PRIVACY POLICY
Effective July 11, 2011

Proffiliates,Inc. respects and values your privacy rights. The following privacy policies describe the type of information we collect about you; how we secure that information; how we use that information; and the choices you have regarding the collection and use of your private information. Each policy describes the use of "Cookies" for each of our businesses.

Proffiliates,Inc, Inc. operates in accordance with the following policies (hereinafter referred to individually as "Privacy Policy" and together as "Privacy Policies"):

* Corporate Privacy Policy. [see below]
* List Management Privacy Policy. [see below]

Below you will find a summary which highlights key aspects of our Privacy Policies. Please read each applicable Privacy Policy to obtain a full understanding of our Privacy Policies. By signing up for any service provided by Proffiliates you consent to the applicable Privacy Policy and the Privacy Policy Introduction.

Privacy Rights Summarized


Proffiliates, Inc.(hereinafter "Proffiliates") collects both personally identifiable information about you and non-personally identifiable information about you to provide you with the services you have requested. This summary and the full set of Privacy Policies in the links above, describe how information is collected and distributed and choices which may be elected with respect to personal identifiable information.

Information We Collect and Retain
Our corporate website collects personal and demographic information from persons and entities who engage our company's services ["Business Clients"] when they choose to provide it to us through an application, contract or request for assistance. Such information may include the business name, address, telephone number email address, IP addresses and URL information [collectively "PII"]. As we operate a list management company as well, we collect and retain consumer PII received from third parties who have licensed such information to us. We utilize a variety of cookies and some of our Business Clients utilize cookies as part of their services ("Cookie Business Associates"). Cookie Business Associates may collect non-personally identifiable information from consumers, which includes behavioral data, web data, and statistical information ("Non-PII"). No PII is collected by our Cookie Business Associates. We also collect information about how you use our sites and the areas of our sites that you visit through the use of proprietary and third party tracking technology. This technology does not record any PII. We may also acquire PII and Non PII about consumers and business associates from third parties in order to further tailor such persons experience on our websites. The resulting logs that we create contain information necessary for us to analyze the use of resources, troubleshoot problems, and improve our services. We also use certain proprietary and third party technologies that allow us to track Business Clients and consumers for payment purposes.

How Information is Used and Shared
We do not lease, sell or distribute any PII provided by our Business Clients to any third parties for commercial use. We may share PII of our Business Clients with service providers or suppliers to fulfill certain services, comply with any legal process such as subpoenas or court orders or in circumstances in which we believe it is necessary to protect our reputation or interests. We use consumer PII provided from third party vendors in our list management division to send or display third party marketing offers to consumers. Our services may include the display of personalized content and advertising on websites owned and operated by third parties or Proffiliates. We may use PII to contact persons about site updates, conduct surveys, or informational and service-related communications, including important security updates. Our third party cookie associates may use the non-PII information collected for behavioral data analysis, statistical analysis or for the purposes of target advertising. Information collected on websites owned and operated by Proffiliates ("Site") is stored in whole or in part in the United States, and may be subject to U.S. law. Finally, we may disclose and transfer PII if Proffiliates is sold or acquired.

Choices Regarding PII Use and Sharing
Any person or entity that has provided their PII to use directly may be removed from our database by contacting us at unsubscribe@proffiliates.com. Consumers who have received emails through our list management division may request suppression from receiving further emails from either a specific advertiser who appears in the email or from our entire system by using the unsubscribe link at the bottom of the email or by unsubscribe@proffiliates.com Business Clients may review, correct, or delete the PII you submit to us at any time by requesting removal of your PII to unsubscribe@proffiliates.com. When you request us to delete your PII it will be deleted, but we will retain logs, demographic and statistical information about you and keep an archival copy of your information in an anonymous form. If your PII was previously accessed by others or transferred to others using our Site, we are unable to delete the information from their systems.

We have no control over the PII that Ad Networks or other third parties may obtain, store or use. We encourage you to visit their web sites to review and read their privacy policies and opt-out practices that govern their usage.

You may also turn off cookies through your web browser. However, this may affect your use of our site as well as other's sites. There are many ways to eliminate or block cookies from your browser. Please see http://cookiecentral.com for more information.

Changes to the Privacy Policies
Proffiliates reserves the right to modify or change each Privacy Policy at any time for any reason. The changes to each Privacy Policy will be effective upon posting without further notice. If the changes to a Privacy Policy or Privacy Policies broaden our rights to collect, use or retain PII such rights will only be asserted from the date of posting forward.

