Last updated November, 2015
We realize the sensitive nature of the information you provide to us. This site describes how we collect and use your personal information. The information collection, use, and dissemination practices of American Council (“Company”) are discussed in this policy. This policy applies to Company’s information collection (a) on the Company’s websites, (b) on various third-party websites, and (c) to Company’s other information collection practices, including the purchase of customer lists from third parties.
COLLECTION OF INFORMATION
1.1 Survey Information. The Company collects information from individuals when they voluntarily complete a Company survey, order form, or registration page either online, in person, by mail, by telephone or other similar means (collectively, a “Survey”). In Surveys, the Company or third-party may ask an individual to provide various information to the Company, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, employment information, personal and online interests, and such other information as may requested from time to time (together, “Survey Information”). An individual may receive incentives from the Company or a third-party in exchange for providing Survey Information to the Company. If a login or password is generated, you are responsible for maintaining the confidentiality of your information and password.
1.2 Third-Party List Information. The Company may collect information from individuals when they provide information to a third-party, and the Company subsequently purchases, licenses, or otherwise acquires the information from the third-party (“Third-Party Seller”). Such purchased information may include, but is not limited to, Survey information (“Third-Party Survey Information”). When acquiring Third-Party Survey Information, the Company seeks assurances from the Third-Party Seller that the Third-Party Seller has a right to transfer the Third Party Survey Information to the Company and that the Third-Party Seller has a right to provide offers from advertisers to the individuals included on the Third-Party Seller’s list.
1.3 Other Information. The Company may obtain other information in situations including, but not limited to (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by the Company or by a third-party, (2) when an individual requests assistance through Company’s or affiliate customer service department, or (3) when an individual voluntarily subscribes to a Company service or newsletter (together, “Other Information”). The Company may also receive information about individuals from third-parties or from other sources outside of the Company including information located in public databases (“Outside Information”).
1.4 Cookies, Web bugs, and Other Technology. The Company currently uses cookie and web beacon technology to associate certain Internet-related information about an individual with information about the individual in our database. This information includes but is not limited to your IP address, the date and time you access the site, the URL that you just came from, which URL you go to next, which browser your are using and which operating system you are using. Additionally, the Company may use other new and evolving sources of information in the future (together, “Technology Information”). As a result, Company strongly encourages individuals to revisit this policy for any updates regarding its use of technology.
(a) Cookies. A cookie is a small amount of data stored on the hard drive of the individual’s computer that allows Company to identify the individual with his or her corresponding data that resides in Company’s database. We may use cookie technology to improve your experience, remember your preferences, customize the content you see, or authenticate our access to your personal information. You may read more about cookies at www.cookiecentral.com. Individuals who use our Websites need to accept cookies in order to use all of the features and functionality of the Websites.
(b) Web bugs. A web bug, web beacon, or action tag is programming code that can be used to display an image on a web page (by using an programming function — see www.w3.org for more information), but can also be used to transfer an individual’s unique user identification (often in the form of a cookie) to a database and associate the individual with previously acquired information about an individual in a database. The Company currently contracts with online partners to help manage and optimize its Internet business and communications. It uses the services of a marketing company to help us measure the effectiveness of its advertising and how visitors use its site. To do this, it uses web beacons and cookies provided by its marketing company on this site. The type of information it collects includes the frequency, duration, and pages viewed by visitors, and the time on a page, their operating system, browser size, type, version and connection speed. By supplementing its records, this information helps it learn things like what pages are most attractive to its visitors, which of its products most interest its customers, and what kinds of offers its customers like to see. Although the marketing company logs the information coming from its site on its behalf, the Company controls how that data may and may not be used. If you do not want to help the Company learn how to improve its site, product, offers and marketing strategy, you can “opt-out” of the website analysis tool by emailing email@example.com. The Company may also use web bugs in email messages or newsletters. If you wish more information about web bugs, you may visit http://www.webopedia.com/TERM/W/Web_beacon.html
1.5 Individual Information. As used herein, “Individual Information” means Survey Information, Third-Party Survey Information, Other Information, Technology Information, Outside Information, and any other information the Company gathers or receives about individuals.
1.6 No Information Collected from Children. The Company’s products and services do not solicit information or target information of any kind to children under the age of 13. The Company will not knowingly collect any personal information about children under the age of 13. It is possible by fraud or deception we may receive information pertaining to children under the age of 13. If the Company obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from its database. Because it does not collect such information, the Company has no such information to use or to disclose to third parties. The Company has designed this policy in order to comply with the Children’s Online Privacy Protection Act (“COPPA”).
1.7 Credit Card Information. The Company may in certain cases collect credit card numbers and related information, such as the expiration date of the card (“Credit Card Information”) when an individual places an order from Company. When the Credit Card Information is submitted to Company, such information is encrypted and is protected with SSL encryption software. The Company will use the Credit Card Information for the purpose of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to Third Parties only as necessary to complete the purchase transaction. Credit Card Information is not included in the definition of “Individual Information” and is not shared with Third Parties. Specific opt-in requirements for sharing of financial information under various state laws such as Vermont and New Mexico do not apply.
