LFO Promotions - Privacy Policy

September 2010

LFO Promotions is committed to protecting your privacy. This Privacy Policy will provide information to you regarding how we collect and use your personal information, and about choices you have concerning our use of such information. Please read this Privacy Policy carefully. From time to time, we may revise this Privacy Policy to address new issues or changes to our practices. These changes will be posted here so that you will always know our privacy policies.

If you have any questions or concerns about our privacy practices, please send us an email at privacy@lfo-promotions.com or mail us at the following address:

LFO Promotions
1555 Sherman Avenue
Box 310
Evanston, Illinois 60201

Scope of Privacy Policy

This Privacy Policy applies to LFO Promotions' method of collection and use of information we gather. Please note the privacy practices of our service providers are not covered by this Privacy Policy. In addition, once you leave our Web Site via a link or otherwise, this Privacy Policy does not apply and LFO Promotions cannot and is not responsible for how data and information obtained from you on other Web sites is used by the operators of such Web sites.

Security

We believe that protecting the security of your Personal Information is very important. Therefore, we have put strong security measures in place to attempt to protect your Personal Information. Access to Personal Information is limited to LFO Promotions employees or other authorized individuals, and a limited number of our fulfillment partners. Identities are verified by internal network access rules and application username/password pairs. Data is physically stored through a third party data system at private facilities on servers leased exclusively by LFO Promotions. Data fields that identify individuals are separated from non-sensitive data fields. Data identifying Personal Information is encrypted through use of industry standard AES encryption methods and practices. Data decryption keys are kept physically separate from encryption keys and encrypted data. Records are marked with tamper-proof authentication digests.

LFO Promotions requires internal users to use LFO Promotions' standardized methods of data transfer, encryption and storage. We encourage external parties, service providers and vendors to use our standardized methods of data transfer, encryption and storage, or an equivalent method.

We also monitor hardware and software logs for operational compliance with security policies. LFO Promotions quarantines data that arrives on a channel not approved in the policy until its source and disposition can be determined in accordance with the security policy. Consequences of non-compliance range from delay in reporting response times to refusal to accept or verify data, in accordance with penalties specified by contract.

Barriers erected to prevent potential breaches of secure information include a sophisticated security system, internal audits, internal policies/procedures and a daily backup of all information. The Director of Technology is responsible for all aspects of secure information within LFO Promotions.

No service provider/vendor/external party should be able to decrypt the encrypted data of any other service provider/vendor/external party should data be mis-delivered.

Enforcement

LFO Promotions monitors data center metrics on approximately a weekly basis. Network vulnerability testing and standard NOC monitoring are provided by the data center administration staff, with options for performing third-party security audits on demand.

LFO Promotions performs full recovery tests prior to live deployment of a new application or server system. LFO Promotions performs recovery tests of backup media on a monthly to quarterly schedule to assure that existing backup regimes have created working recovery sets.

LFO Promotions actively monitors current and upcoming regulatory and compliance issues through outside legal resources.

Information Collected by LFO Promotions

Personal information ("Personal Information") may include the following:

We may request Personal Information from you in connection with your use of, or participation in, the Web Site, including applications, registrations, suggestions or requests for additional information, or in connection with other services or resources provided on or through the Web Site. Personal Information is collected on servers owned and maintained by a third party and leased to LFO Promotions exclusively. A confidentiality agreement exists between LFO Promotions and such third party.

If, and only if, you indicated during the application or registration process you'd like to receive advertising and promotional materials related to LFO Promotions, we may also use your Personal Information to send information to fulfill those advertising and promotional efforts. On occasion, for example, we or our media partners and service providers, may send you email to introduce products or services that might be of interest to you. We may also use your Personal Information to keep in touch with you when necessary, for example, to send to you confirmation, rebuttal, shipment or reminder email messages. If you identify yourself to us by sending us an email with questions or comments, we may use your Personal Information to respond to your questions or comments. (We may also file your comments for future reference.) Our emails will at all times include instructions on how to unsubscribe.

We may also share Personal Information with our service providers and vendors. We will attempt to require that each of these service providers and vendors not use or disclose your Personal Information for any purpose other than providing you or us with products and services. However, we cannot guarantee their compliance with these restrictions. LFO Promotions does not sell Personal Information to third parties.

We reserve the right to provide or use your Personal Information in the following circumstances. We will release specific information about you or your account to comply with any valid legal process such as a search warrant, subpoena, statute or court order. We will also release specific information in special cases, such as if there is an attempted breach of the security of the Web Site, or a physical threat to you or others.

Passively Collected Information and the Use of Cookie Technology

To help make our site more responsive to the needs of our visitors, LFO Promotions may passively collect certain information without your prior consent. Such information (collected in standard Web server logs) may include your IP address, browser type, and Web access times. Such passively collected information is used in standard Web traffic analysis, in conjunction with demographic/aggregate analysis of collected user records.

We may also collect information through the use of "cookies" which are small computer files that are transferred to a computer's hard drive and which permit us to know about site visits. We may use cookies to improve your experience on the Web Site by making it easier for you to navigate through the Web Site or to make a Web Site feature work better. Information collected from a "cookie" might include information regarding your browser, type of computer, operating system, Internet service provider and other similar information. Cookie technology may also gather information about the areas you visit on our Web Site and about the links you may select from within our Web Site to other areas of the Internet. We can build a better Web Site if we know which pages our users are visiting and how often.

We do not extract Personal Information during this process. Currently, only session cookies are used to maintain tracking of a user through an application. Session cookies expire at the end of a Web page visit. Session cookies contain only a numeric session identifier. We use such information in the aggregate to understand which services and resources our visitors prefer and how those services and resources are used.

We may share aggregate demographic/statistical information with our media partners, service providers and other third parties. In addition, LFO Promotions may allow some of our advertisers to display ads which solicit or contain technology to collect information about users.

Most browsers are set to accept cookies, however, you can set your browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of the Web Site may not be accessible or function properly.

Privacy of Children

We are committed to protecting the privacy of children. Neither the LFO Promotions Web Site nor LFO Promotions' activities are intended for or designed to attract children under the age of 13. We do not collect Personal Information from any person we actually know is a child under the age of 13.

Links to Other Web Sites

Our Web Site contains links to other Web sites operated by third parties that may be of interest to you. However, we do not and cannot control the information and content or links contained on these sites. We do not and cannot control the way in which these Web sites collect and/or use your Personal Information. Therefore, LFO Promotions disclaims any liability for any third party's use of your Personal Information obtained through using the third party Web site.

Access to Personal Information

Please note that certain information transmitted to LFO Promotions may not be later modified or retrieved by LFO Promotions. However, at your request, we will use reasonable efforts to provide you with access to your Personal Information (if we still retain it) and to revise, update or replace Personal Information that you inform us is in error. Please send us an email at privacy@lfo-promotions.com to request access to any Personal Information that we have may have retained about you in our user database, to request a change in your Personal Information and/or to request us to inform our service providers of changes in your Personal Information. We cannot guarantee the actions of our service providers after we inform them of any changes.

Certain Personal Information may be stored indefinitely so that LFO Promotions can access data for any customer service issue as well as report on aggregate data in the future.

Opt-Out

LFO Promotions provides you with the opportunity to opt out of receiving communications from LFO Promotions at the point where information is requested of you. You also have the following options to prevent future communications from LFO Promotions: