I. GENERAL MATTERS
At CastleGreetings.com ("CG"), protecting our users' privacy and security is a top priority. For this reason, we comply with the European Union-United States Safe Harbor Framework and US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. CG has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view CG's certification, please visit http://www.export.gov/safeharbor/. In accordance with the Safe Harbor Principles, we have adopted the following policy to advise you of our use of your personal information and your choices regarding that use. This policy describes what types of information we gather about you, how we use it, under what circumstances we disclose it to third parties, and your rights to change or delete it.
B. Scope of Policy
II. INFORMATION ABOUT YOU
A. Information Gathered From All Visitors
1. Aggregate Data
We gather certain generic information about the use of our website, such as the number of unique visitors, the frequency with which they visit, and the areas on the website that they favor. These statistics are very much like television ratings that tell the networks how many people tuned in to a program. We only use this type of data in Aggregate-that is, we look at the data on a collective basis, in summary form, rather than on an individual basis. This data helps us determine the extent to which our customers use certain parts of our website, which, in turn, enables us to make it as appealing as possible. This data does not contain any personally identifiable information about you.
2. IP Addresses
We collect and analyze traffic on our website by keeping track of the IP addresses of our visitors. IP addresses are unique numeric identifiers that are assigned to each computer browser accessing the Internet. An IP address, by itself, cannot identify you personally. However, when combined with other information provided by an Internet Service Provider, an IP address can be used to identify the computer originating a message.
3. When You Send An E-card
If you use our website to send an e-card or any other content, we collect your e-mail address and your recipient's e-mail address. This information is necessary to send the content and provide confirmation that it has been received. We will not use your recipient's e-mail address for any purpose other than to send the e-card.
PLEASE NOTE: We include your IP address in the header information of every e-card notification e-mail we send. It is available to the e-card recipient and anyone else who is forwarded the notification e-mail. This limits your ability to communicate anonymously using our products. Our products are neither intended nor appropriate for anonymous communications, and such activity is expressly prohibited by the acceptable use policy in our Terms of Service.B. Information Gathered From Members and Registered Users
1. Information Gathered From Members
2. Information Gathered From Registered Users
If you elect to register with us without becoming a member, you may be required to provide us with certain personal information, including your name, email address, gender, phone number, and cell phone carrier. You may also provide us with additional information regarding your preferences and interests; however, preference information is not required and is completely optional on your part. We may collect additional data from you based on certain services you elect to utilize on our website. For example, we may track the categories of e-cards you send in order to make appropriate recommendations for products or services available on our site or those of our Business Partners. By obtaining this information, we can provide you with specific content and advertising in which you might be interested. None of this information is required to use our service or to become a Registered User; however, the omission of certain types of data may limit your use of the site.
Third-Party Advertiser Cookies
We use third-party advertising companies to serve our ads on our website. These third-party advertising companies employ cookie and Clear Gif technology (aka 1x1 Pixel .gifs, Web bugs) to measure and improve the effectiveness of ads for their clients. To do so, these companies may use anonymous information about your visits to our Website and other Websites. This information can include: date/time of banner ad shown, the banner ad that was shown, the cookie they used, and your IP address. It may also contain your personally identifiable information if that is something you have Agreed to with the applicable third party. This information can also be used for online preference marketing purposes. CG does not use or have access to this information. If you want to prevent a third-party advertiser from setting or reading cookies on your computer, you may either visit each ad network's website individually and opt out or visit the website of the National Advertising Initiative ("NAI") to opt-out of all network advertising cookies. Click here for the NAI gateway opt-out site. This site will also allow you to review the third-party advertising companies' privacy policies.
Advertising Research Cookies
From time to time, third-party research companies may set cookies on your browser to track exposure to certain ad placements. These cookies may be used for research purposes if you later opt-in to take a survey. If you choose to take the survey, these companies may examine your browser to see if one of their cookies has been set. If the company detects the cookie in your browser, it will gather only 2 pieces of information from it: where you have seen a particular ad and how many times you have seen it. If you do not want these kinds of cookies to be set to your browser, you can opt-out by clicking here. We do not set these kinds of cookies on your browser.
Advertising Targeting Cookies
2. Web Beacons and Pixels
We also collect information on our website through the use of web beacons or 1x1 pixels. These pixels are connected to your personally identifiable information, if you have provided it, and allow us to better serve you by tracking your interests on our website. We do not sell, rent, trade, or otherwise distribute information about you gathered through the web beacons or pixels with any third-parties except for third-parties who provide us with research or analysis services. They may only use the information they gather this way to provide services to us. No other use will be made of your information gathered this way.
III. CG's Uses of Information
A. From All Visitors
We may use non-personally identifiable information to show you advertisements for products that may be of interest to you. For example, we may serve ads from toy companies to users searching the Birthday e-cards . We may also use geographic or other information we have collected from you to make sure that the ads you see are for goods and services that are actually of interest to you or are available in your area. We may use cookie files to assure that you will not be served the same ads repeatedly. If you are not a Member or a Registered User, no information is collected from you when you visit the site.
We may conduct demographic or other research about the users of our website to determine how users engage with our content.
3. Business Partners
We may provide information about how our customers collectively use our website to advertisers, sponsors, and other companies with which we do business ("Business Partners"). This data does not include any personally identifiable information about you.
4. Contests and Promotions
5. If You Send An E-card (as a non-Member)
We may use your e-mail address to contact you after you send an e-card if you have opted-in to receive such communications. You can opt out by following the instructions under Opt-Out/Changing Your Status below.
