DEMO PRIVACY POLICY

We are committed to advising you of the right to your privacy and strive to provide a safe and secure user experience. This Privacy Policy sets forth the online data collection and usage policies and practices that apply to our website.

By using our website, you explicitly accept, without limitation or qualification, the collection, use and transfer of the personally identifiable information (“PII”) and non-personally identifiable (“Non-PII”) information about you in the manner described in this policy. Please read this Statement carefully as it affects your rights and liabilities under the law. If you disagree or do not accept the way we collect and process your PII or Non-PII, please do not use this website.

Scope of This Policy

This policy applies to this website and regulates the processing of PII provided by you and Non-PII collected by us during your visit to our Website. It describes what type of information we collect; how we use that information and to whom we can provide that information. It also informs you of how to notify us to stop collecting and providing your information. We are located in the United States and by registering on our website, you agree to be governed by the laws of the United States.

Our Website may contain links to third-party websites over which we have no control. As such, we are not responsible for the privacy policies or practices of third-party websites, when you choose to link to them from our website. We encourage you to review the privacy policies and terms of use of those third-party websites to understand how they collect, use and share your information.

Members Only Gift is the data controller of your personal information but does not control the data use practices of those persons or entities to whom we transfer your PII and Non-PII for the purposes of providing the service you have requested. We encourage you to review the privacy policies and opt-out choices of those third parties so you can understand how they collect, use and share your information.

We provide the following rights for individuals regarding their data:

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision making and profiling.

Customers have the right to withdraw consent at any time.

Information We Collect and Retain

We collect the following general types of information about you when you register on our website and may collect combinations of these types of information:

Personally identifiable information (PII): is information that can be used to identify you. We do not collect PII except when you choose to provide it to us. Some examples of PII that we might collect from you during our interactions with you include:

• First and Last Name
• Physical Address
• Email address
• Telephone number
• Contact information
• Any other information you provide to us through the course of communicating with us about the products and services provided on our Website.

Demographic information: is information that may or may not be unique to you in the sense that it refers to selected population characteristics. Such information may include, but is not limited to, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, industry of employment, personal and online interests.

Behavioral information: is information pertaining to how you use our website; the areas of our website that you visit; what ads or services you accessed; and information about your computer hardware and software including your IP address, geographic location, browser preference, operating system type, domain names, times that you access the internet and other website you have been referred to us through. This information is necessary to analyze the use of resources, troubleshooting problems, preventing fraud, and improving our services and products.

Third-party information: is information that we may acquire from a third party which may include personal, demographic, behavioral and indirect information. We obtain this information so that we can personalize the advertising shown to you.

Web technology information: is information we automatically collect from you when you open one of our emails or visit our Website. This includes information collected from the use of cookies, web beacons or JavaScript as discussed below.

No Information Collected from Children: We never knowingly collect any Personal Information about children under the age of 13. If we obtain actual knowledge that we have collected Personally Identifiable 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, we have no information regarding its use or disclose to third parties.

Use of Cookies, Web Beacons, and Javascript

Cookies: “Cookies” are a feature in your browser software. If enabled, we may write cookies that may store small amounts of data on your computer about your visit to any of the pages of our Website. Cookies assist us in tracking which of our features appeal the most to you and what content or links you view or may have viewed on past visits. When you visit our site again, cookies can enable us to customize our content according to your preferences. We may use cookies to: keep track of the number of return visits to this site; accumulate and report aggregate, statistical information on website usage; deliver specific content to you based on your past viewing history or the email or site that directed you to our Website. You can disable cookies, although the website may not function properly for you. Your browser preferences can be modified to accept or reject all cookies, or request a notification when a cookie is set. You may read more about cookies at http://cookiecentral.com. In order to use all of the features and functionality of our Website, you need to accept cookies.

We predominately use “session” cookies, which are not permanently stored on your hard drive. Session cookies expire after two hours of inactivity or when you close your browser. When you carry out the purchase of a service or product on our website, a large amount of data is processed by our system and transferred through each page of the search or registration. This information includes all information you input on a registration page or questionnaire you complete as part of the registration process as well as demographic information that is not unique to you. “Session” cookies allow us to keep track of this data until you have completed your search or registration.

Removing Cookies: You have the ability to accept, decline or remove cookies at any time by modifying your browser settings. Please see http://cookiecentral.com. If you choose to decline cookies, however, that may hinder performance and negatively impact your experience on our website.

Web Beacons: We also use electronic images known as web beacons (sometimes called single-pixel gifs, clear gifs or action tags) that allow us to collect certain information about your visit to these Web pages (including the number of users who have visited those pages). This measures and improves the effectiveness of advertisements and delivery of services. Web beacons are not used to access your PII; they are a technique used to compile aggregated statistics about website usage. Web beacons collect only a limited set of information including a cookie number, time and date of page view and a description of the page on which the Web beacon resides. This information may be shared with one or more third parties so that they can understand the types of visitors to our website; how those visitors use our website; and the effectiveness of advertisements. We may also use web beacons in email messages sent to individuals listed in our database.

