THINKCOMMERCE GROUP, LLC

Privacy Policy

Effective Date: July 1, 2012

THIS PRIVACY POLICY, AS AMENDED FROM TIME TO TIME (POLICY), GOVERNS THE INFORMATION WE COLLECT ABOUT YOU WHEN YOU ACCESS THIS WEBSITE (THE WEBSITE). IF YOU DO NOT AGREE TO THIS POLICY, DO NOT VISIT OR USE OUR WEBSITE OR ANY OTHER THINKCOMMERCE GROUP, LLC PROPERTY. THIS POLICY IS PART OF AND INCORPORATED INTO THE WEBSITE TERMS OF USE (THE TERMS).

BY PROVIDING PERSONAL INFORMATION OR OTHER INFORMATION TO US OR BY USING OUR WEBSITE, YOU AGREE TO THIS POLICY AND THE PRACTICES DESCRIBED IN THE POLICY.

1. INFORMATION YOU GIVE US. We collect any information you enter on the WEBSITE or give us in any other way (such as through an email, survey, or letter). The information that we collect varies depending upon how you use our WEBSITE.

2. AUTOMATIC INFORMATION COLLECTION.

A. Cookies. Like many websites, we use cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your Web browser to enable our systems to recognize your browser. We use persistent, identifying cookies to remember your information and to link your activities to you. While you can take steps to warn off, block or disable cookies, if you do, the WEBSITE may not function and appear as we have designed it. Nonetheless, if you want to take these steps, you can do so by following the instructions associated with your browser. Our cookies collection information such as:

i. the domain name and host from which you access the Internet and the Internet address of the site from which you direct-linked to ours;

ii. the date and time you access the WEBSITE and pages you visit;

iii. your computer’s IP address and information about its operating system, platform and the Web browser type and version you use;

iv. demographic and other non-personally identifiable profile information about you; and

v. information to combat fraud or misuse.

B. Pixel Tags. If we email you, our emails may use a pixel tags to determine if your email software or site can display html-formatted email (this helps us optimize the size of our email messages and conserve bandwidth).

C. Collection of Information by Third Parties. Some of the advertisers and other businesses that advertise or place other content on our WEBSITE use cookies on our WEBSITE and may place a cookie on your computer. The content posted by these businesses will be reasonably identifiable as coming from a third party. In addition, we may use third party advertising companies to serve ads. These companies (1) use information obtained from your visits to this WEBSITE and other sites to serve ads to you and (2) place unique third party cookies on your browser. Also, we use web beacons provided by third party advertising companies to help optimize our advertising. Web beacons enable us to recognize your browser when a cookie has been placed on your computer. Some but not all third party advertising companies provide a mechanism to opt-out of their technology. For more information and an identification of advertisers that provide an opt-out mechanism, please click the following: http://www.networkadvertising.org/managing/opt_out.asp. The information collected by third party cookies is subject to the privacy policy of the third party, not this Policy.

D. Promotions, Sweepstakes, and Contests. From time to time, we may host a promotion, sweepstake, or contest on the WEBSITE. You may be asked to provide personal information or permit the transfer to a third party of your personal information in connection with such promotion, sweepstake or contest. It will be disclosed at the point of collection or transfer who is collection or transferring the information and whose privacy statement applies, and it will be your choice whether or not you wish to permit such transfer to our collection of personal information by a third party.

3. OUR USE AND RETENTION OF YOUR INFORMATION.

A. Use of Personal Information. We use personal information that you submit to us for such purposes as responding to your requests; monitoring and providing the WEBSITE; enforcing our rights and the rights of third parties, and investigating and ensuring compliance with the Terms.

B. Use of Other Information. We use other information about our users for purposes such as measuring the number of visitors to sections of our WEBSITE, making the WEBSITE more useful to visitors and delivering targeted advertising and non-advertising content. We use IP addresses to analyze trends, administer the WEBSITE, track a users movement, and gather broad demographic information for aggregate, non-personally identifiable use.

C.  Retention of Information. We retain information for as long as required, allowed or we believe it useful, but do not undertake retention obligations. We may dispose of information in our discretion without notice, subject to applicable law that specifically requires the handling or retention of information.

