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GLOBAL RESPONSE PARTNERS LLC


Effective Date: 5/1/2010

GRPADS WEBSITE PRIVACY POLICY (US)

Thank you for visiting the GRPAds website located at www.grpads.com (the "Site"). The Site is an Internet property of Global Response Partners, LLC ("GRP," "we" or "us"). We respect the privacy of your personally identifiable information. To better protect your privacy, we provide this notice ("Privacy Policy") explaining our online information practices associated with the Site, as well as the choices available to you concerning the way that we use the information collected at the Site. You agree to this Privacy Policy, in its entirety, when you: (a) access or use the Site; and/or (b) register on the Site as either a "Publisher" or "Advertiser" (as those terms are defined in the GRPAds Publisher Agreement and GRPAds Advertiser Agreement, collectively "Network Agreements").

Personal Information Collection and Use

We collect your personally identifiable information when you apply at the Site to become either a Publisher or Advertiser participating in the affiliate network owned and operated by GRP ("GRP Network"). The types of personally identifiable information that we collect at the Site when you apply to become either a Publisher or Advertiser may include, without limitation, some or all of the following as they relate to you and/or your business entity: (a) name; (b) mailing address; (c) e-mail address; (d) instant messenger address; (e) telephone number; (f) title/function in business organization; (g) password and challenge question; (h) website URL and category; (i) tax classification; (j) tax identification number/Social Security Number; and (k) any and all other information requested on the applicable application. For purposes of this Privacy Policy, items (i) and (j) in the preceding sentence shall be considered "Sensitive Information."

As a general rule, and other than in connection with the limited exceptions set forth below, GRP will not sell, share or rent the personally identifiable information collected at the Site to or with others. Notwithstanding the foregoing, GRP reserves the right to disclose your personally identifiable information: (i) in accordance with the terms of any relevant statute or court order; (ii) to the relevant insolvency practioner or purchaser in the event of GRP’s bankruptcy, or if GRP is sold or acquired; (iii) where you are in violation of this Privacy Policy, the Global Response Partner Website Terms and Conditions ("Terms and Conditions") and/or any Privacy Policy or Terms and Conditions of any affiliate Network Agreement; or (iv) where in the good-faith belief GRP determines, in its sole discretion, that such disclosure is necessary to protect the rights of GRP and/or a third party, or necessary to protect GRP from liability of any kind. The aforementioned includes exchanging information with other companies and organizations for fraud protection.

Any personal information that you submit at the Site remains your property. However, by submitting that information to us, you grant to us the right to use your personal information, subject to applicable law: (A) to contact you in connection with your participation in the GRP Network, and with respect to other GRP products and/or services; (B) to track your compliance with the Terms and Conditions and/or Network Agreements; and (C) for validation, suppression, content improvement and feedback purposes. You agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Site and GRP Network.

Choice/Opt-out

If you have registered to receive communications from us and later change your mind, you may contact us to have your name removed from our distribution lists by emailing contactus@grpads.com.

Correct/Update

If you would wish to verify the data we have received from you or to make corrections to it, you may contact us directly at contactus@grpads.com.

Non-Personally Identifiable Information Collection and Use

We may collect certain non-personally identifiable information about you when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Netscape, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or Mac OS) and the domain name of your Internet service provider (e.g., America Online, Earthlink).

We use the non-personally identifiable information that we collect to improve the design and content of the Site and GRP Network, and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze Site and/or GRP Network usage.

The Site uses technology called "cookies." A cookie is a tiny element of data that the Site can send to your browser, which may then be stored on your hard drive so that we can recognize you when you return. Cookies also allow us to store Site users’ preferences and to record session information. We do not link the information we store in cookies to any personal information that you submit while on the Site. You may be able to configure your browser to accept or reject all or some cookies, or notify you when a cookie is set -- each browser is different, so check the applicable "Help" menu of your browser to learn how to change your cookie preferences. If you set your browser not to accept cookies, you will still be able to use the Site. The Site may also use technology called "tracer tags." These may also be referred to as "Clear GIFs" or "Web Beacons." This technology allows us to understand which pages you visit on the Site. These tracer tags are used to help us optimize and tailor the Site for you and other future Site visitors. To find out more about cookies, please visit www.cookiecentral.com.

GRP reserves the right to transfer and/or sell aggregate or group data about Site users for lawful purposes. Aggregate or group data is data that describes the demographics, usage or other characteristics of Site users as a group without disclosing personally identifiable information. Subject to applicable law, by submitting your personal information to, and/or using the Site, you agree to allow GRP to transfer and/or sell such aggregate data to third-parties.

Third Party Links

We do not endorse, nor are we responsible for the accuracy of, the privacy policies and/or terms and conditions of any Publishers, Advertisers or the third party sellers that may advertise on the Site. The entities that participate in the Network or advertise and/or place banner advertisements on the Site are independent third parties and are not affiliated with us.