Disabling Web Beacons: Because web beacons are the same as any other content request, you cannot opt out or refuse them. However, they can be rendered ineffective by either opting out of cookies or changing the cookie setup in your browser.

JavaScript: We may also use JavaScript within certain advertisements. JavaScript is a computer language that enhances the functionality of our website, particularly with respect to pictures. We do not collect any PII through JavaScript but use it to analyze and improve our website’s functions.

Disabling JavaScript: You may deactivate JavaScript via your browser settings or activate it the same way. If you disable JavaScript, you will not be able to use some of the functions of our website.

IP Addresses: Your Internet Protocol (“IP”) is a unique Internet “address” which is assigned to you by your Internet Service Provider (“ISP”). For local area network (“LAN”), DSL, or cable modem users, an IP address may be permanently assigned to a particular computer. IP addresses are automatically logged by web servers and collect information about a user’s traffic patterns. While the IP address does not identify an individual by name, it may, with the cooperation of the ISP, be used to locate and identify an individual using the web. Your IP address can reveal what geographic area you are connecting from and which ISP you are using. We automatically track certain information based upon your actions on our website. We may use this information to do internal research on our users’ demographics, interests, and behavior to better understand, protect and serve you and our community. This information may include the URL that you just came from and which URL you next go to after visiting our website, your computer browser information in addition to your IP address.

Computer Profiles: We may also collect and accumulate other anonymous data which will help us understand and analyze the experience of our visitors. For instance, we may accumulate visitor data relating to referring domain names, the type of browsers used, operating system software, screen resolutions, color capabilities, browser plug-ins, language settings, cookie preferences, search engine keywords and JavaScript enablement. When you provide us with PII, we are able to use such visitor data to identify you.

How We Use the Information Collected

Providing Services and Products: We use the information we gather on our Website for the purposes of providing the services or products you have requested. This may include passing your information on to a third party with whom we have a contract to provide such services. Although our contractual arrangement limits how such third party can use your information, we do not control the privacy practices of this third party. If you have any questions or wish to remove your information from the third party’s database, you will need to contact that party directly.

Improving our Website: We also use the information we gather on our Website to respond to any inquires you make; operate and improve our Website, improve and create a positive user experience on our website; and deliver the services you requested from our Website. Our services include the display of personalized products, content, and advertising relating to your experience and interests. The information we gather on our Website may be shared with other companies under common ownership with ours throughout the world or our Advertisers.

Disclosure of Information to Others

We disclose to third parties throughout the world your combined personal, demographic, behavioral or indirect information, as set forth below:

Service and Product Delivery and Vendors: We may share your information with third parties who help us in the delivery the products and services you have requested. We disclose information to companies and individuals we employ to perform technical functions on our behalf. Examples include third parties who host our website, analyze our data, provide marketing assistance, process credit card payments, and provide customer service. These companies and individuals may not share that information with any other third party or use that data for any other purpose.

Third-Party Products and Services: We may disclose such information to third parties to provide you with information about the opportunities, products or services of third parties. We use the data and data logs we have about you, including interests and preferences you have expressed, to determine whether you might be interested in the opportunities, products or services of a particular third party. This type of marketing may be in the form of email offers or mobile offers sent to by third parties or telemarketing calls from third parties.

Anonymous information: We may also share aggregated anonymous information about you and other persons using our website with third parties so that they can understand the kinds of visitors to our website and how those visitors use our website. This includes demographic information and behavioral information.

Legal Process: We disclose information if legally required to do so, or at our discretion pursuant to a request from a governmental entity, or if we believe in good faith that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect our rights or property or our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.

Acquisition or Merger: We may disclose and transfer information to a third party who acquires any or all of our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In addition, in the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of such information in a transaction approved by the court. You will be notified of the sale of all or a substantial portion of our business to a third party by email or through a prominent notice posted on the Site.

Again, in each of these situations, the recipients of your data may potentially be located in any country in the world.

Third-party Use of Your Information

Third parties also collect and use information about you on our Site in the following way:

Advertiser cookies and web beacons: Advertising agencies, advertising networks, and other companies who place advertisements on our website and on the internet generally may use their own cookies, web beacons, and other technology to collect information about you. We do not control the collection techniques of such third parties and have no responsibility for the use of such technology to gather information about you.

Hyperlinks: Our website may contain hypertext links to the websites of third parties. We are not responsible for the privacy practices or the content of such other websites. Such links are provided for your convenience and reference only. We do not operate or control any information, software, products or services available on such third-party websites. The inclusion of a link to a website does not imply any endorsement of the services or the third-party’s website, its contents, or its sponsoring organization.

Third Party Credit Card Processing: Members Only Gift provides you with the ability to pay for products and services using a credit card through a third party payment processing service provider. Please note that our service provider – not Members Only Gift – collects and processes your credit card information.

