The information collection, use, and dissemination practices of The IVA Advisor Ltd:
This policy applies to The IVA Advisor Ltd’s collection, use, storage and disclosure of information by The IVA Advisor Ltd on its (a) websites, including all its divisions, subsidiaries and related companies (collectively, the “Websites”), (b) on various third party websites, and (c) to The IVA Advisor Ltd’s other information collection, including the purchase of customer lists from third parties.The IVA Advisor Ltd is not responsible for the information collection or privacy practices of third web sites or applications.
The IVA Advisor collects information from various individuals by way of the website. When an Individual Voluntarily Arrangement (IVA) completes an The IVA Advisor Ltd 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 third parties (collectively, a “Survey”). (As used herein, “online” means using the Internet, including the Websites, 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, The IVA Advisor Ltd or a third party (a “Third Party”) may ask an individual to provide various information to The IVA Advisor Ltd, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, 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”).The IVA Advisor Ltd may also collect information concerning an individual from another source and uses 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 The IVA Advisor Ltd or Third Party, but an individual may receive incentives from The IVA Advisor Ltd or a Third Party in exchange for providing Survey Information to The IVA Advisor Ltd.
The IVA Advisor Ltd collects information from individuals when an individual provides information to a third party and The IVA Advisor Ltd 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), 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, The IVA Advisor Ltd seeks assurances from the Seller that the Seller has a right to transfer the Third Party List Information to The IVA Advisor Ltd 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.
Other occasions when The IVA Advisor Ltd obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered byThe IVA Advisor Ltd or by a third party, (2) when an individual requests assistance through The IVA Advisor Ltd customer service department, and (3) when an individual voluntarily subscribes to a The IVA Advisor Ltd service or newsletter (together, “Other Information”).
The IVA Advisor Ltd currently uses cookie and pixel tag technology to associate certain Internet-related information about an individual with information about the individual in our database. Additionally, The IVA Advisor Ltd may use other new and evolving sources of information in the future (together, “Technology Information”).
A cookie is a small amount of data stored on the hard drive of the individual’s computer that allows The IVA Advisor Ltd to identify the individual with his or her corresponding data that resides in The IVA Advisor Ltd database. You may read more about cookies at http://cookiecentral.com. Individuals who use the Websites need to accept cookies in order to use all of the features and functionality of the Websites.
A pixel tag 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 The IVA Advisor Ltd to track certain web sites an individual visits online.
The use of technology on the Internet, including cookies and web beacons, is rapidly evolving, as is The IVA Advisor Ltd’s use of new and evolving technology. As a result, The IVA Advisor Ltd strongly encourages individuals to revisit this policy for any updates regarding its use of technology.
The IVA Advisor Ltd may receive information about individuals from third parties or from other sources of information outside of The IVA Advisor Ltd including information located in public databases (“Outside Information”).
As used herein, Individual Information means Survey Information, Third Party List Information, Other Information, Technology Information, and Outside Information, and any other informationThe IVA Advisor Ltd gathers or receives about individuals.
The IVA Advisor Ltd will never knowingly collect any personal information about children under the age of 13. If The IVA Advisor Ltd 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, The IVA Advisor Ltd has no such information to use or to disclose to third parties. The IVA Advisor Ltd has designed this policy in order to comply with the Children’s Online Privacy Protection Act (“COPPA”).
The IVA Advisor Ltd 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 The IVA Advisor Ltd. When the Credit Card Information is submitted toThe IVA Advisor Ltd, such information is encrypted and is protected with SSL encryption software. The IVA Advisor Ltd will use the Credit Card Information for purposes of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to third parties only as necessary to complete the purchase transaction.
THE COMPANY MAY USE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN COMPANY’S SOLE DISCRETION.
The following paragraphs in Section 2 describe how The IVA Advisor Ltd currently uses Individual Information, but The IVA Advisor Ltd may change or broaden its use at any time. As noted below, The IVA Advisor Ltd may update this policy from time to time. The IVA Advisor Ltd 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.
The IVA Advisor Ltd uses Individual Information to provide newsletters and promotional offers by email to individuals. The IVA Advisor Ltd 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 allThe IVA Advisor Ltd email lists, a person must send an email to [email protected]
In certain commercial email messages sent byThe IVA Advisor Ltd, an advertiser’s name will appear in the “From:” line but hitting the “Reply” button will cause a reply email to be sent to The IVA Advisor Ltd. The “Subject:” line of The IVA Advisor Ltd email messages will usually contain a line provided from the advertiser to The IVA Advisor Ltd.
The IVA Advisor Ltd only sends email to individuals who have agreed on the Websites to receive email from The IVA Advisor Ltd or to individuals who have agreed on third party websites to receive email from third parties such as The IVA Advisor Ltd. The IVA Advisor Ltd does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable toThe IVA Advisor Ltd email messages.
The IVA Advisor Ltd uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones.
The IVA Advisor Ltd 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.
The IVA Advisor Ltd stores the Individual Information in a database on The IVA Advisor Ltd computers and Third Party computers. Our computers and our trusted third party provider computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under The IVA Advisor Ltd’s control. Not withstanding such measures, The IVA Advisor Ltd cannot guarantee that its security measures will prevent The IVA Advisor Ltd or its third party providers’ computers from being illegally accessed, and the Individual Information on them stolen or altered.
The IVA Advisor Ltd DOES NOT SELL, RENT OR SHARE ATTENDEE PERSONAL INFORMATION TO THIRD PARTIES EXCEPT IN THE FOLLOWING SITUATIONS:
The IVA Advisor Ltd 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 The IVA Advisor Ltd web sites or when responding to offers provided by The IVA Advisor Ltd. [Example: The mailhouse that The IVA Advisor Ltd uses receives the mailing database to sendThe IVA Advisor Ltd’s Newsletter to its subscribers.]
The IVA Advisor Ltd may disclose Individual Information to respond to subpoenas, court orders, and other legal processes.
The IVA Advisor Ltd may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.
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 [email protected] The IVA Advisor Ltd 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.
Advertising agencies, merchants, and other companies (together, “Advertisers”) who place advertisements on the Websites and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. The IVA Advisor Ltd does not control Advertisers’ use of such technology andThe IVA Advisor Ltd has no responsibility for the use of such technology to gather information about individuals.
The Websites and email messages sometimes contain hypertext links to the web sites of third parties. The IVA Advisor Ltd 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. The IVA Advisor Ltd 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.
If you wish to discontinue receiving email messages fromThe IVA Advisor Ltd, you have several options:
To unsubscribe from a particular list, either (1) send an email to [email protected] or (2) follow the instructions in each newsletter or promotional email message sent by The IVA Advisor Ltd.
We reserve the right to add Individual Information to multiple lists maintained by The IVA Advisor Ltd. To globally unsubscribe from all of The IVA Advisor Ltd’s lists, send an email to [email protected]
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 [email protected]