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Privacy Policy

OUTDIGIT, LDA.
MEMBER PRIVACY POLICY
AND INFORMATION PRACTICES STATEMENT
Revised June, 2006

Introduction. We at OutDigit, Lda. ("OutDigit"), recognize the importance of protecting the privacy of Personal Information collected online or offline by us about individuals participating in the Program ("Members" or "you"). This policy also explains when and how we treat Personal Information provided to us by other OutDigit business units and affiliates ("Affiliates").

Application
Purpose
Security
The Internet
Cookies
Information We Collect
Feedback/Opt out
Email
Sweepstakes/Contests
Direct Mail/Outbound Telemarketing
Research/Survey
What is Individual Specific Information?
What We Won't Do with Customer Information
What We Will Do With Customer Information
Compliance with Law
Correction
Downloading
Policy Changes

Application. This policy applies to residents of the United States and to the Program activities conducted in the United States only. We do not accept the jurisdiction of any other laws over our activities in the United States.

Purpose. Our purpose in establishing this policy is to balance our legitimate business interests in collecting and using Information with our Members' reasonable expectations of privacy. Our intent is to bring you offers and discounts that we believe are relevant to your interests. We believe that our Members benefit from promotional activity based on Member Information employed to market goods and services offered by and through other OutDigit business units and affiliates ("OutDigit Brands") third party merchants participating in the Network ("Network Partners"), and other carefully selected marketing partners ("Marketing Partners"). For more information on our affiliates, check our corporate Web site, www.outdigit.com.

Security. OutDigit collects Information only in a manner deemed reasonably necessary to serve our legitimate business purposes and comply with our legal obligations.

We safeguard our Members’ 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, this OutDigit Web site utilizes a variety of different security measures designed to protect personally identifiable information from unauthorized access by users both inside and outside OutDigit, 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 all commercially reasonable efforts to create and maintain "fire walls" and other appropriate safeguards to ensure that to the extent OutDigit and OutDigit controls the Information, the Information is used only as authorized by OutDigit and OutDigit 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.

Web sites of all OutDigit Brands and Program Partners,Marketing Partners and any other third party Web sites that are accessed through links, banners and other means of electronic connection on this OutDigit Web site have separate privacy and data collection practices, and security measures. We have no control over these web sites and no responsibility or liability for the practices, policies and security measures implemented by such parties on their Web sites. These web sites have content, advertising, banners, links, sponsors, partners and connections over which we have no control and no responsibility. We encourage you to contact these third parties to ask questions about their terms of use, privacy practices, policies and security measures before disclosing personal information on linked web sites. We do not endorse or approve the content, terms of use, privacy policy, advertising or sponsors of any linked web site.

Please click on this link Feedback/Opt out to give us your feedback about this Policy or opt out of further communications from us.

The Internet. On this OutDigit Web site we do not collect personally identifiable information from Members, unless they provide it to us voluntarily and knowingly. If you provide us with your e-mail address, we may use it to send OutDigit and other offers to you. In addition, you can sign up to receive email offers from OutDigit Brands and Program Partners and Marketing Partners. OutDigit, OutDigit Brands, Program Partners and/or Marketing Partners may contact you via e-mail from time to time if you have asked or agreed to be put on their respective mailing lists. You 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 Members, 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 Members’ needs. Information of this nature does not pertain to your specific identity and is not associated with your personal information.

This OutDigit Web site has hyperlinks that connect the Member to other Web sites, some of which are not affiliated with or controlled by OutDigit. Once you leave this Web site, each new Web site you visit may have its own privacy policy and terms of use. Your access to and use of such linked Web sites through links provided on this Web site is governed by the privacy policies and terms of use and policies of those sites, not this Web site. This Web site’s privacy policy and terms of use do not apply to any other Web site, including other OutDigit Brand web sites.

Cookies. We may place a "cookie" on your web browser. A cookie is a very small text file that is sent to a Member’s browser from a web server and stored on the Member’s computer hard drive. It assigns the computer a unique identifier. The cookie stores information on your hard drive so we can communicate with you more efficiently, respond to you based on prior sessions at which you provided information about you or your preferences to us and understand what you prefer to view on our web sites. We do not use cookies to store passwords or credit card information. Cookies do not tell us your individual identity unless you have chosen to provide it to us.

