Effective
Date: 5/1/2010
GRPADS
WEBSITE PRIVACY POLICY
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