As an
Infomediary, the purpose of
AGLOCO.com is to use technology to
enable businesses to interact with
consumers in highly personalized
ways, without forfeiting the privacy
of the user. Therefore privacy is at
the core of AGLOCO™.
We
do not give, sell, rent, share, or
trade any identifiable personal
information regarding our members to
any third party, with the exception
of third-party contractors and
service providers who work with
AGLOCO to provide the Viewbar and
other services, and who are strictly
prohibited from later use of the
information that they may have
access to. We will disclose personal
information to local, state, or
federal law enforcement officials
when we believe in good faith that
the law requires it.
This Privacy Policy provides both
members of the AGLOCO™ service and
visitors to the AGLOCO.com website
with information about what
information we collect, to what uses
that information is put, and to whom
that information may be given. If
you become a member of AGLOCO™, the
membership agreement encompasses the
provisions that are explained by
this document. If you are only a
visitor to our website, this Privacy
Policy is our promise to you about
how information about your visit
will be handled.
This document is a "work in
progress," insofar as certain
portions may be updated from time to
time as the programs and services we
offer to our members change. However
the principles upon which this
document is based will not change,
nor will our fundamental commitment
to protecting the privacy of our
members. We also welcome your
continuing input into this policy.
Please give us your feedback at
privacy@AGLOCO.com.
AGLOCO™'s Privacy Policy and our
information practices are based upon
the eight principles of Fair
Information Practices first issued
by the Organization for Economic
Cooperation and Development in
1980. These guidelines continue to
be the touchstone of all modern
privacy laws and regulations, and
the concepts set forth in them
remain at the heart of privacy
protection principles that guide all
responsible businesses today. More
information about the OECD's
“Guidelines on the Protection of
Privacy and Transborder Flows of
Personal Data” may be found by
clicking here.
Collection Limitation
Principle
AGLOCO.com adheres to
the principle that the collection of
personal information should be
limited to that obtained through
fair and lawful means and only with
the knowledge and consent of the
data subject.
How we deliver:
AGLOCO™ makes very clear our
policies regarding our data
gathering processes and seeks
consent before obtaining personally
identifiable data from the
individual.
Information We
Collect from Visitors
For
visitors to our website, we gather
only aggregate, non-personally
identifying data about your visit to
our website. If you visit AGLOCO™'s
website (whether you are using
AGLOCO™'s Viewbar™ software or not),
AGLOCO™'s web servers log a number
of basic pieces of information,
including the following:
-
The URL (address) of the page(s)
requested;
-
The time and date of the request(s)
and the duration of your visit;
-
The "User Agent" (the make and
model of the web browser being
used, including the name and
version of the operating system
upon which that web browser is
running);
-
The "Referrer" (the address of the
site whose link you followed to
get to our website);
-
The IP address and domain name of
the computer to which we are
sending pages for display by your
web browser.
For
information about why we gather and
how we use this information, see the
Purpose Specification and Use
Limitation sections of this Privacy
Policy.
Information We
Collect from Members
In
our online registration form for new
members of the service, we require
you to provide us with your full
name, full mailing address, email
address and a password. In addition,
we require your gender, birth date,
and a password question with its
corresponding answer, so that we may
identify you if you ever lose your
password.
Certain information such as your
name, address, email address, and
birth date constitute "Personal
Data" because that information can
be used to directly or indirectly
identify you. This information is
collected and used according to the
terms of this Privacy Policy. In the
future, we may offer additional
services that will have their own
usage agreements and/or privacy
policies. At the time those services
are offered, you will be given an
opportunity to review and accept
those documents.
For
information about why we gather and
how we use this information, see the
Purpose Specification and Use
Limitation sections of this Privacy
Policy.
Other
Data We May Request from Members
We
may ask you for personal information
at other times, including, but not
limited to, when you enter a
sweepstakes, contest or promotion
sponsored by AGLOCO.com and/or when
you report a problem with any of our
services. Any data collected at
those times will be used in
accordance with this policy, unless
otherwise explicitly stated at the
time of collection. Many of those
sweepstakes, contests, or promotions
will have terms of service
agreements associated with them and
those agreements may differ from
provisions of this policy.
Therefore, it is important that you
read and understand those agreements
as the nature of those offerings may
require different data privacy
provisions that may supercede this
Privacy Policy.
