The VideoConferencingStore.com,
and its publisher Access Business Communications, Inc. (ABCI), Marketing
information usage practices are based on two beliefs: first,
that protecting user privacy is essential to the growth and
prosperity of the Internet; second, that a personalized web
experience can provide significant benefits to Internet end
users if done properly. In accordance with these beliefs, the
ABCI Network creates results for advertisers and publishers in
revolutionary ways without compromising individual privacy. The ABCI Network is committed to
proper Internet practices and full compliance with the
CAN-SPAM Act of 2003 (15 U.S.C. § 7701). It is our policy to
prohibit the sending of unsolicited or "Spam" e-mail by ABCI
or any of its marketing partners.
To receive no further
emails . . .
Opt-Out Mechanism to Use
about the advertiser
Advertiser's
from the email marketing
company
Opt-Out Mechanism to Use
from the advertiser or
email marketing company
Both
VII. DATA PROCESSING/SAFE HARBOR CLIENT
PRIVACY
CONSUMER PRIVACY
I. INFORMATION WE
COLLECT: INDIVIDUAL INTERNET CONSUMERS
A.
Personally Identifiable Information (PII).
The ABCI
Network sites are designed to promote and facilitate the
business of the ABCI companies with advertisers and marketers.
These sites are not directed towards individual Internet
consumers nor do they seek any PII from such consumers. PII
may be collected should a consumer contact a ABCI company on
his/her own initiative or respond to a ABCI advertisement and
provide any PII. Under no circumstances does the ABCI Network
request or collect sensitive PII such as an Internet user's
medical/health conditions; racial or ethnic origin; political,
religious or philosophical beliefs or affiliations; trade
union membership or sex life.
B. Non-Personally
Identifiable Information (Non-PII).
When a consumer
responds to or views an Internet advertisement served by a
ABCI company (such as through third-party Web sites or email
solicitation) or visits a ABCI Network site, we send a cookie
and/or gif file ("Cookies") to assign an anonymous, unique
identifier to the end user's Internet browser. Cookies are
small data files commonly used on the Internet to help
optimize and personalize the Internet end user experience and
identify repeat visitors to Web sites.
The function of
these Cookies is to provide ABCI with information for the
purpose of paying third-parties commissions when an Internet
user clicks on a link, creates a lead, or makes a purchase on
an advertiser's Web site; and also to optimize and personalize
the Internet user's experience. If the Internet user re-visits
the advertiser's site directly, ABCI is able to continue to
track the user's activities on the advertiser's site and
reward the third-party Web site that referred the user. We
reserve the right to retain all ad delivery and reporting data
as long as may be reasonably necessary for accounting and
audit purposes.
Like most standard Web site servers, we
use log files to collect Internet protocol (IP) addresses,
browser type, Internet service provider (ISP), referring/exit
pages, platform type, and date/time stamp. We use the
information to analyze site usage, administer the site,
understand usage and navigation trends in aggregate, and
determine the relevance of content. This information, however,
is not linked to any personally identifiable information.
We also may use Internet browsing and online purchase data
associated with an anonymous identifier to develop a
predictive statistical user profile of the end user's needs
and interests. ABCI does not use Cookies or log files to
collect end users' names, physical addresses, email addresses,
phone numbers, credit card numbers, social security numbers,
or any other information which can be used to identify a
specific person. We may match the IP address and user profile
with email address data obtained separately in order to better
target campaigns to meet user's interests, but will not share
this information with third parties.
For improved
audience targeting, some ABCI Network sites use marketing
technology that allows advertisers to add
non-personally-identifying demographic information, such as
age, gender, area code, or ZIP code, to the non-identifiable
profile data. Thus, there is no direct connection between an
end user's online choices and his or her personal identity.
In some cases, ABCI receives and records partial email
addresses of Internet users, only in circumstances where the
user voluntarily provided its identity and contact information
through the Advertiser's site or third-party marketer's site.
This partial email address does not enable ABCI to personally
identify an Internet User.
II. INFORMATION SHARING
The ABCI Network may make any PII provided in
responding to an advertisement available to the company
sponsoring the advertisement, as well as to other trusted
third parties in accordance with the terms of this privacy
policy. As a result, you may receive information on additional
products, services and offers that may be of interest to you.
The ABCI Network and/or our marketing partners may enhance
and/or merge PII about consumers who have opted-in to receive
marketing communications with commercially-available third
party data collected from other sources in an effort to ensure
that the messages being sent to the consumer in online and/or
offline marketing programs are relevant to their interests. In
the event we enhance and/or merge such personally identifiable
information with data collected from other sources, we will
take reasonable steps to maintain the integrity and quality of
that information.
