel tags" (also knows as clear gifs) to track the pages that visitors and/or members visit at the ResponsePath Hosted Partner Page for purposes of formatting future campaigns and upgrading visitor information used in reporting statistics. ResponsePath Hosted Partner Page may also contain pixel tags placed there by third parties to help determine the effectiveness of a joint promotional or advertising campaign.

The "help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.


Our Use of Your Information

The personal information that you submit to us remains your property. By submitting personal information to Company's Advertisers, you grant the right to use that information for marketing purposes, including sharing such information with the third parties. For example, when you select to receive information about offerings from a third party company, we will share your personal information with that third party company to carry out your information request. We may also use such information to monitor compliance with our Terms and Conditions and for content improvement and feedback purposes.

In addition, we reserve the right to release current or past consumer information in the event that we believe that the consumer information is being or has been used in violation of the Terms and Conditions or to commit unlawful acts, if the information is subpoenaed, if we are acquired, or when we deem it necessary or appropriate. By agreeing to the terms of this Privacy Policy, you hereby consent to disclosure of any record or communication to any third party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with other third-parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time and Federal Trade Commission enabling regulations.

To the extent that customer credit card-specific information is collected by us in connection with a purchase you make from a Partner's Website, said information will be kept in confidence and will not be shared with any third parties (other than consumer credit agencies and in connection with processing of your order) without your prior informed consent. Notwithstanding the foregoing, we reserve the right to share with third parties the fact that we have credit card information on file for specific customers but we will not share the specific credit card information with third parties without your prior informed consent.

You also agree that we, and other third parties, may contact you via e-mail, direct mail and telemarketing for feedback purposes and surveys. In addition, by using the ResponsePath Hosted Partner Page, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the "Rule"). Notwithstanding that your telephone number may be listed at the Federal Trade Commission's Do-Not-Call List, we retain the right to contact you via telemarketing in accordance with the Rule.

We may also employ other companies and individuals to perform certain functions on our behalf. Examples include sending direct and electronic mail, removing duplicate information from customer lists, analyzing data, and providing marketing analysis. These agents have access to our members' personal information as needed to perform their functions for us, but we do not permit them to use your personal information for other purposes.


Security

The ResponsePath Hosted Partner Page has security measures in place to protect against the loss, misuse, and alteration of personal information under our control. Currently we use Secure Socket Layer Software (SSL) to protect data and secure any transactions. SSL encrypts information, including credit card numbers, names and addresses as they are transmitted over the Internet. Please be advised that although we take every reasonable technological precaution available to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, we cannot and do not warrant that your information will be absolutely secure. Any transmission of data at or through ResponsePath Hosted Partner Page is at your own risk. However, access to your information is strictly limited, and not accessible to the public. Our employees are dedicated to ensuring the security and privacy of all user information. Employees not adhering to our firm policies are subject to disciplinary action.

Minors

Individuals under 18 years of age are not permitted to participate in obtaining products and/or services at the ResponsePath Hosted Partner Page. No information should be submitted to, or posted at, the ResponsePath Hosted Partner Page by visitors under 18 years of age without the prior consent of their parent or guardian. Notwithstanding the foregoing, children 13 years of age and younger are not permitted to access the ResponsePath Hosted Partner Page for any reason and we do not knowingly collect personal information from such children. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Third-Party Links

We do not endorse, nor are we responsible for the accuracy of, the privacy policies and/or terms and conditions of each of the advertisers and/or third parties accessible through the ResponsePath Hosted Partner Page . The entities that advertise and/or place banner ads at the Partner's Website are independent third parties and not affiliated with us.

Acceptance of this Privacy Policy

By using ResponsePath Hosted Partner Page including, without limitation, signing up for offers and/or continuing to receive information from the Partner's Website, you agree to this Privacy Policy. We reserve the right, at our discretion, to change, modify, add, and/or remove portions of this Privacy Policy at any time. All changes will take effect immediately upon their posting on our Website. Please check this page periodically for changes. Your continued use of the ResponsePath Hosted Partner Page following the posting of changes to this Privacy Policy will mean that you accept any and all such changes and agree to continue receiving directing marketing from us and other third party companies. If you do not agree to the terms of this Privacy Policy, please unsubscribe. If you have questions about this Privacy Policy, please contact us at privacy info@responsepath.com.

This Privacy Policy is governed by the internal substantive laws of the State of New York in the United States, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Privacy Policy shall lie exclusively with the state and federal courts within the State of New York. If any provision of this Privacy Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions, which shall remain in full force and effect. The failure of ResponsePath to enforce any term or condition of this Privacy Policy shall not be deemed a waiver thereof and shall not prevent its later enforcement.



 
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