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Vpass
B Barnett Inc., d/b/a Vpass, knows that you care how information about you is used
and shared, and we want you to know how that data is collected and used. The collection,
use and dissemination practices of Vpass are discussed in this policy. This policy
applies to our information collection (a) on our website(s) [Website(s)]; (b) on
third party websites and affiliate websites; and (c) our other information collection,
including the purchase of customer lists and data from third parties.
Information You Give Us: We collect information from individuals when you
voluntarily enter one of our websites and complete a survey, order form or registration
page, either online or offline. You can choose not to provide certain information,
but then you might not be able to take advantage of many of our features or be eligible
to win prizes or receive special offers. The information that you are asked to provide
may include your name, address, email address, street address, zip code, telephone
numbers, birth date, gender, salary range, education, marital status, occupation,
employment status, personal and online interests, and other information that may
be requested from time to time. Vpass or a third party may offer you incentives
in exchange for providing the requested information. We may also collect information,
including what web browser you are using and your Internet Protocol (IP) address.
Information from Third Parties: We may collect your information when you
provide it to a third party and we subsequently purchase, license or lawfully acquire
the information from that party. The information that we collect may include your
name, address, email address, street address, zip code, telephone numbers, birth
date, gender, salary range, education, marital status, occupation, employment status,
personal and online interests, and other information that you may have provided
to the third party. When receiving data from outside sources, we seek assurances
that the party has the right to transfer the information to us, that the data was
not improperly obtained, that the data is CAN SPAM compliant, that data also does
not violate COPPA, GRAMM-LEACH-BLILEY, HIPAA or SB-1386 Privacy Acts, and that we
have the right to provide offers from advertisers to the individuals whose information
is provided to us.
Other Information Provided To Us: Other times that we may obtain information
from you include (1) when you make a claim for a prize or seek to redeem an incentive
offered by us or a third party, (2) when you request assistance through our customer
service department, or (3) when you voluntarily subscribe to a service, purchase
from us or newsletter provided by us or a third party. We may also receive information
about you from a third party or from other sources, including information located
in public databases.
Cookies, Web Beacons and Other Information Collected Using Technology: A
cookie is a small file that is placed on your hard drive that allows us to analyze
our web page effectiveness and identify you with the corresponding data that we
have in our database. You are always free to decline cookies if your web browser
permits, although in that case you may not be able to use all of the features and
functionality of our Websites.
Web Beacons: Web pages may contain electronic images (called a “single-pixel
GIF” or “web beacon”) that allow a web site to count users who have visited that
page or to access certain cookies. We use web beacons to track the effectiveness
of a promotional campaign and to transfer an individual’s unique user identification
(often in the form of a cookie) and associate your updated information into our
database. Our practice is to include web beacons in HTML-formatted email messages
(messages that include graphics) that we send directly or through third parties
in order to determine which email messages were opened and to note whether a message
was acted upon. In general, any electronic image viewed as part of a web page, including
an ad banner, can act as a web beacon.
New Technology: Since the use of new technology, including cookies, web beacons
and other technology, is rapidly evolving, as is our use of new and evolving technology,
we may change or use additional or new technology from time to time. You are encouraged
to visit this page for any updates on notification of Privacy Policy changes.
Credit Card Information: In certain cases, we may collect credit card numbers
and related information, such as the billing address and expiration date of the
credit card, when you place an order with us. When you provide us with this information,
it is encrypted and protected with SSL encryption software. We will use your credit
card information for the purposes of processing and completing the purchase transaction,
and we may need to disclose your card information to third parties only as necessary
to complete the purchase transaction.
What We Do With the Information That We Obtain: With the exception of a change
in control of our Company or the sale of substantially all of the Company’s assets,
Vpass may license, rent or sell your personal information to any third party, without
sending you an email notice of our intent. We use individual information to provide
promotional offers to you. The promotional offers may be made to you by means of
email advertising, telephone marketing, postal mail and by other means of communication.