Message Boards and
Messaging Services
If
you utilize a message board or other
messaging service operated by AGLOCO™,
your use of those services is
governed by the Terms of Service
agreement associated with those
services. If you choose to publish
your e-mail address or publish other
personal data, you do so at your own
risk. If you have concerns regarding
privacy issues related to the
message boards or messaging
services, or wish to have a message
removed from the message boards for
privacy-related reasons, you should
contact
support@AGLOCO.com for
assistance.
About
Cookies
If
you decide to join the AGLOCO™
community, at the time you submit
your registration, and any time you
access your account information,
AGLOCO™'s servers place a "session
cookie." A cookie is a little piece
of text stored by your browser on
your computer, at the request of our
server. Session cookies last until
the conclusion of your visit to our
website and allows our servers to
correctly display pages based upon
your account information.
The
process we use to serve
advertisements and to enable certain
personalized experiences, including
the storage of certain user
preferences on the AGLOCO™ website
may involve the use of persistent
cookies. These cookies remain stored
over a longer period of time and
help our ad serving vendors to make
sure that you do not see the same
ads repeatedly. Cookies received in
this way are monitored by our
ad-serving company, and we do not
have access to this information.
However, we have contractual
arrangements that restrict our
partners, including the ad-serving
company, from using these cookies
for anything other than fulfilling
their service to AGLOCO.com. We may
also use cookies to deliver content
specific to your interests, and to
save your password so you don't have
to re-enter it each time you connect
to the Internet.
You
are always free to decline our
cookies, if your browser permits, or
to ask your browser to indicate when
a cookie is being sent. You can also
delete cookie files from your
computer at your discretion. Note
that if you decline our cookies or
ask for notification each time a
cookie is being sent, your Viewbar™
may not function properly and we may
have difficulty rendering service to
you. If you would like more
information about cookies, you may
wish to visit
http://en.wikipedia.org/wiki/HTTP_cookie.
Sites Linked Via the
website
Information about you may be
collected by advertisers, merchants
or other third parties when you
click through advertisements on the
AGLOCO™ website. We have no control
over the collection or handling of
such data and urge you to review the
privacy policies of those sites
before providing them with personal
data. AGLOCO.com is not responsible
for the privacy practices or the
content of such websites.
A
Special Note About Children
AGLOCO.com wants to help parents
protect the privacy of children and
takes steps to obtain parental
permission before children may join
AGLOCO™. AGLOCO.com does not
consider our web Site or services to
be directed at children but some
children may have signed up as
Members. We have designed our
parental consent process to comply
with the requirements of the
Children's Online Privacy Protection
Act (COPPA), which is further
described at the Federal Trade
Commission's website at
http://www.ftc.gov/bcp/conline/edcams/coppa/index.html.
Under the provisions of that law, we
require that children under 13
obtain parental permission before
joining AGLOCO.com. To remove your
child from AGLOCO.com membership,
please contact us at
support@AGLOCO.com. For more
information about protecting
children online, see "Kidz Privacy"
at:
http://www.ftc.gov/bcp/conline/edcams/kidzprivacy/index.html.
Members are always free to quit the
service and close their account by
contacting Member Support at the
email address
support@AGLOCO.com.
Purpose Specification Principle
AGLOCO.com adheres to the principle
that the purposes for which personal
data are collected should be
specified at or prior to the time of
collection, and that any subsequent
use should be limited to the
fulfillment of purposes not
inconsistent with those purposes
previously specified.
How we deliver:
We clearly specify the purposes for
which we collect personal
information from our members and
restrict our usage of that data to
purposes reasonably related to those
described. Prior to any new data
usage that may be beyond the scope
of previously disclosed purposes, we
will disclose such new uses and
obtain the data subject's
permission.
Visitors to Our website
We
use information gathered from
visitors to our website in an
aggregate form to get a better
understanding of where our visitors
come from and to help us better
design and organize our website.
Although an IP address doesn't
necessarily identify a visitor
personally, it can sometimes suggest
a connection to a particular
individual or their computer,
therefore we do not disclose the
information contained in those logs
to third parties unless compelled to
by law. Information contained in our
web server logs may be used in the
course of fraud investigations.
