TGL Group Privacy Policy

TGL GROUP, LLC, and each of its related web sites (“TGL Group”) Privacy Policy

Last updated March 8, 2013.

This Privacy Policy outlines important information regarding the use and disclosure of information collected via this Website. TGL Group provides this Privacy Policy to help users make an informed decision as to whether to use or continue using the Website.

PLEASE NOTE: OUR PRIVACY POLICY CHANGES FROM TIME TO TIME AND CHANGES ARE EFFECTIVE UPON POSTING. PLEASE CHECK BACK FREQUENTLY FOR UPDATES AS IT IS YOUR SOLE RESPONSIBILITY TO BE AWARE OF CHANGES. TGL GROUP DOES NOT PROVIDE NOTICES OF CHANGES IN ANY MANNER OTHER THAN BY POSTING THE CHANGES AT THIS WEB SITE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY PLEASE DO NOT PROVIDE ANY INFORMATION TO TGL GROUP OR USE ANY OF THE SERVICES OR PRODUCTS OFFERED OR PROVIDED ON ANY OF THE WEB SITES REFERRED IN THIS PRIVACY POLICY.

This Privacy Policy applies to TGL Group’s collection, use, storage and disclosure of information by TGL Group on its (a) websites, including all its divisions, subsidiaries and related companies (collectively, the “Website”), (b) on various third party websites, and (c) to TGL Group’s other information collection, including the purchase of customer lists from third parties. TGL Group is not responsible for the information collection or privacy practices of third web sites or applications. By reference, this Privacy Policy is incorporated into and is subject to the Website Terms of Use. Your use of the Website and any personal information you provide via the Website or through other official TGL Group contact remains subject to this Privacy Policy, as well as the Terms of Use and/or other stated policies.

1. Collection of Information.

1.1 Information Collection By Registration and Survey.

TGL Group collects information from individuals primarily by having the individuals provide that information directly to TGL Group through its registration and surveys and other opportunities to share information. Information collection may happen by various methods, including, but not limited to, an individual who transmits or receives a message through the TGL Group web site by any means including, but not limited to posts and text messages, when an individual supplies a photo, when an individual voluntarily completes a TGL Group survey, order form, or a registration page either online or offline, or by means of online or offline surveys, order forms, or registration pages operated by TGL Group or third parties (collectively, a “Survey”). (As used herein, “online” means using the Internet, including the Website, and related technologies, and “offline” means by methods other than online, including in person, in the postal mail, using telephones and cell phones, and other similar means.) In the Surveys, TGL Group or a third party (a “Third Party”) may ask an individual to provide various information to TGL Group, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), SMS messaging details (e.g. date, time and content of the SMS message), birth date, gender, photo, salary range, education and marital status, occupation, social security number, employment information, personal and online interests, and such other information as may be requested from time to time (together, “Survey Information”). TGL Group may also collect information concerning an individual from another source and use that information in combination with information provided from this Web Site. Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to TGL Group or Third Party, but an individual may receive incentives from TGL Group or a Third Party in exchange for providing Survey Information to TGL Group.

1.2 Third Party List Information.

TGL Group may collect information from individuals when an individual provides information to a Third Party and TGL Group subsequently purchases, licenses, or otherwise acquires the information from the Third Party (the “Seller”). Such purchased information may include, but is not limited to, an individual’s name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), SMS messaging details (e.g. date, time and content of the SMS message), birth date, gender, salary range, education and marital status, occupation, industry of employment, personal and online interests, and such other information as the individual may have provided to the Seller (together, “Third Party List Information”). When acquiring Third Party List Information, TGL Group seeks assurances from the Seller that the Seller has a right to transfer the Third Party List Information to TGL Group and that the Seller has a right to provide offers from advertisers to the individuals whose personal information is included on the Seller’s list.

1.3 Other Information.

Other occasions when TGL Group obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by TGL Group or by a Third Party, (2) when an individual requests assistance through TGL Group’s customer service department, and (3) when an individual voluntarily subscribes to a TGL Group service or newsletter (together, “Other Information”).

1.4 Cookies, Web Beacons, and Other Info Collected Using Technology.

TGL Group currently uses cookie and web beacon technology to associate certain Internet-related information about an individual with information about the individual in our database. Additionally, TGL Group may use other new and evolving sources of information in the future (together, “Technology Information”).

(a) Cookies. A cookie is a small amount of data stored on the hard drive of the individual’s computer that allows TGL Group to identify the individual with his or her corresponding data that resides in TGL Group’s database. You may read more about cookies at http://cookiecentral.com. Individuals who use the Website need to accept cookies in order to use all of the features and functionality of the Website.