Your browser should be set to allow you to be notified when a cookie is to be placed on your browser, decline the cookie or delete cookies that have been placed on your browser. Some functions of our web sites may not work or may work slowly if a cookie is refused.

Our web site uses third party service providers to serve and host our advertisements. These third parties may place cookies on your computer if you click on 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.

Our web site also uses invisible pixels, sometimes called web beacons, 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 Member'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. For more information about our third party ad server, or to learn your choices about not having this non-personal information used to serve ads to you, please click here.

The Information We Collect. As part of the enrollment process for the Program, we must collect and store names and addresses, and other basic Information that we solicit from you in order to make the Program benefits available to you. In addition, we will collect and store optional information that you choose to provide to us directly, or indirectly through third parties, including telephone numbers, e-mail address and credit card information for purposes of sending you information about OutDigit offers. We send to the OutDigit Loyalty Database and Enterprise Data Warehouses certain personally identifiable information, including the name, address, telephone number, email address and transaction detail ( what credit card purchases were made from OutDigit Brands and Program Partners ). In addition, we may append personally identifiable information that we obtain from third parties to the Information that we collect from you. We do not collect Social Security or driver's license numbers from Members.

Feedback/Opt out. We always offer Members the opportunity to "opt-out" of communications. A Member may elect to opt out of communication by following the directions generally included in every email communication or by visiting this OutDigit Web site or by contacting the OutDigit Member Services department. Members can elect to opt out from any of the following: (1) Mail - email 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 incorporate into the OutDigit Loyalty Database and Enterprise Data Warehouse "do not call" and "do not mail" lists maintained by other organizations. 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.

Any Member may opt out of communication by contacting OutDigit using the following methods:

      By email -
      By phone -
      By mail - Opt Out/ Privacy
            OutDigit Member Services
            OutDigit LDA
            

We also invite your feedback and comments on this Policy. Please contact us at the email address above or by writing to the above address.

Email. Members will have the option of submitting their email address to us. Your e-mail address may be used by us to send OutDigit offers to you . In addition, Members may sign up to receive e-mail offers from OutDigit Brands, Program Partners and/or Marketing Partners. Members will always have the ability to opt-out of future email communications.

It is our intent to only send email communications to Members who have elected to provide us with their e-mail address, who have consented to receive email from the OutDigit Brands, Program Partners and/or Marketing Partners, or who have permitted third parties to share the Member's e-mail address with entities such as OutDigit for purposes of receiving promotional e-mails. These communications will relate to promotions from OutDigit, OutDigit Brands, Program Partners and/or Marketing Partners, as applicable. At any time a Member may opt-out of receiving email communications by following the directions posted in every email communication, by visiting this OutDigit website and following the opt-out instructions or by contacting the OutDigit Member Services Department.

We may use a third party email service provider to send emails. Any such service provider is prohibited by contract from using our Member’s email address for any purpose other than to send Program related e-mail.

SWEEPSTAKES / CONTESTS:
Occasionally OutDigit may run sweepstakes and contests. We use Information provided by Members in connection with enrollment for the Program or ask Members who participate or enter to provide contact information (like an email address). If a Member participates in a sweepstakes or contest, his/her contact information may be used to reach him/her about the sweepstakes or contest, and for other promotional, marketing and business purposes.

All sweepstakes/contests entry forms will provide a way for participants to opt-out of any communication from the sweepstake’s/contest’s manager that is not related to awarding prizes for the sweepstake/contest.

DIRECT MAIL / OUTBOUND TELEMARKETING:
Members who supply us with Information, or whose Information we obtain from third parties may receive periodic mailings or phone calls from us with information on OutDigit and other offers. Members may also receive mailings/calls from OutDigit Brands, Program Partners and/or Marketing Partners.

We offer our Members the option to decline these communications. Members may contact us to opt-out of such communications as follows:

By email -
By phone -
By mail - Opt Out/ Privacy
            OutDigit Member Services
            OutDigit LDA
            

RESEARCH/SURVEY SOLICITATIONS
From time to time we may perform research (online and offline) via surveys. All survey responses are voluntary, and the information collected will only be used for research and reporting purposes, to help us to better serve Members by learning more about their needs. We may contact a Member to inquire or survey about the Program or the improvements needed to the Program. The survey responses may also be used to determine the effectiveness of our Web site, various types of communications, advertising campaigns, and/or promotional activities.
If a Member participates in a survey, the information given by the Member will be used along with that of other study participants (for example, a finding that 50% of a survey's respondents are men). We may share anonymous individual and aggregate data for research and analysis purposes.