Members of Our Service
We
collect and process information
about you in order to provide the
services described in the Membership
Agreement. We will process your
information to administer your
membership, determine your
eligibility for certain services,
provide services to you, and enable
you to take advantage of other
member benefits. In addition to the
purposes specified under the
Collection Limitation portion of
this agreement, we will use the
personal information provided by
members to verify your identity, to
protect against fraud, and to send
you updates about your account,
including new products and services
that are specific to your membership
and participation in AGLOCO™, as
well as company news updates, and
notices regarding our policies and
practices.
Use
Limitation Principle
AGLOCO.com adheres to the principle
that personal data should not be
disclosed, made available, or
otherwise used for purposes other
than those specified in accordance
with the Purpose Specification
Principle, except with the consent
of the data subject or as required
by law.
How we deliver:
AGLOCO™ treats each members'
personal information as confidential
and does not disclose it or use it
except as stated in Membership
Agreement and as further explained
in this Privacy Policy.
Specifically, AGLOCO™ will not
disclose personally identifiable
information about you to others
unless:
-
you give AGLOCO™ explicit and
specific prior permission, or
-
the disclosure is required by law
or by warrant authorized by a
court of competent jurisdiction.
We
do not give, sell, rent, share, or
trade any identifiable personal
information regarding our members
with any third party, with the
exception of third party contractors
or service providers who work with
AGLOCO™ to provide this service. All
parties with whom we contract for
such services are strictly
prohibited by the terms of those
contracts from any other use of the
information. For more information
regarding the AGLOCO™ Group of
international subsidiaries, please
see the Openness section of this
policy.
It
is AGLOCO™'s policy to comply with
reasonable warrants issued by courts
to law enforcement officials.
However, our policy is to oppose
attempts to seek release of member
information by private parties
through the use of civil subpoenas.
When served with a civil subpoena,
our policy is to notify the
specified member of the request
prior to disclosure of any personal
data, and to require the requesting
party to seek court review of the
appropriateness and sufficiency of
the subpoena before we will disclose
any of the requested member
information.
AGLOCO™ may share non-personal
information in aggregate or summary
form with its customers, partners,
or other third parties.
Individual Participation Principle
AGLOCO.com adheres to the principle
that our members have a right to
know what type of information we
maintain relating to him/her, to
have communicated to him/her the
data relating to him/her in a
reasonable time at reasonable cost,
and to challenge the accuracy of
that data.
How we deliver:
AGLOCO™ provides its members with
access to their account information
via a secure web interface. We allow
our members to correct and update
that information in a timely manner,
following processes designed to
insure the integrity of the
information.
Personal Data recorded about
members, as described in the
Collection Limitation Principle
section, will be provided to members
upon their request, within a
reasonable period of time, according
to policies designed to assure the
identity of the requesting party
before this personal data is
released. If the member discovers
errors in that data, we will correct
them upon request. You may update,
correct, access, or delete your
Personal Data in accordance with the
following procedures:
Accessing and Updating Your Personal
Data Online and Offline
You
may update and correct your Personal
Data by sending an email to
privacy@AGLOCO.com.
You
may request that a paper copy of
your Personal Data be sent to you by
contacting our support organization
using the form at (insert URL) or by
sending e-mail to
support@AGLOCO.com.
Subject to applicable law, the
release of this Personal Data may
require the pre-payment of
reasonable costs related to
providing such information, due to
the volume of data that is often
involved and the costs of preparing
and shipping such quantities of
data.
You
may request to be sent a copy of all
of your Personal Data by contacting
our support organization using the
form at
http://www.AGLOCO.com/supportform.asp.
A representative of Member Services
will contact you with further
information about the costs
associated with retrieving and
shipping that data to you.
Objecting to Processing of Your
Personal Data
You
may object at any time to our
processing of your Personal Data by
contacting our support organization
using the membership cancellation
process at (Insert URL). Upon
cancellation of your account, any
member benefits accrued in your
account will be deemed "unearned"
and will be forfeited.
Retention of your Personal Data
You may quit the
service at any time and all Personal
Data relating to you will be taken
out of active use for our
advertising targeting processes. Our
data retention policy requires that
data pertaining to former members
will be retained for a reasonable
period of time necessary to fulfill
our service obligations to members
and to comply with applicable laws,
and will then be deleted according
to a schedule established by AGLOCO™.
