PRIVACY POLICY

Last Updated on April 17, 2018

Efficient Collaborative Retail Marketing Company, LLC (together with its affiliates, “ECRM”, “we”, “us”, and “our”) respect your concerns about privacy and personal data protection and value our relationship with you. This Privacy Policy (the “Policy”) applies to the ECRM website, online services, mobile applications, and web pages that post and reference this Policy (collectively, the “Site”), whether accessed via computer, mobile device, or other device (collectively, “Device”). The Policy describes the types of personal information we collect through the Site and how that personal information may be, used and/or with whom it may be shared. Please read this Policy carefully, because by accessing, visiting or otherwise using the “Site”, you acknowledge and consent to the data collection and use practices described in this Policy.

1. COLLECTION OF INFORMATION
A. Purpose. Users can access limited features of the Site without directly providing personal information to ECRM. In order to access the entire Site, including certain special features, users must register for an account with ECRM, which will provide the registrant with full access to the Site, including access to the Site's forums, message boards and chat rooms.
B. Information Sought During Registration. During the account registration process, you may be asked or choose to submit personal information that could reasonably be used to contact you or to identify you personally, including, but not limited to, your proper name, at least one active e-mail address, job title, address, phone number, password, username, company name, and business address.
C. Information Sought During Website Sweepstakes or Contests. When the Site offers sweepstakes or contests, you may choose to provide certain personal information to us to enter such sweepstakes or contest.
D. Automatically Collected Information. Along with the personal information that you provide to us directly, we may passively collect certain information as you navigate the Site, using various technologies (as further described below). This information may include, but not be limited to: your IP address, Device information, screen resolution, operating system, browser type, domain names, access times and referring website addresses.
E. We may combine the personal information you submit directly through this Site with other personal information we have collected from you, whether online or offline. We may also combine it with information we receive about you from other sources, such as other companies, publicly available information sources, and other third parties.

2. USE OF AND SHARING OF INFORMATION
ECRM collects, uses, and shares your personal information (i) in order to operate the website and to provide its online and electronic services; (ii) to respond to your inquiries and fulfill your requests, such as to send you documents you request or e-mail; (iii) for our business purposes, such as marketing new products and services, trouble shooting, data analysis, audits, developing new products or services, enhancing our Site, improving our products and services, identifying Site usage trends, and determining the effectiveness of our Site; and (iv) with our third party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, infrastructure provision, credit card processing, IT services, e-mail services, marketing services, auditing services, and other services, in order to enable them to provide services.

The collection of your personal information during account registration enables ECRM to send you any requested newsletter(s) or to send you any requested mailings or offers. You will have the opportunity to unsubscribe to any and all Site newsletters and mailings at any time by updating registration account information online, or through links contained in such newsletters. Information concerning your geographical location is used to determine if ECRM should provide regionalized information to its customers.

Except as otherwise herein, the personal information collected from you on this Site will not be shared with any third-parties, although ECRM reserves the right to share such information with its affiliates and subsidiaries without your permission. ECRM sometimes hires other companies to provide limited services on our behalf, such as sending newsletters, providing customer service, provided IT services, and performing statistical analysis of our services. We will only provide those companies with the information that they need to provide us with such services, and we take reasonable efforts to prohibit them from using that information for any other purpose.

ECRM reserves the right to disclose your personal information if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with legal process served on ECRM or the Site; (b) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (c) to enforce our Terms of Use; (d) to protect our operations or those of any of our affiliates; (e) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (f) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use and disclose personal information collected through this Site in other ways, with your prior consent. ECRM provides links to send e-mail messages to this Site for your convenience and your e-mail address is used so that this Site may reply to your inquiry. If we are involved in a merger, reorganization, joint venture, assignment, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.

We use aggregate information, which does not identify individuals, to monitor customer traffic patterns to the Site and particular pages, as well as Site usage, in order to help us improve the design and layout of the content. In addition, we may use and disclose information that is not in personally identifiable form (such as anonymized, masked or de-identified information) for any purpose. ECRM uses this information to maintain the quality of its service and to provide general statistics about Site visitors. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.

Storage and Transfer of Personally Identifiable Information
ECRM may store and process in the United States or any other country in which ECRM or its affiliates, subsidiaries, or agents maintain facilities. By using Site, you consent to any such transfer of information outside of your country.

Retention
We retain your personal information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.

3. INFORMATION FROM OTHER SOURCES
We sometimes supplement the information that we receive that has been outlined in this Policy with information from other sources and companies. Such outside information includes updated delivery and address information from carriers or third parties, which enables us to correct our records and deliver information from this Site or future communications more easily; account information, purchase or redemption information, and page-view information from some merchants with which we operate co-branded businesses or for which we provide technical, fulfillment, advertising, or other services.

4. INFORMATION SECURITY
We use reasonable organizational, technical, and administrative measures designed to protect personal information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the contact information below.