The ABCI Network may share PII
(including information that has been enhanced with information
from other sources) with advertisers, third party marketers,
our affiliated entities for their online and/or offline
marketing programs or in connection with the sale, merger,
consolidation, change in control, transfer of substantial
asset, reorganization or liquidation of any of the ABCI
Network companies. While ABCI strongly encourages clients and
partners to adopt responsible approaches to online marketing,
ABCI is not responsible for the information practices of
clients or their partners. The collection, use, and disclosure
of information by clients and partners are subject to their
respective privacy policies, which may differ from ABCI's
policy.
The ABCI Network may release account and any
other personal information when we believe release is
appropriate to respond to a subpoena or otherwise comply with
the law; enforce or apply our Terms and Conditions
and other agreements; or protect the rights, property, or
safety of ABCI or others. This includes exchanging information
with other companies and organizations for fraud protection.
III. CONSUMER CHOICE AND ACCESS
A.
Opting Out.
Some ABCI Cookies have an "opt-out"
option. This process does not remove the ABCI Cookie from your
system; it simply replaces it with an opt-out Cookie that does
not contain any unique identifiers. If this site provides such
a process it is detailed below.
Some of ABCI's Cookies
do not have an "opt-out" option, yet you still have the option
of blocking the use of Cookies by changing a setting in your
Internet browser. Please see your browser supplier's Web site
for details on how to do this.
This site does not
maintain a process for an individual consumer to opt-out of a
ABCI ad serving Cookie.
B. Accessing Consumer
Information.
Because they are not directed towards
individual Internet users, most ABCI Network sites do not
maintain a process for an individual consumer to review and/or
request changes to any PII collected.
Except as
provided below, this site does not maintain a process for an
individual consumer to access his/her PII.
IV.
SECURITY
The ABCI Network employs industry
standard security measures to ensure the security of all data.
Any data that is stored on ABCI's servers is treated as
proprietary and confidential and is not available to the
public. ABCI has an internal security policy with respect to
the confidentiality of customer and other data, allowing
access only to those employees or third parties who have a
need to know such information for the purpose of effectively
delivering ABCI products and services by means of user login
and password requirements. The ABCI Network routinely
evaluates its data security practices to identify security
threats or opportunities for improvement.
No
transmission of data over the Internet is guaranteed to be
completely secure. It may be possible for third parties not
under the control of ABCI to intercept or access transmissions
or private communications unlawfully. While we strive to
protect your PII, ABCI cannot ensure or warrant the security
of any information you transmit to us. You acknowledge and
assume this risk when communicating with a ABCI Network
company.
V. CONSENT AND CHANGES
The ABCI
Network may find it necessary or be legally obligated to
update this Privacy Policy from time to time. When we do, we
will post those changes on this page and update the effective
date so that you are always aware of the information we
collect, how we use it, and under what circumstances we
disclose it. Except as otherwise required by law,
modifications to this Privacy Policy will not affect the
privacy of data collected by ABCI prior to the effective date
of the policy change.
VI. CHILDREN'S PRIVACY AND
SPAM
The ABCI Network is very sensitive to the
issue of children's privacy and makes every effort to protect
the privacy of children using the Internet. ABCI's Web site,
products, and services are not developed for or directed at
children. Children (persons under the age of 18) are not
eligible to do business with us and we do not collect personal
information from any person we actually know is under the age
of 13.
Please note that
under the CAN-SPAM Act, an advertiser is required to provide
an opt-out mechanism for consumers to unsubscribe from future
emails about the advertiser. Although not required to by law,
many email marketers also include an opt-out mechanism to
enable consumers to be removed from their mailing list. This
has caused some confusion for consumers in opting out. The
table below clarifies which opt-out mechanism you should use
for commercial emails.
The European Union
("EU") maintains strict privacy laws. These rules differ
significantly from US laws. To reconcile these differences,
the US and the EU have created a Safe Harbor that defines
mutually acceptable privacy operations. ABCI, Inc. adheres to
the Safe Harbor principals. For more information see
www.export.gov/safeharbor.
By providing information
to ABCI Network sites, you acknowledge that they operate in
the United States and agree to (i) permit ABCI to transmit and
use your User information anywhere necessary, including across
international boundaries, to affect the services and
transactions provided by this Site; and (ii) that such use by
ABCI shall be subject to the terms and conditions stated in
this Privacy Statement and our Terms and Conditions.
