Searchgency LLC, and all related Websites.
This policy describes the information collection, use, and dissemination practices of Searchgency LLC, (“EM Searchgency LLC”) and applies to Searchgency LLC’s collection, use, storage and disclosure of information by Searchgency LLC on its (a) websites, including all its divisions, subsidiaries and related companies (collectively, the “Websites”), (b) on various Third Party websites, and (c) to Searchgency LLC ‘s other information collection, including the purchase of customer lists from Third Parties. Searchgency LLC is not responsible for the information collection or privacy practices of Third Party websites or applications.
CALIFORNIARESIDENTS 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 yourPIInot be shared with Third Parties by sending your request, including your full name, email address and postal address to: EM Global Marketing LLC, 185 Madison Avenue, Suite 1104, New York, NY 10016. In accordance with California Civil Code Sec. 1789.3,Californiaresident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs,400 R Street, Suite 1080,Sacramento,CA95814; or by phone at 916-445-1254 or 800-952-5210; or by email to firstname.lastname@example.org.
THE INFORMATION COLLECTION, USEANDDISSEMINATION PRACTICES OF SEARCHGENCY LLC.
1. Collection of Information.
1.1 Survey Information.
Searchgency LLC 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, Searchgency LLC or a Third Party (a “Third Party”) may ask an individual to provide various information to Searchgency LLC, 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”). Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to Searchgency LLC or Third Party, but an individual may receive incentives from Searchgency LLC or a Third Party in exchange for providing Survey Information to Searchgency LLC.
1.2 Site Membership or Registration.
“Subscription” occurs when an end-user registers for Searchgency LLC’s services, either via registration at our website, via co-registration at a marketing partner’s website, Searchgency LLC 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.
Information purchased by Searchgency LLC 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, Searchgency LLC seeks assurances from the Seller that the Seller has a right to transfer the Third Party List Information to Searchgency LLC 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 Searchgency LLC obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by Searchgency LLC or by a Third Party, (2) when an individual requests assistance through Searchgency LLC’s customer service department, and (3) when an individual voluntarily subscribes to a Searchgency LLC service or newsletter (together, “Other Information”).
1.5 Cookies, Web Beacons, and Other Info Collected Using Technology.
Searchgency LLC 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, Searchgency LLC may use other new and evolving sources of information in the future (together, “Technology Information”).
A cookie is a small amount of data stored on the hard drive of the individual’s computer that allows Searchgency LLC to identify the individual with his or her corresponding data that resides in Searchgency LLC’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 Searchgency LLC 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, Searchgency LLC 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 Searchgency LLC ‘s database, visits the cosmetic website, Searchgency LLC receives notice by means of the web beacon that Jane visited the cosmetics site, and Searchgency LLC would then update Jane’s profile with the information that Jane is interested in cosmetics. Searchgency LLC may thereafter present offers of cosmetic related products and services to Jane. In addition to using web beacons on web pages, Searchgency LLC also uses web beacons in email messages sent to individuals listed in Searchgency LLC ‘s database.
(c) New Technology.
The use of technology on the Internet, including cookies and web beacons, is rapidly evolving, as is Searchgency LLC’s use of new and evolving technology. As a result, Searchgency LLC strongly encourages individuals to revisit this policy for any updates regarding its use of technology.
(d) Usage Tracking.
Searchgency LLC tracks information related to the electronic mailings and web pages viewed by users and subscribers, as well as the hyperlinks clicked by subscribers, while viewing our emails or visiting our websites.
(e) Log Files.
Log files are used to track and monitor subscriber usage.
(f) Optional Registration.
Searchgency LLC may offer free voluntary registration to potential subscribers. During such registration, the subscriber is required to supply an email address and other personal information. This information is required if the subscriber wants to participate in Company services.
(g) Feedback and Inquiries.
You have the ability to contact Searchgency LLC to provide us with their feedback. Searchgency LLC uses this information to respond to you and analyze customer service issues.
1.6 Outside Information.
Searchgency LLC may receive information about individuals from Third Parties or from other sources of information outside of Searchgency LLC 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 Searchgency LLC gathers or receives about individuals.
1.8 No Information Collected from Children.
Searchgency LLC will never knowingly collect any personal information about children under the age of eighteen (18). If Searchgency LLC obtains actual knowledge that it has collected personal information about a child under the age of eighteen (18), that information will be immediately deleted from our database. Because it does not collect such information, Searchgency LLC has no such information to use or to disclose to Third Parties. Searchgency LLC is designed this policy in order to comply with the Children’s Online Privacy Protection Act (“COPPA”).
