You have a right
to know how information about you is used and protected. This policy
explains how LL Strategies, LLC (hereinafter called “Company”
or “We”) collects, uses and disseminates information about individuals.
Collection
of Information
Non
Personal Information. As part of the standard operation
of our Web sites and the Web pages that you access via hyperlinks
in our online marketing campaigns ("Other Web Pages"),
we may collect certain non-personal information from visitors including,
but not limited to, their browser type (e.g., Netscape or Internet
Explorer), operating system (e.g., Windows or Macintosh), IP address,
and the domain name from which they accessed the site (e.g., lycos.com).
In addition, we may collect information about visitors' browsing
behavior, such as the date and time they visit our Web sites or
Other Web Pages, the areas or pages of our Web sites and Other Web
Pages that they visit, the amount of time spent viewing our Web
sites and Other Web Pages, the number of times the visitor returns
to our Web sites and Other Web Pages, and other click-stream data.
We may use cookies (small text files that are stored on the hard
drives of visitors computers when they access our Web sites) to
collect this information, which may be combined with visitors' personal
information and shared with our marketing partners, advertisers,
and other third parties. We may also use cookies for other purposes,
including, but not limited to, retrieving information previously
provided by recipients of our marketing campaigns and visitors to
our Web sites and remembering the passwords of visitors' to our
Web Sites and Other Web pages.
Survey, Order Form, Registration Pages.
We collect information from individuals when an individual voluntarily
completes an order form, a Company survey, or a registration page
online or by means of online order forms or registration pages operated
by third parties (collectively, a "Survey"). (As used
herein, "online" means using the Internet and related
technologies.) In the Surveys, the Company or the third party (the
"Third Party") may ask an individual to provide various
information, which may include his or her name, email address, street
address, zip code, telephone numbers, cell phone numbers and carriers,
birth date, age, gender, salary range, education, marital status,
occupation, employment information, personal and online interests,
and such other information as may be requested from time to time
(together, "Survey Information"). Completing a Survey
is completely voluntary, and individuals are under no obligation
to provide Survey Information to the Company or Third Party, but
an individual may receive incentives from the Company or a Third
Party in exchange for providing Survey Information, including but
not limited to software programs, screensavers, sweepstakes entries
etc.
Co-Registration Partners. The
Company collects information from subscribers when an individual
provides information to a third party, and the individual subsequently
is given the opportunity to subscribe to The Company's email marketing
lists. Such subscriptions are provided at no cost to the individual.
When acquiring subscribers through the "co-registration"
process, the Company seeks assurances from the Third Party that
the Third Party has provided a conspicuous option for the individual
to choose not to become a subscriber of Company's lists and that
a hyperlink to this privacy policy is available for each individual
to read before deciding to become a subscriber of Company's lists.
Other Information. The
Company may request personal information on other occasions, including
(1) when an individual makes a claim for a prize or seeks to redeem
an incentive offered by the Company or by a third party; (2) when
an individual requests assistance through Company’s customer service
department; and (3) when an individual voluntarily subscribes to
a Company service or newsletter (together, "Other Information").
Outside Information. The
Company may receive, store and disseminate information about individuals
from third parties ("Outside Information").
No Information Collected from Children. The
Company does not intentionally collect personal information from
children who are younger than age 13. The Company therefore has
no such information to disclose to third parties or to use.
Use
of Individual Information.
Individual Information. As
used in this Policy, Individual Information means Survey Information,
Third Party List Information, Other Information, and Outside Information,
and any other information the Company gathers or receives about
individuals.
Discretion to Use Information. We
may use Individual Information for any legally permissible purpose
in the Company’s sole discretion. The following paragraphs describe
how the Company currently uses Individual Information, but we may
change or broaden its use at any time, and we may update this Policy
from time to time. The Company 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.
Targeted Advertising. Based
on the Individual Information, we sometimes attempt to customize
and target advertising to an individual, and attempt to show advertising
for products and services in which the person has expressed an interest
in the Surveys and otherwise. We may, at our discretion, target
advertising by using email, direct mail, telephones, cell phones,
and other means of communication to provide promotional offers.
