Web User Privacy Policy/Your California Privacy Rights

This privacy policy applies to all consumer information collected by Smart Retail ("Company", "we" or "us"). This Privacy Policy will tell you, among other things:

ACKNOWLEDGEMENT/YOUR AGREEMENT

Company websites and web pages are not intended for use by individuals under the age of 18 or those who are not legal residents of the United States, Canada or Australia. By using our website or web page or submitting information to us, you consent to the Company's use and sharing of the information collected or submitted as described in this Privacy Policy. If you are not 18 years of age or older and a valid resident of the United States, Canada, Australia or you do not agree with the terms of this Privacy Policy, do not provide us with any information or use any of the products or services offered or provided on Company websites or web pages or through Company technology.

PRIVACY POLICY CHANGES

Company reserves the right to revise this Privacy Policy at any time simply by posting such revision. It is your responsibility to periodically revisit this Privacy Policy to review any changes. Should this Privacy Policy be revised, we will include a list of revision dates at the end of this document for your reference. Your continued use of Company websites, web pages or technology following the posting of changes to this Privacy Policy will constitute your acceptance of any and all changes.

YOUR CALIFORNIA PRIVACY RIGHTS

Under California's "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to either: (1) a list detailing the categories of information shared and the entities to which such information was provided; or (2) to be notified of a mechanism by which a consumer may opt-out of having their information shared with third parties. We have elected the second option. To opt-out of having your information shared with third parties, emailing a request to cs@smartretailingsite.com.

TYPES OF INFORMATION WE MAY COLLECT

We collect and combine personally identifiable information ("PII") and non-personally identifiable information ("Non-PII") through various sources, including those discussed below. For your reference, PII is data collected with an intention to specifically identify, contact or locate a person, including but not limited to name, address, telephone number, or e-mail address. Conversely, Non-PII is data that is not used to specifically identify, contact or locate an individual, including but not limited to zip code, gender, age, or Internet Protocol or "IP" address.

HOW WE MAY COLLECT INFORMATION

Website Registration

We collect information about you when you register on one of our websites. This registration information may include, but is not limited to, your: e-mail address, name, mailing address, telephone number, date of birth, and gender.

Offers/Advertisements

We collect information about you when you complete a survey, request information or purchase a product or service through an advertisement or web page that we host. This information may include, but is not limited to: your e-mail address, name, mailing address, telephone number, date of birth, gender, and payment information; information about your background, interests, health, education, career goals, and shopping preferences; and any other personal information or unique preference information you provide to us or our advertisers.

Advertisers

When you complete all or a portion of a registration or offer form that is hosted by one of our advertisers, the advertiser may submit all or a portion of the information that you submitted on the form to the Company. This information may include, but is not limited to: your IP address, sign-up date and time, e-mail address, name, mailing address, telephone number, date of birth, gender, and payment information; information about your background, interests, health, education, career goals, and shopping preferences; and any other information you provide to the advertiser.

Publishers

When you complete a registration or offer form that is hosted by one of our website publisher partners, the partner may submit all or a portion of the information that you submitted on the form to the Company. This information may include, but is not limited to: your IP address, sign-up date and time, e-mail address, name, mailing address, telephone number, date of birth, gender, and payment information; information about your background, interests, health, education, career goals, and shopping preferences; and any other information you provide to our website publisher partner.

Data Partners

We may receive information about you, including but not limited to your IP address, sign-up date and time, e-mail address, name, mailing address, and telephone number, from third party marketing partners that provide us with consumer data to manage or utilize in our business.

Automatic Information/Digital Identifiers

We may automatically receive and store certain types of information about you through the data sources listed above.

You may be familiar with the term "cookies", which are unique alphanumeric identifiers that store information on your computer. A cookie is placed on your computer when your web browser accesses our website. We use cookies for tracking transactions and the user characteristics explained in detail throughout this Privacy Policy. If you choose, there are utilities available for purchase from independent software providers to install on your computer, as well as tools/preferences you can choose through most web browsers, to make website visits anonymous.

