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Shoutlet Website Privacy Policy Shoutlet, Inc. ("Shoutlet" or "we" or "us") desires to protect the privacy of our online guests at www.Shoutlet.com (the "Site") and the Shoutlet web applications, tools, widgets, and other services on our site and those we deploy elsewhere (collectively, “Shoutlet Applications”). This privacy policy (this "Privacy Policy") is intended to provide you notice of our information management practices with respect to the information that we receive from the Site or through Shoutlet Applications we deploy elsewhere, how we can use, share, retain, and dispose of that information, and the choices and consent required before we use and share that information. It is also intended to provide you notice of other important matters related to that information, such as those related to your access to your information, security, future updates to this Privacy Policy, and how you may contact us with inquiries, complaints, and disputes regarding matters covered by this Privacy Policy. This Privacy Policy does not apply to information collected by our customers’ use of Shoutlet Applications. The privacy policy related to such information can be found at http://shoutlet.com/about/privacy.php. Your use of the Site or a Shoutlet Application constitutes acceptance of this Privacy Policy and the Terms and Conditions of Use (http://shoutlet.com/about/terms.php), which are hereby incorporated by reference. 1. Collection: Information We Receive We receive information concerning individuals such as you from a variety of sources. We receive information from people who visit the Site. We also receive information from certain social media sites (e.g., Facebook, Twitter, and YouTube) used by us when we incorporate a Shoutlet Application into those social media sites and the visitors to those sites voluntarily provide information by populating screens associated with that Shoutlet Application. For example, we can deploy Shoutlet Applications to collect information from individual users about their product preferences or other matters. The Shoutlet Applications can be in the form of a website-based contest, survey, poll, or other information-gathering tool. Either on the Site or through a Shoutlet Application deployed by us elsewhere, you may voluntarily provide to us your name, address, telephone number, email address, or other types of personally identifiable information (collectively, “Personally Identifiable Information”) or other information. We may also receive other information that you voluntarily provide, such as your age, gender, education, and occupation. This information may be gathered through the Site or through a Shoutlet Application when you, for example, register for an account, post information on the Site, or enter a promotion, sweepstakes, survey, or contest created by us. In all cases, you control the initial release and have the option of providing us, either directly or through a social media site, with the Personally Identifiable Information or other information. If you do not want to provide Personally Identifiable Information to Shoutlet, you may choose not to. The specific types of information we receive include the following: Information You Provide to Us Information about you. When you sign up for our newsletter, participate in surveys, comment on our blog, or use a Shoutlet Application deployed by us, you are likely providing us with Personally Identifiable Information or other information concerning you. Content. There are many opportunities for you to provide content to the Site or through a Shoutlet Application deployed by us. In many situations, you can provide general information and your opinions, upload pictures and videos, or refer, share, or provide information to a relative, friend, or contact, whose information you provide to us. Information We Collect from Your Computer or Internet Device Access device and browser information. When you access the Site or use a Shoutlet Application from a computer or other Internet device, we may collect information from that device about your browser type, location of the device, operating system, and IP address, as well as which Shoutlet Application you use, the pages you visit on the Site, which site you came from, and which site you went to after using the Site. Cookie and web beacon Information. We may store cookies on your computer or other Internet device. A cookie is a small amount of data that is sent from a web server and stored on your device. We also occasionally use web beacons, which assist us (and our customers) to determine, for example, whether an email has been read or forwarded to someone else. We also collect and monitor aggregate data called “web log information” (such as your web browser, operating system, pages visited, etc.) when you visit the Site and use cookies and web beacons in connection with certain Shoutlet Applications (collectively, the "Aggregate and Statistical Data"). For instance, when you visit the Site, our web server will automatically recognize some non-personal information concerning you and your computer or Internet device, including but not limited to the date and time you visited the Site, the pages you visited, the website you came from, the type of browser you are using, the type of operating system you are using, and the domain name and address of your Internet service provider. Information We Receive from Third Parties Social media websites. We do not own or operate the social media sites used by us that integrate Shoutlet Applications. However, whenever you provide information through a Shoutlet Application, we likely will receive information not only from you, but also from the relevant social media site, including information about actions you take and perhaps some additional information that the social media site previously collected. Most of the Shoutlet Applications are set up to collect Personally Identifiable Information and other information. When this information is collected by a Shoutlet Application, we collect the information (a) fairly, without intimidation or deception, and (b) lawfully, adhering to all relevant rules of law, whether derived from statute or common law, relating to collection of personal information. Information from other websites. We may obtain information from partners and other websites that share information with us. For example, we may ask others to tell us additional information about you or how you responded to ads or offers. Information from other users. We may receive information about you from our customers or other users. This information may include Personally Identifiable Information, such as your name and email address and may include other information, such as your connections with others or exchanges of information between you and another user. 2. Quality, Use, Disclosure, Retention, and Disposal: How We Can Use and Share Your Information Maintaining the privacy of your Personally Identifiable Information is important to us. Except as provided in this Privacy Policy or our Terms and Conditions of