Privacy Policy

Effective date: August 1, 2005

This page set forth the privacy policies and practices of C2B Direct, Inc., and its affiliated companies (“C2B”, “C2B Network”, “we” or “us”).

Please read this privacy policy carefully since by visiting a C2B site and sharing information with one our companies you agree to be bound by the terms and conditions of this Privacy Policy unless you offer different terms which are accepted by C2B in writing.


CALIFORNIA RESIDENTS: YOUR PRIVACY RIGHTS


Effective January 1, 2005, 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:

C2B Direct, Inc.
Attn: Privacy
8568 Warren Pkwy.
Suite 421
Frisco, TX 75034

If you have questions or concerns regarding this statement, email us at privacy@c2bdirect.com.

CONSUMER PRIVACY

I. INFORMATION WE COLLECT: INDIVIDUAL INTERNET CONSUMERS

A. Personally Identifiable Information (PII).

The C2B Network sites are designed to promote and facilitate the business of the C2B companies with advertisers and marketers. These sites are not directed towards individual Internet consumers nor do they seek any PII from such consumers. PII may be collected should a consumer contact a C2B company on his/her own initiative or respond to a C2B advertisement and provide any PII. Under no circumstances does the C2B Network request or collect sensitive PII such as an Internet user's medical/health conditions; racial or ethnic origin; political, religious or philosophical beliefs or affiliations; trade union membership or sex life.

From time to time, however, C2B may host response forms for one of our advertisers which will ask the Internet user to provide PII (e.g. name, address, zip code, email address, gender, and birth date). All information provided will be shared with the advertiser. We also may collect PII through co-registrations, i.e., when an Internet user registers on a third party site and agrees to receive offers from C2B.

B. Non-Personally Identifiable Information (Non-PII).

When a consumer responds to or views an Internet advertisement served by a C2B company (such as through third-party websites or email solicitation) or visits a C2B site, we send a cookie and/or gif file (“Cookies”) to assign an anonymous, unique identifier to the end user's Internet browser. Cookies are small data files commonly used on the Internet to help optimize and personalize the Internet end user experience and identify repeat visitors to websites.

The function of these Cookies is to provide C2B with information for the purpose of paying third-parties commissions when an Internet user clicks on a link, creates a lead, or makes a purchase on an advertiser's Web site; and also to optimize and personalize the Internet user's experience. If the Internet user re-visits the advertiser's site directly, C2B is able to continue to track the user's activities on the advertiser's site and reward the third-party website that referred the user. We reserve the right to retain all ad delivery and reporting data indefinitely as long as may be reasonably necessary for accounting and audit purposes.

Like most standard website servers, we use log files to collect Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, and date/time stamp. We use the information to analyze site usage, administer the site, understand usage and navigation trends in aggregate, and determine the relevance of content. This information, however, is not linked to any personally identifiable information.

We also may use Internet browsing and online purchase data associated with an anonymous identifier to develop a predictive statistical user profile of the end user's needs and interests. C2B does not use Cookies or log files to collect end users' names, physical addresses, email addresses, phone numbers, credit card numbers, social security numbers, or any other information which can be used to identify a specific person. We may match the IP address and user profile with email address data obtained separately in order to better target campaigns to meet user's interests.

For improved audience targeting, some C2B sites use marketing technology that allows advertisers to add non-personally-identifying demographic information, such as age, gender, area code, or ZIP code, to the non-identifiable profile data. Thus, there is no direct connection between an end user's online choices and his or her personal identity.
In some cases, C2B receives and records partial email addresses of Internet users, only in circumstances where the user voluntarily provided its identity and contact information through the Advertiser's site or third-party marketer's site. This partial email address does not enable C2B to personally identify an Internet User.

II. INFORMATION SHARING

The C2B Network may make any PII provided in responding to an advertisement available to the company sponsoring the advertisement, as well as to other trusted third parties in accordance with the terms of this privacy policy. As a result, you may receive information on additional products, services and offers that may be of interest to you.

The C2B and/or our marketing partners may enhance and/or merge PII about consumers who have opted-in to receive marketing communications with commercially-available third party data collected from other sources in an effort to ensure that the messages being sent to the consumer in online and/or offline marketing programs are relevant to their interests. In the event we enhance and/or merge such personally identifiable information with data collected from other sources, we will take reasonable steps to maintain the integrity and quality of that information.

The C2B Network may share PII (including information that has been enhanced with information from other sources) with advertisers, third party marketers, our affiliated entities for their online and/or offline marketing programs or in connection with the sale, merger, consolidation, change in control, transfer of substantial asset, reorganization or liquidation of any of the C2B companies. While C2B strongly encourages clients and partners to adopt responsible approaches to online marketing, C2B is not responsible for the information practices of clients or their partners. The collection, use, and disclosure of information by clients and partners are subject to their respective privacy policies, which may differ from C2B's policy.

