PRIVACY POLICY

 Last Updated Date: April 20, 2014

383Media, Inc., (“Securewebpayments, “SWP”, or “we”) has developed various software and e-commerce solutions, including payment processing services (collectively, the “Service”) to enable marketing affiliates and retail partners (collectively, “Affiliates”) to sell their digital products and services to end-users (“End-Users”). We provide this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of information through our Service, including through the Affiliates’ websites where the Service is available (each an “Affiliate Site”), and our website at www.securewebpayments.com (the “SWP Site”). This Privacy Policy may be updated from time to time.  We will notify you of any material changes by posting the new Privacy Policy on the SWP Site.

As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

383Media, Inc. has been awarded TRUSTe’s Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe’s program requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. The TRUSTe program covers only information that is collected through this Website, www.securewebpayments.com . TRUSTe’s mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at privacy@securewebpayments.com. If you are not satisfied with our response you can contact TRUSTe here.

Information Collection and Use

 Our primary goals in collecting information from End-Users are to provide and improve the Service and the SWP Site, and to administer the Service and the SWP Site.

  • If you are an End-User purchasing a product or service offered by an Affiliate, we may collect at the check-out page certain Personal Information about you, including name, company’s name, email address, telephone number, physical address, credit card details, and order ID. “Personal Information” means information that can be used to identify or contact a living individual. Upon payment, you may be required to provide additional information to the applicable Affiliate.
  • We use your Personal Information to provide the Service and administer your inquiries, including in the following ways:
  • To process, validate and verify payments for purchases made through the Service.
  • To make payments to Affiliates.
  • To verify accuracy of your information.
  • To contact you about the Service.
  • To enable you to receive personalize content, advertising and promotions based on your preferences. You may opt-out of these types of communications at any time by following the unsubscribe link located at the bottom of each communication or by emailing us at privacy@securewebpayments.com.
  • To enforce our Terms of Use.
  • We may also use your Personal Information to contact you with our newsletters, marketing or promotional materials and other information that may be of interest.  If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications. (See “Changing or Deleting Information” below)
  • We may also collect Personal Information from Affiliates, including business contact details and any information that the Affiliates decide to provide to use, whether through the SWP Site or otherwise. We use such information only in connection with our relationship with the applicable Affiliate.
  • If you use our contact us form located on our Web site we will collect your name and email address.  We will use this information to respond to your inquiry.
  • If you wish to track your orders, you will be directed to a page that has the look and feel of our client’s site, however the information collected here is governed by SWP’s privacy policy.

Anonymous Information

We may also collect various information regarding the interaction(s) between End-Users and Affiliate Sites, including IP addresses and usage information, such as  ad content/banner delivery, counting click-throughs on an ad/banner, tracking web page views following a click-through, and sales tracking] (collectively, “Anonymous Information”). We use Anonymous Information mainly to evaluate and improve the Service, and to provide Affiliates with insights into their End-Users’ behaviors and preferences all on an anonymous basis.

Log Data.  When you visit the SWP Site or an Affiliate Site, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”)This Log Data may include information such as pages that you visit, the time spent on those pages, access times and dates, and other statistics.  We use this information to monitor and analyze use of the Service and for the Service’s technical administration, to increase our Service’s functionality and user-friendliness, and to better tailor our Service to our visitors’ needs.  We also use this information to verify that visitors to the Service meet the criteria required to process their requests.  We do not use Log Data in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Anonymous Information.

Cookies

Like many websites, we use “cookies” to collect information on the SWP Site as well as on Affiliate Sites. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes.  We use cookies for two purposes.  First, we utilize persistent cookies to save your login information for future logins.  Second, we utilize session ID cookies to enable certain features of the SWP Site or the Affiliate Sites, to better understand how you interact with such sites and to monitor aggregate usage by users and web traffic routing on such sites.  Unlike persistent cookies, session cookies are deleted from your computer when you log off from the applicable site and then close your browser.  You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.  If you do not accept cookies, however, you may not be able to use all functionality of the SWP Site or the Affiliate Sites.  We do not link the information we store in cookies to any personal information you submit while on our site or our affiliate’s sites.

The use of cookies by third parties is not covered by our privacy policy.  We do not have access or control over these cookies.

Clear Gifs (Web Beacons/Web Bugs)

We employ or our third party tracking utility partner employs a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective.  Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users.  In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.

Phishing

Identity theft and the practice currently known as “phishing” are of great concern to us.  Safeguarding information to help protect you from identity theft is a top priority.  We do not and will not, at any time, request your credit card information, your login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.  For more information about phishing, visit the Federal Trade Commission’s website.

Information Sharing and Disclosure

We will not sell your personal information to third parties.  We will only share your personal information in the ways described below.

Affiliates.  We may share information collected from End-Users, whether Personal or Anonymous Information (collectively, “End-User Information”) with the applicable Affiliate, i.e., the Affiliate that provides the products or services purchased by the End-User. You may opt-out from third party sharing by emailing us at privacy@securewebpayments.com by contacting that third party directly.

Service Providers.  We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform services related to the SWP Site or the applicable Affiliate Site  (e.g., without limitation, maintenance services, database management, web analytics, payment processing ) or to assist us in analyzing how our Service is used.  These third parties have access to End-User Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Compliance with Laws and Law Enforcement.  We cooperate with government and law enforcement officials and private parties to enforce and comply with the law.  We will disclose End-User Information to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to, subpoenas or similar legal process), when we believe in good faith that disclosure is necessary to protect the property and rights of Securewebpayments or a third party, to protect the safety of our users, the public or any person, investigate fraud, respond to a government request, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

Business Transfers.  We may be involved in a merger, acquisition, or sale of a portion or all of our assets, you will be notified via email and/or prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Changing or Deleting Your Information

If you are an End-User with an account with us, you may review, update, correct or delete the Personal Information provided during registration by contacting us at privacy@securewebpayments.com.  If you completely delete all such information, then your account may become deactivated.  If you would like us to delete your account in our system, please contact us as described above with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request.  We may retain an archived copy of your records as required by law or for legitimate business purposes.  We will respond to your access request within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at privacy@securewebpayments.com.  We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security

Securewebpayments is very concerned with safeguarding your information.  We process payments in connection with the Service in compliance with the PCI Security Standards and employ reasonable physical, technological, and administrative security measures and attempt to ensure they are applicable under the circumstances.  No method of transmission over the Internet, or method of electronic storage, is 100% secure, however.  Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.  When you enter sensitive information (such as credit card number on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).

We will make any legally required disclosures of any  breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting via the Service in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary todetermine the scope of the breach and restore the reasonable integrity of the data system.

International Transfer

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.  If you are located outside the United States and choose to provide information to us, Securewebpayments transfers Personal Information to the United States and processes it there.  Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Links to Other Websites

Our Service contains links to other websites.  If you choose to click on a third party link, you will be directed to that third party’s website.  The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices.  We do not exercise control over third party websites.  These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you.  Other websites follow different rules regarding the use or disclosure of the personal information you submit to them.  We encourage you to read the privacy policies or statements of the other websites you visit.

Our Policy Toward Children

This Service is not directed to persons under 18.  We do not knowingly collect personally identifiable information from children under 13.   If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at privacy@securewebpayments.com.  If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.

Changes in this Privacy Statement

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at privacy@securewebpayments.com or at:

383 Media, Inc.
7600 Dublin Boulevard, Suite 210
Dublin, CA, 94568