The information collection, use, and dissemination practices of Pogo Pass LLC. (the "Company") are discussed in this policy. This policy applies to Company's information collection (a) on Company's websites, (b) on various third party websites, and (c) to Company's other information collection, including the purchase of customer lists from third parties.
1. Collection of Information.
1.1 Survey Information. The Company collects information from individuals when an individual voluntarily completes a Company 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, the Company or a third party (a "Third Party") may ask an individual to provide various information to the Company, 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, employment information, personal and online interests, and such other information as may requested from time to time (together, "Survey Information"). Company or third party may also collect information such as what browser you are using and your Internet Protocol ("IP") address. 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 to the Company.
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, licenses, or otherwise acquires the information from the third party (the "Seller"). Such purchased information 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, 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 offers from advertisers to the individuals whose personal information is included on the Seller's list.
1.3 Other Information. Other occasions when the Company obtains information from individuals include (1) when an individual is making a claim for a prize or seeking 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 Cookies, Web bugs, and Other Information Collected Using Technology. The Company 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, the Company may use other new and evolving sources of information in the future (together, "Technology Information").
(a) Cookies. A cookie is a small amount of data stored on the hard drive of the individual's computer that allows Company to identify the individual with his or her corresponding data that resides in Company's database. You may read more about cookies at www.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 bugs. A web beacon is programming code that can be used to display an image on a web page (by using an programming function -- see www.w3.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 Company to track certain web sites an individual visits online. Web bugs are used to determine products or services an individual may be interested in, and to track online behavioral habits for marketing purposes. For example, Company might place, with the consent of a third party website, a web beacon on the third party's website where fishing products are sold. When Joe, an individual listed in Company's database, visits the fishing website, Company receives notice by means of the web beacon that Joe visited the fishing site, and Company would then update Joe's profile with the information that Joe is interested in fishing. Company may thereafter present offers of fishing related products and services to Joe. In addition to using web bugs on web pages, Company also uses web bugs in email messages sent to individuals listed in Company's database. If you wish more information about web bugs, you may wish to visit http://www.webopedia.com/TERM/W/Web_beacon.html
(c) New Technology. The use of technology on the Internet, including cookies and web bugs, is rapidly evolving, as is Company's use of new and evolving technology. As a result, Company strongly encourages individuals to revisit this policy for any updates regarding its use of technology.
1.5 Outside Information. The Company may receive information about individuals from third parties or from other sources of information outside of the Company including information located in public databases ("Outside Information").
1.6 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 the Company gathers or receives about individuals.
1.7 No Information Collected from Children. The Company will never knowingly collect any personal information about children under the age of 13. If the 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 our database. Because it does not collect such information, the Company has no such information to use or to disclose to third parties. The Company has designed this policy in order to comply with the Children's Online Protection Act ("COPA").
1.8 Credit Card Information. The Company 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 Company. When the Credit Card Information is submitted to Company, such information is encrypted and is protected with SSL encryption software. The Company will use the Credit Card Information for purposes 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.
2. Use of Individual Information.
2.1 Discretion to Use Information. THE COMPANY MAY USE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN COMPANY'S SOLE DISCRETION. The following paragraphs in Section 2 describe how the Company currently uses Individual Information, but the Company may change or broaden its use at any time. As noted below, the Company 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.
2.2 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 must email email@example.com and write in the subject line: "REMOVE FROM ALL LISTS".
2.2(a) Content of Email Messages. In certain commercial email messages sent by Company, an advertiser's name will appear in the "From:" line but hitting the "Reply" button will cause a reply email to be sent to Company. The "Subject:" line of Company email messages will usually contain a line provided from the advertiser to Company. The subject line will not usually contain phrases such as "ADV:" or "ADVERTISEMENT". Company's commercial email messages will contain information how an individual may unsubscribe from that particular list.
2.2(b) Solicited Email. Company only sends email to individuals who have agreed on the Websites to receive email from Company or to individuals who have agreed on third party websites to receive email from third parties such as Company. Company does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable to Company's email messages.
2.3 Targeted Advertising. The Company uses Individual Information to target advertising to an individual. When an individual is using the Internet, the Company uses Technology Information (see also Section 2.5 below) to associate an individual with that person's Individual Information, and the Company 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. The Company may, at its discretion, target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers.
2.4 Direct Mail and Telemarketing. The Company uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones.
2.5 Use of Technology Information. The Company 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 Company's web sites are most frequently visited. This information helps the Company to better understand the online habits of individuals so that the Company can target advertising and promotions to them.
2.6 Profiles of Individuals. The Company 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.
2.7 Storage of Individual Information. The Company stores the Individual Information in a database on Company computers. Our computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under Company's control. Notwithstanding such measures, the Company cannot guarantee that its security measures will prevent the Company computers from being illegally accessed, and the Individual Information on them stolen or altered.
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 COMPANY'S SOLE DISCRETION.
3.2 Order Fulfillment. The Company 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 process.
3.4 Summary Data. The Company may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.
4. Privacy Practices of Third Parties.
4.1 Advertiser cookies and web bugs. 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 bugs, and other technology to collect information about individuals. The Company does not control Advertisers' use of such technology and the Company has no responsibility for the use of such technology to gather information about individuals.
4.2 Links. The Websites 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. The Company may disclose, transfer, and sell Individual Information to entities affiliated with Company in Company's discretion.
5. Unsubscribe Procedure. If you wish to discontinue receiving email messages from Company, you have several options:
(a) Unsubscribe from one email list. To unsubscribe from a particular list follow the instructions in each promotional email message sent by the Company.
(b) Unsubscribe from all Company email lists. We reserve the right to add Individual Information to multiple lists maintained by Company. To globally unsubscribe from all of Company's lists email firstname.lastname@example.org and write in the subject line: "REMOVE FROM ALL LISTS".
6. More Information. If you have questions about this policy, please contact us.
7. SMS Wireless Policy. We may use personal information to provide the services you've requested, including services that display customized content and advertising. In addition to any fee of which you are notified, your provider's standard messaging rates apply to our confirmation and all subsequent SMS correspondence. You may opt-out and remove your SMS information by sending "STOP", "END", "QUIT" to the SMS text message you have received. If you remove your SMS information from our database it will no longer be used by us for secondary purposes, disclosed to third parties, or used by us or third parties to send promotional correspondence to you.