Use, we will not use or disclose to anyone your Personally Identifiable Information. We use Personally Identifiable Information only in ways that are relevant and compatible with the purposes for which that information was collected or subsequently authorized by the individual to be used, or as otherwise provided in this Privacy Policy. We take reasonable steps to ensure that Personally Identifiable Information is accurate, complete, current, and reliable for its intended use. Our policy is to limit access to your Personally Identifiable Information to those of our employees who need access to it to perform their duties. Any employee who violates our privacy or security policies may be subject to disciplinary action. We consider information that is not Personally Identifiable Information, such as answers to surveys, comments, ideas, and suggestions that do not include your Personally Identifiable Information, to be non-personal, and except as otherwise provided by contract, we are free to disclose and use such data or information without any obligation to you. Associate You with Your Account We may use the information that you provide us in an effort to identify and associate you with your account or to otherwise verify your identity. Cookie-related Information As most websites do, we use cookies for several purposes. First, we use it to track general information about our users. The information collected through cookies is not Personally Identifiable Information and we use this information for statistical, market research, and business and Site improvement purposes. We also use cookies to establish a link between your computer or Internet device and Shoutlet. This link assures that when you return to Shoutlet you will be able to log in without the necessity of providing your password, or helps us to avoid asking for the same information on your return visits to the Site. Aggregate and Statistical Data We use Aggregate and Statistical Data in the aggregate and on an individual basis to enable us and our customers to better understand the Site and our tools and services-related activity. We use it to track general information about you. We also use the Aggregate and Statistical Data to enable us and our customers to monitor their social media efforts with customizable report options that track user communications, who sees it, and where it is shared. The Aggregate and Statistical Data also allows us to (a) better troubleshoot and resolve issues, (b) provide technical support assistance, and (c) improve the Site and our offerings by enabling us to better understand which areas of the Site and Shoutlet Applications our users prefer, based on visits and usage. When we use Aggregate and Statistical Data, we do not link it to your Personally Identifiable Information. We use the Aggregate and Statistical Data we collect and share it with selected affiliates and customers in analyzing trends, the demographics of the users, and usage of the Site and Shoutlet Applications. We may use Aggregate and Statistical Data to improve our marketing and promotional efforts, to statistically analyze Site and Shoutlet Application usage, and to improve our content and product and service offerings. Point of Collection Purposes Sometimes, we have specific purposes for which we plan to use your information and we describe those purposes at the point of collecting your information. For example, we may solicit your feedback in order to improve the Site or our services and products, respond to your questions or comments, register you in connection with a contest, giveaway, or drawing, respond to a request for a brochure, or to otherwise send information to you. Vendor Services to Shoutlet We may share your Personally Identifiable Information and other information with our vendors, contractors, and partners in connection with services that these individuals or entities perform for or with us and our customers. These vendors, contractors, and partners are restricted from using this information in any way other than to provide services for us, and they may not share or resell that data. The services they provide may include such activities as direct mailing, fulfillment services, and email campaigns. Acquiror of Shoutlet We may disclose your Personally Identifiable Information and other information in connection with an anticipated merger, acquisition, or sale of all or substantially all of our assets or the Site’s assets or services. Disclosure and Use for Legal Reasons We may disclose your Personally Identifiable Information and other information about you if we believe in good faith that we are required to do so by law or court order. We may also disclose or use your information if it is necessary to identify, contact, or bring legal action against someone who may cause or be causing harm to, or interference with, the Site or our rights or other property, other Site users, or anyone else. In addition, we may also use IP addresses in cooperation with Internet service providers to identify users if we deem it necessary to comply with laws, to enforce compliance with this Privacy Policy or contractual obligations, or to protect our customers, ourselves, or others. Respond to Requests You Initiate We may disclose and use Personally Identifiable Information and other information about you in order to respond to an inquiry, request, or complaint that you have made or to provide you with additional information, alerts, and updates regarding our services and products. Deletion of Personally Identifiable Information At your request, we will delete from our active databases your Personally Identifiable Information collected by us through the Site or a Shoutlet Application deployed by us. We may retain such information to the extent required by law or if copies are kept in archival backups, but in no event will we use or disclose such information except as required by law. To request the removal of Personally Identifiable Information, please send us an email at techtherapy@shoutlet.com. See “Your Access to and Correction of Your Personally Identifiable Information” below for additional information as to correction of your Personally Identifiable Information. 