VIII. DIGITAL POLICY FORUM
ABCI, Inc. is a
member of the Digital Policy Forum ("DPF"). The DPF is made up
of online marketing, analytics, advertising, publishing, and
email companies that are committed to examining and developing
responses to important privacy and consumer protection issues
in emerging media.
IX. LIMITATION OF LIABILITY,
THIRD PARTY INFORMATION & LANGUAGE
YOU UNDERSTAND
AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE
TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND OUR TERMS AND CONDITIONS
(INCLUDING LIMITATIONS ON DAMAGES, AND ARBITRATION OF
DISPUTES). YOU AGREE THAT ABCI'S LIABILITY FOR ANY BREACH OF
THIS PRIVACY POLICY SHALL BE LIMITED TO THE GREATER OF THE
VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY ABCI
OR $250 TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY
OUR TERMS AND CONDITIONS. You also agree that you have
provided notice to, and obtained consent from, any third party
individuals whose personal data you supply to ABCI with regard
to: (a) the purposes for which such third party's personal
data has been collected; (b) the intended recipients or
categories of recipients of the third party's personal data;
(c) which of the third party's data are obligatory and which
data, if any, are voluntary; and (d) how the third party can
access and, if necessary, rectify the data held about them. It
is the express will of the parties that this agreement and all
related documents have been drawn up in English.
I. INFORMATION WE COLLECT: ADVERTISERS
AND PUBLISHERS
A. Personally Identifiable
Information (PII).
The ABCI Network collects personally
identifiable information from all Advertisers and Publishers
(collectively "Clients") wishing to work with any ABCI
company. The collection of this information is a part of our
normal business practices. Advertisers or their
representatives will be asked to provide personally
identifiable data through the host sign up and registration
process. Examples of personally identifiable data that may be
requested include name, address, phone number, email address,
and social security number, tax ID number, etc. The ABCI
Network will never request or collect data from a Client on
subject areas including medical/health conditions; racial or
ethnic origin; political, religious or philosophical beliefs
or affiliations; trade union membership or sex life.
B. Non-Personally Identifiable Information (Non-PII).
The ABCI Network may use cookies and log files to optimize
and personalize the Clients' experience and allow ABCI to
monitor site traffic patterns.
II. INFORMATION
SHARING
The ABCI Network does not use any
personally identifiable data about a Client for profiling
purposes. All PII that ABCI collects from Clients is
principally intended for administrative needs (e.g.,
accounting and pay-out and performance reporting), for which
purpose such data are required.
The ABCI Network may
provide email address and basic account data to an Advertiser
or Publisher to facilitate a potential or continued working
relationship between the Advertiser and Publisher. Once an
affiliation is established, Advertiser and Publisher (or their
agents or other third parties as designated by a Client) are
privy to their respective campaign information and PII,
including anonymous Internet user transaction data for
Internet users referred by Publisher and any other information
that a Client may instruct ABCI to disclose. While ABCI
strongly encourages Clients to adopt responsible approaches to
online marketing, ABCI is not responsible for the information
practices of Clients or their partners. The collection, use,
and disclosure of information by clients and partners are
subject to their respective privacy policies, which may differ
from ABCI's policy.
Periodically ABCI Network sites may
use Clients' PII in order to communicate with our network of
hosts via email newsletters or other avenues to offer
strategic marketing information and other communications to
assist in business related activities. In the event that a
Client of the ABCI Network wishes not to have their PII used
for these purposes, they may elect to opt-out from future
communications. For more information on opting-out please see
the "Client Choice Concerning Data Collection" section below.
Except as may be agreed between a ABCI company and a
Client, all PII data provided by individual Clients will be
kept in strict confidence by ABCI Network companies and will
be treated with the same level of respect and care that they
treat other proprietary information and trade secrets. ABCI
will never sell, rent, exchange or barter any personally
identifiable Client information to or with any third party for
financial gain or marketing purposes. The ABCI Network may,
from time to time, provide such information to certain
third-party administrative vendors for efficiency purposes in
providing administrative or program management services such
as billing, delivery and payouts. Any third-party vendor so
used has agreed to protect the confidentiality of information
provided by ABCI.
The ABCI Network may share PII in
connection with our affiliated entities or in connection with
the sale, merger, consolidation, change in control, transfer
of substantial asset, or reorganization or liquidation of any
of the ABCI Network companies. The ABCI Network may release
account and any other personal information when we believe
release is appropriate to respond to a subpoena or otherwise
comply with the law; enforce or apply our
Advertiser Terms of Use*,
Publisher Terms of Use*
and other agreements; or protect the rights, property, or
safety of ABCI or others. This includes exchanging information
with other companies and organizations for fraud protection.