USE OF INDIVIDUAL INFORMATION
2.1 Discretion to Use Information. THE COMPANY MAY USE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN COMPANY’S SOLE DISCRETION. The Company may use Individual Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses.
2.2 Email. The Company uses Individual Information to provide promotional offers by email to individuals. If email recipients wish to end their email subscription, they may do so as described in paragraph 5 below. In certain commercial email messages sent by Company, an advertiser’s name will appear in the “From:” line, but hitting the “Reply” button will cause a reply email to be sent to Company. The “Subject:” line of Company email messages will usually contain a line provided from the advertiser to Company. The subject line will not usually contain phrases such as “ADV:” or “ADVERTISEMENT”. The Company only sends email to individuals who have agreed on its websites to receive email from the Company or to individuals who have agreed on third-party websites to receive email from third-parties such as Company. The Company does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable to Company’s email messages.
2.3 Targeted Advertising. The Company uses Individual Information to target advertising to an individuals. The Company uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones. Monitoring and Recording. You hereby give permission and consent to the Company or its affiliates to contact you via phone or email and agree to allow the Company or its affiliates to monitor or record your phone conversations. Verbal notice may not be provided of monitoring or recording.
2.4 Storage of Individual Information. The Company stores the Individual Information in a database on Company computers. Our computers have security measures (such as a firewall and monitoring) in place to protect against the loss, misuse, and alteration of the information under Company’s control. Notwithstanding such measures, even the most robust security systems are not foolproof and the Company cannot guarantee that its security measures will prevent the Company computers from being illegally accessed, and the Individual Information on them stolen or altered.
DISSEMINATION OF INDIVIDUAL INFORMATION
3.1 Sale or Transfer to Affiliates or Third-Parties. THE COMPANY MAY SELL OR TRANSFER INDIVIDUAL INFORMATION TO AFFILIATES OR THIRD-PARTIES FOR ANY PURPOSE IN COMPANY’S SOLE DISCRETION. The Company will transfer Individual Information to third-parties when necessary to provide a product or service that a person orders from such third-party while using Company websites or when responding to offers provided by Company. The Company may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.
3.2 Other. The Company may disclose Individual Information to respond to subpoenas, court orders, regulatory requests and other legal process. The Company may also disclose or exchange Individual Information with other companies for fraud protection and credit risk reduction. The Company may disclose Individual Information to protect or defend the rights or property of the Company or its websites, its products, or services, the personal safety of its employees or in urgent circumstances, the safety of members of the public. The Company’s websites are located in the United States. If you are located in the European Union or anywhere outside the United States, any information you provide will be transferred to the United States. Your use of our websites means that you consent to such transfers.
3.3 Changes to Individual Information. Currently there are no processes or procedures which you can use to review and/or request changes to personally identifiable information.
PRIVACY PRACTICES OF THIRD PARTIES
4.1 Advertiser cookies and web bugs. Advertising agencies, advertising networks, and other companies (together, “Advertisers”) who place advertisements on their websites and on the Internet generally may use their own cookies, web bugs, and other technology to collect information about individuals. The Company does not control Advertisers’ use of such technology, and the Company has no responsibility for the use of such technology to gather information about individuals.
4.2 Links. The Websites and email messages sometimes contain hypertext links to the web sites of third parties. The Company is not responsible or liable for the privacy practices or the content of such other websites.
5.1 Unsubscribe Procedure. If you wish to discontinue receiving email messages from Company, you have several options:
(a) Unsubscribe from one email list. To unsubscribe from a particular list follow the instructions in each promotional email message sent by the Company.
(b) Unsubscribe from all Company email lists. We reserve the right to add Individual Information to multiple lists maintained by Company. To globally unsubscribe from all of Company’s lists go to http://www.fcoikit.com/remove and complete the web form.
(c) Unsubscribe by sending a letter to:
Attn.: Privacy Department
2710 Thomes Ave Suite 334
Cheyenne, WY 82001
6.2 California Residents. Under California law, California residents who have an established business relationship with the Company may choose to opt-out of the Company’s disclosure of Individual Information to third-parties for marketing purposes. The Company discloses Individual information to companies for product fulfillment, to other companies in its sole discretion, and to Governmental and/or regulatory authorities. If, having provided your consent, you would like to revoke your consent to future disclosures of your Individual Information to third-parties, you may do so. This opt-out will not prevent the use of Individual Information that has already been disclosed to third parties with your consent and you should contact such third parties directly to opt-out from such communications. If you choose to opt-out, send a request by email or by sending a letter by postal mail to the street address provided in paragraph 5(c) above. For requests sent by email, you must put the statement “Privacy Department – Your California Privacy Rights” in the subject field of your email. For requests sent by postal mail, you must address the letter to the attention of “Privacy Department – Your California Privacy Rights”. For all requests, include your name, street address, city, the state of California, and zip code. The Company will not accept requests via the telephone or by facsimile. The Company is not responsible for notices that are mislabeled, misdirected or have incomplete information. Because the Company provides its California users with the ability to exercise his or her “opt-out” right, pursuant to Section 1798.83 (c)(2) of the California Civil Code, the Company is not obligated to provide California users with the names and addresses of all the third parties that received Individual Information for the third parties’ direct marketing purposes during the preceding calendar year.