3. Choice and Consent In accessing the Site or using a Shoutlet Application we deploy, you do not have to provide to us your Personally Identifiable Information. We enable you the opportunity to choose (opt out) by contacting us whether your Personally Identifiable Information can be (a) disclosed to a non-agent third party, or (b) used for purposes other than the purposes for which it was originally collected or subsequently authorized to be used by you. 4. Access, Security, and Other Important Matters Related to Your Privacy Your Access to and Correction of Your Personally Identifiable Information If you have submitted Personally Identifiable Information to us and would like to update or correct that information, please contact us at our email address, techtherapy@shoutlet.com, with the subject line "Privacy Policy Request" and provide us with your name, postal address, and any other information necessary to respond to your request. If requested to do so, we will use reasonable efforts to make corrections of and updates to your Personally Identifiable Information that are contained in our active databases. Protection of Children’s Personally Identifiable Information We do not intend to collect Personally Identifiable Information from anyone under age 13 and will not knowingly collect, maintain, or disclose such information. If you are under age 13, do not enter any Personally Identifiable Information about yourself on our Site or through a Shoutlet Application. If you are a parent or guardian who has discovered that your child under age 13 has submitted his or her Personally Identifiable Information to us without your permission or consent, we will make reasonable efforts to remove the information from our database, at your written request. To request the removal of your child’s information, please send us an email at techtherapy@shoutlet.com and include in your message your child’s name and the email address that your child submitted. Security Program We have developed and implemented a security policy and program that includes administrative, technical, and physical safeguards to protect Personally Identifiable Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. In addition, we have restricted logical access to Personally Identifiable Information, and we have restricted physical access to the environment where we store that information. Links to Other Sites We may offer links to other sites from the Site. We have no control over these external sites or their content and are not responsible for any actions they may take or any information they might collect. You may arrive at the Site or a website that incorporates a Shoutlet Application through clicking on a banner advertisement, as part of a co-branding arrangement, or simply by selecting a link on a web page. You should be aware that this Privacy Policy does not apply to your use of these sites. If you provide any information to such sites, different rules regarding the collection and use of your Personally Identifiable Information and other information may apply. Before using these linked sites, you may wish to review their privacy policies to understand how they treat privacy, security, data collection, and distribution. Staying Informed about this Privacy Policy and Our Information Practices Changes to our Privacy Policy. If we make a material change to this Privacy Policy, we will notify you by one of the following methods: (a) we will post a notice on the Site describing the change; or (b) we will send you an email notifying you of the change. That ensures that you can remain aware of what information we collect, how we use it, and under what circumstances we share it. Contacting us with questions. Questions or concerns about this Privacy Policy or our related information practices should be directed to us by email at techtherapy@shoutlet.com, with the subject line "Privacy Policy Question," or by writing to us at Shoutlet, Inc., Attention: Customer Service, 1 Erdman Place, Suite 102, Madison, WI 53717. Please include your name, address, and any other information necessary to respond to your question. Your California Privacy Rights Residents of the State of California, under the California Civil Code, have the right to request from certain companies conducting business in California a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes and a disclosure of the shared information. Alternatively, the law provides that if the company has a privacy policy that provides you with an “opt-out” choice for use of your personal information by third parties for marketing purposes, the company may instead provide you with information on how to exercise your choice. We qualify for and select the alternative option. As described above under the heading, “Choice and Consent” you may opt out of our providing your personal contact information to third parties for direct marketing purposes. If you are a California resident and would like more information about our compliance with your California privacy rights, send your request to us at techtherapy@shoutlet.com. EU Safe Harbor We adhere to the U.S. Department of Commerce’s EU Safe Harbor Program (the "Safe Harbor Principles") of Notice (see section on “Quality, Use, Disclosure, Retention, and Disposal: How We Can Use and Share Your Information”), Choice (see section on “Choice and Consent”), Onward Transfer (see section on “Quality, Use, Disclosure, Retention, and Disposal: How We Can Use and Share Your Information”), Security (see section on “Security Program”), Data Integrity (see section on “Quality, Use, Disclosure, Retention, and Disposal: How We Can Use and Share Your Information”), Access (see section on “Your Access to and Correction of Your Personally Identifiable Information”), and Enforcement (see section on“BBBOnline Program: Privacy Complaints by European Union Citizens”) with respect to personal information (as defined below). We will respond to your request to access or delete personal information within 30 days as is required under the Safe Harbor program. We will adhere to the requirements of the Safe Harbor Principles with respect to sensitive information (as defined below). For purposes of this EU Safe Harbor notice, "personal information" means data that is (a) transferred from the European Union to the United States; (b) recorded in any form; and (c) about, or pertains to, a specific individual who is identified in, or is identifiable from, the data. "Sensitive information" means personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or the sex life of the individual. Sensitive information also includes personal information received from a third party where the third party treats and identifies it as sensitive. Monitoring and Enforcement Generally. We have a process in place to address inquiries, complaints, and disputes. Each inquiry or complaint is addressed and its resolution is documented and communicated to the individual initiating the inquiry, complaint, or dispute. Instances of non-compliance with this Privacy Policy and its procedures are documented and reported to management. If needed, corrective actions are taken on a timely basis. BBBOnline Program: Privacy Complaints by European Union Citizens In compliance with the Safe Harbor Principles, Shoutlet commits to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this Privacy Policy should first send us an email at techtherapy@shoutlet.com. Shoutlet has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Shoutlet, you may contact: Council of Better Business Bureaus, Inc. BBB EU Safe Harbor 4200 Wilson Boulevard, Suite 800 Arlington, VA 22203 Phone: 703-276-0100 Web: www.bbb.org/us Email: eusafeharbor@council.bbb.org If there is a conflict between this Privacy Policy and a legal requirement (including the Safe Harbor Principles with respect to personal information), the legal requirement will take precedence over this Privacy Policy. Effective Date of this Privacy Policy: October 10, 2011.
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