Privacy Policy



1st Marketing Traffic, Inc (“MTI”) Privacy Policy
(Last updated July 14, 2007)

MTI has established this Privacy Policy consisting of ten principles, to protect and manage your (the customer’s) personal information. MTI will occasionally update this Privacy Policy. When it does, MTI will also revise the “last update” date at the top of this Privacy Policy. For changes to this policy, MTI will notify you by placing a notice on its web site home page.

1. Accountability

MTI collects, at time of your registration and your sign-on to its web site, certain “personal information” (information that personally identifies you) such as your name, email address, home or work address, telephone number, and your computer hardware and software (e.g. IP address, operating system, browser type, domain name, URL, access times, and referring web site addresses).

MTI has implemented this Privacy Policy to protect personal information received from its customers, and to respond to any inquiries and complaints. The Privacy Policy also provides that MTI will use appropriate contractual means to establish a comparable level of protection for personal information which is sent for processing by third parties on MTI’s behalf .

MTI has designated responsibility for your personal information to its Privacy Officer, who ensures compliance with the principles in this Privacy Policy. Other MTI individuals may be delegated to act on behalf of the Privacy Officer.

2. Purposes for Collecting Personal Information

MTI collects and uses personal information for the following Identified Purposes:

(a) to understand customer needs regarding MTI’s services;

(b) to develop and provide products and services for its customers;

(c) to communicate with customers, and to inform customers of upgrades, products and services available from MTI and its affiliates;

(d) to personalize some of our services and products for you;

(e) to bill accounts and maintain payment records;

(f) to satisfy any applicable law, regulation, legal process or government request;

(g) to respond to a legitimate claim that you are violating the rights of any third party;

(h) to protect the services, products or rights of MTI; and

(I) to identify and resolve technical problems concerning MTI’s products and services.

MTI also uses personal information in an aggregate form (i.e. not individually attributable to you) for its business analysis, operational, marketing and other promotional purposes.

If we hire other companies to provide some products or services on our behalf, then we will only provide those companies the personal information they need for the Identified Purposes.

3. Consent for Collection, Use or Disclosure

Registration for MTI products and services by a customer will constitute the customer’s consent for MTI to collect, use and disclose personal information under this Privacy Policy. MTI will normally seek a customer’s consent for any new uses and disclosures of the customer’s personal information, either at the same time it collects the personal information or after it has been collected but before it is used or disclosed for a new purpose. In certain circumstances however, MTI will not be required to inform and obtain the consent of the customer, such as investigation of a breach of an agreement, contravention of laws, an emergency where the life, health or security of an individual is threatened, or the collection of a debt.

A customer may withdraw such consent for collection, use and disclosure at any time, on prior written notice, provided that MTI may on such withdrawal suspend or terminate its products and services.

4. Limiting the Collection of Personal Information

MTI limits its collection of personal information to only that information which is necessary for the Identified Purposes. MTI does not knowingly collect personal information from children.

When you visit the MTI web site, a cookie may be placed on your computer or the cookie may be read if you have visited the MTI site previously. MTI uses cookies to allow MTI to determine which products and services you have already purchased so that MTI does not provide redundant information to you, and to track MTI sales made to customers referred by you so that you can receive compensation under our affiliate program. If you choose to not have your browser accept cookies from the MTI web site, you may not be able to view all the text on the screens, or to experience a personalized visit, or to subscribe to certain service and product offerings on the MTI site.

5. Disclosure, Processing and Retention

MTI does not sell, rent or disclose your personal information to anyone else except, when the Identified Purposes require MTI to disclose the personal information to:

(a) an agent of the customer;

(b) agents of MTI acting on its behalf for the Identified Purposes;

(c) a public authority, to avoid or minimize danger to life or property; and

(d) a third party to which disclosure is required by any law, regulation, legal process or government request.

Your information may be stored and processed in the United States, or in any other country in which MTI or its affiliates, subsidiaries or agents maintain facilities. By using this web site, you consent to any such transfer of information outside of your country.

After your account becomes inactive, MTI will keep your personal information only for those purposes which are established by law, and for archival record purposes.

6. Accuracy of Personal Information

MTI will use reasonable efforts to keep customer personal information accurate for the Identified Purposes, and for minimizing the possibility of making inappropriate customer decisions based on such information. Customers are responsible for informing MTI about changes to their personal information. MTI will update personal information when necessary to keep it accurate or else provide customers the facility to make such updates.

7. Security Safeguards

MTI will use reasonable efforts to protect personal information against loss, unauthorized access, disclosure, misuse or modification, through security safeguards that depend on the level of sensitivity of the information. Methods of protection include organizational measures (contract provisions, security clearance, limiting access to need-to-know MTI personnel), technological measures (passwords, encryption), and physical measures (locked file storage, security card access). MTI will control personal information disclosed to authorized third parties by entering into agreements which contain confidentiality provisions and restrictions on use and which limit the amount of information disclosed to only that which is needed for the Identified Purposes.

8. Openness of Policy

This Privacy Policy, and all updates to the Privacy Policy made from time to time, are published and made available to MTI’s customers on its web site It is the customer’s obligation to periodically check the MTI web site for Privacy Policy updates.

9. Access to Personal Information

MTI will afford you a reasonable opportunity to review the personal information in your file, in understandable format, either by direct access or upon request to the Privacy Officer made by you after providing sufficient identification.

If MTI is not able to provide access to some aspect of a customer’s personal information, it will provide reasons for denying access such as; that by doing so would likely reveal personal information about a third party, or that it is confidential commercial information or attorney–client privileged communications, or that the information relates to a breach of an agreement or a contravention of law, or that its disclosure could reasonably be expected to threaten the life or security of another individual.

Customers have the right to request that inaccurate or incomplete information be amended as appropriate, and MTI will promptly correct such personal information or provide the means for you to do so directly.

10. Challenging Compliance

MTI wants to ensure that its Privacy Policy meets its customers’ needs. If you feel that the Privacy Policy needs improvement, or believe that MTI is not following its Privacy Policy, please contact the Privacy Officer .

MTI will investigate your suggestions and complaints concerning the MTI Privacy Policy. If a complaint is found to be justified, MTI will take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. Each customer will be informed of the outcome of the investigation regarding the customer’s complaint.

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