As an Infomediary, the purpose of
AGLOCO.com is to use technology to enable businesses to interact
with consumers in highly personalized ways, without forfeiting
the privacy of the user. Therefore privacy is at the core of
AGLOCO™.
We do not give,
sell, rent, share, or trade any identifiable personal
information regarding our members to any third party, with the
exception of third-party contractors and service providers who
work with AGLOCO to provide the Viewbar and other services, and
who are strictly prohibited from later use of the information
that they may have access to. We will disclose personal
information to local, state, or federal law enforcement
officials when we believe in good faith that the law requires
it.
This Privacy
Policy provides both members of the AGLOCO™ service and visitors
to the AGLOCO.com website with information about what
information we collect, to what uses that information is put,
and to whom that information may be given. If you become a
member of AGLOCO™, the membership agreement encompasses the
provisions that are explained by this document. If you are only
a visitor to our website, this Privacy Policy is our promise to
you about how information about your visit will be handled.
This document is a
"work in progress," insofar as certain portions may be updated
from time to time as the programs and services we offer to our
members change. However the principles upon which this document
is based will not change, nor will our fundamental commitment to
protecting the privacy of our members. We also welcome your
continuing input into this policy. Please give us your feedback
at
privacy@AGLOCO.com.
AGLOCO™'s Privacy
Policy and our information practices are based upon the eight
principles of Fair Information Practices first issued by the
Organization for Economic Cooperation and Development in
1980. These guidelines continue to be the touchstone of all
modern privacy laws and regulations, and the concepts set forth
in them remain at the heart of privacy protection principles
that guide all responsible businesses today. More information
about the OECD's “Guidelines on the Protection of Privacy and
Transborder Flows of Personal Data” may be found at: <http://www.oecd.org/document/18/0,2340,en_2649_34255_1815186_1_1_1_1,00.html>.
Collection Limitation Principle
AGLOCO.com adheres to the principle that the collection of
personal information should be limited to that obtained through
fair and lawful means and only with the knowledge and consent of
the data subject.
How we
deliver: AGLOCO™ makes very clear our policies
regarding our data gathering processes and seeks consent before
obtaining personally identifiable data from the individual.
Information We Collect from Visitors
For visitors to
our website, we gather only aggregate, non-personally
identifying data about your visit to our website. If you visit
AGLOCO™'s website (whether you are using AGLOCO™'s Viewbar™
software or not), AGLOCO™'s web servers log a number of basic
pieces of information, including the following:
-
The URL (address)
of the page(s) requested;
-
The time and
date of the request(s) and the duration of your visit;
-
The "User Agent"
(the make and model of the web browser being used, including
the name and version of the operating system upon which that
web browser is running);
-
The "Referrer"
(the address of the site whose link you followed to get to our
website);
-
The IP address
and domain name of the computer to which we are sending pages
for display by your web browser.
For information
about why we gather and how we use this information, see the
Purpose Specification and Use Limitation sections of this
Privacy Policy.
Information We Collect from Members
In our online
registration form for new members of the service, we require you
to provide us with your full name, full mailing address, email
address and a password. In addition, we require your gender,
birth date, and a password question with its corresponding
answer, so that we may identify you if you ever lose your
password.
Certain
information such as your name, address, email address, and birth
date constitute "Personal Data" because that information can be
used to directly or indirectly identify you. This information is
collected and used according to the terms of this Privacy Policy.
In the future, we may offer additional services that will have
their own usage agreements and/or privacy policies. At the time
those services are offered, you will be given an opportunity to
review and accept those documents.
For information
about why we gather and how we use this information, see the
Purpose Specification and Use Limitation sections of this
Privacy Policy.
Other Data
We May Request from Members
We may ask you for
personal information at other times, including, but not limited
to, when you enter a sweepstakes, contest or promotion sponsored
by AGLOCO.com and/or when you report a problem with any of our
services. Any data collected at those times will be used in
accordance with this policy, unless otherwise explicitly stated
at the time of collection. Many of those sweepstakes, contests,
or promotions will have terms of service agreements associated
with them and those agreements may differ from provisions of
this policy. Therefore, it is important that you read and
understand those agreements as the nature of those offerings may
require different data privacy provisions that may supercede
this Privacy Policy.