If you would like to stop receiving further contact from us regarding your participation in the GRP Network and other GRP products and/or services, please contact us at: Contactus@grpads.com. If you would like to delete or update the personally identifiable information that we have collected from you, please contact us at: ContactUs@grpads.com . We will process your request, where possible and subject to the terms and conditions contained herein, within a reasonable period of time after receipt. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.

Minors

We do not knowingly collect information from minors under eighteen (18) years of age. No information should be submitted to, or posted at, the Site by individuals under eighteen (18) years of age. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Security

All collected information is stored in a technically and physically secure environment. When our registration/application process prompts users to enter Sensitive Information, and when we store and transmit such Sensitive Information, that Sensitive Information is encrypted and is protected with SSL encryption software. While we use SSL encryption to protect Sensitive Information online, we take reasonable measures to protect all other user information both online and off-line. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information that you transmit to us, and you do so at your own risk. Once we receive your transmission, we make reasonable efforts to ensure its security on our systems. All of our users’ information, not just the Sensitive Information, is restricted in our offices. Only employees who need the information to perform a specific job function are granted access to personal information. Furthermore, access to this information is strictly limited, and not accessible to the public. Our employees are dedicated to ensuring the security and privacy of all user information. Employees not adhering to our written firm policies are subject to disciplinary action.

We adhere to the EU Safe Harbor Privacy Principles with respect to the use and processing of data originating from the EU ("EU Safe Harbor"). For further background about the EU Safe Harbor, please refer to the U.S. Department of Commerce’s website at http://www.export.gov/safeharbor, or contact us.

Please note that any attempt to breach the security of the network, our servers, databases or other hardware or software supporting the Site or other websites under the control of GRP may constitute an offence punishable by law. We will turn over to relevant authorities any and all evidence relating to such potential breach of security or other abuse against the network, servers, databases or other such supporting equipment or software. In compliance with applicable federal and state laws, we shall notify you in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Changes to the Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add and/or remove portions of this Privacy Policy at any time. If we change our Privacy Policy, we will prominently post a link to those changes on the Site’s homepage so that the Site users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify the affected Site users by way of an e-mail communication. Your continued use of the Site, GRP Network and/or continued receipt of GRP communications after posting of the Privacy Policy change on the Site, or receipt of a Privacy Policy change notification e-mail, as applicable, constitutes an affirmative acknowledgement and acceptance by you of the modified Privacy Policy.

Contact Us

If you have any questions regarding this statement, or would like more information on our privacy practices, please contact us at: ContactUs@grpads.com



GRPADS WEBSITE PRIVACY POLICY (UK)


Global Response Partners LLC (GRP, we, us, our or the Company) act as a consumer credit broker and are authorised and regulated by the FCA for these purposes under FCA reference number 636923. This privacy policy has been prepared by us to meet the requirements of the Data Protection Act 1998 (the Act). The Company is registered under the Act with registration number: Z2352609.

This privacy policy (together with our Terms of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data.

1 INFORMATION WE MAY COLLECT FROM YOU

  1. 1.1.1  Evidence that you have expressed an interest, opted in or agreed to receive further marketing material by GRP or our Broker Partners (this may be in the form of a web link, call to action button, i.e. a “tick box” or “I agree” button)

  2. 1.1.2  Evidence that you have agreed to visit a Broker Partners direct website to consider their product or service offering (this may be in the form of a web link, call to action button, i.e. a “tick box” or “I agree button” a website cookie stored on your computer or a pixel fire, which evidences that you have viewed a screen detailing your agreement to interact with the promotion.

  3. 1.1.3  All correspondence and communications, and a record of them if you initiate or engage in correspondence with GRP or our Broker Partners. This includes emails, the use of mobile devices, and any other form of written or electronic correspondence or interaction.

  4. 1.1.4  Any Interaction with GRP or its Broker Partners via verbal communication, including landline or mobile telephone calls, Skype or any other medium may be recorded both for training and monitoring purposes and the protection of your interests and that of GRP and our Broker Partners.

  5. 1.1.5  Surveys that we may use for research purposes, which we have asked you to complete;

  6. 1.1.6  Details of your visits to our website(s), including your personal IP address and the resources that you access; and:

2 WHERE WE STORE YOUR PERSONAL DATA

  1.  
  2. 2.1  All information you provide to us is, as far as reasonably practicable, stored on our secure servers. We ask you not to permit anyone to use your name.

  3. 2.2  Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website(s); any transmission is at your own risk.

  4. 2.3  We will retain your information securely stored for a reasonable period or for as long as the law requires.

3 HOW WE USE YOUR INFORMATION

  1. 3.1  The Company collects and processes your data in order to provide you with our services, or that of our Broker Partners.

  2. 3.2  We will store and process your information on our computers and in any other way we consider appropriate.