Members are always free to quit the
service and close their account by
sending an email to
support@AGLOCO.com.
Data Quality Principle
AGLOCO.com adheres to the principle
that any personal data collected
should be relevant to the purpose
for which they are used and, to the
extent necessary for those purposes,
should be kept accurate and
up-to-date.
How we deliver:
As an
Infomediary, the information we
collect from our members is the
basis upon which we obtain value on
behalf of our members. Therefore,
the nature of our business requires
that we continuously collect data
about our members. The relevance,
accuracy, and currency of that
information are all critical to
serving the interests of our
members, therefore the processes
underlying this principle are a core
component of our business, and
adherence to this Privacy Policy is
essential to the value proposition
we present to our members.
Openness Principle
AGLOCO.com adheres to the principle
that we should provide our members
with information regarding changes
in our practices and policies with
respect to their personal data,
providing them with reasonable
opportunities to know what type of
personal information we retain, the
purposes of their use, and other
information regarding how we adhere
to the principles stated in this
document.
How we deliver:
AGLOCO™ has a general policy of
openness about its practices and
policies regarding personal data of
consumers. AGLOCO™ states in detail
what personal data it collects and
why it collects it. AGLOCO™ also
maintains a policy of disclosing any
changes to its practices and
policies. Any changes to our
policies or procedures that
materially reduce the privacy
protections encompassed therein,
including any changes in corporate
ownership that impact upon the
promises made in this policy, will
be disclosed with sufficient advance
notice to allow those individuals
affected to exercise informed
choices regarding their personal
information.
AGLOCO.com is a Hong Kong
corporation. All consumer data
collected by AGLOCO™ is managed by
Infomediary Services Corporation, a
management company that AGLOCO™ has
engaged to perform all management
functions for AGLOCO™’s activities
worldwide. The data physically
resides at numerous data storage
facilities around the globe
according to practices and policies
detailed under the Security
Safeguards section of this
document. We may also transfer or
share your personal information as
well as part of a transfer of your
membership agreement to a successor
organization. By becoming a Member
you give your consent to this
transfer of your personal data. All
information collected as a result of
your membership in AGLOCO™ will be
treated in accordance with this
Privacy Policy. Should the Privacy
Policy change in any significant
way, you will be notified in advance
and given an opportunity to
terminate your membership and delete
your data.
For
our European members, please note
that AGLOCO™ stores its records in
several locations around the world.
To provide these services, AGLOCO™
may transfer your personal data
internationally to other vendors or
service providers located in other
countries. Some of the countries may
have laws that protect personal
data, some may not. Regardless of
applicable law, AGLOCO™ will protect
your information according to the
terms of this Privacy Policy, no
matter where we process or store
your data.
Security Safeguards Principle
AGLOCO.com adheres to the principle
that personal data should be
protected by reasonable security
safeguards against the loss,
unauthorized access, use,
modification, or disclosure of data.
How we deliver:
AGLOCO™ has mandated that its
management company employ a variety
of security measures to protect the
loss, misuse, and alteration of the
information under our control.
Whenever possible, we make use of
current industry standard procedures
and processes to safeguard the
confidentiality of your identifiable
personal information, such as
firewalls, encryption, token
authentication, application proxies,
monitoring technology, and adaptive
analysis of network traffic to track
abuse of our network and its data.
In some cases we may employ
practices that exceed current
industry standards, and in other
cases we may diverge therefrom when
we reasonably believe circumstances
dictate doing so. Unfortunately,
when you submit information about
yourself to AGLOCO.com over the
Internet, the information may travel
over many systems that are not under
the control of AGLOCO.com. The
Internet is not 100% secure and it
is possible that others may be able
to intercept the information that
you are sending. While we endeavor
to provide the greatest possible
protection to your data, we cannot
guarantee absolute security in all
circumstances.
Accountability Principle
AGLOCO.com adheres to
the principle that an individual
should be empowered to and
accountable for assuring the
corporation complies with the
measures that give effect to the
principles stated herein.
How we deliver: AGLOCO™ has
mandated that its management company
engage a Chief Privacy
Officer who is responsible for
ensuring that the principles stated
in this policy are adhered to
throughout all of the activities in
which AGLOCO™ engages on behalf of
its membership.
If
you have any questions about this
Privacy Policy, please contact
privacy@AGLOCO.com. |