(b) Web Beacons. A web beacon is programming code that can be used to display an image on a web page (by using an programming function — see http://truste.org for more information), but can also be used to transfer an individual’s unique user identification (often in the form of a cookie) to a database and associate the individual with previously acquired information about an individual in a database. This allows TGL Group to track certain web sites an individual visits online. Web beacons are used to determine products or services an individual may be interested in, and to track online behavioral habits for marketing purposes. For example, TGL Group might place, with the consent of a Third Party website, a web beacon on the Third Party’s website where baseball products are sold. When Joe, an individual listed in TGL Group’s database, visits the fishing website, TGL Group receives notice by means of the web beacon that Joe visited the baseball site, and TGL Group would then update Joe’s profile with the information that Joe is interested in baseball. TGL Group may thereafter present offers of baseball related products and services to Joe. In addition to using web beacons on web pages, TGL Group also uses web beacons in email messages sent to individuals listed in TGL Group’s database.

(c) New Technology. The use of technology on the Internet, including search engine indexing, cookies and web beacons, is rapidly evolving, as is TGL Group’s use of new and evolving technology. As a result, TGL Group strongly encourages individuals to revisit this policy for any updates regarding its use of technology.

1.5 Outside Information.

TGL Group may receive information about individuals from Third Parties or from other sources of information outside of TGL Group including information located in public databases (“Outside Information”).

1.6 Individual Information.

As used herein, Individual Information means Survey Information, Third Party List Information, Other Information, Technology Information, and Outside Information, and any other information TGL Group gathers or receives about individuals such as usage data, file transfer and viewing data

1.7 No Information Collected from Children.

TGL Group does not knowingly collect any personal information about children under the age of 13. If TGL Group obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from our database. Because it does not collect such information, TGL Group has no such information to use or to disclose to Third Parties. TGL Group has designed this policy in order to comply with the Children’s Online Privacy Protection Act (“COPPA”).

1.8 Log File Information.

When users log-in to access their account, our servers may automatically record and archive certain information that web-browsers send whenever visiting a Website. These server logs may include information vital to validating the user’s authorization to access the account. Information, such as a web request, Internet Protocol (the “IP”) address, browser type, browser language, referring pages, exit pages and visited URLs, platform type, click counts, pages viewed and in what order, time spent, the date and time of the request, and other important data is necessary to validate and authorize a user’s entry and activity on the Website.

1.9 Credit Card Information.

TGL Group may in certain cases collect credit card numbers and related information, such as the expiration date of the card (“Credit Card Information”) when an individual places an order from TGL Group. When the Credit Card Information is submitted to TGL Group, such information is encrypted and is protected with SSL encryption software. TGL Group will use the Credit Card Information for purposes of processing and completing user-initiated purchase transactions, and the Credit Card Information will be disclosed to Third Parties only as necessary to complete the purchase transaction.

2. Use of Individual Information.

2.1 Discretion to Use Information.

THE COMPANY MAY USE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN COMPANY’S SOLE DISCRETION.

The following paragraphs in Section 2 describe how TGL Group currently uses Individual Information, but TGL Group may change or broaden its use at any time. As noted, TGL Group may update this policy from time to time. TGL Group may use Individual Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses. By default, your full name will be used as your screen name.

2.2 Email.

TGL Group uses Individual Information to provide promotional offers by email to individuals. TGL Group may maintain separate email lists for different purposes. If email recipients wish to end their email subscription from a particular list, they need to follow the instructions at the end of each email message to unsubscribe from the particular list. To unsubscribe from all TGL Group’s email lists, a person must send an email to unsubscribe@thetglgroup.com.

(a) Content of Email Messages.

In certain commercial email messages sent by TGL Group, an advertiser’s name will appear in the “From:” line but hitting the “Reply” button will cause a reply email to be sent to TGL Group. The “Subject:” line of TGL Group email messages will usually contain a line provided from the advertiser to TGL Group.

(b) Solicited Email.

TGL Group only sends email to individuals who have agreed on the Website to receive email from TGL Group or to individuals who have agreed on Third Party websites to receive email from Third Parties such as TGL Group. TGL Group does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable to TGL Group’s email messages.

2.3 Targeted Advertising.

TGL Group uses Individual Information to target advertising to an individual and others. When an individual is using the Internet, TGL Group uses Technology Information (see also Section 2.5 below) to associate an individual with that person’s Individual Information, and TGL Group attempts to show advertising for products and services in which the person has expressed an interest in the Surveys, indicated an interest by means of Technology Information, through indexing of search engines, and otherwise. TGL Group may, at its discretion, target advertising by using email, internet, search engines, direct mail, telephones, cell phones, and other means of communication to provide promotional offers to individuals and others.

