As part of the FinalStepMarketing database,
Users are registered at an FinalStepMarketing
partner or affiliate website. Users
are asked to provide their name, email
address, postal address and self reported
interest category selections. Our Users
may voluntarily provide additional information,
including personal, geographic and demographic
information. In addition to the information
provided by members, FinalStepMarketing
may also collect information about consumers
from third party sources. These third
party sources may include, but is not
limited to, co-registrations as part
of a User's registration on another
website or acquisition of information
from a website who's privacy policy
allows for the data to be acquired.
FinalStepMarketing
uses this data to assemble broad demographic
information about its consumer databases
in general. The purpose of this data
collection is to ensure that FinalStepMarketing
Users receive only the most relevant,
targeted promotions, offers and information.
In an attempt to customize FinalStepMarketing's
service and provide consumers with
the information they may be most interested
in, FinalStepMarketing also conducts
internal research on our database's
demographics, interests, and behavior.
This internal research is based upon
information provided directly to FinalStepMarketing.
This internal research may be in the
form of surveys, sweepstakes, contests,
information obtained from consumer's
response to advertising and marketing
offers or information such as browser
type or IP address which can be collected
electronically. FinalStepMarketing
may also collect information from
third party sources. FinalStepMarketing
may combine or otherwise overlay some
or all of the foregoing information
to build profiles about FinalStepMarketing's
database, which may be individual
specific or in aggregate form. By
contributing to the FinalStepMarketing
Database data contributors consent
to FinalStepMarketing employing the
foregoing techniques in its continuing
efforts to better serve its Users
by providing them with the information
in which they may be most interested.
FinalStepMarketing
does not collect information regarding
an individual's medical records or
credit or financial information relating
to an individual's credit worthiness
and if such information is received,
FinalStepMarketing deletes or destroys
it upon receipt.
FinalStepMarketing
does not use information about its
members for any purposes unrelated
to the services offered by FinalStepMarketing.
Please be aware that this Privacy
Policy does not cover the conduct
or practices of third party sources.
However, FinalStepMarketing will treat
information that it receives from
third party sources according to the
terms of this Privacy Policy.
| Children's
Online Privacy |
| Protection |
| |
| FinalStepMarketing
services are not directed to nor
intended for anyone under the
age of 13. FinalStepMarketing
will not knowingly accept records
of consumers who are under the
age of 13 years nor will it knowingly
collect or maintain personally
identifiable information from
or about anyone under the age
of 13 years. FinalStepMarketing
relies on the truthfulness of
the owners of the consumer files
when accepting new data from 3rd
party sources. In the event that
FinalStepMarketing receives information
that establishes that a consumer
is under the age of 13 years,
FinalStepMarketing will delete
that record and any corresponding
information. |
| |
| Confidentiality |
| FinalStepMarketing
will not provide personally identifiable
information of an FinalStepMarketing
database record or knowingly reveal
any member's identity to marketers,
except as noted under "Limits
of Confidentiality." Personally
identifiable information means
the member's name, postal address,
email address or other information
from which the member's identity
may be reasonably ascertained. |
| |
| Limits
of Confidentiality |
| As
part of its day-to-day business
activities, FinalStepMarketing
must disclose certain aggregate
level information about the FinalStepMarketing
database to certain third parties;
principally, |
| |
| FinalStepMarketing
Clients |
| Marketers
who use the FinalStepMarketing
database and
To comply with the law or contractual
obligations.
Below is the information and
circumstances under which FinalStepMarketing
may be required to disclose
information to third parties.
FinalStepMarketing
may disclose aggregate level
information to clients about
the number of consumers who
have responded to any particular
campaign, the response rates
of the FinalStepMarketing file;
and statistics on the interest
categories selected by the FinalStepMarketing
consumers.
FinalStepMarketing
will disclose aggregate level
information about FinalStepMarketing
files to marketers as reasonably
necessary to explain the services
that FinalStepMarketing can
offer, to report on the advertising
campaigns that FinalStepMarketing
undertakes for any particular
marketer, and/or to implement
and explain campaign strategies.
FinalStepMarketing
may release personally identifiable
information or account information
as is necessary to comply with
the law; to enforce or apply
the terms and conditions of
marketing contracts or contracts
when supplying 3rd party information;
or to protect the rights, property,
or safety of FinalStepMarketing,
its subsidiaries, affiliates,
partners or others. This includes
exchanging information with
other companies and organizations
for fraud protection. |
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| Use
of Information |
FinalStepMarketing
uses its database information
to deliver the FinalStepMarketing
services.
FinalStepMarketing
services include promoting marketing
offers to consumers and providing
marketing information to 3rd parties.
