PRIVACY POLICY

Your privacy is very important to us. We want to make your experience on the Internet as enjoyable and rewarding as possible, and we want you to use the Internet's vast array of information, tools, and opportunities with complete confidence. 

We have created this Privacy Policy to demonstrate our firm commitment to privacy and security. This Privacy Policy describes how MSquaredMarketing (“our Company”) collects information from all end users of our Internet services (the "Services")-those who access some of our Services but do not have accounts ("Visitors") as well as those who may purchase Products and/or pay a monthly service fee to subscribe to the Service ("Members"). This Policy also explains what we do with the information we collect, and the choices Visitors and Members have concerning the collection and use of such information. We request that you read this Privacy Policy carefully.

Personal Information Our Company Collects and How It Is Used

Introduction

Members may be asked to provide certain personal information when they sign up for our Products or Services including name, address, telephone number, billing information (such as a credit card number), and the type of personal computer being used to access the Services. The personal information collected from Members during the registration process (or at any other time) is used primarily to provide a customized experience as you use our Products and Services. Your information will never be licensed or sold to any third party. However, we may make limited disclosure of personal information under the specific circumstances described in the "Disclosure" section below.

Disclosure

We may disclose Member and Visitor information to the following third parties, under the following circumstances:

• Companies who work on our behalf: We contract with other companies to perform business support functions on our behalf, which may involve limited access to your personal information. We require these companies to use the information only to provide the contracted services; they are prohibited from transferring the information to another party except as needed to provide those services. Some examples of these business support functions include order fulfilment, coupon fulfilment, award and rebate fulfilments, customer survey execution and information systems management. We also may make aggregate non-personal information available to select service providers.
• Subsidiaries and joint ventures: A subsidiary or a joint venture is an organization in which we own at least a 50% interest. If our Company shares your information with a subsidiary or joint venture partner, our Company will require that they not transfer your information to another party for marketing purposes or use your information contrary to your expressed choices. If you have indicated that you do not want to receive any marketing information from our Company, we will not share your information with our subsidiary or joint venture partner for their marketing purposes.
• Co-branded and Partner Pages: Our Company may share information with partner companies who jointly present special offers or promotions on co-branded pages within our site. You will be notified of this sharing when you are asked to furnish personal data on such a page. The partner's use of any information you submit will be governed by the partner's own privacy notice, which you can review before submitting your information.
• Business Transfers: Our Company reserves the right to transfer your personal information in connection with the sale or transfer of all or a portion of our business or assets. If the business is sold or transferred, our Company will give you an opportunity to tell us not to transfer your personal information. In some cases, this may mean that the new organization will not be able to continue providing to you the services or products that our Company provided.
• Law Enforcement: Our Company may disclose personal information to third parties without your consent for any of the following reasons: to comply with any law, regulation or court order, to cooperate with Government investigations, to help prevent fraud or to enforce or protect the rights of our Company or its subsidiaries.
• With Your Consent: In all other cases, our Company will obtain your express consent before sharing your information with third parties. For example, our Company may conduct a joint offer or contest with a third party and you will be asked whether your personal information should be shared with that third party.

Online Shopping

If you order services or products directly from our Company we will use the personal information you provide only to process that order. We do not share this information with outside parties except to the extent necessary to complete that order.

If you complete an order for some other company(ies) that may be linked to our Site, such as an online gift order sent directly to a recipient, you may be asked to provide information about the recipient, such as the recipient's name, address, and phone number. Our company has no control over the third parties' use of any personal information you provide when placing such an order. Please exercise care when doing so. We recommend that you familiarize yourself with the Privacy and Terms of Use policies of any other company(ies) whose web sites you may access from our site.

Online Advertisements

Our company may display our online advertisements. In those cases we share aggregated and non-identifying information about our Visitors and Members collected through the registration process as well as through online surveys and promotions with these advertisers.

Additionally, in some instances, we use this aggregated and non-identifying information to deliver tailored advertisements or joint ventures. For instance, an advertiser or joint venture company tells us the audience they want to reach and provides us an advertisement tailored to the audience. Based upon the aggregated and non-identifying information we have collected, we may then display or send the advertisement to the intended audience. Our company does not share personal information about its Visitors or Members with these advertisers or joint venture companies. Information about how to opt-out of online advertisements you may receive from our Company will be contained in the ads themselves.

Responses to Email Inquiries

When Visitors or Members send email inquiries to our company, the return email address is used to answer the email inquiry we receive. Our company does not use the return email address for any other purpose and does not share the return email address with any third party.