We also collect information through our web server applications. This information includes your IP address, date/time stamp, browser type, and referring URL.

Additionally, we may use pixel tracking technology to track the completion of transactions with us or our advertisers, the source information for those transactions, and your IP address, date/time stamp, browser type, and referring URL.

HOW WE MAY USE INFORMATION

We may use the collected PII and Non-PII for any legally permissible purpose in our sole discretion, including but not limited to those explained below.

Ad Serving/Targeting

We may serve advertisements to you based, in part, on your IP address, the demographic and geographic information you submitted to the Company during the website registration process, and other socio-economic information, psychographic information, Internet behavior (e.g., browsing, search, shopping, purchase, and ad response behavior), and lifestyle information about you that we obtain from other entities and from third parties.

We also use third party advertising companies to serve advertisements when you visit our websites. These companies may use and optimize information about your visits to this and other websites in order to provide advertisements about goods and services that may be of interest to you.

Pre-select/Pre-fill Offers

Our website technology may pre-select certain offers for you to view based on the demographic and geographic information you submitted to the Company during the website registration process. Additionally, this technology may pre-fill some or all of the offers' data fields with the information you submitted during the website registration process in order to prevent you from having to re-enter this information. We may not show all of the pre-filled data fields to you.

Upsell

We may utilize "upsell" technology to help advertisers generate sales, while providing you with a series of offers we think may be of interest to you. After you purchase a product or service from one of our advertisers, you may be offered additional products or services. If you elect to purchase products or services from an advertiser in the upsell channel, we will pass the information that you provided during the initial transaction to the subsequent advertiser, including but not limited to your credit card information. This information pass is done to enhance and simplify your purchasing experience. Your information will only be passed to an advertiser in the upsell channel after you have elected to purchase their product or service. By electing to purchase their product or service, you consent to the passing of your data to the third party advertiser in question.

Customer Service

We may use your information to respond to your questions or inquiries. We may also use your information to verify your identity or investigate your compliance with the terms and conditions of a Company website or advertiser offer.

Credit Card Preauthorization

By submitting your credit card information to us or to one of our advertisers, you are authorizing the Company or its agent to periodically verify that your credit card account is valid and has credit available by charging, and thereafter crediting, a small sum to the card.

Marketing

We may use your information in our e-mail marketing, telemarketing, text messaging, and direct mail marketing programs. If you would like to be removed from these programs, email your request to cs@smartretailingsite.com.

HOW WE MAY SHARE INFORMATION

We may share the collected PII and Non-PII for any legally permissible purpose in our sole discretion, including but not limited to those explained below.

Affiliated Companies

We may share information we collect with affiliated companies for use in their ad serving and marketing programs. This Privacy Policy does not apply to affiliated companies and their collection, use and sharing of information.

Vendors

We may share your information with various third party vendors, including but not limited to vendors that provide us with technology to deploy commercial e-mail, lead validation services, suppression or opt-out services, list scrubbing, and compliance services.

Advertisers

When you participate in an offer by completing a form, we will transfer the information you submitted on the form to the applicable advertiser.

When you answer "yes" or "no" to a survey question, some or all of the information that you submitted during the website registration process may be transferred to advertisers that we believe may be of interest to you without providing you with another opportunity to review the information.

When you select "yes" next to an offer, we will transfer some or all of the information that you submitted during the website registration process to the applicable advertiser without providing you with another opportunity to review the information.

Ad Serving Companies

We may use third party ad networks or ad serving companies to serve advertisements on our websites. We may pass information about you to these companies so that they can deliver targeted advertisements that they believe will be of interest to you. The information passed to these companies may include, but is not limited to, your IP address, e-mail address, name, mailing address, telephone number, date of birth, gender, and any other information you provide to us.