Message
Boards and Messaging Services
If you utilize a
message board or other messaging service operated by AGLOCO™,
your use of those services is governed by the Terms of Service
agreement associated with those services. If you choose to
publish your e-mail address or publish other personal data, you
do so at your own risk. If you have concerns regarding privacy
issues related to the message boards or messaging services, or
wish to have a message removed from the message boards for
privacy-related reasons, you should contact
support@AGLOCO.com
for assistance.
About
Cookies
If you decide to
join the AGLOCO™ community, at the time you submit your
registration, and any time you access your account information,
AGLOCO™'s servers place a "session cookie." A cookie is a little
piece of text stored by your browser on your computer, at the
request of our server. Session cookies last until the conclusion
of your visit to our website and allows our servers to correctly
display pages based upon your account information.
The process we use
to serve advertisements and to enable certain personalized
experiences, including the storage of certain user preferences
on the AGLOCO™ website may involve the use of persistent cookies.
These cookies remain stored over a longer period of time and
help our ad serving vendors to make sure that you do not see the
same ads repeatedly. Cookies received in this way are monitored
by our ad-serving company, and we do not have access to this
information. However, we have contractual arrangements that
restrict our partners, including the ad-serving company, from
using these cookies for anything other than fulfilling their
service to AGLOCO.com. We may also use cookies to deliver
content specific to your interests, and to save your password so
you don't have to re-enter it each time you connect to the
Internet.
You are always
free to decline our cookies, if your browser permits, or to ask
your browser to indicate when a cookie is being sent. You can
also delete cookie files from your computer at your discretion.
Note that if you decline our cookies or ask for notification
each time a cookie is being sent, your Viewbar™ may not function
properly and we may have difficulty rendering service to you. If
you would like more information about cookies, you may wish to
visit
http://en.wikipedia.org/wiki/HTTP_cookie.
Sites
Linked Via the website
Information about
you may be collected by advertisers, merchants or other third
parties when you click through advertisements on the AGLOCO™
website. We have no control over the collection or handling of
such data and urge you to review the privacy policies of those
sites before providing them with personal data. AGLOCO.com is
not responsible for the privacy practices or the content of such
websites.
A Special
Note About Children
AGLOCO.com wants
to help parents protect the privacy of children and takes steps
to obtain parental permission before children may join AGLOCO™.
AGLOCO.com does not consider our web Site or services to be
directed at children but some children may have signed up as
Members. We have designed our parental consent process to comply
with the requirements of the Children's Online Privacy
Protection Act (COPPA), which is further described at the
Federal Trade Commission's website at
http://www.ftc.gov/bcp/conline/edcams/coppa/index.html.
Under the provisions of that law, we require that children under
13 obtain parental permission before joining AGLOCO.com. To
remove your child from AGLOCO.com membership, please contact us
at
support@AGLOCO.com.
For more information about protecting children online, see "Kidz
Privacy" at:
http://www.ftc.gov/bcp/conline/edcams/kidzprivacy/index.html.
Members are always
free to quit the service and close their account by contacting
Member Support at the email address
support@AGLOCO.com.
Purpose
Specification Principle
AGLOCO.com adheres to the principle that the purposes for which
personal data are collected should be specified at or prior to
the time of collection, and that any subsequent use should be
limited to the fulfillment of purposes not inconsistent with
those purposes previously specified.
How we
deliver: We clearly specify the purposes for which we
collect personal information from our members and restrict our
usage of that data to purposes reasonably related to those
described. Prior to any new data usage that may be beyond the
scope of previously disclosed purposes, we will disclose such
new uses and obtain the data subject's permission.
Visitors
to Our website
We use information
gathered from visitors to our website in an aggregate form to
get a better understanding of where our visitors come from and
to help us better design and organize our website. Although an
IP address doesn't necessarily identify a visitor personally, it
can sometimes suggest a connection to a particular individual or
their computer, therefore we do not disclose the information
contained in those logs to third parties unless compelled to by
law. Information contained in our web server logs may be used in
the course of fraud investigations.
