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Creative Marketing, Inc. (“CMI”) Online Privacy
Policy (Last updated
February 15,
2007)
CMI has established this Privacy Policy to
explain how it protects and manages the personal
information that it collects from you (the
customer) online.
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1. |
Consent for Collection, Use and
Disclosure |
Your use of the CMI site and/or your
registration for CMI products and services
constitute your consent to the terms of this
Privacy Policy.
If you do not agree to the terms of this Privacy
Policy, please do not use the CMI site.
CMI may occasionally update this Privacy
Policy. When it does, CMI will also revise the
“last update” date at the top of this Privacy
Policy. In addition, CMI will seek a customer’s
prior consent, by email, for any new uses or
proposed disclosures of information collected
from the customer prior to the change.
CMI will notify customers by email of
changes to this policy that will affect
information collected from them in the future.
In certain circumstances, however, CMI will not
inform and obtain the consent of the customer,
such as in connection with an investigation of a
breach of an agreement, contravention of laws,
an emergency where the life, health or security
of an individual is threatened, the collection
of a debt or in compliance with the request of a
law enforcement agency or a court order.
A customer may withdraw his or her consent for
collection, use and disclosure at any time by
sending an email to
unsubscribe@cjofsa.com. Please note that,
if you do, CMI may suspend its provision of
products and services to you.
When
you unsubscribe, if you fall within the
guarantee period for any CMI product and you
request a refund, the guarantee will be
honored.
CMI collects, at the time of your registration
and your sign-on to its web site, certain
“personal information” (information that
personally identifies you) including but not
limited to your name, email address, home or
work address, telephone number, and information
about your computer hardware and software (e.g.,
IP address, operating system, browser type,
domain name, URL, access times, and referring
web site addresses).
CMI has implemented this Privacy Policy to
protect personal information received from its
customers, and to respond to any inquiries.
The Privacy Policy also provides that CMI will
use appropriate contractual means to establish a
comparable level of protection for personal
information which is sent for processing by
third parties on CMI’s behalf.
CMI has designated responsibility for your
personal information to its
Privacy Officer, who ensures compliance with
the principles in this Privacy Policy. Other
CMI individuals may be delegated to act on
behalf of the
Privacy Officer.
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3. |
Purposes for Collecting Personal
Information |
CMI collects and uses personal information for
the following Identified Purposes:
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(a) |
to understand customer needs regarding
CMI’s services; |
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(b)
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to develop and provide our web site and
our products and services for our
customers; |
(c) to fulfill your
requests for products, services or information;
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(d) |
to communicate with customers and site
visitors, when necessary, and to inform
customers of upgrades, as well as of
other products and services available
from CMI, its affiliates and third
parties; |
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(e) |
to allow customers to access
limited-entry areas of CMI’s site; |
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(f) |
to personalize some of our services and
products for you and to deliver targeted
advertisements and offers from CMI and
third parties; |
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(g) |
to bill accounts and maintain payment
records; |
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(h) |
to comply with any applicable law,
regulation, legal process or government
request; |
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(i) |
to respond to a legitimate claim, or to
address our reasonable belief, that you
are violating the rights of any third
party or any of the agreements or
policies that govern your use of the CMI
site or any CMI product or service; |
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(j) |
to protect the services, products or
rights of CMI, including but not limited
to the security or integrity of the CMI
site; and |
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(k) |
to
identify and resolve technical problems
concerning CMI’s site, products and
services. |
CMI 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, and we will limit their rights to use
and further disclose your personal information
as appropriate in the course of their work for
us.
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4. |
Limiting the Collection of Personal
Information |
CMI limits its collection of personal
information to only that information which is
necessary for the Identified Purposes. CMI does
not direct its site to, nor does it knowingly
collect any personal information from children
under the age of thirteen.
When you visit the CMI web site, a cookie may be
placed on your computer or the cookie may be
read if you have visited the CMI site
previously. CMI uses cookies to allow CMI to
determine which products and services you have
already purchased so that CMI does not provide
redundant information to you, and, if you are an
CMI affiliate, to track CMI 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 CMI web site, you may
not be able to view all the text on the screens,
or to experience a personalised visit, or to
subscribe to certain service and product
offerings on the CMI site.
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5. |
Disclosure, Processing and Retention
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CMI does not sell, rent or disclose your
personal information to anyone else, except:
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(a) |
to someone you have designated to act as
your agent, for one or more of the
Identified Purposes (listed in Section
2, above); |
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(b) |
to CMI’s employees, independent
contractors, subsidiaries, affiliates,
consultants, business associates,
service providers, suppliers and agents,
acting on CMI’s
behalf for any of the Identified
Purposes; |
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(c) |
as necessary if CMI has reason to
believe that disclosure is necessary to
identify, contact or bring legal action
against someone who may be causing
injury to or interference (either
intentionally or unintentionally) with
CMI’s rights or property, other users of
CMI’s web site, products or services, or
anyone else that could be harmed by such
activities; and |
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(d) |
to
respond to judicial process and provide
information to law enforcement agencies
or in connection with an investigation
on matters related to public safety, as
permitted by law, or otherwise as
required by law. |
In addition, as we continue to develop our
business, we or our affiliates may sell or buy
other businesses or entities, or we may merge
with another company. In such transactions,
personal information may be one of the
transferred business assets. Also, in the event
that CMI or substantially all of its assets are
acquired, your personal information may be one
of the transferred assets.
Your information may be stored and processed in
the United States, or in any other country in
which CMI 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 (that is, if
you request to be removed from our database),
CMI will keep your personal information in its
archives. Your information will then be used
only as necessary for tax reasons or to prove
CMI’s compliance
with any applicable law.
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6. |
Accuracy of Personal Information |
CMI 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 CMI about changes to their personal
information. You can do this by calling 415
721-0668 or sending an email to
our privacy department. CMI will use new or
updated personal information it receives from
customers to update its own records.
CMI will use reasonable efforts to protect
customers’ personal information.
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8. |
Access to Personal Information |
CMI will afford you a reasonable opportunity to
review the personal information in your file, if
you so request by calling
415-721-0668,
writing to:
Creative
Marketing, Inc.
405 El Camino Real #410
Menlo Park, CA, USA
94025-5240
... or upon request to the
Privacy Officer.
If CMI 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, by contacting CMI or the Privacy
Officer as described above. CMI will promptly
correct such personal information. |