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1 Privacy Policy Your personal and corporate privacy is important to FunkyCouture.com. This privacy policy ( Policy ) applies to the FunkyCouture.com e Web sites and services and tells you how personal and corporate information is collected, used, disclosed, and protected by FunkyCouture.com. This statement includes the Website Privacy Statements. CHANGES TO THIS POLICY We may change this Policy from time to time. If we make any changes to this Policy, we will change the last updated date above. If there are material changes to this Policy, we will notify you more directly. We encourage you to check this Policy whenever you use our Web sites and services to understand how your personal information is used. INFORMATION COLLECTED We collect information from you and your company in various ways when you use our Web sites and services. We may also supplement this information with information from other sources. We collect several types of information, namely personal information, corporate contact information and corporate transactional information. As used in this Policy, the term personal information means information that specifically identifies an individual (such as a name and address), and demographic and other information when directly linked to information that can identify an individual. The term corporate information means information that specifically identifies a corporation, but may not be ties to a specific individual (such as a generic , info@company.com or a physical address). Our definition of personal information, corporate profile information and corporate transactional information does not include aggregate data. Aggregate data is information we collect about a group or category of services or users from which individual user or corporate identities have been removed. In other words, no personal information or information that can link back to a corporation is included in aggregate data. Aggregate data helps us understand trends in our users needs so that we can better consider new features or otherwise tailor our services. This Policy in no way restricts or limits our collection and use of aggregate data, and we may share aggregate data about our users and their companies with third parties for various purposes, including to help us better understand our customer needs and improve our services and for advertising and marketing purposes. The following are the specific types of information we collect from you. Information You Give Us. We collect information you give us on our Web site and when you register for and use our services. Examples include the following: Registration and Profile Information. When you register to use our services or update your profile, we may collect various kinds of information about you including, names and addresses; titles, company name, industry segment, and other profile information you provide; demographic information; and information you upload like photos, files, and documents. Payment Information. If you choose to use a paid FunkyCouture.com account or service, our payment processing vendor collects your credit card information and billing address. 1
2 Third-Party Account Information. When you connect our services to your marketplace accounts on third-party websites, we collect the log-in and authentication information necessary to maintain the connection, as well as any information downloaded from these third-party websites, such as order and inventory information. Submissions and Customer Service. From time to time we may use surveys, contests or sweepstakes requesting personal or demographic information and customer feedback. Automatically Collected Information. We automatically receive certain types of information when you interact with our Web pages, services and communications. For example, it is standard for your Web browser to automatically send information to every Web site you visit, including ours. That information includes your computer s IP address, access times, your browser type and language, and referring Web site addresses. We may also collect information about the type of operating system you use, your account activity, and files and pages accessed or used by you. Cookies and Web Beacons. We may also use certain kinds of technology such as cookies and Web beacons to collect information. Among other things, the use of cookies and Web beacons enables us to improve our Web sites and s by seeing which areas and features are most popular, to count the number of computers accessing our Web site, to personalize and improve your experience, to record your preferences, and to allow you to visit our Web site without re-entering your member ID and/or password. A cookie is a small amount of data which is sent to your browser from a Web site s computers and stored on your computer s hard drive. Most browsers automatically accept cookies as the default setting. You can modify your browser setting to reject our cookies or to prompt you before accepting a cookie by editing your browser options. However, if a browser is set not to accept cookies or if a user rejects a cookie, some portions of the Web site and services may not function properly. For example, you may not be able to sign in and access certain Web page features or services. A Web beacon is an electronic image, also called a gif, that may be used on our Web pages to deliver cookies, count visits and compile statistics on usage and campaign effectiveness or in our s to tell if an has been opened and acted upon. USE OF PERSONAL INFORMATION In general, we use your personal information to process your requests or transactions, to provide you with information or services you request, to inform you about other information, events, promotions, products or services we think will be of interest to you, to facilitate your use of, and our administration and operation of, the Web site and services and to otherwise serve you and our users. For example, we may use your personal information: -to request feedback and to enable us to develop, customize and improve the Web site and our publications, products and services; -to conduct marketing analysis, to send you surveys or newsletters, to contact you about services, products, activities, special events or offers from FunkyCouture.com or our partners and for other marketing, informational, product development and promotional purposes; -to send you a welcoming and to contact you about your use of the Web site and services; to respond to your s, submissions, comments, requests or complaints; to perform after-sales services; to anticipate and resolve problems with our service; to respond to customer support inquiries, for 2