Members of
Our Service
We collect and
process information about you in order to provide the services
described in the Membership Agreement. We will process your
information to administer your membership, determine your
eligibility for certain services, provide services to you, and
enable you to take advantage of other member benefits. In
addition to the purposes specified under the Collection
Limitation portion of this agreement, we will use the personal
information provided by members to verify your identity, to
protect against fraud, and to send you updates about your
account, including new products and services that are specific
to your membership and participation in AGLOCO™, as well as
company news updates, and notices regarding our policies and
practices.
Use
Limitation Principle
AGLOCO.com adheres to the principle that personal data should
not be disclosed, made available, or otherwise used for purposes
other than those specified in accordance with the Purpose
Specification Principle, except with the consent of the data
subject or as required by law.
How we
deliver: AGLOCO™ treats each members' personal
information as confidential and does not disclose it or use it
except as stated in Membership Agreement and as further
explained in this Privacy Policy. Specifically, AGLOCO™ will not
disclose personally identifiable information about you to others
unless:
We do not give,
sell, rent, share, or trade any identifiable personal
information regarding our members with any third party, with the
exception of third party contractors or service providers who
work with AGLOCO™ to provide this service. All parties with whom
we contract for such services are strictly prohibited by the
terms of those contracts from any other use of the information.
For more information regarding the AGLOCO™ Group of
international subsidiaries, please see the Openness section of
this policy.
It is AGLOCO™'s
policy to comply with reasonable warrants issued by courts to
law enforcement officials. However, our policy is to oppose
attempts to seek release of member information by private
parties through the use of civil subpoenas. When served with a
civil subpoena, our policy is to notify the specified member of
the request prior to disclosure of any personal data, and to
require the requesting party to seek court review of the
appropriateness and sufficiency of the subpoena before we will
disclose any of the requested member information.
AGLOCO™ may share non-personal information in aggregate or
summary form with its customers, partners, or other third
parties.
Individual Participation Principle
AGLOCO.com adheres to the principle that our members have a
right to know what type of information we maintain relating to
him/her, to have communicated to him/her the data relating to
him/her in a reasonable time at reasonable cost, and to
challenge the accuracy of that data.
How we
deliver: AGLOCO™ provides its members with access to
their account information via a secure web interface. We allow
our members to correct and update that information in a timely
manner, following processes designed to insure the integrity of
the information.
Personal Data
recorded about members, as described in the Collection
Limitation Principle section, will be provided to members upon
their request, within a reasonable period of time, according to
policies designed to assure the identity of the requesting party
before this personal data is released. If the member discovers
errors in that data, we will correct them upon request. You may
update, correct, access, or delete your Personal Data in
accordance with the following procedures:
Accessing
and Updating Your Personal Data Online and Offline
You may update and
correct your Personal Data by sending an email to
privacy@AGLOCO.com.
You may request
that a paper copy of your Personal Data be sent to you by
contacting our support organization using the form at (insert
URL) or by sending e-mail to
support@AGLOCO.com.
Subject to applicable law, the release of this Personal Data may
require the pre-payment of reasonable costs related to providing
such information, due to the volume of data that is often
involved and the costs of preparing and shipping such quantities
of data.
You may request to
be sent a copy of all of your Personal Data by contacting our
support organization using the form at
mailto:privacy@agloco.com.
A representative of Member Services will contact you with
further information about the costs associated with retrieving
and shipping that data to you.
Objecting
to Processing of Your Personal Data
You may object at
any time to our processing of your Personal Data by contacting
our support organization using the membership cancellation
process at (Insert URL). Upon cancellation of your account, any
member benefits accrued in your account will be deemed "unearned"
and will be forfeited.
Retention
of your Personal Data
You may quit the
service at any time and all Personal Data relating to you will
be taken out of active use for our advertising targeting
processes. Our data retention policy requires that data
pertaining to former members will be retained for a reasonable
period of time necessary to fulfill our service obligations to
members and to comply with applicable laws, and will then be
deleted according to a schedule established by AGLOCO™.
