Adtransformation
Privacy Policy This policy explains how
Adtransformation.com, Inc. (hereinafter "the Company" or "We")
collects, uses and disseminates information about
individuals.
1. Information
Collection.
1.1 Survey, Order Form,
Registration Pages. We collect information from
individuals when an individual voluntarily completes an order form,
a Company survey, or a registration page online or by means of
online order forms or registration pages operated by third parties
(collectively, a "Survey"). (As used herein, "online" means using
the Internet and related technologies.) In the Surveys, the Company
or the third party (the "Third Party") may ask an individual to
provide various information, which may include his or her name,
email address, street address, zip code, telephone numbers, cell
phone numbers and carriers, birth date, age, gender, salary range,
education, marital status, occupation, 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 the Company or
Third Party, but an individual may receive incentives from the
Company or a Third Party in exchange for providing Survey
Information.
1.2 Third Party List
Information. The Company collects information from
individuals when an individual provides information to a third
party, and the Company subsequently purchases or otherwise acquires
the information from the third party (the "Seller"). Such purchased
information may include his or her name, email address, street
address, zip code, telephone numbers, cell phone numbers and
carriers, birth date, age, gender, salary range, education, marital
status, occupation, employment information, 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, the Company seeks
assurances from the Seller that the Seller has a right to transfer
the Third Party List Information to the Company and that the Seller
has a right to provide promotional offers to the individuals whose
personal information is included on the
list.
1.3 Other
Information. The Company may request personal
information on other occasions, including (1) when an individual
makes a claim for a prize or seeks to redeem an incentive offered by
the Company or by a third party; (2) when an individual requests
assistance through Company's customer service department; and (3)
when an individual voluntarily subscribes to a Company service or
newsletter (together, "Other
Information").
1.4 Outside
Information. The Company may receive information
about individuals from third parties ("Outside
Information").
1.5 No Information Collected
from Children. The Company does not intentionally
collect personal information from children who are younger than age
13. The Company therefore has no such information to disclose to
third parties or to use.
2. Use of Individual
Information.
2.1 Individual
Information. As used in this Policy, Individual
Information means Survey Information, Third Party List Information,
Other Information, and Outside Information, and any other
information the Company gathers or receives about
individuals.
2.2 Discretion to Use
Information. We may use Individual Information for
any legally permissible purpose in the Company's sole discretion.
The following paragraphs describe how the Company currently uses
Individual Information, but we may change or broaden its use at any
time. We may update this Policy from time to time. The Company may
use Individual Information to provide promotional offers to
individuals by means of email advertising, telephone marketing,
direct mail marketing, online banner advertising, and package
stuffers, among other possible uses.
2.3
Targeted Advertising. Based on the Individual
Information, we sometimes attempt to customize and target
advertising to an individual, and attempt to show advertising for
products and services in which the person has expressed an interest
in the Surveys and otherwise. We may, at our discretion, target
advertising by using email, direct mail, telephones, cell phones,
and other means of communication to provide promotional
offers.
2.4 Email. The Company
uses Individual Information to provide promotional offers by email
to individuals. The Company may maintain separate email lists for
different purposes. If email recipients wish to end their email
subscription from a particular list, they need to follow the
instructions at the end of each email message to unsubscribe from
the particular list. To unsubscribe from all Company email lists, a
person may visit and follow the instructions provided at http://www.Adtransformation.com/
or by sending an email to abuse@adtransformation.com.
2.5
Direct Mail and Telemarketing. We may use Individual
Information to advertise, directly or indirectly to individuals
using direct mail marketing or telemarketing using telephones and
cell phones.
2.6 Profiles of
Individuals. The Company may gather Individual
Information to make a profile of a person. A profile is created by
associating the various sources of Individual
Information.
2.7 Storage of Individual
Information. The Company stores the Individual
Information on Company computers. Our computers have reasonable
security measures in place to guard against the loss, misuse and
alteration of the information under Company's control. Nonetheless,
We cannot guarantee that our security measures will prevent the
Company computers from being accessed without authorization and the
Individual Information stored on them being stolen, deleted or
changed, and the Company assumes no responsibility for such
actions.
3. Dissemination of Individual
Information.
3.1 Sale or Transfer to Third
Parties. The Company may sell or transfer Individual
Information to third parties for any purpose in the Company's
discretion.
3.2 Order
Fulfillment. We will transfer Individual Information
to third parties when necessary to provide a product or service that
a person orders from such third party while using Company web sites
or when responding to offers provided by
Company.
3.3 Legal Process.
The Company may disclose Individual Information to respond to
subpoenas, court orders, and other legal
processes.
3.4 Summary Data.
We may sell or transfer non-individualized information, such as
summary or aggregated anonymous information about all persons or
sub-groups of persons, for any purpose in the Company's
discretion.
4. Privacy Practices of Third
Parties.
4.1 Advertiser
cookies. Advertising agencies, advertising networks,
and other companies (together, "Advertisers") who place
advertisements on Company web sites may use their own cookies on
your computer and collect information from such cookies. The Company
does not control the Advertisers' use of their own cookies and the
Company has no responsibility for such cookies and the use of
information gathered from them.
4.2
Links. The Company's web sites and email messages
sometimes contain hypertext links to the web sites of third parties.
The Company is not responsible for the privacy practices or the
content of such other web sites.
4.3
Affiliated Companies. We may disclose, transfer and
sell Individual Information to entities affiliated with Company in
Company's discretion. Affiliated companies and websites include but are not limited
to the following: Amalfimarketing.com Inc., OfferFinders.com, TheBountyHunters.com
and Promohunter.net.
4.4 Deleting Individual
Information. Individuals have the ability to request
deletion of their Individual Information by sending an email to abuse@adtransformation.com
in which they clearly request to have their Individual Information
deleted from the Company database.
4.5 More
Information. If you have questions about this
Policy, please contact us at abuse@adtransformation.com.
We reserve the right to revise this policy from time to time without
prior notice, so you should review this policy
regularly (most recent update 1/31/2005).
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