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 www.1stMarketingTraffic.com/privacy.htm.
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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