Email. The Company
uses Individual Information to provide promotional offers by email
to individuals. The Company may maintain separate email lists for
different purposes and may send promotional offers from more than
one list. If email recipients wish to be removed 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 Company email lists, a person may send an email to abuse@liquidleads.net.
Direct Mail and Telemarketing.
We may use Individual Information to advertise, directly or indirectly
to individuals using direct mail marketing or telemarketing using
telephones and cell phones.
Profiles of Individuals.
The Company may gather Individual Information to make a profile
of a person. A profile is created by associating the various sources
of Individual Information.
Storage of Individual Information and
Security. The Company has appropriate security
measures in place in our physical facilities to protect against
the loss, misuse or alteration of information that we have collected
from you. We store the Individual Information on Company computers.
However, we cannot guarantee that our security measures will prevent
the Company computers from being accessed without authorization
and the Individual Information stored on them stolen, deleted or
changed, and the Company assumes no responsibility for such actions.
Dissemination
of Individual Information.
Sale or Transfer to Third Parties. The Company may sell or transfer Individual Information
to third parties for any purpose in the Company’s discretion.
Order Fulfillment.
We 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 Company web sites or when responding to offers
provided by Company.
Legal Process.
The Company may disclose Individual Information to respond to subpoenas,
court orders, and other legal process.
Summary Data.
We may sell or transfer non-individualized information, such as
summary or aggregated anonymous information about all persons or
sub-groups of persons, for any purpose in the Company’s discretion.
Privacy
Practices of Third Parties.
Advertiser cookies.
Advertising agencies, advertising networks, and other companies
(together, "Advertisers") who place advertisements on
Company web sites may use their own cookies on your computer and
collect information from such cookies. The Company does not control
the Advertisers’ use of their own cookies and the Company has no
responsibility for such cookies and the use of information gathered
from them.
Links. The Company’s
web sites and email messages sometimes contain hypertext links to
the web sites of third parties. The Company is not responsible for
the privacy practices or the content of such other web sites.
Affiliated Companies.
We may disclose, transfer and sell Individual Information to entities
affiliated with Company in Company’s discretion.
Deleting Individual Information.
Individuals have the ability to request deletion of their Individual
Information by sending an email to abuse@liquidleads.net in which they
clearly request to have their Individual Information deleted from
the Company database.
Information Exchanges. Individuals
may opt-out of information exchanges with Third Parties by sending
an email to abuse@liquidleads.net in which they clearly request to have
their Individual Information deleted from the Company’s Information
Exchange database.
Standard
Operating Procedure (SOP).
Data
Protection and Process.
Our organization
has a procedure in place for determining what procedures and processes
need to be documented. The SOP has been written by individuals who
are knowledgeable with the activity of the organization from a technical
and business perspective. These individuals are subject matter experts
who created the data platform, perform the work and use the process.
We
protect all data records within a highly secure redundant infrastructure
with architectural layers such as proven Bug Free UNIX OS, MySQL,
ACID, SNORT between multiple locations. We have contracted experienced
vendors to test our intrusion detection system from both internal
and external locations with no Issues.
Other
SOP Documentation Contents.
- Monthly
Checklists and Documentation Control
- DNC Removal
Process
- Data Hygiene
Process and Models
- Review
of Potential Intrusion Attempts to our External & Internal
IP Addresses
- Review
of Replication and MySQL Clustering Model
- Quality
Assurance (Stress Testing, Manual Testing, Power Fail Over,
Release / Change Control)
- Redundancy
between Multiple Data Centers
- Review
and Approval of Infrastructure Changes / Releases
- Proper
User Entitlements for Employees
- Continuity
of Business
Miscellaneous.
Privacy Policy Updates. This Privacy
Policy was last updated on May 15, 2007. We reserve the right to
revise this policy from time to time without prior notice, so please
review this Privacy Policy regularly.
More
Information. If you have questions about this Policy, please contact
us at info@liquidleads.net
