MONETATE, INC. WEBSITE PRIVACY POLICY
Last Updated June 22, 2012

We at Monetate, Inc. (“Monetate,” “we,” “us,” or “our”) have created this privacy policy (this “Website Privacy Policy”) because we know that you care about how information you provide to us is used and shared.  This Website Privacy Policy relates to the information collection and use practices of Monetate in connection with our website located at http://monetate.com (the “Website”).  Please note that our privacy practices governing our proprietary marketing optimization technology is governed by our Platform Privacy Policy.

Acceptance of Terms

By visiting our Website, you are agreeing to the terms of this Website Privacy Policy and the accompanying Terms and Conditions.

The Information We Collect

In the course of operating the Website, Monetate will collect the following types of information.

 1.      Personal Information

When you request information about our products and services or sign up to receive information from us, you may be required to provide us with personal information about yourself, such as your name, company, title, address, e-mail address, and phone number.  We do not collect any personal information from you when you access and use the Website unless you provide such information voluntarily.  All information we collect and/or receive under this section is collectively called “Personal Information.”

2.       Other Information.

In addition to the Personal Information, we may collect additional information (collectively, the “Other Information”).  Such Other Information may include:

       a.      From Your Activity.  Information that we or our technology providers may automatically collect when you visit, access, and/or use the Website, such as your IP addresses, Internet service provider, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website you visit, number of links you click while on the Website, search terms, and operating system.

       b.      From Cookies and JavaScript Tags.  Information that we collect using “cookie” technology and JavaScript tags.  Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit.  We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Website.  If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer.  Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies.  However, if you decide not to accept cookies from us, the Website may not function properly.  We use JavaScript tags to trigger a sequence of events that includes viewing a first-party cookie (or setting that cookie if it does not already exist) and to help us tailor and optimize our Website and provide you relevant Monetate advertisements outside of our Website.

How We Use and Share the Information  

We use the Personal Information and the Other Information (collectively, the “Information”) to administer our rewards and promotional programs; to improve our Website and services to you; to solicit your feedback; and to inform you about our products and services.

We may also use and/or share Information as described below.

 ·    We may employ other companies and individuals to perform functions on our behalf.  Examples may include providing technical assistance, customer service, and marketing assistance.  These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.

·    In an ongoing effort to better understand visitors to our Website and our products and services, we may analyze the Other Information in aggregate form in order to operate, maintain, manage, and improve the Website and/or our products and services.  This aggregate information does not identify you personally.  We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.

  • In order to provide our services and administer our rewards and promotional programs, we may share your Personal Information and Other Information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.

  • If you have opted out of our ability to use your e-mail address, as set forth on the Website, we may share your decision to opt out with third parties to effectuate that decision.

  • We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

  • As we develop our businesses, we might sell or buy businesses or assets.  In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

  • To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of Monetate or others.

Accessing and Modifying Information and Communication Preferences

Visitors who have provided Personal Information to us may access, remove, review, and/or make changes to the same by following the instructions found on the Website.  In addition, you may manage your receipt of marketing and communications by clicking on the “unsubscribe” link located on the bottom of any Monetate marketing e-mail or by following the instructions found on the Website.  We will use commercially reasonable efforts to process such requests in a timely manner.  You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.

How We Protect the Information

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.  Please understand, however, that no security system is impenetrable.  We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet.  In particular, e-mail sent to or from the Website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Important Notices to Non-U.S. Residents/Safe Harbor Certification

Monetate complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland.  Monetate has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view Monetate’s certification, please visit http://www.export.gov/safeharbor/.

However, it is important to note that the Website and its servers are operated in the United States.  If you are located outside of the United States, please be aware that any Personal Information you provide to us will be transferred to the United States.  By using the Website and by providing us Personal Information when using our Website, you consent to this transfer and our use of the information and data provided by you in accordance with this Website Privacy Policy.

In order to comply with the Safe Harbor framework, Monetate commits to the resolution of complaints about your privacy and our collection or use of your Personal Information.  We have also committed to resolve any complaints by European Union citizens relating to this Website Privacy Policy, which cannot be resolved directly with our company, through the Council of Better Business Bureaus, Inc.’s Safe Harbor Privacy Dispute Resolution Procedures.

If you have any questions regarding this Website Privacy Policy, please contact us as described in the “How to Contact Us” section below.  We will investigate your question, respond to your inquiry, and attempt to resolve any concerns regarding your privacy question.  If you do not receive acknowledgement of your complaint or if your complaint is not satisfactorily addressed by Monetate, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

External Websites

The Website may contain links to third-party websites.  Monetate has no control over the privacy practices or the content of these websites.  As such, we are not responsible for the content or the privacy policies of those third-party websites.  You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Changes to This Website Privacy Policy

This Website Privacy Policy is effective as of the date stated at the top of this Website Privacy Policy.  We may change this Website Privacy Policy from time to time.  By accessing and/or using the Website after we make any such changes to this Website Privacy Policy, you are deemed to have accepted such changes.  Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Website Privacy Policy in effect at the time we collect the Information.  Please refer back to this Website Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Website Privacy Policy, please contact Monetate via e-mail at privacy@monetate.com with “PRIVACY POLICY” in the subject line or at the contact information on our Contact Us page.