Voluntary Customer Surveys

We may periodically conduct both business and individual customer surveys. We encourage our customers to participate in these surveys because they provide us with important information that helps us to improve the types of products and services we offer and how we provide them to you. Your personal information and responses will remain strictly confidential, even if the survey is conducted by a third party. Participation in our customer surveys is voluntary. Information about how to opt-out of surveys will be contained in survey communications.

We may take the information we receive from individuals responding to our customer surveys and combine (or aggregate) it with the responses of other customers we may have, to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information). We then use the aggregated information to improve the quality of our services to you, and to develop new services and products. This aggregated, non-personally identifying information may be shared with third parties.

Automatic Collection of Information

Cookies: Our Company may use "“Cookies" to collect information. Cookies are small pieces of information stored by your browser on your computer's hard drive, at a web site's request. Our Company Cookies do not contain any personal information, but are used primarily as follows:

• to keep track of temporary information. For example, Cookies allow us to keep track of the pictures you upload and download;
• to register you in special programs. Cookies allow us to remember you when you login to the places on our site that require Membership;
• to remember your country and language preferences;
• to help us understand the size of our audience and traffic patterns;
• to collect and record information about what you viewed on our Web site and what you viewed in our e-mail;
• to manage and present site information and the pictures displayed on your computer, and
• to deliver information specific to your interests.

Web Beacons: We may also place small "tracker gifs" or "beacons" on many of the pages on our website, in online advertising with third parties, and in our email. We use these beacons, in connection with Cookies, to collect non-personal data on the usage of our site including but not limited to the date and time of the visit, the pages visited, the referring web page, the type of browser (e.g., Internet Explorer, NetScape), the type of operating system (e.g., Windows, Linux, or Mac), and the domain name of the visitor's Internet service provider (e.g., AOL). This information is collected about thousands of site visits and analyzed as a whole. This information is useful in, for example, tracking the performance of our online advertising such as online banner ads and to determine where to place future advertising on other web sites.

Disabling Cookies and Beacons : If you are uncomfortable with the collection of such information through the use of Cookies and Beacons, we recommend disabling these features through your browser preferences, though please understand this will limit the performance and functionality of our Company's Web site. Your browser documentation should provide specific procedures for disabling cookie and beacon support.

Child Privacy

Protecting the online privacy of children is especially important, and those under the age of 13 are protected by law. For that reason, our Company does not knowingly permit children under the age of 13 to become registered members of our sites, or to buy goods and services on our sites, without verifiable parental consent. Our Company does not knowingly collect or solicit personal information about children under 13, except with their parent's express consent.

If we ever include children under the age of 13 as part of our intended site audience, those specific web pages will, in accordance with the provisions of the Children's Online Privacy Protection Act (COPPA), be clearly identified and provide an explicit privacy notice; and we will provide processes to obtain parental approval, provide access to information and allow parents to request removal of their children's personal information.

Our Company encourages parents and guardians to spend time with their children online and to participate in their interactive activities and interests.

Public Forums

Some parts of our site may enable you to participate in public services such as discussion boards, chats, and live events. Please use discretion when posting personal information about yourself when using these services. Be aware that when you disclose personal information at these sites, such as your name, member name, email address, etc., the information may be collected and used by others to send unsolicited email. The services are open to the public, and what you post there can be seen by anyone and is not protected. We cannot control the comments that you may receive while you participate in these services. You may find other people's comments to be offensive, harmful or inaccurate.

Our Company's Commitment to Data Security

We implement a variety of administrative, managerial, and technical security measures to help protect your personal information. Our Company has various internal control standards which relate specifically to the handling of personal information. These include certain controls to help safeguard the information we collect online. Our employees are trained to understand and comply with these controls and we communicate our Privacy Notice, practices and guidelines to our employees. However, while we strive to protect your personal information, you must also take steps to protect your information. We urge you to take every precaution to protect your personal information while you are on the Internet.

Services and Web sites we sponsor have security measures in place to protect the loss, misuse, and alteration of the information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party "hackers" from illegally obtaining this information.

Where to Direct Questions About Our Privacy Policy

If you have any questions about this Privacy Policy or the practices described herein, you may contact us through the contact information provided on this Web site. Revisions to This Policy Our Company reserves the right to revise, amend, or modify this policy, our Terms Of Use & Service agreement, and our other policies and agreements at any time and in any manner, by updating this posting.