III. CLIENT CHOICE AND ACCESS
When a Client
registers for services with a ABCI Network company, PII is
required as a part of doing business. ABCI's primary intent in
collecting personally identifiable information is for
administrative purposes including accounting and payouts.
However, the ABCI Network may periodically use personally
identifiable information for marketing and communication
purposes targeted to our Clients. Clients wishing not to
receive such communications from a ABCI Network company may do
so by "opting-out" during the registration and application
procedure process. A Client may change their "opt" status at
anytime during their tenure with ABCI by accessing their
online account.
When a Client logs on any browser-based
ABCI Network reporting system, a "Cookie" is placed within
their computer. The purpose of the Cookie is to allow ABCI to
validate the identity of the Client and maintain the security
and privacy of the Client's account data. This Cookie is
required to log into ABCI's reporting systems and there is no
method to opt-out of this Cookie.
IV. SECURITY
The ABCI Network employs industry standard security
measures to ensure the security of all data. Any data that is
stored on ABCI's servers is treated as proprietary and
confidential and is not available to the public. ABCI has an
internal security policy with respect to the confidentiality
of customer and other data, allowing access only to those
employees or third parties who have a need to know such
information for the purpose of effectively delivering ABCI
products and services by means of user login and password
requirements. The ABCI Network routinely evaluates its data
security practices to identify security threats or
opportunities for improvement.
No transmission of data
over the Internet is guaranteed to be completely secure. It
may be possible for third parties not under the control of
ABCI to intercept or access transmissions or private
communications unlawfully. While we strive to protect your
PII, ABCI cannot ensure or warrant the security of any
information you transmit to us. You acknowledge and assume
this risk when communicating with a ABCI Network company.
V. CONSENT AND CHANGES
The ABCI Network may
find it necessary or be legally obligated to update this
Privacy Policy from time to time. When we do, we will post
those changes on this page and update the effective date so
that you are always aware of the information we collect, how
we use it, and under what circumstances we disclose it. Except
as otherwise required by law, modifications to this Privacy
Policy will not affect the privacy of data collected by ABCI
prior to the effective date of the policy change.
VI. DATA PROCESSING/SAFE HARBOR
The European Union
("EU") maintains strict privacy laws. These rules differ
significantly from US laws. To reconcile these differences,
the US and the EU have created a Safe Harbor that defines
mutually acceptable privacy operations. ABCI, Inc. adheres to
the Safe Harbor principals. For more information see
www.export.gov/safeharbor.
By providing information
to ABCI Network sites, you acknowledge that they operate in
the United States and agree to (i) permit ABCI to transmit and
use your User information anywhere necessary, including across
international boundaries, to effect the services and
transactions provided by this Site; and (ii) that such use by
ABCI shall be subject to the terms and conditions stated in
this Privacy Statement and our Advertiser Terms of Use*
and Publisher Terms of
Use*.
VII.
DIGITAL POLICY FORUM
ABCI, Inc. is a member of the
Digital Policy Forum ("DPF"). The DPF is made up of online
marketing, analytics, advertising, publishing, and email
companies that are committed to examining and developing
responses to important privacy and consumer protection issues
in emerging media.
VIII. LIMITATION OF LIABILITY,
THIRD PARTY INFORMATION & LANGUAGE
YOU UNDERSTAND
AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE
TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND OUR ADVERTISER TERMS OF USE*
and PUBLISHER TERMS OF
USE* (INCLUDING
LIMITATIONS ON DAMAGES, AND ARBITRATION OF DISPUTES). YOU
AGREE THAT ABCI'S LIABILITY FOR ANY BREACH OF THIS PRIVACY
POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR
SERVICES PROVIDED TO YOU BY ABCI TO THE EXTENT SUCH CLAIM IS
NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS. You also
agree that you have provided notice to, and obtained consent
from, any third party individuals whose personal data you
supply to ABCI with regard to: (a) the purposes for which such
third party's personal data has been collected; (b) the
intended recipients or categories of recipients of the third
party's personal data; (c) which of the third party's data are
obligatory and which data, if any, are voluntary; and (d) how
the third party can access and, if necessary, rectify the data
held about them. It is the express will of the parties that
this agreement and all related documents have been drawn up in
English.