How to Contact Us
You may contact us for questions or concerns about our privacy practices by emailing or calling us at:

Proffiliates, Inc.
50 California Street, Suite 1500 San Francisco, CA 94111
E: general@proffiliates.com
T: 415.647.7601



Corporate Privacy Policy


Effective July 11, 2011

Proffiliates, Inc. ("Proffiliates") and its wholly owned subsidiaries (collectively "Company") respect and values your privacy rights. The following Privacy Policy describes the type of information we collect about Business Clients including, but not limited to, advertisers, publishers, ad networks, and list owners; how we secure that information; how we use that information; and the choices you have regarding the collection and use of your private information.

Information We Collect and Retain
User Direct Information. Each time you provide or transmit information to our Company, we 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 ("PII").

Survey Information. Company may collect PII 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.

Third Party Information. Company may collect PII 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, Proffiliates seeks assurances from the third party that you agreed to provide and have such information acquired by Proffiliates. 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 or you may change your PII using your log in password.

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, Cookies may store small amounts of data on your computer about your visit to any of the pages of our Sites. 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 our 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 our 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. They are also known as "clear gifs", "one-pixel gifs", "web bugs", "Internet tags", or "pixel tags." 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"), dedicated server line ("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 PII, 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 Business Client of Company.

How Information is Used and Shared
Disclosure of Information to Service Providers and Third Party Vendors. Company will disclose your PII to third party service providers and vendors in order to effect or carry out any transaction that you have requested from us or as necessary to complete our contractual obligations with you. This includes email service providers, providers of direct marketing services and applications, including lookup and reference, and data enhancement, suppression and validation services. We contractually prohibit the sale or transfer of PII by such service providers and vendors. We may share PII with affiliated companies that are directly or indirectly controlled by, or under common control of Company.

Disclosure of Web Technology Related PII: Company uses and discloses information collected by Cookies and web technology to third party vendors to enhance your online experience by allowing Company to save your preferences for your next visit. Cookies may also measure the general activity on the website, which allows Company to determine which areas and features are most popular in order to make improvements to the website. Web beacons, also known as "clear gifs", "one-pixel gifs", "web bugs", "Internet tags", or "pixel tags" are used by the Company and third parties to monitor the activity on our website or to make cookies more effective. We use log files to store the data that is collected through web beacons.

Complying with Legal Process. Company will use or disclose your PII in response to subpoenas, court orders, warrants, or legal process, or to otherwise establish or exercise Company's legal rights or defend against legal claims or in the event of a breach in an agreement with Company. Company will use and disclose your PII if Company believes that a user of this Site or Business Client will harm the property or rights of Company, its owners, or Company's other customers. Finally, Company will use or disclose PII if it believes it is necessary 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.

Merger or Sale of Company. If Company sells, merge or otherwise reorganizes its business, Company reserves the right to transfer and disclose PII to the purchaser or investors, but will require such person or entity to govern the collection, storage and use of PII by the same privacy policy that existed prior to any such business change unless and until you consent to the new privacy policy.

Choices Regarding PII Use and Sharing
As the only information we collect through our website is information we use to connect with Business Clients and prospective clients, we do not provide an opt-out for information collected through our website. If you would like to be removed from our client database, please contact us at general@proffiliates.com. If you wish to review the PII related to you collected by Company on this website, please provide the request in writing to general@proffiliates.com. Company reserves the right to confirm the identity and association of the person requesting such information prior to disclosure.

Security
We endeavor to safeguard and protect your information. We use redundant and robust servers to host internal data, which are also protected by high performance firewalls housed in one of the premium collocation services in California. Our web frontend and application systems are user and password protected to prevent access from unauthorized users. The servers in which we store PII are kept in a secure physical environment. Company has security measures in place to protect against the loss, misuse, and alteration of personal information under our control. In addition, the Company currently uses Secure Socket Layer Software ("SSL") to protect data and to 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 Company takes reasonable technological precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, Company cannot and does not warrant that your information will be absolutely secure. Any transmission of data at or through our website is at your own risk. However, access to your information is strictly limited, and not accessible to the public.