We may use the information that we collect for any legally permissible purpose in
our sole discretion.
Summary Data: We may sell, transfer or share non-individual information,
such as a summary of the response to an advertisement, as long as the information
does not identify any individuals or groups.
Solicited Email: We only send email if you have agreed on one of our own,
or on a third-party, Websites to receive messages from us, or if you have agreed
from a third party website to receive messages. You may receive multiple messages
in a day from us or a third party. We do not send unsolicited email messages. We
are CAN SPAM compliant.
How to Unsubscribe: If you wish to unsubscribe from a particular offer, you
will need to follow the instructions that are at the end of each email message.
If you wish to unsubscribe from all of our offers, you must visit and follow the
instructions provided at http://myvpass.com/remove.html.
Storage of Information: We store your information in a database on our computers
which are in a secure location. We use procedural and technical safeguards such
as a firewall in place to protect against the loss, misuse and alteration of information
under our control, including encryption, firewalls and secure sockets layers. We
treat data as an asset that must be protected against loss and unauthorized access.
We employ security techniques to protect such data from unauthorized access by users,
both inside and outside of the Company, but we cannot guarantee that the data will
not be illegally accessed.
Legal Requests: We cooperate with law enforcement inquiries, as well as third
parties, to enforce laws, court orders, protect intellectual property rights, elimination
of fraud and other laws, to help protect both you and us from bad actors. In response
to a verified request by a law enforcement or other government official relating
to a criminal investigation or alleged criminal activity, suspected illegal activity
or potential threats to the safety of an individual, we may disclose your information
to law enforcement or other government officials or as otherwise required by law.
Due to the existing regulatory environment (USA Patriot Act), we cannot ensure that
all of your information will never be disclosed in ways not otherwise described
in this Privacy Policy.
Practices of Third Parties: We cannot control and are not responsible for
any third party’s use of cookies, web beacons or other technology to collect information
about an individual. Advertising agencies, advertising networks and other companies
who place advertisements on Websites, email messages and on the Internet may use
this or other technology to collect information about you.
Information Regarding Children: We will never knowingly collect any personal
information about children under the age of 13. If you are under the age of 18,
but at least 13 years of age, you may use our Websites only under the supervision
of a parent or legal guardian who agrees to be bound by our Privacy Policy. If we
obtain actual knowledge that we have collected personal information about a child
under the age of 13, that information will be immediately deleted from our database.
Because we do not collect such information, to the best of our knowledge, we have
no such information to use or to disclose to any third parties. We have designed
this policy in order to comply with the Children’s Online Privacy Protection Act
(COPPA).
Information Regarding Other Privacy Acts: a) GRAMM-LEACH-BLILEY – Financial
institutions must develop initial and annual privacy notices that describe information
sharing practices. Financial institutions that share non-public personal information
about consumers with non-affiliated third parties must also provide consumers with
an opt out notice and a reasonable period of time for consumers to opt out; b) HIPAA
– The Health Insurance Portability & Accountability Act limits the non-consensual
use and release of private health information. The Act also gives patients new rights
to access their medical records and to know who else has accessed them; c) SB-1386
Act – The California Security Breach Information Act (SB-1386) is a California state
law requiring organizations that maintain personal information about individuals
to inform those individuals if the security of their information is compromised.
The Act stipulates that, if there is a security breach of a database containing
personal data, the responsible organization must notify each individual for whom
it maintained information. The Act, which went into effect on July 1, 2003, was
created to help stem the increasing incidence of identity theft.
Unsubscribe Procedure: To unsubscribe from all of our offers, visit
http://www.myvpass.com/remove.aspx
.
More Information: If you have questions about this policy, please contact
us at: privacy@myvpass.com. WE RESERVE THE RIGHT TO UPDATE THIS POLICY FROM TIME
TO TIME WITHOUT NOTICE, SO YOU SHOULD REVIEW THIS POLICY FREQUENTLY.
Vpass. All rights reserved.
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