2.4 Direct Mail and Telemarketing.

TGL Group uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones.

2.5 Mobile Phone SMS Messaging.

In certain cases, when requested by an individual, a Third Party may use Individual Information to provide customized content and advertising via SMS messaging to an individual’s cell phone. TGL Group is not responsible for the privacy practices or the content of such Third Parties.

2.6 Use of Technology Information.

TGL Group uses Technology Information (1) to match a person’s Survey Information and Third Party List Information to other categories of Individual Information to make and improve profiles of individuals, (2) to track a person’s online browsing habits on the Internet, (3) to determine which areas of TGL Group’s web sites are most frequently visited. This information helps TGL Group to better understand the online habits of individuals so that TGL Group can target advertising and promotions to them.

2.7 Profiles of Individuals.

TGL Group uses Individual Information to make a profile of an individual. A profile can be created by combining Survey Information and Third Party List Information with other sources of Individual Information such as information obtained from public databases.

2.8 Storage of Individual Information.

TGL Group stores the Individual Information in a database on TGL Group computers. Our computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under TGL Group’s control. Notwithstanding such measures, TGL Group cannot guarantee that its security measures will prevent TGL Group computers from being illegally accessed, and the Individual Information on them stolen or altered.

3. Dissemination of Individual Information.

3.1 Sale or Transfer to Third Parties.

TGL Group MAY SELL OR TRANSFER INDIVIDUAL INFORMATION TO THIRD PARTIES FOR ANY LEGALLY PERMISSIBLE PURPOSE IN TGL GROUP’S SOLE DISCRETION.

3.2 Order Fulfillment.

TGL Group will transfer Individual Information to Third Parties when necessary to provide a product or service that a person orders from such Third Party while using TGL Group web sites or when responding to offers provided by TGL Group.

3.3 Legal Process.

TGL Group may disclose Individual Information to respond to subpoenas, court orders, and other legal processes. We may also share information when we have a good faith belief it is necessary to prevent fraud or other illegal activity. This may include sharing information with other companies, lawyers, courts or other government entities.

3.4 Summary Data.

TGL Group may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.

3.5 Access.

Individuals have access to their Individual Information collected to provide an opportunity for an individual to correct, amend, or delete such information. Access can be obtained by contacting legal@thetglgroup.com. TGL Group may also grant advertising clients and email services providers’ access to an individual’s email address to verify the origin of the Individual Information collected.

4. Privacy Practices of Third Parties.

4.1 Advertiser cookies and web beacons.

Advertising agencies, advertising networks, and other companies (together, “Advertisers”) who place advertisements on the Website and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. TGL Group does not control Advertisers’ use of such technology and TGL Group has no responsibility for the use of such technology to gather information about individuals.

4.2 Links.

The Website and email messages sometimes contain hypertext links to the web sites of Third Parties. TGL Group is not responsible for the privacy practices or the content of such other web sites. Linked web sites may contain links to web sites maintained by Third Parties. Such links are provided for your convenience and reference only. TGL Group does not operate or control in any respect any information, software, products or services available on such Third Party web sites. The inclusion of a link to a web site does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.

4.3 Affiliated Companies.

TGL Group may disclose, transfer, and sell Individual Information to entities affiliated with TGL Group in TGL Group’s discretion. California residents have the right to opt-out of allowing TGL Group to do any of the acts in the sentence above by sending an opt out request to unsubscribe@thetglgroup.com. Should TGL Group be subject to an acquisition, merger, sale or other change of control or business entity status, TGL Group reserves the right to transfer or assign the Information collected from the Website.

5. Individuals Outside of the United States.

Anyone using the Website outside of the United States acknowledges that personal information will be collected and stored by TGL Group in the United States. By using the Website, you consent to the transfer of information to and/or storage of information outside of your country and in the United States.

6. Unsubscribe Procedures.

6.1 If you wish to discontinue receiving email messages from TGL Group, you have several options:

Unsubscribe from one email list. To unsubscribe from a particular list, either (1) send an email to unsubscribe@thetglgroup.com or (2) follow the instructions in each promotional email message sent by TGL Group.

Unsubscribe from all of TGL Group’s email lists.

We reserve the right to add Individual Information to multiple lists maintained by TGL Group. To globally unsubscribe from all of TGL Group’s lists, send an email to unsubscribe@thetglgroup.com.

For more information about protecting your privacy, you may wish to visit: www.ftc.gov. If you have questions about this policy, please contact us at legal@thetglgroup.com.

California User Consumer Rights. In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, STE 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to dca@dca.ca.gov.

© 2013 TGL Group, LLC. All rights reserved.

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