Marketing Partners

We may share, license or sell your information to third parties for various marketing purposes, including but not limited to e-mail marketing, telemarketing, text messaging, and direct mail.

Data Enhancement/Appending/Validation

We may use third party service providers to enhance our database with additional elements, including but not limited to age ranges present in your household, whether you own or rent a home, the length of time you have lived at your residence, whether you are a mail order buyer or responder, household income, and gender. Further, we may use third party service providers to append telephone numbers or mailing addresses to other data points we have in our database. We also may use third party service providers to validate the data we have in our database.

Additionally, we may share, license or sell your information to third parties for use in their data validation, enhancement, information verification services, and, to the extent permitted by law, individual reference or look-up services.

Governmental Agencies/Legal Reasons

We may share your information with law enforcement officials or government agencies: (1) in response to their request; (2) when permitted or required by law; or (3) to establish our compliance with applicable laws, rules, regulations, or guidelines.

We also may share your information with third parties when: (1) trying to protect against or prevent actual or potential fraud or unauthorized transactions; (2) investigating fraud that has already taken place; (3) enforcing or applying existing terms and conditions and/or other agreements; (4) protecting the rights, property or safety of our websites, our users or others; (5) responding to subpoenas, court orders or legal process; or (6) to establish or exercise our legal rights or defend against legal claims.

In all cases, this information is not provided to these entities or persons for marketing purposes.

Right to Transfer

Should the Company choose to sell or transfer business assets, it is possible that the information we possess may be transferred as part of that transaction. The Company may decide to retain a copy of the information post sale or transfer.

CUSTOMER CHOICES

Marketing Communications

By completing and submitting a Company registration or offer form, you are consenting to receive marketing communications from the Company and its third party marketing partners. If, after you have shared your information with the Company, you decide that you do not want to receive marketing communications from the Company, you can discontinue the communications from the Company emailing a request to cs@smartretailingsite.com. If you have registered or submitted information under more than one e-mail account, you must submit separate unsubscribe requests for each account.

Request for More Information

As it relates to marketing communications or any other questions you might have about this Privacy Policy, write to us at: Smart Retailing 2207 Concord Pike, #670 Wilmington DE 19803-2908

 

OTHER WEBSITES

Our websites may offer links to other websites. Other websites have their own terms of use and privacy and security policies. If you choose to visit one of these sites, you should review the policies that govern that particular site.

APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy applies to all information collected by or submitted to the Company, unless otherwise stated. Other affiliated entities of the Company may obtain information independently from transactions and experiences with you or from other sources. This Privacy Policy does not pertain to that information.

SPECIAL CONCERNS REGARDING CHILDREN

We recognize the unique privacy concerns regarding children. We are committed to carefully protecting privacy where children are involved no matter the point of contact. In particular, our intention is to fully comply with the Children's Online Privacy Protection Act ("COPPA"). Per COPPA guidelines, we do not knowingly collect PII from children under the age of 13. If a parent or guardian is made aware that a child under the age of 13 has provided us with PII through any point of contact, please write to us at Media Communications, Attn: Privacy Officer, 1212 Communications Circle, Virginia Beach VA 23455 and we will delete the information about the child referenced from our files.

SECURITY

There is no such thing as complete security on the Internet or otherwise. The Company uses various security techniques on our websites to help protect against the loss, misuse or modification of information we've collected from you. When you access your personal information or transmit information to us, that information is stored on servers that we have taken steps to protect from unauthorized access or intrusion. While we strive to protect your information, the Company cannot ensure or warrant the security of any information you transmit to us. You acknowledge and assume this risk when communicating with the Company, its partners and affiliates.

LIMITATION OF LIABILITY

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, AS WELL AS THE TERMS AND CONDITIONS OF THIS WEBSITE (INCLUDING LIMITATIONS ON DAMAGES). YOU AGREE THAT THE COMPANY'S LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY THE COMPANY TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS.

This privacy policy was revised on February 2, 2012.