Do Not Call Waiver
By registering at the website or for our services, 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 and other telemarketing laws such as FCC rules. Notwithstanding that your telephone number may be listed on the Federal Trade Commission's Do-Not-Call List, we reserve the right to contact you via telemarketing in accordance with the Amended Telemarketing Sales Rule.

No Information Collected from Children.
Proffiliates will never knowingly collect any PII about children under the age of 13. If Company obtains actual knowledge that it has collected PII 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.

California User Consumer Rights
California Civil Code Section 1798.83 permits California residents who have provided PII to Company or third parties under a list management arrangement with Company to request certain information regarding Company's disclosure of such information to third parties for their direct marketing purposes. Within thirty days of receiving such a request, we will provide a list of the categories of PII disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this section. If you have questions about this policy, please contact us at privacy@proffiliates.com or in writing at:

Proffiliates, Inc.
50 California Street, Suite 1500 San Francisco, CA 94111


List Management Privacy Policy


Effective July 11, 2011

Proffiliates, Inc. ("Proffiliates") and its wholly owned subsidiaries (collectively "Company") respect and values your privacy rights. Accordingly this Privacy Policy is specific for Company's list management division through which Company collects and uses consumer personally identifiable information including your name, address, telephone number and any additional information you may have supplied upon registration to the original website for which your signed up ("Consumer PII"). Accordingly, this Privacy Policy details Company's treatment of Consumer PII which is leased to it from third party data owners ("Data Owners") for the purpose of sending consumers marketing on behalf of third party advertisers ("List Management Arrangements"). This policy does not apply to information collected from our corporate website. .

Information We Collect and Retain
Data Owner Transfer. Company enters into contractual relationships with third party Data Owners through which Company leases certain Consumer PII for commercial use. Company requires representations and warranties that such data was collected and transferred to company consistent with such Data Owner's posted privacy policy. Company receives the following consumer information from Data Owners: first and last name, physical address, email address, phone number, fax number, IP address and any other information the consumer provided to the Data Owner at the time of registration at the Data Owner's site.

Behavioral Data Collection. In addition, either directly or through third party vendors, Company may collect or receive information pertaining to behavioral or web data as follows:

(a) Cookies. "Cookies" are a feature in your browser software. If enabled, Cookies may store small amounts of data on your computer about your visit to any of the pages of our Sites. 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 our 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 our 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. They are also known as "clear gifs", "one-pixel gifs", "web bugs", "Internet tags", or "pixel tags." 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"), dedicated server line ("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 PII, 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 Business Client of Company.

How Information is Used and Shared
Service of Marketing Material. Upon receipt of Consumer PII from Data Owner, Company uses that Consumer PII to send relevant marketing content to those consumers. Company's use of Consumer PII collected by Data Owners is only limited to the uses allowed pursuant to the Data Owner's privacy policy or terms of use at the time of registration by the consumer. The Data Owner has represented to us that they act consistently with their privacy policies and that those policies permit their sharing of Consumer PII for commercial purposes. Company may also use information collected from web technology to supplement the Consumer PII provided to us. The combination of web technology information with the Consumer's PII enables Company to offer tailored and relevant marketing material via email. If the Data Owner has permission from consumer for a third party such as Company to sell, rent or lease the Consumer PII, then Company may undertake those actions as well.

Service Providers. Company may also share Consumer PII with third parties who provide services to us, including, but are not limited to: email service providers, providers of direct marketing services and applications, including lookup and reference, and data enhancement, suppression and validation services ("Service Providers"). Our Service Providers undertake services for marketing efforts on behalf of third party advertisers who have retained Company to provide for such marketing. However, the Service Providers are under written contract not use this Consumer PII for any other marketing purposes including marketing their own companies and are strictly prohibited from sharing this Consumer PII with any third party. These Service Providers are retained to enable Company to deliver marketing materials to consumers, verify and update information about the consumer, allow the consumer to unsubscribe from receiving further emails and better tailor relevant advertising to the consumer.

Complying with Legal Process. Company will use or disclose your Consumer PII in response to subpoenas, court orders, warrants, or legal process, or to otherwise establish or exercise Company's legal rights or defend against legal claims or in the event of a breach in an agreement with Company. Company will use and disclose your Consumer PII if Company believes that a user of this site or the services provided by Company will harm the property or rights of Company, its owners, or Company's other customers. Finally, Company will use or disclose Consumer PII if it believes it is necessary 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.

