 |
|||||
 |
|||||
 |
|||||
|
PRIVACY
POLICY OF Frontline
Direct, Inc., and all related Websites. Last
updated March 16, 2006. BY VISITING THIS
WEBSITE AND REQUESTING INFORMATION, PRODUCTS OR SERVICES THERON, YOU AGREE TO
BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY.
IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO
NOT PROVIDE ANY INFORMATION OR USE ANY OF THE SERVICES OR PRODUCTS OFFERED OR
PROVIDED ON ANY OF THE WEBSITES REFERRED TO IN THIS PRIVACY POLICY. PLEASE NOTE: THIS
PRIVACY POLICY CHANGES FROM TIME TO TIME AND CHANGES ARE EFFECTIVE UPON
POSTING. PLEASE CHECK BACK FREQUENTLY FOR UPDATES AS IT IS YOUR SOLE
RESPONSIBILITY TO BE AWARE OF CHANGES. WE DO NOT PROVIDE NOTICES OF CHANGES IN
ANY MANNER OTHER THAN BY POSTING THE CHANGES AT THIS WEB SITE. This policy
describes the information collection, use, and dissemination practices of
Frontline Direct, Inc., (“Frontline Direct”) and applies to Frontline
Direct’s collection, use, storage and disclosure of information by Frontline
Direct on its (a) websites, including all its divisions, subsidiaries and
related companies (collectively, the "Websites"), (b) on various
Third Party websites, and (c) to Frontline Direct's other information
collection, including the purchase of customer lists from Third Parties.
Frontline Direct is not responsible for the information collection or privacy
practices of Third Party websites or applications. 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: Frontline Direct, Inc., 11839 Sorrento Valley Road,
Suite D, 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 dca@dca.ca.gov. THE INFORMATION
COLLECTION, USE AND DISSEMINATION PRACTICES OF Frontline
Direct. 1.
Collection of Information. 1.1
Survey Information. Frontline Direct
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, Frontline Direct or a Third Party (a
"Third Party") may ask an individual to provide various information
to Frontline Direct, 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"). Frontline
Direct may also collect information concerning an individual from another
source and uses that information in combination with information provided from
this web site. Completing the
Surveys is completely voluntary, and individuals are under no obligation to
provide Survey Information to Frontline Direct or Third Party, but an
individual may receive incentives from Frontline Direct or a Third Party in
exchange for providing Survey Information to Frontline Direct. 1.2
Site Membership or Registration. To the extent
registration is required to receive email and possibly postal communications
from Frontline Direct, this Privacy Policy also applies to consumers that have
agreed to receive e-mail marketing from Frontline Direct, whether at our
Website, via email, on Third Party websites or otherwise. We
collect information in certain portions of our Website, where guests provide
content submissions and suggestions or participate in interactive online
activities (i.e., by way of responding to questions and surveys, community
listings, ratings, searches and comparison searches, bidding, purchasing,
chat, games, or bulletin boards, etc.). The
personal profile information you submit to Frontline Direct remains your
property, but by submitting that information to Frontline Direct, you grant
Frontline Direct, the right to use that information for marketing purposes. Frontline
Direct, may also use such information for content improvement and feedback
purposes. We may sell the
personal information that you supply to us and we may join together with other
businesses to bring selected retail opportunities to our members. These
businesses may include providers of direct marketing services and
applications, including lookup and reference, data enhancement, suppression
and validation. In addition, Frontline Direct reserves the right to release
current or past member information in the event Frontline Direct believes that
the membership is being or has been used in violation of the Rules or to
commit unlawful acts, if the information is subpoenaed, if Frontline Direct is
sold or acquired, or when Frontline Direct deems it necessary or appropriate. By
agreeing to these terms, you hereby consent to disclosure of any record or
communication to any Third Party when Frontline Direct in its sole discretion,
determines the disclosure to be appropriate. "Subscription"
occurs when an end-user registers for Frontline Direct'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 Frontline Direct
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
Third Party List Information. Frontline Direct
collects information from individuals when an individual provides information
to a Third Party and Frontline Direct subsequently purchases, licenses, or
otherwise acquires the information from the Third Party (the
"Seller"). Such
purchased 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 to
the Seller (together, "Third Party List Information"). When
acquiring Third Party List Information, Frontline Direct seeks assurances from
the Seller that the Seller has a right to transfer the Third Party List
Information to Frontline Direct and that the Seller has a right to provide
offers from Advertisers to the individuals whose personal information is
included on the Seller's list. 1.4
Other Information. Other occasions when
Frontline Direct obtains information from individuals include (1) when an
individual is making a claim for a prize or seeking to redeem an incentive
offered by Frontline Direct or by a Third Party, (2) when an individual
requests assistance through Frontline Direct's customer service department,
and (3) when an individual voluntarily subscribes to a service or newsletter (together, "Other
Information"). 1.5
Cookies, Web Beacons, and Other Info Collected Using Technology. Frontline Direct
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, Frontline Direct 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 Frontline Direct to identify the individual with his or her
corresponding data that resides in Frontline Direct'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
an <img src="x"> programming function -- 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 Frontline Direct 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, Frontline Direct 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 Frontline Direct's database, visits the cosmetic
website, Frontline Direct receives notice by means of the web beacon that Jane
visited the cosmetics site, and Frontline Direct would then update Jane’s
profile with the information that Jane is interested in cosmetics. Frontline
Direct may thereafter present offers of cosmetic related products and services
to Jane. In addition to using web
beacons on web pages, Frontline Direct also uses web beacons in email messages
sent to individuals listed in Frontline Direct's database. (c)
New Technology. The use of
technology on the Internet, including cookies and web beacons, is rapidly
evolving, as is Frontline Direct's use of new and evolving technology. As
a result, Frontline Direct strongly encourages individuals to revisit this
policy for any updates regarding its use of technology. (d)
Usage Tracking. 1.6
Outside Information. Frontline Direct may
receive information about individuals from Third Parties or from other sources
of information outside of Frontline Direct 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 Frontline Direct gathers or receives about individuals. 1.8
No Information Collected from Children. Frontline Direct
will never knowingly collect any personal information about children under the
age of 13. If Frontline Direct
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, Frontline Direct has no such information to use or
to disclose to Third Parties. Frontline
Direct has designed this policy in order to comply with the Children's Online
Privacy Protection Act ("COPPA"). 1.9
Credit Card Information. Frontline Direct 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 Frontline Direct. When the Credit Card Information is submitted to Frontline
Direct, such information is encrypted and is protected with SSL encryption
software. Frontline Direct 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. 1.10
Links to External Websites. Frontline Direct’s emails and websites contain links to external websites. You will be taken to external websites if you click on these links. Your information may be passed from Frontline Direct’s database to the external website, and/or external database, for your convenience (e.g. your information may be used to pre-fill a form at a destination website). Frontline Direct is not responsible for the privacy practices or content of any external website owner. We encourage you to review the privacy policy of any website they visit 2.
