This policy describes the information collection, use, and dissemination practices of VAB, Inc., its subsidiaries and affiliates, (collectively referred herein as “COMPANY”) and applies to COMPANY’s collection, use, storage and disclosure of information by COMPANY on its (a) websites, including all its divisions, subsidiaries and related companies (collectively, the "Websites"), (b) on various Third Party websites, and (c) to COMPANY's other information collection. COMPANY is not responsible for the information collection or privacy practices of its Clients or other Third Party websites or applications.
1. Collection of Information.
1.1 Survey Information. COMPANY collects information from individuals by various methods, including, but not limited to, when an individual voluntarily completes a survey, order form, or a registration page either online or offline, or by means of online or offline surveys, order forms, or registration pages operated by Third Parties (collectively, a "Survey"). (As used herein, "online" means using the Internet, including the Websites, and related technologies, and "offline" means by methods other than online, including in person, in the postal mail, using telephones and cell phones, and other similar means.) In the Surveys, COMPANY or a Third Party (a "Third Party") may ask an individual to provide various information to COMPANY, which may include his or her 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 (together, "Survey Information"). COMPANY may also collect information concerning an individual from another source and uses that information in combination with information provided from this website. Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to COMPANY or Third Party, but an individual may receive incentives from COMPANY or a Third Party in exchange for providing Survey Information to COMPANY.
"Subscription" occurs when an end-user registers for COMPANY's services, either via registration at our website, via co-registration at a marketing partner's website, or via a permission pass / opt-out / no-opt mailing COMPANY collects personally identifiable information about our subscribers, based on: information gathered at the time of registration, subscriber interaction and response to subsequent electronic mailings and website use, information provided by marketing partners, and information appended from data aggregators. Information collected may include, but is not necessarily limited to: name, email address, postal address, gender, birth date, telephone number, activity, interests, user behavior and other demographic information. This information enables us to better tailor our content to subscribers' needs and to help our clients to promote and sell their products and services.
1.3 Other Information. COMPANY may also obtain your information from individuals when you provide it to another party and COMPANY enters into a business relationship with such third party to purchases, licenses, or otherwise acquire the information. Such information may include, but is not limited to, an individual's 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 as the individual may have provided. When such business relationships occur, COMPANY seeks assurances from the other party that they have obtained your permission to transfer the information to COMPANY and provide offers to you.
1.4 Requests for Assistance or Service. Other occasions when COMPANY obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by COMPANY or by a Third Party, (2) when an individual requests assistance through COMPANY's customer service department, and (3) when an individual voluntarily subscribes to a COMPANY’s service or newsletter (together, "Other Information").
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 an individual with information about the individual in our database. Additionally, COMPANY may use other new and evolving sources of information in the future (together, "Technology Information").
- (a) Cookies. A cookie is a small amount of data stored on the hard drive of the individual's computer that allows COMPANY to identify the individual with his or her corresponding data that resides in COMPANY’s database. You may read more about cookies at http://cookiecentral.com. Individuals who use the Websites need to accept cookies in order to use all of the features and functionality of the Websites.
- (b) Web Beacons. A web beacon is programming code that can be used to display an image on a web page (by using a programming function <img src="x" /> -- see http://truste.org for more information), but can also be used to transfer an individual's unique user identification (often in the form of a cookie) to a database and associate the individual with previously acquired information about an individual in a database. This allows COMPANY to track certain websites an individual visits online. Web beacons are used to determine products or services an individual may be interested in, and to track online behavioral habits for marketing purposes. For example, COMPANY might place, with the consent of a Third Party website, a web beacon on the Third Party's website where cosmetics are sold. When Jane, an individual listed in COMPANY's database, visits the cosmetic website, COMPANY receives notice by means of the web beacon that Jane visited the cosmetics site, and COMPANY would then update Jane’s profile with the information that Jane is interested in cosmetics. COMPANY may thereafter present offers of cosmetic related products and services to Jane. 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) New Technology. The use of technology on the Internet, including cookies and web beacons, is rapidly evolving, as is COMPANY's use of new and evolving technology. As a result, COMPANY strongly encourages individuals to revisit this policy for any updates regarding its use of technology.
- (d) Usage Tracking and Log Files. COMPANY tracks information related to the electronic mailings and web pages viewed by users and subscribers, as well as the hyperlinks clicked by subscribers, while viewing our emails or visiting our websites. Log files are used to track and monitor subscriber usage.
- (e) Optional Registration. COMPANY may offer free voluntary registration to potential subscribers. During such registration, the subscriber is required to supply an email address and other personal information. This information is required if the subscriber wants to participate in Company services.
- (f) Feedback and Inquiries. You have the ability to contact COMPANY to provide us with their feedback. COMPANY uses this information to respond to you and analyze customer service issues.
- (g) IP Address. We collect your IP (Internet Protocol) address to help diagnose problems with our server, and to administer this Site. An IP address is a number that is assigned to your computer when you use the Internet. Your IP address is also used to help identify you during a particular session and to gather broad demographic data.
- (h) Clear GIFs . We use a common technology known as a “Clear GIF” or “1-by-1 Pixel” on the Site and in e-mail communications with users. A Clear GIF or “graphic interface format” is a small graphic (in fact, truly a 1x1 pixel) that we (or our partners) place on a page of the Site. We may also occasionally place GIFs in e-mail messages that we send to users. GIFs, which do not contain any PII, provide us with important information about how users use the Site and respond to e-mail messages. With this information, we are better able to track the performance of certain promotions and understand the effectiveness of particular creative e-mail presentations. We may also allow our advertisers and promotional partners the ability to use GIFs on the Site solely to track users who link from their respective sites to this Site, but this ability to track such activity does not allow these entities access to user PII.
