NOTICE: UPDATED JANUARY 16, 2017
The Information We Collect and Use
We may collect and use certain information and data when you visit the Website. When you visit the Website, we may collect certain data that does not tell us specifically who you are. This is “Non-Personally Identifiable Information.” It includes things like your Internet Protocol (IP) address, browser type, and the last domain you visited before coming to the Website or the domain you go to when you leave. It also includes various statistical data regarding your use of the Website such as which pages you visit, how long you stay on them, and what you click. We collect some Non-Personally Identifiable Information through “cookies.” Cookies and web tags also let us learn how people use our Website, which in turn helps us improve our Website for you to use. We reserve the right to use your IP address to help diagnose problems with our server, and to administer the Website. Your IP address may be used to gather broad and specific demographic information as well as for validation purposes. We may use “cookies” to recognize you as you use or return to our Website. This is done so that we can provide a continuous and more personalized experience for you. A cookie is a small text file that a website or e-mail may save to your browser and store on your hard drive. Cookies are text files that we place in your computer’s browser to store your preferences. To find out more about cookies, please visit www.cookiecentral.com. Even in the case where a user rejects a cookie, he or she may still use the Website. We may also use web beacons. Web beacons allow us to know if a certain page was visited, an email was opened, or if ad banners on our Website and other sites were effective. Web beacons utilize certain tracking software to capture your domain name address (the address of your Internet service provider) for purposes of tracking statistics at our Website. The capture of your domain name is a common practice among websites for measuring the number of hits, pages visited, and length of user session. We use this information to measure the effectiveness of the applicable Website offerings in order to service you better.
We also may collect information that can be used to identify you (“Personally Identifiable Information”). This might include your name, email address, mailing address, telephone number or credit card number. We only collect Personally Identifiable Information when you specifically provide it to us. This might happen, for example, when you register for a user account, log on with your user name and password, order a publication or service, participate in a promotional offer or submit content to the Website. We may use Personally Identifiable Information to offer you products and services from Marquis, to enhance your experience at the Website, and, if applicable, to enhance your experience as a subscriber to Marquis’ products and services.
Dissemination of Your Information
We use information about how you interact with our Website in order to personalize it for you, to keep both you safe from harm, and to improve the Website and our services. We use your information to provide requested services and to support core business functions such as: (i) fulfilling your requests for services and communicating with you about those requests; (ii) confirming registration at the Website and servicing your account; (iii) providing customer service and alerting you to the services we provide; (iv) helping us improve and customize our service offerings, Website, and advertising; (v) sending you information about our services; (vi) protecting the security or integrity of our Website and our business; and (vii) analyzing and underwriting your requests for our services. To accomplish these purposes, we may combine personal and non-personal information we collect online with offline information, including information from third parties. We may also share Personally Identifiable Information with third parties, who may contact you to offer products and services. At any time, you can contact Marquis by sending an email to firstname.lastname@example.org (or call 1-844-394-6946, option 2) to request that we not share your Personally Identifiable Information with third parties.
We may employ other people or firms (“Outside Contractors”) to provide services and products, such as credit card processing, fraud screening, order fulfillment and shipment, and website hosting or development. Outside Contractors may sometimes have access to Personally Identifiable Information to the extent necessary to do their work for us, however, we require Outside Contractors to protect the privacy of your Personally Identifiable Information. We also require them not to use or disclose your Personally Identifiable Information for any purpose other than providing us with products or services for which we contracted.
CAN-SPAM Act of 2003 Compliance
Moreover, you hereby consent to disclosure of any record or communication to any third party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with other third parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time. We also reserve the right to release current or past user or borrower and personally identifiable information in situations where we believe in good faith that the law requires it, or that the sharing is necessary to protect the safety, property, or other rights of Marquis, our borrowers, our employees, contractors, or any other person. We may also share Personally Identifiable Information with third parties, who may contact you to offer products and services. At any time, you can contact Marquis by sending an email to email@example.com (or call 1-844-394-6946, option 2) to request that we not share your Personally Identifiable Information with third parties.