Participation in surveys is voluntary. Participants who do not wish to receive email communications may opt out of the receipt of such communication by notifying us as provided in the Feedback/Opt-Out section above.

What is Individual Specific Information? Individual-specific or personally identifiable information is any information or data about a Member that in itself, or as part of a unique combination of information, specifically recognizes the Member 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 Customer Information. OutDigit will not:

1. Sell or rent Information to parties outside the OutDigit family of present and former companies, OutDigit franchisees and affiliates, or allow OutDigit affiliates to sell or rent the Information to parties outside the OutDigit family of companies, franchisees and affiliates;
2. Use the Member Information we collect and store to make decisions about granting or extending consumer credit unless the Member submits a separate credit application and authorizes us to use or disclose this information;
3. Act as a consumer reporting agency, or furnish information about any Member's credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics or mode of living to any consumer reporting agency;
4. Maintain in our OutDigit Loyalty Database or Enterprise Data Warehouse any Information about any Member on billing, collection or payment disputes with any franchisee, creditor or OutDigit affiliate;

What We Will Do With Customer Information: OutDigit will:

1. Use Member Information to inform Members about new offers, and to offer goods and services we believe may be of interest to Members, under joint marketing arrangements with OutDigit Brands, former OutDigit affiliates, and OutDigit franchisees, and on behalf of Program Partners and/or Marketing Partners;
2. With Member consent, provide Member Information to OutDigit Brands, Program Partners and/or Marketing Partners, for purposes of directly offering their goods and services to Members.
3. Include information about Members gathered from other sources we believe to be reliable to identify our Members 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;
4. Provide the name, address, telephone number and transaction Information, including payment method, about Members to a OutDigit Brand's or Program Partner's or Marketing Partner's designated affinity credit card issuer(s) and loyalty club providers for use in the preselection process for a OutDigit Brand's or Program Partner's or Marketing Partner's affinity credit card and loyalty club;
5. Create and use aggregate Member data that is not personally identifiable to understand more about the common traits and interests of our Members;
6. Use Member Information to enforce a contract with a OutDigit Brand or with a OutDigit franchisee or any Terms of Use of our web site, or provide access or disclosures that we believe in good faith are required to comply with applicable law (See Compliance with Law in this Policy);
7. Provide information on corporate credit card usage to the corporate card holder Member directly or through third parties;
8. Transfer Member Information to the party that acquires the business or assets to which the information relates, or as part of the sale, merger or consolidation of OutDigit to or with another business, or the consolidation of OutDigit with another loyalty program.

Service Providers. We may utilize the services of, and disclose Information to, our subcontractors and affiliates for purposes of collecting Information on our behalf, and for administrative and other purposes that we deem necessary to maintain, service, and improve the Program.

Compliance with Laws.We may be obligated to disclose Information about you to a law enforcement agency or by a court order, or under the discovery process in litigation and prosecutions. We may provide Information to assist a OutDigit Brand or franchisee to enforce a contact you may have breached. We may also disclose information voluntarily to cooperate with law enforcement agencies in matters of national security. We may ask certain questions to comply with certain laws if you reside outside the United States or meet certain other criteria established by law or executive order.

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 Member believes that such Information held by OutDigit or OutDigit is inaccurate or outdated, OutDigit or OutDigit, 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.

Downloading. Please feel free to download or copy this Policy. You may obtain a copy free of charge by writing to us at the following address:

            OutDigit Member Services
            OutDigit LDA
            

Policy Changes. We may change or terminate this Policy at any time without prior notice. We will post any Policy changes to our web site to notify you of these changes and provide you with the ability to opt out of any new, unanticipated uses of Information not previously disclosed in the Policy. The Policy in effect at the time of each visit to this Web site applies to that visit. Please check our Policy each time you visit our web site if you are concerned about how your Information will be used.

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