5. USE OF COOKIES
This Site uses cookies to assist you with making your online experience more individualized. A cookie is a text file that is placed on the hard disk of your computer by a web page server. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. Cookies are used for convenience and to save you time when you next visit this Site. We and our service providers use this information to monitor and analyze use of the Site, for security purposes, to facilitate navigation, to display information more effectively, for the Site’s technical administration, to increase the Site’s functionality and user-friendliness, and to verify users have the authorization needed for the Service to process their requests. In addition, we use cookies to gather statistical information about Site usage in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to set your computer to accept cookies from this Site, you may also choose to be logged into the Site automatically. If you choose to decline cookies, you may not be able to fully experience the interactive features of this Site or the other websites that you visit and you may experience technical problems receiving current information from such cookie-disabled websites. We also collect some information (ourselves or using third party services) using logging and cookies, such as IP address, which can sometimes be correlated with personal information.

Google Analytics
We use a tool called “Google Analytics” to collect information about use of this Site. Google Analytics collects information such as how often users visit this Site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. We use the information we get from Google Analytics only to improve this Site. Google Analytics collects only the IP address assigned to you on the date you visit this Site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this Site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy . You can prevent Google Analytics from recognizing you on return visits to this Site by disabling cookies on your browser.

Do Not Track
Some web browsers incorporate a “Do Not Track” (DNT) or similar feature that signals to digital devices that a visitor does not want to have his/her online activity tracked. Because not all web browsers offer DNT options and DNT signals are not yet uniform, we and many other website operators do not respond to DNT signals.

6. USE OF WEB BEACONS
The Site’s pages may contain electronic images known as web beacons - also referred to as single-pixel gifs - that permit ECRM to count users who have visited those pages and for other related statistics - (e.g., recording the popularity of certain content and verifying system and server integrity). Web beacons are not used to access your personal information on the Site; they are solely used to compile aggregated statistics concerning the use of the Site. Web beacons collect only a limited set of information including a cookie number, the time and date of a page view, and a description of the page on which the web beacon resides.

7. COMMUNITIES AND FORUMS OFFERED ON THIS WEBSITE
Any personally identifiable information, personally sensitive data, or other content that you disclose through the Communities, Forums, Message Boards, Chat Rooms, or other public online forums hosted on this Site, may be collected and used by others. We recommend caution when giving out personal information to others in these public online forums.

8. USER ACCESS TO AND CONTROL OF INFORMATION
You can access some of the information that we collect and process about you. For example, you can access information regarding recent orders from the Site; personal information (including name, e-mail, password, communications preferences, address book); payment settings (including credit card information and gift certificates); e-mail notification settings; and prior order history. With respect to your communications preferences, you can unsubscribe from newsletters by following the instructions included in the newsletter you receive. If your e-mail address has changed and you would like to continue to receive newsletters, you will need to access your account and update your e-mail address information in your account and sign-up again for the newsletter. Occasionally, ECRM will send out e-mails concerning Site disruptions, new products and other news about ECRM's products and services. These e-mails are sent to all account holders and are not subscription-based. Such e-mails are considered a part of ECRM's service to the users of its Site. It is your responsibility to provide ECRM with accurate personal information. If applicable, and you would like to review, correct, update, or delete the personal information that you have provided via this Site, please contact us as specified below. We will try to comply with your request as soon as reasonably practicable.

9. CHILDREN
The Site is not directed to individuals under the age of 13, and we do not knowingly attempt to solicit or receive information from children under 13 years of age.

10. INTERNATIONAL USERS
This Policy is meant to guide ECRM with respect to personal information collected from or about you at this Site. While this Policy applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to ECRM (“Local Laws”) may require standards which are stricter than this Policy and, in such event, ECRM will comply with applicable Local Laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions. All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Site or by providing consent to us (where required by law), you specifically acknowledge and agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules, and a lower standard of required protection, than in your country. Irrespective of which country your personal data is transferred, we would only share your personal data under a ‘need to know’ basis. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by organizational, technical, contractual and/or other lawful means.

11. THIRD PARTY SITES AND SERVICES
This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any application) that is available through this Site or to which this Site contains a link. The availability of, or inclusion of a link to, any such site or property on this Site does not imply endorsement of it by us or by our affiliates.

12. REVISIONS AND COMPLIANCE
ECRM reserves the right to occasionally update this Privacy Policy. At such time, ECRM will also revise the "last updated" date at the beginning of the Privacy Policy. We recommend that you periodically review this Privacy Policy.

ECRM will use a self-assessment approach to verify compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible. If you believe that your personal information has been processed or disclosed in violation of this Policy, ECRM encourages you to raise any concerns using the contact information provided in this Policy. ECRM will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.

13. CONTACT INFORMATION
If you have any questions about this Policy, please contact us via one of these methods:

by phone please call (440) 498-0500 (Monday to Friday, 8am – 5pm EST);

or by e-mail at privacy@ecrm.marketgate.com;

or please write to the following address:

Attn: Privacy Compliance
Efficient Collaborative Retail Marketing Company, LLC
27070 Miles Road, Suite A
Solon, OH 44139