Members are always free to quit the service and close their
account by sending an email to
support@AGLOCO.com.
Data Quality Principle
AGLOCO.com adheres to the principle that any personal data
collected should be relevant to the purpose for which they are
used and, to the extent necessary for those purposes, should be
kept accurate and up-to-date.
How we
deliver: As an Infomediary, the information we collect
from our members is the basis upon which we obtain value on
behalf of our members. Therefore, the nature of our business
requires that we continuously collect data about our members.
The relevance, accuracy, and currency of that information are
all critical to serving the interests of our members, therefore
the processes underlying this principle are a core component of
our business, and adherence to this Privacy Policy is essential
to the value proposition we present to our members.
Openness Principle
AGLOCO.com adheres to the principle that we should provide our
members with information regarding changes in our practices and
policies with respect to their personal data, providing them
with reasonable opportunities to know what type of personal
information we retain, the purposes of their use, and other
information regarding how we adhere to the principles stated in
this document.
How we
deliver: AGLOCO™ has a general policy of openness about
its practices and policies regarding personal data of consumers.
AGLOCO™ states in detail what personal data it collects and why
it collects it. AGLOCO™ also maintains a policy of disclosing
any changes to its practices and policies. Any changes to our
policies or procedures that materially reduce the privacy
protections encompassed therein, including any changes in
corporate ownership that impact upon the promises made in this
policy, will be disclosed with sufficient advance notice to
allow those individuals affected to exercise informed choices
regarding their personal information.
AGLOCO.com is a
Hong Kong corporation. All consumer data collected by AGLOCO™
is managed by Infomediary Services Corporation, a management
company that AGLOCO™ has engaged to perform all management
functions for AGLOCO™’s activities worldwide. The data
physically resides at numerous data storage facilities around
the globe according to practices and policies detailed under the
Security Safeguards section of this document. We may also
transfer or share your personal information as well as part of a
transfer of your membership agreement to a successor
organization. By becoming a Member you give your consent to this
transfer of your personal data. All information collected as a
result of your membership in AGLOCO™ will be treated in
accordance with this Privacy Policy. Should the Privacy Policy
change in any significant way, you will be notified in advance
and given an opportunity to terminate your membership and delete
your data.
For our European
members, please note that AGLOCO™ stores its records in several
locations around the world. To provide these services, AGLOCO™
may transfer your personal data internationally to other vendors
or service providers located in other countries. Some of the
countries may have laws that protect personal data, some may not.
Regardless of applicable law, AGLOCO™ will protect your
information according to the terms of this Privacy Policy, no
matter where we process or store your data.
Security Safeguards Principle
AGLOCO.com adheres to the principle that personal data should be
protected by reasonable security safeguards against the loss,
unauthorized access, use, modification, or disclosure of data.
How we
deliver: AGLOCO™ has mandated that its management
company employ a variety of security measures to protect the
loss, misuse, and alteration of the information under our
control. Whenever possible, we make use of current industry
standard procedures and processes to safeguard the
confidentiality of your identifiable personal information, such
as firewalls, encryption, token authentication, application
proxies, monitoring technology, and adaptive analysis of network
traffic to track abuse of our network and its data. In some
cases we may employ practices that exceed current industry
standards, and in other cases we may diverge therefrom when we
reasonably believe circumstances dictate doing so. Unfortunately,
when you submit information about yourself to AGLOCO.com over
the Internet, the information may travel over many systems that
are not under the control of AGLOCO.com. The Internet is not
100% secure and it is possible that others may be able to
intercept the information that you are sending. While we
endeavor to provide the greatest possible protection to your
data, we cannot guarantee absolute security in all circumstances.
Accountability Principle
AGLOCO.com adheres to the principle that an individual should be
empowered to and accountable for assuring the corporation
complies with the measures that give effect to the principles
stated herein.
How we deliver: AGLOCO™ has mandated that its management
company engage a Chief Privacy Officer who is
responsible for ensuring that the principles stated in this
policy are adhered to throughout all of the activities in which
AGLOCO™ engages on behalf of its membership.
If you have any questions about
this Privacy Policy, please contact
privacy@AGLOCO.com. | 