1.9 Credit Card Information.
Searchgency LLC 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 Searchgency LLC. When the Credit Card Information is submitted to Searchgency LLC, such information is encrypted and is protected with SSL encryption software. Searchgency LLC 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.
2. Use of Individual Information.
2.1 Discretion to Use Information.
SEARCHGENCY LLCMAYUSE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN COMPANY’S SOLE DISCRETION.
The following paragraphs in Section 2 describe how Searchgency LLC currently uses Individual Information, but Searchgency LLC may change or broaden its use at any time. As noted below, Searchgency LLC may update this policy from time to time. Searchgency LLC 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.
Searchgency LLC uses Individual Information to provide promotional offers by email to individuals. Searchgency LLC 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 Searchgency’s LLC email lists, a person must send an email to email@example.com
Searchgency’S LLC unsubscribe process impacts only the future delivery of electronic mailings disseminated by Searchgency LLC 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 Searchgency’S LLC 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 Searchgency LLC, 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 Searchgency LLC, an Advertiser’s name will appear in the “From:” line but hitting the “Reply” button will cause a reply email to be sent to Searchgency LLC. The “Subject:” line of Searchgency LLC email messages will usually contain a line provided from the Advertiser to Searchgency LLC.
2.4 Solicited Email.
Searchgency LLC only sends email to individuals who have agreed on the Websites to receive email from Searchgency LLC or to individuals who have agreed on Third Party websites to receive email from Third Parties such as Searchgency LLC does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable to Searchgency’s LLC email messages.
2.5 Targeted Advertising.
Searchgency LLC uses Individual Information to target advertising to an individual. When an individual is using the Internet, Searchgency LLC uses Technology Information (see also Section 2.7 below) to associate an individual with that person’s Individual Information, and Searchgency LLC 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. Searchgency LLC 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.
Searchgency LLC 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.
Searchgency LLC 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 Searchgency’s LLC websites are most frequently visited. This information helps Searchgency LLC to better understand the online habits of individuals so that Searchgency LLC can target advertising and promotions to them.
2.8 Profiles of Individuals.
Searchgency LLC 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.
Searchgency LLC stores the Individual Information in a database on its’ computers. Our computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under Searchgency’s LLC control. Not withstanding such measures, Searchgency LLC cannot guarantee that its security measures will prevent its computers from being illegally accessed, and the Individual Information on them stolen or altered.
3. Dissemination of Individual Information.
3.1 Saleor Transfer to Third Parties.
SEARCHGENCY LLCMAYSELL OR TRANSFER INDIVIDUAL INFORMATION TO THIRD PARTIES FOR ANY PURPOSE IN EM GLOBAL MARKETING LLC’S SOLE DISCRETION.
3.2 Order Fulfillment.
Searchgency LLC 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 Searchgency’S LLC websites or when responding to offers provided by Searchgency LLC.
3.3 Legal Process.
Searchgency LLC may disclose Individual Information to respond to subpoenas, court orders, and other legal processes.
3.4 Summary Data.
Searchgency LLC may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.
Individuals have access to their Individual Information collected to provide an opportunity for an individual to correct, amend, or delete such information. Access can be obtained by contacting firstname.lastname@example.org Searchgency LLC 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. Searchgency LLC does not control Advertisers’ use of such technology and Searchgency LLC has no responsibility for the use of such technology to gather information about individuals.
The Websites and email messages sometimes contain hypertext links to the websites of Third Parties. Searchgency LLC 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. Searchgency LLC 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.
Searchgency LLC may disclose, transfer, and sell Individual Information to entities affiliated with Searchgency LLC in Searchgency’s LLC discretion.
5. Unsubscribe Procedures.
If you wish to discontinue receiving email messages from Searchgency LLC, you have several options:
(a) Unsubscribe from one email list.
To unsubscribe from a particular list, either (1) send an email to email@example.com or (2) follow the instructions in each promotional email message sent by Searchgency LLC.
(b) Unsubscribe from all of Searchgency’s LLC email lists.
We reserve the right to add Individual Information to multiple lists maintained by Searchgency LLC. To globally unsubscribe from all of Searchgency’s LLC lists, send an email to firstname.lastname@example.org
For more information about protecting your privacy, you may wish to visit: www.ftc.gov
If you have questions about this policy, please contact us at email@example.com