The C2B Network may release account and any other personal information when we believe release is appropriate to respond to a subpoena or otherwise comply with the law; enforce or apply our Terms and Conditions and other agreements; or protect the rights, property, or safety of C2B or others. This includes exchanging information with other companies and organizations for fraud protection.

III. CONSUMER CHOICE AND ACCESS

A. Opting Out.
C2B provides an "opt-out" option from all of its sites within the C2B Network.

C2B's Cookies do not have an "opt-out" option, yet you still have the option of blocking the use of Cookies by changing a setting in your Internet browser. Please see your browser supplier's website for details on how to do this.

B. Accessing Consumer Information.
Because they are not directed towards individual Internet users, most C2B sites do not maintain a process for an individual consumer to review and/or request changes to any PII collected. This site does not maintain a process for an individual consumer to access his/her PII.

IV. SECURITY

The C2B Network employs industry standard security measures to ensure the security of all data. Any data that is stored on C2B's servers is treated as proprietary and confidential and is not available to the public. C2B has an internal security policy with respect to the confidentiality of customer and other data, allowing access only to those employees or third parties who have a need to know such information for the purpose of effectively delivering C2B products and services by means of user login and password requirements. The C2B Network routinely evaluates its data security practices to identify security threats or opportunities for improvement.

No transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties not under the control of C2B to intercept or access transmissions or private communications unlawfully. While we strive to protect your PII, C2B cannot ensure or warrant the security of any information you transmit to us. You acknowledge and assume this risk when communicating with a C2B company.

V. CONSENT AND CHANGES

C2B may find it necessary or be legally obligated to update this Privacy Policy from time to time. When we do, we will post those changes on this page and update the effective date so that you are always aware of the information we collect, how we use it, and under what circumstances we disclose it. Except as otherwise required by law, modifications to this Privacy Policy will not affect the privacy of data collected by C2B prior to the effective date of the policy change unless we provide you direct notice and the opportunity to opt-out of such proposed change.

VI. CHILDREN'S PRIVACY AND SPAM

C2B is very sensitive to the issue of children's privacy and makes every effort to protect the privacy of children using the Internet. C2B's web site(s), products, and services are not developed for or directed at children. Children (persons under the age of 18) are not eligible to do business with us and we do not collect personal information from any person we actually know is under the age of 13. If you believe your child has provided C2B with any personally identifiable data by registering at a C2B web site, please email us at privacy@c2bdirect.com to have them removed.

C2B is committed to proper Internet practices and full compliance with the CAN-SPAM Act of 2003 (15 U.S.C. § 7701). It is our policy to prohibit the sending of unsolicited or "Spam" e-mail by C2B or any of its marketing partners.

Please note that under the CAN-SPAM Act, an advertiser is required to provide an opt-out mechanism for consumers to unsubscribe from future emails about the advertiser. Although not required to by law, many email marketers also include an opt-out mechanism to enable consumers to be removed from their mailing list. This has caused some confusion for consumers in opting out. The table below clarifies which opt-out mechanism you should use for commercial emails.

To receive no further emails . . .

Opt-Out Mechanism to Use

about the advertiser

Advertiser's

from the email marketing company

Mark eter's

from the advertiser or email marketing company

Both

VII. DATA PROCESSING/SAFE HARBOR

The European Union (“EU”) maintains strict privacy laws. These rules differ significantly from US laws. To reconcile these differences, the US and the EU have created a Safe Harbor that defines mutually acceptable privacy operations. C2B adheres to the Safe Harbor principals. For more information see www.export.gov/safeharbor.

By providing information to C2B sites, you acknowledge that they operate in the United States and agree to (i) permit C2B to transmit and use your User information anywhere necessary, including across international boundaries, to affect the services and transactions provided by this Site; and (ii) that such use by C2B shall be subject to the terms and conditions stated in this Privacy Statement and applicable Terms and Conditions and Policies.

VIII. LIMITATION OF LIABILITY, THIRD PARTY INFORMATION & LANGUAGE

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE TERMS AND CONDITIONS AND POLICIES (INCLUDING LIMITATIONS ON DAMAGES, AND ARBITRATION OF DISPUTES). YOU AGREE THAT C2B'S LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE GREATER OF THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY C2B $250 TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS.

You also agree that you have provided notice to, and obtained consent from, any third party individuals whose personal data you supply to C2B with regard to: (a) the purposes for which such third party's personal data has been collected; (b) the intended recipients or categories of recipients of the third party's personal data; (c) which of the third party's data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them. It is the express will of the parties that this agreement and all related documents have been drawn up in English.


CONTACT US

For more information or if you have questions or concerns regarding the C2B Privacy Policy, please email us at privacy@c2bdirect.com or you can send correspondence to the following address:

C2B Direct, Inc.
Attn: Privacy
8568 Warren Pkwy.
Suite 421
Frisco, TX 75034

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