Merger or Sale of Company. If Company sells, merge or otherwise reorganizes its business, Company reserves the right to transfer and disclose PII to the purchaser or investors, but will require such person or entity to govern the collection, storage and use of PII by the same privacy policy that existed prior to any such business change unless and until you consent to the new privacy policy.

How Cookie and other Technology Information is Used and Shared
Company uses the cookies identified above to track, monitor and target the interests of consumers for advertising and delivery purposes. No cookies used by Company contain Consumer PII.

In addition, for the purpose of formatting and delivering campaigns, Company uses pixel tags ("clear GIFs") to track whether a user opens and/or clicks on targeted email advertising. Clear GIFs are small, transparent images placed on web pages and in emails that allow Company to track when a user opens an email. The links in email also contain code that allows Company to track when a user has utilized a link within the email to visit a website. Such web beacons and links do not collect Consumer PII and are used for contractual payment purposes.

Choices Regarding PII Use and Sharing in List Management
All commercial emails sent by Company contain an unsubscribe hyperlink that allows the recipient to unsubscribe from receiving commercial emails from the advertiser whose marketing material appears in the commercial email by clicking the hyperlink provided and following the instructions provided by such Advertiser. Advertisers are required by law and our contract to process all unsubscribe requests promptly.

In addition, a recipient may unsubscribe from receiving any commercial emails from Company. All commercial emails sent by Company contains a second hyperlink that allows the recipient to unsubscribe from all lists managed by Company by clicking the hyperlink provided and following the instructions provided by Company. Upon selecting the Company unsubscribe link, the consumer's request will be forwarded to the Data Owner. There is no legal requirement that Data Owners remove consumers from their database and as such we cannot guarantee that the Company's unsubscribe notice will be honored in every instance.

Unsubscribe requests are either processed on an advertiser specific basis or on a Company specific basis depending on the selection the recipient makes. Unsubscribing from one advertiser will not prevent the recipient from receiving other advertisers' emails. Similarly unsubscribing from Company may not remove the recipients address from the Data Owner's database.

Security
We endeavor to safeguard and protect your information. We use redundant and robust servers to host internal data, which are also protected by high performance firewalls housed in one of the premium collocation services in California. Our web frontend and application systems are user and password protected to prevent access from unauthorized users. The servers in which we store PII are kept in a secure physical environment. Company has security measures in place to protect against the loss, misuse, and alteration of personal information under our control. In addition, the Company currently uses Secure Socket Layer Software ("SSL") to protect data and to 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 Company takes reasonable technological precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, Company cannot and does not warrant that your information will be absolutely secure. Any transmission of data at or through our website is at your own risk. However, access to your information is strictly limited, and not accessible to the public.

No Information Collected from Children.
Company will never knowingly collect any Consumer PII about children under the age of 13. If Company obtains actual knowledge that it has collected Consumer PII 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.

California User Consumer Rights.
California Civil Code Section 1798.83 permits California residents who have provided Consumer PII to Company or third parties under a list management arrangement with Company to request certain information regarding Company's disclosure of such information to third parties for their direct marketing purposes. Within thirty days of receiving such a request, we will provide a list of the categories of Consumer PII disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this section. If you have questions about this policy, please contact us at privacy@proffiliates.com or in writing at:

Proffiliates, Inc.
50 California Street, Suite 1500 San Francisco, CA 94111
E: general@proffiliates.com
T: 415.647.7601



Online Lead Generation Privacy Policy


Effective July 11, 2011

Proffiliates, Inc. ("Proffiliates") and its wholly owned subsidiaries (collectively "Company") respect and values consumer's privacy rights. Accordingly this Privacy Policy is specific for Company's lead generation division through which Company collects and uses consumer personally identifiable information including their name, address, telephone number and any additional information which the consumer may have supplied upon registration to the original website for which they registered ("Consumer PII"). Accordingly, this Privacy Policy details Company's treatment of Consumer PII which is obtained by and through its lead generation websites. This policy does not apply to information collected from our corporate website.

Information We Collect and Retain
We collect the following general types of information about the consumer when they visit and use one of our websites: personal information, demographic information, behavioral information, and indirect information. Sometimes we collect combinations of these types of information.

