Mutualink – www. mutualink.net (the “Site”)
Revised July 2007
Purpose. Our purpose in establishing this Policy is to balance our legitimate business interests in collecting and using Information with Our Users’ reasonable expectations of privacy. Our intent is to bring Our Users offers and discounts that We believe are relevant to Our Users’ interests. We believe that our Users benefit from promotional activity based on User Information employed to market goods and services.
What is Individual Specific Information? Individual-specific or personally identifiable information is any information or data about a User that in itself, or as part of a unique combination of information, specifically recognizes the User by a unique identifier or descriptor. Examples of individual-specific include name, address, telephone number, email address, employment status, credit card type and number, and other financial information.
What We Won’t Do With User Information. We will not:
1. Sell or rent Information to parties outside of Us or Our network or product and services partners who provide services and products within the Site and other parties listed on the Site;
2. Use the User Information We collect and store to make decisions about granting or extending consumer credit unless the User submits a separate credit application and authorizes Us to use or disclose this information; and
3. Act as a consumer reporting agency, or furnish information about any User’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics or mode of living to any consumer reporting agency.
What We May Do With User Information: We may:
1. Use User Information to offer Our interoperable communications technology and solutions and other related goods and services We believe may be of interest to Users on behalf of ourselves or Our business partners;
2. Include information about Users gathered from other sources We believe to be reliable to identify Our Users more thoroughly and update Information We store and provide to third parties when the information changes, such as changes of address or new credit card expiration dates;
3. Create and use aggregate User data that is not personally identifiable to understand more about the common traits and interests of Our Users;
5. Provide information on corporate credit card usage to the corporate card holder User directly or through third parties;
6. Transfer User Information to the party that acquires the business or assets to which the information relates.
7. Provide information in response to bona-fide requests for information in response to claims of patent or alleged patent or intellectual property infringement, or in response to governmental subpoenas or court orders.
The Internet and Information Collected. When a User contacts Us via the Internet, fax or other means about Our interoperable communications technology and solutions business, We need certain information such as name, address, telephone number, email address, and other information to respond to the inquiry. If a User completes a transaction with Us, a confirmation will be sent to the User. The confirmation may contain additional offers from Us and/or Our business partners that We believe may be of interest based on the information provided to Us. If a User has asked to be put on Our mailing lists, We may contact the User via e-mail from time to time. Notwithstanding anything to the contrary, the User will always be provided with a way to opt-out of future e-mailings.
Like many other Internet sites, We automatically collect certain non-personal information regarding our Users, such as software client information (for example, IP addresses, browser versions and operating systems) and aggregate information (for example, number of pages accessed) in order to analyze Web traffic and usage trends, and to enable Us to tailor content and services to provide a better fit to Our Users’ needs. Information of this nature does not pertain to a User’s specific identity and is not associated with a User’s personal information.
Security. We collect Information only in a manner deemed reasonably necessary to serve Our legitimate business purposes and comply with Our legal obligations. We safeguard our Users’ personally identifiable information by using industry standard practices. Although “guaranteed security” does not exist either on or off the Internet, We make commercially reasonable efforts to make Our collection of such Information consistent with all applicable laws and regulations.
Currently, Our Site utilizes a variety of different security measures designed to protect personally identifiable information from unauthorized access by users both inside and outside Mutualink, including the use of 128-bit encryption based on a Class 3 Digital Certificate issued by Verisign Inc. This allows for utilization of Secure Sockets Layer, which is a method for encrypting data. This protects confidential information – such as credit card numbers, online forms, and financial data – from loss, misuse, interception and hacking. We take commercially reasonable efforts to create and maintain “fire walls” and other appropriate safeguards to ensure that to the extent We control the Information, the Information is used only as authorized by Us and consistent with this Policy, and that the Information is not improperly altered or destroyed. Our privacy protection practices help Us to maintain accurate, timely, complete and relevant information for Our business purposes. Our communication system, software and database practices have been designed to aid Us in supporting authenticity, integrity and confidentiality. Although We use commercially reasonable efforts to maintain data security when data is transmitted through third party communication service providers, We do not warrant the security of data during such transmission.