4. OUR SHARING OF INFORMATION. ThinkCommerce Group, LLC shares information with third parties, but only as described in this Section 4.

A. Advertisers and Others. We share non-personally identifiable information with advertisers, site providers, and other persons with whom we conduct business. Conversely, these advertisers, site providers, and other persons may share with us information about you that they have independently developed or acquired.

B. WEBSITE Third Parties. We contract with affiliated and non-affiliated third parties to provide sites to us or to you on our behalf. Examples include providing marketing assistance and analyzing data. These third parties have access to personal information needed to perform their functions.

C. Business Transfer. As we develop our business, we might sell or buy businesses or their assets, or engage in acquisitions, mergers, restructurings, changes of control, or similar transactions. In such transactions, customer information generally is one of the transferred business assets. Also, in the unlikely event of a bankruptcy, customer information may be transferred to a bankruptcy trustee or debtor in possession and then to a subsequent purchaser.

D. Affiliates. We may share user information with our corporate affiliates. Corporate affiliates are those entities that we control, are controlled by us, or are under common control with us and any joint venture in which any of the controlled entities may participate from time to time. Conversely, we may obtain information about you from our corporate affiliates or from your visits to other web sites that we or our corporate affiliates control.

E. We use third-party advertising companies to serve ads when you visit the Website. These companies may use information (not including your name, address, email address or telephone number) about your visits to this and other websites in order to provide advertisements on the Website and other sites about goods and services that may be of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please click here:

http://www.networkadvertising.org/managing/opt_out.asp

F. Compliance and Safety. We may release user information when we believe release is appropriate to:

i.  comply with applicable law, and to respond to legal process, including subpoenas, search warrants and court orders, and to respond to or otherwise address written complaints of copyright infringement;

ii. make disclosures under programs intended to prevent potential crimes or investigate persons;

iii. enforce or apply agreements, including the Terms; or

iv. protect the rights, property, or safety of the WEBSITE, our users, or others, including exchanging information with other companies for fraud protection and credit risk reduction.

5. INFORMATION SECURITY

A. Your Obligations. You must protect against unauthorized access to your personal information and to your computer. YOU MUST DO WHAT YOU REASONABLY CAN TO ENSURE THE SECURITY OF YOUR PERSONAL INFORMATION.

B. Our Security Measures. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. HOWEVER, WE DO NOT GUARANTEE SECURITY. Neither people nor security systems are foolproof, including encryption systems.

6.  LINKS. The WEBSITE may contain links to other sites. We are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our WEBSITE and to read the privacy statements of every web site that collects your personally identifiable information. This Policy applies only to information collected by the WEBSITE.

7. CHOICE. If you have sent us your email or other contact information, we reserve the right to send you customary business communications.

8. CONDITIONS OF USE, NOTICES, AND REVISIONS.

A.  Privacy Concerns. Your use of the WEBSITE and any dispute over privacy is subject to the Terms. If you have any concern about privacy at ThinkCommerce Group, LLC or any of its websites within the WEBSITE, please send us a thorough description to [email protected], and we will try to resolve it. If you think we are in default of the Terms, you may contact us at Our Legal Notices Address in Section 9 below.

B. Notice Required by Law. In those jurisdictions that permit email notice, if we are required to disclose or provide notice of invasion of certain security systems, we will do so by email to the most current email address provided by you to us.

C. Identity Theft. If you believe that you are a victim of identity theft entitled by law to request information from us, write us at our Legal Notice address (see Section 9) and we will let you know what additional information you must provide to us. After we have received that information, we will supply without charge the information legally required to be disclosed that we then have, subject to applicable law and reserving all of our rights and defenses.

9. CONTACT INFORMATION AND INFORMATION ABOUT ENFORCEMENT OF OUR POLICY. For customer site matters (including questions relating to this Policy), you may email us at [email protected] To send us a legal notice, mail it by certified mail (return receipt requested) to: Legal Department, THINKCOMMERCE Group, LLC, 2O9OO NE 3OTH AVENUE, SUITE 822, AVENTURA, FLORIDA 33180.

Copyright© 2012 THINKCOMMERCE GROUP, LLC