Personal information: is information that can be used to identify the consumer, or any other individual to whom the information may relate, personally. We do not collect personal information unless the consumer chooses to provide it to us. Some examples of personal information that we collect in some areas of our Site, depending on the services the consumer use and local law, are:

  • First and Last Name
  • Physical Address
  • Email Address
  • Telephone number
  • Credit Card number
  • Contact information
  • Billing information
  • Any other information the consumer provides to us during the registration process or though the course of communicating with us about the products and services provided on the Site.

Demographic information: is information that may or may not be unique to the consumer in the sense that it refers to selected population characteristics, Such information may include, but is not limited to, 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.

Behavioral information: is information pertaining to how the consumer use our site, the areas of our site that the consumer visit, what services the consumer access, and information about the consumers computer hardware and software including the consumers IP address, geographic location, browser preference, operating system type, domain names, times that the consumer access the internet and other website the consumer have been referred to us through. This information is necessary for analyzing the use of resources, troubleshooting problems, preventing fraud, and improving our services and products.

Third party information: is information that we acquire from a third party which may include personal, demographic, behavioral and indirect information. We obtain this information so that we can personalize the advertising to the consumer shown our site.

Web Technology information: is information we automatically collect from the consumer when the consumer open one of our emails or visit our site. This includes information collected from the use of cookies, web beacons or java script.

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.

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 the consumer 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.

Use of Cookies, Web Beacons, and Java Script
Cookies: "Cookies" are a feature in the consumer's browser software. If enabled, we may write cookies that may store small amounts of data on the consumer's computer about the consumers visit to any of the pages of this Site. Cookies assist us in tracking which of our features appeal the most to the consumer and what content the consumer may have viewed on past visits. When the consumer visits this site again, cookies can enable us to customize our content according to the consumer's 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 the consumer based on the consumer's interests or past viewing history; save the consumer's password for ease of access to our Site. The consumer can disable cookies, although the Site may not function properly for the consumer. The consumer's browser preferences can be modified to accept or reject all cookies, or request a notification when a cookie is set. The consumer may read more about cookies at http://cookiecentral.com. In order to use all of the features and functionality of Company's websites, the consumer needs to accept cookies.

We predominately use "session" cookies, which are not permanently stored on the consumer's hard drive. Session cookies expire after two hours of inactivity or when the consumer closes the consumer's browser. When the consumer carry out the purchase of a service or product on our website, a large amount of data is processed by our system and transferred through each page of the search or registration. This information includes all information the consumer input on a registration page or questionnaire the consumer complete as part of the registration process as well as demographic information that is not unique to the consumer. "Session" cookies allow us to keep track of this data until the consumer have completed the consumers search or registration.

Removing Cookies: The consumer have the ability to accept, decline or move cookies at any time by modifying the consumers browser settings. Please see http://cookiecentral.com. If the consumer chooses to decline cookies, however, that may hinder performance and negatively impact the consumers experience on the web site.

Web Beacons: We also use electronic images known as Web beacons (sometimes called single-pixel gifs, clear gifs or action tags) that allow us to collect certain information about the consumers visit to these Web pages (including the number of users who have visited those pages), measure and improve the effectiveness of advertisements, and deliver services. Web beacons are not used to access the consumer's personally identifiable information; they are a technique used to compile aggregated statistics about web site usage. Web beacons collect only a limited set of information including a cookie number, time and date of page view and a description of the page on which the Web beacon resides. This information may be shared with one or more third parties so that they can understand the kinds of visitors to the Web pages, how those visitors use those Web Pages, and the effectiveness of their advertisements. We may also use web beacons in email messages sent to individuals listed in our database.

Disabling Web Beacons: Because Web beacons are the same as any other content request, the consumer cannot opt out or refuse them. However, they can be rendered ineffective by either opting out of cookies or changing the cookie setup in the consumer's browser.

JavaScript: We may also use JavaScript within certain advertisements. JavaScript is a computer language that enhances the functionality of websites, particularly in respect to pictures. We do not collecting any personal data via JavaScript but use it to analyze and improve the site's functions.

Disabling JavaScript: The consumer may deactivate JavaScript via the consumer's browser settings or activate it the same way. If the consumer disables JavaScript the consumer will not be able to use some of the functions of the website.

IP Addresses: We automatically track certain information based upon the consumer's 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 the consumer and our community. This information may include the URL that the consumer just came from (whether this URL is on the site or not), which URL the consumer next go to (whether this URL is on the site or not), the consumers computer browser information, and the consumers IP address. The consumers Internet Protocol ("IP") is a unique Internet "address" which is assigned to the consumer by the consumers 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. The consumers IP address can, however, reveal what geographic area the consumer are connecting from, or which ISP the consumer are using. Finally, other websites the consumer visit have IP addresses, and we may collect the IP addresses of those websites and their pages.