Use of Individual Information. 2.1
Discretion to Use Information. THE COMPANY MAY USE
INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN COMPANY'S SOLE
DISCRETION. The following
paragraphs in Section 2 describe how Frontline Direct currently uses
Individual Information, but Frontline Direct may change or broaden its use at
any time. As noted below,
Frontline Direct may update this policy from time to time. Frontline
Direct 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. Frontline Direct
uses Individual Information to provide promotional offers by email to
individuals. Frontline Direct 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 Frontline Direct’s email lists, a person must send an
email to unsubscribe@frontlinedirectinc.com.
Frontline Direct's
unsubscribe process impacts only the future delivery of electronic mailings
disseminated by Frontline Direct 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 Frontline Direct’s electronic mailings will not
automatically unsubscribe the subscriber’s information from any Third Party
associates and licensees of the data. Since
Third Party associates and licensee partners maintain separate databases from
Frontline Direct, 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 Frontline Direct, an Advertiser's name will
appear in the "From:" line but hitting the "Reply" button
will cause a reply email to be sent to Frontline Direct. The
"Subject:" line of Frontline Direct email messages will usually
contain a line provided from the Advertiser to Frontline Direct. 2.4
Solicited Email. Frontline Direct
only sends email to individuals who have agreed on the Websites to receive
email from Frontline Direct or to individuals who have agreed on Third Party
websites to receive email from Third Parties.
As such, Frontline does not send unsolicited email messages. As
a result, statutes requiring certain formatting for unsolicited email are not
applicable to Frontline Direct's email messages. 2.5
Targeted Advertising. Frontline Direct
uses Individual Information to target advertising to an individual. When
an individual is using the Internet, Frontline Direct uses Technology
Information (see also Section 2.7 below) to associate an individual with that
person's Individual Information, and Frontline Direct 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. Frontline Direct 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
Direct Mail and Telemarketing. Frontline Direct
uses Individual Information to advertise, directly or indirectly, to
individuals using direct mail marketing or telemarketing using telephones and
cell phones. 2.7
Use of Technology Information. Frontline Direct
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 Frontline
Direct's websites are most frequently visited. This information helps
Frontline Direct to better understand the online habits of individuals so that
Frontline Direct can target advertising and promotions to them. 2.8
Profiles of Individuals. Frontline Direct
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. 2.9
Storage of Individual Information. Frontline Direct
stores the Individual Information in a database on computers. Our
computers have security measures (such as a firewall) in place to protect
against the loss, misuse, and alteration of the information under Frontline
Direct's control. Not withstanding such measures, Frontline Direct cannot
guarantee that its security measures will prevent computers from being
illegally accessed, and the Individual Information on them stolen or altered. 3.
Dissemination of Individual Information. 3.1
Sale or Transfer to Third Parties. Frontline
Direct MAY SELL OR TRANSFER
INDIVIDUAL INFORMATION TO THIRD PARTIES FOR ANY PURPOSE IN Frontline
Direct'S SOLE DISCRETION. 3.2
Order Fulfillment. Frontline Direct
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 Frontline Direct websites or when responding to offers provided by
Frontline Direct. 3.3
Legal Process. Frontline Direct may
disclose Individual Information to respond to subpoenas, court orders, and
other legal processes. 3.4
Summary Data. Frontline Direct 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 info@frontlinedirectinc.com.
Frontline Direct 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. Frontline Direct does not control Advertisers' use of such
technology and Frontline Direct 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. Frontline Direct 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. Frontline
Direct 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 web site does not imply any
endorsement of the services or the site, its contents, or its sponsoring
organization. 4.3
Affiliated Companies. Frontline Direct may
disclose, transfer, and sell Individual Information to entities affiliated
with Frontline in Frontline Direct's sole discretion. 5.
Unsubscribe Procedures. If you wish to
discontinue receiving email messages from Frontline Direct, you have several
options: (a)
Unsubscribe from one email list. To unsubscribe from
a particular list, either (1) send an email to unsubscribe@frontlinedirectinc.com
or (2) follow the instructions in each promotional email message sent by
Frontline Direct. (b)
Unsubscribe from all of Frontline
Direct's email lists. We reserve the right to add Individual Information to multiple lists maintained by Frontline Direct. To globally unsubscribe from all of Frontline Direct’s lists, send an email to unsubscribe@frontlinedirectinc.com
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 info@frontlinedirectinc.com.
|
|||||