1. Communications From CG
We send our exclusive CG Newsletter to all of our Members and Register Users. The Newsletter alerts you to new features, content, and services, premiums available on our site. From time to time, we may also send you invitations to enhance your CG membership, offers for new products and services from CG, special "Member's Only" premiums, or special offers from our affiliates and our sponsors. We do not share your personally identifiable information with any third parties in connection with the Newsletter. You can always decline the Newsletter by un-checking the opt-in box on the My Account page on our site. If you are already receiving the Newsletter and you want to unsubscribe, simply follow the "unsubscribe" link at the bottom of each edition. For other ways to unsubscribe, see Opt-Out/Changing Your Status, below.
2. Mandatory Communications
CG reserves the right to communicate with you from time to time about important administrative, policy, legal, credit card, and billing matters that affect your use of our services, including, without limitation, any alleged violations of our Terms of Service. These communications are mandatory.
3. Third Party Information Sharing
Generally, we do not share your information with third parties without your prior consent. We do reserve the right to share your information with third-party companies we may use to offer premiums, maintain subscriptions, and perform other service functions for us. We do not share equipment or databases with these companies and will not share your credit card information with them without your express permission. Additionally, any company we use for these reasons will not share, sell, or distribute your information, or otherwise use your information except to provide us services.
We reserve the right to disclose your personal information to appropriate third parties if we are required to do so by law or we believe that such action is necessary:
- To comply with legal process such as a search warrant, subpoena or court order;
- To protect the company's rights and property;
- To investigate reports of users sending material using a false e-mail address or users sending harassing, threatening, or abusive messages;
- To protect against misuse or unauthorized use of our website, products, or services; or
- During emergencies, such as when we believe someone's physical safety is at risk.
Your IP address can be accessed by e-card recipients in the header of the notification e-mail we send for each e-card. Under certain circumstances, recipients, their legal representatives, or law enforcement authorities may be able to combine this with information disclosed by ISPs to determine the source of a particular communication. By using this service, you knowingly and voluntarily assume any risks associated with such disclosure.
IV. Your Control Over Your Information
A. Information We Have About You
You may request information about what information we have about you by contacting our Customer Support Department.B. Opt-Out/Changing Your Status
At any time, you can change choices you have previously made about the use of your personal information. Except for mandatory communications, every communication we send you will contain a clearly worded "Opt-Out" or "Unsubscribe" link allowing you to withdraw your permission for future mailings. Alternatively, you can send a blank e-mail to Support@CastleGreetings.com and type "unsubscribe" in the subject field. This system is automated and must be contacted from the email address you wish to have removed from our mailing lists. Permission changes will be honored as soon as possible after receipt. Please allow five to seven days for processing. Permission changes will not affect any information that you provided to us and that we previously shared with our Business Partners.C. Editing Your Profile
If you are a Member or a Registered User, you have the ability to review and correct your personally identifiable information at any time. Simply click on the "My Account" link at the top of the every page to go to the "My Account" page. There, you can change your address information, e-mail type, sign-in, and e-mail permissions. You can revise, add, delete, or completely cancel all Reminder alerts by navigating to the Reminders "my preferences" section from the "Reminders" link found at the top of each page.D. Editing Your Information
If you are a Member or Registered User, you may edit your information by signing in to your account and clicking on "My. CG.com." From there, click on My Account.E. Resolve Issues
In compliance with the US-EU and US-Swiss Safe Harbor Principles, CG commits to resolve complaints about your privacy and our collection or use of your personal information. If you are concerned about our use of your personal information, please contact us at Support@CastleGreetings.com. CG has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss 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 acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by CG, please visit the BBB EU Safe Harbor Website at www.bbb.org/us/european-dispute-resolution/consumer/ for more information and to file a complaint.
V. OTHER MATTERS
A. Protection For Children - COPPA Compliance
We are committed to protecting the privacy and rights of children online. To that end, we do not collect any personally identifiable information from users whom we know are under the age of 13. Our registration process blocks the registration of users under 13 years old and will automatically delete all personally identifiable information collected from such users.
B. Sale of Assets
In the event that CG or its units or subsidiaries are ever sold, acquired, merged, liquidated, reorganized, or otherwise transferred, we reserve the right to transfer our user databases together with any personally identifiable information contained in them, to a third-party acquiring CG's assets. In the event we do so, we will place a prominent notice of the sale on the homepage of our site, with links to information about how you can change your privacy preferences.
C. Data Security
When you place orders or access your payment information, we use an advanced encryption technology known as Secure Socket Layer (SSL) to protect the storage and transfer of your data from unauthorized parties. While on a secure page, such as our registration form, a lock or key icon appears at the bottom of your web browser. In addition to our online security efforts, we take steps to protect your personal data offline as well. All of your information, not just your personally identifiable information, is restricted in our offices. Employees are granted access on a need-to-know basis (for example, our billing clerk or a customer support representative). Furthermore, ALL employees are kept up-to-date on our security and privacy practices. We also comply with the Payment Card Industry Data Security Standards for safeguarding and handling your payment information. These standards are set by Visa and dictate levels of network and physical security that must be met in order for us to be allowed to process credit cards. Our main servers are operated from a dedicated Internet hosting facility with state-of-the-art physical security features, including smoke detection and fire suppression systems, motion sensors, 24x7 secured access, and video camera surveillance and security breach alarms. Unfortunately, the transmission of information via the Internet or over mobile networks is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to the Application or over mobile networks; any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorized access.