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 the consumer provides us with Personal Identification Information, we are able to use such visitor data to identify the consumer.

How We Use the Information Collected
Providing Services and Products: We use the information we gather on the Site for the purposes of providing the services and or products the consumer have requested. This may include passing the consumers information on to a third party with which we have a contract to provide such services. Although our contractual arrangement limits how such third party can use the consumer's information, we do not control the privacy practices of this third party. If the consumer have any questions or wish to remove the consumer's information from the third party's database, the consumer will need to contact that party directly.

Improving our Website: We use the information we gather on the Site to respond to any inquires the consumer make; operate and improve our Site, improve and create a positive user experience; and deliver the products and services advertised on our Site. Our services include the display of personalized products, content, and advertising relating to the consumers experience and interests. The information we gather on this Site may be shared the other companies under common ownership with ours throughout the world.

Disclosure of Information to Others
We disclose to third parties throughout the world the consumer's personal information, combined personal, demographic, behavioral or indirect information, as set forth below:

We disclose to third parties throughout the world the consumer's personal information, combined personal, demographic, behavioral or indirect information, as set forth below:

Product and Service Delivery: We may share the consumer's information with third parties who help us in the delivery the products and services the consumer have requested. We disclose information to companies and individuals we employ to perform technical functions on our behalf. Examples include third parties who host our website, analyze our data, provide marketing assistance, process credit card payments, and provide customer service. These companies and individuals may not share that information with any other third party or use that data for any other purpose.

Third Party Products and Services: We may disclose such information to third parties to provide the consumer with information about the opportunities, products or services of third parties. We use the data and data logs we have about the consumer, including interests and preferences the consumer have expressed, to determine whether the consumer might be interested in the opportunities, products or services of a particular third party. This type of marketing may be in the form of email offers or mobile offers sent to by third parties or telemarketing calls from third parties.

Anonymous information: We also share aggregated anonymous information about the consumer and other persons using our Site with third parties so that they can understand the kinds of visitors to the Site and how those visitors use the Sites. This includes demographic information and behavioral information.

Legal Process: We disclose information if legally required to do so, or at our discretion pursuant to a request from a governmental entity or if we believe in good faith - after considering the consumers privacy interests and other factors - that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect our rights or property or our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.

Acquisition or Merger: We may disclose and transfer information to a third party who acquires any or all of our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In addition, in the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of such information in a transaction approved by the court. The consumer will be notified of the sale of all or a substantial portion of our business to a third party by email or through a prominent notice posted on the Site. Again, in each of these situations, the recipients of the consumer's data may potentially be located in any country in the world.

Third Party Use of The Consumers Information
Third parties also collect and use information about the consumer on our Site in the following way:

Advertiser cookies and web beacons: Advertising agencies, advertising networks, and other companies who place advertisements on the Site and on the internet generally may use their own cookies, web beacons, and other technology to collect information about the consumer. We do not control the use of such technology and have no responsibility for the use of such technology to gather information about the consumer.

Hyperlinks: Our Site and email messages sometimes contain hypertext links to the websites of third parties. We are not responsible for the privacy practices or the content of such other websites. Such links are provided for the consumer's convenience and reference only. We do 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.

Use of The Consumers Information for Email and Telemarketing
Email and Unsubscribe Policy: We may provide the consumers personal information to third parties for promotional offers by email. These offers may be our services and products or those of third parties. We 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@proffiliatesinc.com.

Content of Email Messages: The consumer may receive certain commercial email messages sent by third parties for products which may be of interest to the consumer. 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 the consumer.

Opting Out of Email Marketing Material: We provide the consumer the opportunity to 'opt-out' of having the consumers personally identifiable information used for certain purposes, when it asks for this information. For example, if the consumer purchases a product/service but do not wish to receive any additional marketing material from us, the consumer can indicate the consumers preference by emailing or calling us per the information contained on our contact page.

If the consumer no longer wish to receive our promotions, the consumer may opt-out of receiving it by following the instructions included in each newsletter or communication or by emailing or email us at unsubscribe@proffiliatesinc.com.