A person's email address will
be used by FinalStepMarketing
to contact that consumer about
selected interests. Additionally,
FinalStepMarketing may deliver
marketing, promotional and information
messages through direct mail,
telemarketing or any other marketing
or advertising medium. FinalStepMarketing
also uses member information to
monitor, interpret, analyze and
report campaign results. |
| |
| Protection
of Consumer |
| Information |
| FinalStepMarketing
undertakes substantial efforts
to protect the confidentiality
of the identity, preferences and
other information it has collected
about individual members and will
never knowingly allow access to
this information to anyone outside
FinalStepMarketing other than
for the services FinalStepMarketing
offers. FinalStepMarketing has
made a substantial investment
in its server, database, backup
and firewall technologies for
the protection and security of
its information assets, including
the confidentiality of the information
assets. These technologies are
deployed as part of a sophisticated
security architecture and protocol.
Consumers should also do their
part in protecting their information.
Unfortunately, neither FinalStepMarketing,
nor data transmission over the
Internet, can be guaranteed
to be 100% secure. As a result,
while we strive to protect our
database information, FinalStepMarketing
cannot ensure or warrant the
security of our information.
Thus, any information a User
transmits to us is done so at
the User's own risk. Once we
receive User information, FinalStepMarketing
undertakes substantial efforts
to protect the confidentiality
of this information consistent
with this Policy. |
| |
| Choices
In Disclosing Information |
Because we want our Users to feel
completely comfortable using the
FinalStepMarketing services, Users
are provided with various opportunities
to control how the information
they provide to us will be used.
FinalStepMarketing requests information
from our customers' registration,
as well as via surveys, contests
or other promotions. A User's
participation in these activities
is completely voluntary and they
therefore have a choice whether
or not to disclose this information.
Nevertheless, certain basic information
is required in order to register
as a User. Information requested
may include contact information
and demographic information. Users
also may choose whether or not
to get e-mails from FinalStepMarketing
and whether or not to accept special
offers from our partners. If they
choose not to receive e-mail from
FinalStepMarketing, we will not
send them e-mail, although it
may take a short time to remove
their name from our database.
Please note, FinalStepMarketing
may send the user a confirmation
e-mail to the email address
that was supplied us acknowledging
the new account. This e-mail
will give the user the option
to delete the account if the
user does not desire the account.
Users should keep the confirmation
e-mail, as it will also contain
information that will help in
the case they run into problems
accessing our services.
Refund Policy:
Refunds are issued by our sales
department at its sole discretion.
Membership may be cancel for
the following month by noon
on the 30th to avoid fees.
Service Cancellation:
FinalStepMarketing
reserves the right to cancel
anyones membership for any reason
at any time and without notice.
In the event the membership
is canceled a full refund will
be granted.
Data Quality and Access:
FinalStepMarketing
uses a proprietary process to
verify the validity of the data
received. This process validates
several data points including
electronic and postal addresses.
FinalStepMarketing regularly
purges its database of incorrect
and outdated information. All
data is maintained until such
time the user unsubscribes or
the data has been determined
to be inaccurate or obsolete.
Should a User not want FinalStepMarketing
to continue to utilize their
data, they should follow the
unsubscribe procedures described
in this policy.
Privacy Audit and Third
Party Verification:
FinalStepMarketing employs
the services of an independent,
3rd party service to review
the privacy policies and procedures
to ensure that they are in accord
with the current published privacy
policy as posted and dated on
the FinalStepMarketing website.
Cookies: FinalStepMarketing
does not use cookies, although
we reserve the right to implement
them in the future. However,
certain third party partners
and clients of FinalStepMarketing
may use cookies in the process
of sending email advertising
to you. A cookie is a piece
of data stored on the User's
hard drive containing information
about the User. Cookies do not
store any personally identifiable
information. They can be very
beneficial to the Internet user
and allow for a more personal
and efficient Internet experience.
For instance, by accepting a
cookie from a site, the User
would not have to log in a password
more than once, thereby saving
time while on the site. Cookies
allow for personalization features
such as stock portfolio tracking
and targeted news stories, they
allow for shopping cart capabilities
and quick navigation across
multiple zones of e-commerce
sites, they remember user names
and passwords for future visits
and allow for the delivery of
advertisements targeted to a
user's interests and controlling
ad frequency. A User can reject
cookies and still use most websites.
The only drawback to this is
that in some instances the User
will be limited in some areas
of some websites. For example,
the User may not be able to
participate in selected Sweepstakes,
Contests or monthly Drawings.
Cookies also can enable us to
track and target the interests
of our Users to enhance their
experience on the FinalStepMarketing
Sites. You can set your browser
to not accept cookies. See your
browser's documentation for
more information on accepting
cookies.
Privacy Policy Effective
Date and Changes: The
foregoing policy is effective
as of August 15, 2003. FinalStepMarketing
reserves the right to change
this policy at any time. Please
check this page periodically
for changes. FinalStepMarketing
will take reasonable measures
to notify you if there is a
material change in our privacy
practices with respect to use
of the information that has
been provided to FinalStepMarketing.
FinalStepMarketing will conspicuously
post these changes in our Privacy
Policy. FinalStepMarketing also
will post a message on the home
page of its Web site that states
that the Privacy Policy has
been changed, and will provide
a link to the Privacy Policy.
These postings will occur on
the FinalStepMarketing Web site
at least 30 days prior to any
material change. |
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