Use of Your Information for Email and Telemarketing

Email and Unsubscribe Policy: We may provide your PII or Non-PII to third parties for promotional offers by email. These offers may be for our services and products or those of third parties. We may maintain separate email lists for different purposes. If you wish to end your inclusion in a particular list, you need only to follow the instructions at the end of each email message to unsubscribe from the particular list. 

Content of Email Messages: You may receive certain commercial email messages sent by third parties for products and services which may be of interest to you. In such case, the sender’s name will appear in the “From:” and the email will have a method at the bottom of the email to unsubscribe from that Advertiser, including us when we are the advertiser. We are not responsible for third-party emails sent to you that do not contain advertising from us.

Opting Out of Email Marketing Material: If you no longer wish to receive our promotions, you may opt-out of receiving it by following the instructions included in each email you may receive from us.

Telemarketing: We or our Advertisers may use your PII to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones even if you have your telephone number or cell phone number listed on a state or federal do not call registry. By registering and using our website, you agree that such registration and request constitutes a purchase, an inquiry and/or an application for purposes of the Amended Telemarketing Sales Rule, 16 CFR §310 et seq. (the “ATSR”). Notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, you have authorized us to contact you via telemarketing in accordance with the ATSR. Moreover, by registering with, or requesting information from, a third-party advertiser at or through our website or other advertisement media made available by us (e.g., email marketing), you agree that such action shall constitute a purchase, an inquiry and/or an application with the respective third-party advertiser for purposes of the ATSR and you may be contacted via email, direct mail and/or telemarketing by such third-party advertiser in accordance with the ATSR.

Wireless Addresses: If the e-mail address you provide to us is a wireless e-mail address, you agree to receive messages at such address from us or third parties with whom we may share your wireless email address or wireless telephone number (unless and until you have elected not to receive such messages by following the instructions in the removal portion of this policy). You understand that your wireless carrier’s standard rates apply to these messages. You represent that you are the owner or authorized user of the wireless device on which messages will be received, and that you are authorized to approve the applicable charges.

Short Message Service: We may make available a service through which you can receive messages on your wireless device via short message service (“SMS Service”). Data obtained from you in connection with this SMS service may include your name, address, cell phone number, your provider’s name, and the date, time, and content of your messages. You represent that you are 18 years of age and the owner or authorized user of the wireless device on which messages will be received, and that you are authorized to approve the applicable charges. In addition to any fee of which you are notified your provider’s standard messaging rates apply to our confirmation and all subsequent SMS correspondence. All charges are billed by and payable to your mobile service provider. We will not be liable for any delays in the receipt of any SMS messages, as delivery is subject to effective transmission from your network operator. SMS message services are provided on an AS IS basis. We may also obtain the date, time and content of your messages in the course of your use of the SMS Service. We will use the information we obtain in connection with our SMS Service in accordance with this Privacy Policy. If fees are charged to your wireless account invoice, we may provide your carrier with your applicable information in connection therewith. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies.

You acknowledge and agree that the SMS Service is provided via wireless systems which use radios (and other means) to transmit communications over complex networks. We do not guarantee that your use of the SMS Service will be private or secure, and we are not liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the SMS Service. We may also access the content of your account and wireless account with your carrier for the purpose of identifying and resolving technical problems and service-related complaints.

Removal of Wireless or SMS addresses: You may remove your information from our database. If you remove your information from our database it will no longer be used by us for secondary purposes, disclosed to third parties, or used by us or third parties to send promotional correspondence to you.

Retention of Personally Identifiable Information

We keep your Personally Identifiable Information for no longer than necessary for the purposes for which the Personally Identifiable Information is processed. The length of time we retain Personally Identifiable Information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

International Privacy Practices

Members Gift Only is primarily operated and managed on servers located and operated within the United States. In order to provide our products and services to you, we may send and store your Personally Identifiable Information (also commonly referred to as personal data) outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your Personally Identifiable Information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personally Identifiable Information. We are committed to protecting the privacy and confidentiality of Personally Identifiable Information when it is transferred. If you reside or are located within the European Economic Area (EEA) and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA to the extent feasible under applicable law. We participate in and commit to adhering to the EU-U.S. Privacy Shield Framework when transferring data from the EEA to the United States.

Security

We endeavor to safeguard and protect your information. When you submit information at the website, such information is protected both online and offline. The servers in which we store Personal Information are kept in a secure physical environment. We have security measures in place to protect against the loss, misuse, and alteration of personal information under our control. Currently, we use Secure Socket Layer Software (“SSL”) to protect data and to secure any transactions. SSL encrypts information, including names and addresses as they are transmitted over the Internet. Please be advised that, although we take commercially reasonable technological precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, we cannot and do not warrant that your information will be absolutely secure. Any transmission of data at or through this site is at your own risk. However, access to your information is strictly limited, and not accessible to the public.

Changes to Privacy Statement

We reserve the right to make material changes to the substance of this Privacy Statement. We will post those changes through a prominent notice on the website so that you will always know what information we gather, how we might use that information, and to whom we will disclose it.

Information

• Working Hours: Monday – Friday (9am – 5pm US EST)