Telemarketing: We may use the consumers Personal Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones. The consumer may have the consumer's telephone number or cell phone number listed on a state or federal do not call registry. By registering and using this Site, the consumer 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 the consumers telephone number may be listed on the Federal Trade Commission's Do-Not-Call List, the consumer have authorized us to contact the consumer 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), the consumer 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 the consumer may be contacted via email, direct mail and/or telemarketing by such third-party advertiser in accordance with the ATSR. We may use Personal Information to provide the services the consumer requested, including services that display customized content and advertising.

Wireless Addresses: If the e-mail address the consumer provide to us is a wireless e-mail address, the consumer agree to receive messages at such address from us or our business associates (unless and until the consumer have elected not to receive such messages by following the instructions in the unsubscribe portion of this policy). The consumer understands that the consumer's wireless carrier's standard rates apply to these messages. The consumer represent that the consumer are the owner or authorized user of the wireless device on which messages will be received, and that the consumer are authorized to approve the applicable charges.

Short Message Service: We may make available a service through which the consumer can receive messages on the consumer's wireless device via short message service ("SMS Service"). Data obtained from the consumer in connection with this SMS service may include the consumers name, address, cell phone number, the consumer's provider's name, and the date, time, and content of the consumer's messages. The consumer represent that the consumer are 18 years of age and the owner or authorized user of the wireless device on which messages will be received, and that the consumer are authorized to approve the applicable charges. In addition to any fee of which the consumer are notified the consumer's provider's standard messaging rates apply to our confirmation and all subsequent SMS correspondence. All charges are billed by and payable to the consumer's mobile service provider. We will not be liable for any delays in the receipt of any SMS messages, as delivery is subject to effective transmission from the consumer's network operator. SMS message services are provided on an AS IS basis. We may also obtain the date, time and content of the consumer's messages in the course of the consumer's 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 the consumers wireless account invoice, we may provide the consumers carrier with the consumers applicable information in connection therewith. The consumer's wireless carrier and other service providers may also collect data about the consumers wireless device usage, and their practices are governed by their own policies.

The consumers acknowledges 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 the consumer's use of the SMS Service will be private or secure, and we are not liable to the consumer for any lack of privacy or security the consumer may experience. The consumer are fully responsible for taking precautions and providing security measures best suited for the consumers situation and intended use of the SMS Service. We may also access the content of the consumers account and wireless account with the consumer's carrier for the purpose of identifying and resolving technical problems and service-related complaints.

Removal of Wireless or SMS addresses: The consumer may remove the consumer's information from our database. If the consumer remove the consumers information from our 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 the consumer. The consumer may remove the consumers information by sending the consumers request in writing via email to unsubscribe@proffiliatesinc.com or by sending "STOP", "END", "QUIT" to the SMS text message the consumer have received.

Security
We endeavor to safeguard and protect the consumer's information. When the consumer submit information at the website, such information is protected both online and offline. The servers in which we store Personal Information are kept in a secure physical environment. We have 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 to 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 commercially reasonable technological precautions to protect the consumers data, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, We cannot and do not warrant that the consumers information will be absolutely secure. Any transmission of data at or through this site is at the consumers own risk. However, access to the consumer's information is strictly limited, and not accessible to the public.

Changes to Privacy Statement
We reserve the right to make material changes to the substance of this Privacy Statement. We will post those changes through a prominent notice on the web site so that the consumer will always know what information we gather, how we might use that information, and to whom we will disclose it.

The Consumers California Rights
A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes ("California customer") is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties' direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed.

However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy) a policy of not disclosing customer's personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and providing a cost free means to exercise that right. As stated in this policy, the consumer have agreed to allow us to share information with third parties for their direct marketing purposes until the consumer remove the consumers information and thus, agreement for such disclosure. To prevent disclosure of the consumers personal information for use in direct marketing by a third party, do not opt in to such use when the consumer provide personally identifiable information on one of our sites or contact us via email to remove the consumers information from our database. Please note that whenever the consumer opts in to receive future communications from a third party, the consumer's information will be subject to the third party's privacy policy. If the consumer later decide that the consumer do not want that third party to use the consumers information, the consumer will need to contact the third party directly, as we have no control over how third parties use information. The consumer should always review the privacy policy of any party that collects the consumer's information to determine how that entity will handle the consumer's information.

California customers may request further information about our compliance with this law by e-mailing privacy@proffiliates.com Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address.