1.6 Outside Information. COMPANY may receive information about individuals from Third Parties or from other sources of information outside of COMPANY including information located in public databases ("Outside Information").
1.7 Individual Information. As used herein, Individual Information means Survey Information, Third Party List Information, Other Information, Technology Information, and Outside Information, and any other information COMPANY gathers or receives about individuals.
1.8 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 our database. Because it does not collect such information, COMPANY has no such information to use or to disclose to Third Parties. COMPANY is designed this policy in order to comply with the Children's Online Privacy Protection Act ("COPPA").
1.9 Credit Card Information. Company may in certain cases collect credit card numbers and related information, such as the expiration date of the card ("Credit Card Information") when an individual places an order from COMPANY. When the Credit Card Information is submitted to COMPANY, such information is encrypted and is protected with SSL encryption software. COMPANY will use the Credit Card Information for purposes of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to Third Parties only as necessary to complete the purchase transaction.
2. Use of Individual Information.
2.1 General Use. The following paragraphs in Section 2 describe how COMPANY currently uses Individual 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 Individual Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses.
2.2 Email and Unsubscribe Policy. COMPANY uses Individual Information to provide promotional offers by email to individuals and companies including its clients. 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 firstname.lastname@example.org .
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.
You should also note that unsubscribing from COMPANY’s electronic mailings will not automatically unsubscribe the subscriber’s 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. In certain commercial email messages sent by COMPANY, an Advertiser's name will appear in the "From:" line but hitting the "Reply" button will cause a reply email to be sent to COMPANY. The "Subject:" line of COMPANY email messages will usually contain a line provided from the Advertiser to COMPANY.
2.4 Solicited Email. COMPANY only sends email to individuals who have agreed on the Websites 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, statutes requiring certain formatting for unsolicited email are not applicable to COMPANY 's email messages.
2.5 Targeted Advertising. COMPANY uses Individual 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 Individual 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 uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones. By registering and using this Site, You acknowledge that the processing of your individual information may involve the transfer of such PII from within the European Economic Area (“EEA”) to countries outside the EEA whose data protection regulation may not be as stringent as that within the European Union. We may use individual 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 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 email@example.com or by sending "STOP", "END", "QUIT" to the SMS text message you have received.
2.9 Use of Technology Information. COMPANY uses Technology Information (1) to match a person's Survey Information and Third Party List Information to other categories of Individual 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 uses Individual 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 Individual Information such as information obtained from public databases.
2.11 Storage of Individual Information. COMPANY stores the Individual Information in a database on its’ computers. Our computers have security measures (such as a firewall) 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 Individual Information on them stolen or altered.
3. Dissemination of Individual Information.
3.1 Business Associates. COMPANY may enter into agreements with various business associates to provide and/or host online services and additional offers to you and as such may license your personal information to such business associates. These third parties will be contractually bound to treat your information in accordance with the applicable COMPANY privacy policies.
3.2 Marketing and Order Fulfillment. COMPANY will transfer Individual Information to Third Parties when necessary to provide a product or service that a person orders from such Third Party while using COMPANY’s websites or when responding to offers provided by COMPANY. Company may also use a Third Party to provide you with information regarding Company, its services and products or to provide you with Third party services and information which you have requested.
3.3 Legal Process. COMPANY may disclose Individual Information to respond to subpoenas, court orders, and other legal processes.
3.4 Summary Data. COMPANY may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.
3.5 Access. Individuals have access to their Individual Information collected to provide an opportunity for an individual to correct, amend, or delete such information. Access can be obtained by contacting firstname.lastname@example.org. COMPANY may also grant advertising clients and email services providers’ access to an individual's email address to verify the origin of the Individual Information collected.
4. Privacy Practices of Third Parties.
4.1 Advertiser cookies and web beacons. Advertising agencies, advertising networks, and other companies (together, "Advertisers") 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 Advertisers' use of such technology and COMPANY has no responsibility for the use of such technology to gather information about individuals.
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 Affiliated Companies. COMPANY may disclose, transfer, and sell Individual Information to entities affiliated with COMPANY in COMPANY’s discretion.
5. Unsubscribe Procedures. If you wish to discontinue receiving email messages from COMPANY, you have several options:
(a) Unsubscribe from one email list. To unsubscribe from a particular list, either (1) send an email to email@example.com or (2) follow the instructions in each promotional email message sent.
(b) Unsubscribe from all of COMPANY's email lists. We reserve the right to add Individual Information to multiple lists maintained by COMPANY. To globally unsubscribe from all of COMPANY’s lists, send an email to firstname.lastname@example.org .
6. CALIFORNIA RESIDENTS PRIVACY RIGHTS
Companies that collect personally identifiable information ("PII") from California residents and disclose such information to Third Parties (including affiliated entities) for marketing purposes must, in response to a request by a consumer, either (1) provide a list detailing the categories of information shared and the entities to which such information was provided, or (2) provide a mechanism by which a consumer may opt-out of having their information shared with Third Parties. We have elected the second option and you may request that your PII not be shared with Third Parties by sending your request, including your full name, email address and postal address to: email@example.com, or by mail to California Privacy Information c/o VAB, Inc., 6675 Mesa Ridge Road, San Diego, CA 92121. In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, Suite 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to firstname.lastname@example.org.
For more information about protecting your privacy, you may wish to visit: www.ftc.gov. If you have questions about this policy, please contact us at email@example.com.