3 assistance with our product and service development; and to inform you of updates to products and services from FunkyCouture.com that better meet your needs; -to send and receive order and inventory information from third-party websites in which you have an account for the purposes of the services of our websites; -to contact you if you win a contest; and -for other purposes about which we notify you. FunkyCouture.com may store and process personal information in the United States and other countries. USE OF CORPORATE PROFILE INFORMATION In general, our use of corporate profile information is similar to that of personal information. We will also use this information as a means to facilitate third-party interaction with your company when the interaction is general in nature and could be handled by any number of individuals and is hence, not personal, e.g. sales, accounting, or legal issues. SHARING PERSONAL INFORMATION FunkyCouture.com reserves the right to share aggregated demographic information about our customers to our partners and advertisers. We will not give, sell, rent, share, or trade any of your personal information that we gathered from or through you to any third party except as outlined in this Policy or with your consent. We may disclose information to a third party to (a) comply with laws or respond to lawful requests and legal process, (b) to protect FunkyCouture.com, agents, customers, and others including to enforce our agreements, policies and terms of use or (c) in the good faith belief that disclosure is needed to respond to an emergency, or protect the personal safety of any person. We may share personal information in connection with an acquisition, merger, or sale of all or a substantial portion of our business, with or to another company. In any such event, you will receive notice if your data is transferred and becomes subject to a substantially different privacy policy. SHARING CORPORATE PROFILE INFORMATION FunkyCouture.com reserves the right to share aggregated corporate profile information about our customers, sales, and traffic to our partners and advertisers. We will not give, sell, rent, share, or trade any of your corporate profile information that we gathered from or through you to any third party except as outlined in this Policy or with your consent. We may disclose information to a third party to (a) comply with laws or respond to lawful requests and legal process, (b) comply with the policies and procedures of the entities with which we are mutually engaged or represent (c) to protect FunkyCouture.com, agents, customers, and others including to enforce our agreements, policies and terms of use or (d) in the good faith belief that disclosure is needed to respond to an emergency, or protect the personal safety of any person. We may share corporate transactional information in connection with an acquisition, merger, or sale of all or a substantial portion of our business, with or to another company. In any such event, you will receive notice if your data is transferred and becomes subject to a substantially different privacy policy. SHARING CORPORATE TRANSACTIONAL INFORMATION FunkyCouture.com reserves the right to share aggregated corporate transactional information about our customers to our partners and advertisers. We will not give, sell, rent, share, or trade any of your 3
4 specific corporate transactional information to any third party except as outlined in this Policy or with your consent. We may disclose information to a third party to (a) comply with laws or respond to lawful requests and legal process, (b) to protect FunkyCouture.com, agents, customers, and others including to enforce our agreements, policies and terms of use or (c) in the good faith belief that disclosure is needed to respond to an emergency, or protect the personal safety of any person. FunkyCouture.com provides you with opportunities to connect with third party services and includes product features that by their nature share information with those third party services. Those services may see your corporate order information, inventory information and counts, shipment tracking numbers and other related information. If you choose to use any such third party services, we may facilitate sharing of your information with those services. Your use of such services is not governed by FunkyCouture.com s terms or privacy policy. FunkyCouture.com does not control the services of those third parties or how they use your information and documents. Be sure to review the terms and the privacy policies of those third parties before using their services. We may incorporate transactional information in connection with an acquisition, merger, or sale of all or a substantial portion of our business, with or to another company. In any such event, you will receive notice if your data is transferred and becomes subject to a substantially different privacy policy. NETWORK AND INFORMATION SECURITY FunkyCouture.com takes reasonable steps to protect information we collect from you to prevent loss, misuse and unauthorized access, disclosure, alteration, and destruction. In addition, highly confidential personal information such as credit card number and password that we request from you on our Web site is protected with encryption, such as Secured Socket Layer (SSL) protocol, during transmission over the Internet. The servers on which information is stored are kept in a controlled environment with limited access. While we take reasonable efforts to guard personal information we knowingly collect directly from you, no security system is impenetrable. In addition, we cannot guarantee that any passively-collected personal information you choose to store on our systems are maintained at adequate levels of protection to meet specific needs or obligations you may have relating to that information. Your account information and access to our service is accessible only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always log-out and close your browser when you finish your session. Please note that we will never ask you to disclose your password in an unsolicited phone call or . UPDATING AND ACCESSING PERSONAL INFORMATION If your personal information changes in any way, we invite you to correct or update your information as soon as possible. You can make updates to your profile information by logging into your account on FunkyCouture.com at any time. You can also request changes or access to your information by ing privacy@funkycouture.com. CHOICE/OPT-OUT FunkyCouture.com may send you communications or data regarding our Web sites and services, including but not limited to (i) notices about your use of our Web sites and services, including any 4
5 notices concerning violations of use, (ii) updates, and (iii) promotional information and materials regarding our products and services. You may opt-out of receiving promotional s from FunkyCouture.com by following the opt-out instructions provided in those s. Opt-out requests will not apply to transactional service messages, such as security alerts and notices about your current account and services. ENFORCEMENT If you have any questions about this Policy, you should first contact us at CONTACTING US Any questions about this Policy should be addressed to 5
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