A User’s browser may be set to allow him/her to be notified when a cookie is to be placed on the browser, decline the cookie or delete cookies that have been placed on the browser. Some functions of Our Site may not work or may work slowly if a cookie is refused. Our Site uses third party service providers to serve and host Our advertisements. These third parties may place cookies on a User’s computer if a User clicks on or accesses the advertising.
The third party cookies are used to track whether the site was accessed from the advertisement. The cookies generated from the advertisements do not contain personally identifiable information. We do not control these cookies and they may not follow the rules We have set for Our own cookies. We and Our third party ad server also use invisible pixels, sometimes called web beacons, on Our Site to count how many people visit certain web pages. Information collected from invisible pixels is used and reported in the aggregate without the use of a User’s personally identifiable information. This information may be used to improve marketing programs and content and to target our Internet advertisements on Our Site and other web sites.
Email. The primary purpose of capturing email addresses is to send transaction confirmations to Our Users. Our confirmations may contain additional offers from Our affiliates and business partners based on information a User has provided. In addition, We may collect User email addresses and share them with Our third party service providers for purposes of conducting consumer research and surveys. Users will always have the ability to opt-out of future email communications, however, We will continue to send e-mails to confirm transactions. In the event We use a third party email service provider to send emails, this service provider shall be prohibited from using Our Users’ email addresses for any other purpose.
Other Disclosures. Regardless of whether a User opted out from having his/her Information shared, We may be obligated to disclose Information about a User to a law enforcement agency or by a court order, or under the discovery process in litigation, investigations, and prosecutions. Unless otherwise prohibited by law or Our contractual obligations, We may disclose personal information if required to do so by law, court order, or as requested by a governmental or law enforcement authority, or in good faith believe that disclosure is otherwise necessary or advisable. Situations may include: to perform, maintain or enforce contracts with Our Users, to protect the rights or properties of Our business partners, Our Users or others, or when We have reason to believe that disclosing the information is necessary to identify, contact or bring legal action against someone who may be causing or who may be threatening to cause interference with or damage to Our rights, properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.
Correction. We make repeated efforts to verify the accuracy of Information and to correct and update Our database from Information available to Us. In the event a User believes that such Information held by Us is inaccurate or outdated, We, upon notification and sufficient time for verification, will take all reasonable steps to correct any inaccuracy or update outdated information of which We are made aware.
Opt out. We always offer Users the opportunity to “opt-out” of communications and/or from having their information shared as set forth herein. A User may elect to opt out by notifying Us of the request by following the directions posted on every email communication, by writing to us at Opt Out, Mutualink, Inc., 1269 South Broad Street, Wallingford, CT 06492 or by clicking on this link Opt out.
Users can elect to opt out from any of the following: (1) Mail – email (excluding confirmation emails) and direct mail; (2) Phone – telephone and fax solicitation; or (3) Contact – all communications including email, direct mail, fax and telephone. We maintain telephone “do not call” lists as mandated by law. We process requests to be placed on do not mail, do not phone and do not contact lists within 60 days after receipt, or such shorter time as may be required by law.
Acceptance. By using Our Site, User signifies his/her agreement with Our Policy. If User does not agree with this Policy, please do not use Our Site. We reserve the right, in Our sole discretion, to modify, alter or otherwise update this Policy (“Revised Policy”) at any time withoutprior notice. Such Revised Policy shall be effective immediately upon posting and shall govern User’s rights and Our obligations with respect to the use, disclosure and protection of User’s Information as of such posting. User should check this Policy periodically for, and read carefully, any such Revised Policy if User is concerned about how his/her Information will be used and before continuing on with the use of this Site. User’s continued use of this Site following the posting of changes to these terms will mean User accepts those changes.