  3. 3.3  We use information held about you in the following ways:

    1. 3.3.1  To provide your information to a lender, product or service provider for them to assess your suitability if you are applying for a credit product;

    2. 3.3.2  To provide you with the best possible service;

    3. 3.3.3  To request customer feedback;

    4. 3.3.4  To develop, improve and update our products to better meet your needs and preferences;

    5. 3.3.5  For statistical analysis;

    6. 3.3.6  To notify you about changes to our service; and

    7. 3.3.7  To provide you with information about goods and services which may be of interest to you, and we may contact you about these by post, telephone, email, SMS, mobile marketing or other reasonable method.

  4. 3.4  If you have provided us with consent to do so, we may pass your details to third parties, so that they can provide information and services which may be of interest to you. They may contact you by post, telephone, email, SMS, mobile marketing or other reasonable methods.

  5. 3.5  If you would like to opt out of receiving marketing information from us or to revoke your consent for us to pass your details to third parties, you can do so by:

  1. 3.5.1  Selecting unsubscribe on an email or mobile marketing message sent by us or our Broker Partners;

  2. 3.5.2  Emailing us at customerservices@grpads.com; or

  3. 3.5.3  Writing to us at Global Response Partners LLC, Thornfield House, Delamer Road, Altrincham, Cheshire, WA14 2NG

We reserve the right to take reasonable steps to authenticate your identity with respect to any such request or other enquiry.

  1. 3.6  Any information or statistics relating to our business that we disclose to others shall not identify you personally.

  2. 3.7  As a US limited liability company, we may transfer your personal data outside of the European Economic Area (EEA). Any transfers made will be in compliance with all aspects of the Act to ensure that your personal information is protected to an equivalent standard outside the EEA.

4 DISCLOSURE OF YOUR INFORMATION

4.1 We may disclose your personal information to third parties:

  1. 4.1.1  To enable lenders, product or service providers to make a decision (where you wish to apply for credit to one of our lender partners);

  2. 4.1.2  To prepare or send any communications to you, or to assist us in connection with any of our administrative or business functions, or in the provision of any of our services to you;

  3. 4.1.3  If the Company or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;

  4. 4.1.4  To anyone whom we transfer our rights and duties to; and

  5. 4.1.5  if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce other agreements with you; or to protect the rights, property, or safety of the Company , our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

5 IP ADDRESSES AND COOKIES

What are cookies?

5.2 Cookies are small text files stored on a user’s computer by their web browser or the website visited, designed to store basic information (such as visitor preferences) to help the browser 'remember' things that you have done in the past.

Our use of cookies

5.3 When you visit our website(s) a bar is displayed at the [top/bottom] of the page. This alerts visitors to the fact that our website(s) uses cookies to identify a previous visitor to our website and allows a user to click to find out more information about our use of cookies. By continuing to use our website(s) you are consenting to our use of cookies. Once consent is obtained, it is not necessary to obtain it again for the same user each time the same cookie is used in the future.

Managing cookies

5.4 You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our website(s). You can find out how to do this by visiting http://www.aboutcookies.org/. This site has a guide on how to change the settings for most of the major internet browsers.

Web tools

  1. 5.5  We might also use web tools to collect information about your browsing activities while on our website(s). In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes.

  2. 5.6  Some of our advertisers and Broker Partners may also use cookies or web tools that are set by other people such as advertising agencies, or the businesses to which the advertisements in question relate. We do not have access to any information collected in this way and, if you are concerned, you should contact the advertiser for more information.

6 YOUR RIGHTS

  1. 6.1  Our website(s) may, from time to time, contain links to and from the websites of our advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

  2. 6.2  You have the right to access information held about you. Your right of access can be exercised in accordance with the Act by writing to us at Global Response Partners LLC, Thornfield House, Delamer Road, Altrincham, Cheshire, WA14 2NG. Any access request may be subject to a small statutory fee to meet our costs in providing you with details of the information we hold about you.

  3. 6.3  Calls between us may be recorded and/or monitored for training and compliance purposes.

7  CREDIT REFERENCE AND FRAUD PREVENTION AGENCIES

  1.  
  2. 7.1  Some lenders whom we or our Broker Partners may pass your information to may run a credit check with credit references agencies and fraud protection agencies to make a decision as to whether to provide you with a loan.

  3. 7.2  If you apply for a loan or consumer credit product and it is refused by one of our lender or Broker Partners on the basis of information they have received from a credit reference agency, they must inform you of this and provide you with the details of the agency concerned.

  4. 7.3  If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies.

  5. 7.4  Law enforcement agencies may access and use this information.

  6. 7.5  We and other organisations may also access and use your information to prevent fraud and money laundering.

  7. 7.6  Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Act.

8  CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page.

9  CONTACT

Questions, comments and requests regarding this privacy policy are welcomed at customerservices@grpads.com or Global Response Partners LLC, Thornfield House, Delamer Road, Altrincham, Cheshire, WA14 2NG.