Amended Telemarketing Sales Rule
We may share aggregate and statistical data that does not identify you personally. We may do this for research and marketing purposes, for instance to describe our services to prospective partners or advertisers, and for other lawful purposes. You agree that by submitting your e-mail address at the Website you may receive email marketing from us and our third party advertisers. In addition, you agree that such act constitutes a purchase, an inquiry and/or an application for purposes of the Amended Telemarketing Sales Rule, 16 CFR §310 et seq. (the “ATSR”). With respect to the ATSR, and notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, we or our designee retain the right and you hereby expressly authorize us and/or our designee to contact you via telemarketing in accordance with the terms of the ATSR. Moreover, by registering with, or requesting information from us or another third party advertiser at or through the Website, such action shall constitute a purchase, an inquiry and/or an application with the respective affiliated third party advertiser for purposes of their compliance with the ATSR and you may be contacted via e-mail, instant messaging, text messaging, direct mail and/or telemarketing by such third party advertiser in accordance with the terms of the ATSR.
How We Use and Share Financial Information
As set forth hereinabove, we do not collect social security information. However, to the extent applicable, for purposes of compliance with the Gramm-Leach-Bliley Act, 15 U.S.C. 6802 (the “GLB Act”), the California Financial Information Privacy Act (“CFIPA”) and the Vermont Consumer Protection Act, 8 V.S.A. 10202 (“VCPA”), we will not share nonpublic personally identifiable financial information with our affiliates or non-affiliates without providing borrowers with an annual Privacy Notice explaining that we will be sharing this nonpublic personally identifiable information with our affiliates or non-affiliates and, for purposes of the GLB Act, providing borrowers with the opportunity to opt-out from such disclosures.
Notwithstanding the foregoing, we reserve the right to share personally identifiable financial information in accordance with the terms of the GLB Act, for California State residents only, the CFIPA and, for Vermont State residents only, the VCPA. The nonpublic personal information of California State residents shall not be shared by us with third parties unless: (i) we have obtained a fully executed consent acknowledgement from the applicable California resident; or (ii) the California resident already has a relationship with a nonaffiliated financial institution pursuant to, and as defined under, the CFIPA. If you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third party for marketing purposes, please email us at firstname.lastname@example.org. However, where California residents opt-out from permitting their personal information to be shared with third party marketing partners, such individuals may still receive selected offers directly from us, in accordance with the law. Notwithstanding the foregoing and despite the fact that we do not collect Social Security information, we nevertheless hereby agree not to share the Social Security Number of California State residents with third parties without first obtaining their consent to do so pursuant to the terms and conditions set forth in the CFIPA. California Civil Code Section 1798.83 permits visitors to our Website, who are California residents, to request certain information regarding its disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an e-mail or write us at the address below.
Again, to the extent applicable, for purposes of compliance with the VCPA, we will not share nonpublic personal financial information (as defined in the VCPA) with third parties without providing Vermont State residents with an annual notice explaining that we will be sharing this nonpublic personal information with non-affiliated third parties. Notwithstanding the foregoing, the nonpublic personal financial information of Vermont State residents shall not be shared by us with nonaffiliated third-parties unless: (i) we have obtained authorization from the applicable Vermont resident; provided, however, that such authorization must be in written form, or where the applicable Vermont resident agrees, electronic form; (ii) the disclosure is made to third-parties for the sole purpose of processing transactions or other related processes on our behalf; and/or (iii) the disclosure is made to third-parties that market our own services to our borrowers.
Third Party Links
Securing your information is a company priority. When our registration/application process requests that you provide us with sensitive information and when we store and transmit such sensitive information, that information is encrypted and is protected with SSL encryption software. While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user information off-line. However, no method of security is 100% effective and we cannot be responsible for the actions of those who may gain unauthorized access to your personal information. Marquis makes no warranties, express, implied or otherwise as to the ultimate effectiveness of these reasonable and appropriate safeguards. All collected information is stored in a technically and physically secure environment. Access to this information is strictly limited, and not accessible to the public. Only employees who need the information to perform a specific job (for example an account representative) are granted access to personal information. Our employees are dedicated to ensuring the security and privacy of all user information. Employees not adhering to our firm policies are subject to disciplinary action. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures. Your account information is protected by the password you use to access your online account. Please keep this password confidential. If your browser is capable of SSL (and most are), your account information will be protected during transport across the Internet. We comply with industry standard requirements. These standards require safeguards for handling and securing borrower information. These include using secure networks; encryption or other protection of cardholder data; physical and technical access controls; monitors and tests of security systems; and information security policies.
We are committed to protecting the online privacy of minors. In order to protect children’s personal information, and to meet the standards of the Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect personally identifiable information from children under the age of 18 on the Website.
Electronic Signatures and Electronic Records
You may contact Marquis regarding our privacy practices at the following address:
Marquis Who’s Who Ventures
Information Privacy Manager
100 Connell Drive, Suite 2300
Berkeley Heights, NJ 07922