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Internet Privacy Statement
INTERNET PRIVACY STATEMENT

At CLEARROOT.COM, we recognize and respect the importance of maintaining the privacy of our customers and members. Our Internet Privacy Statement (“Statement”) has been created in order to demonstrate our firm commitment to protecting your privacy. Our Statement applies to the collection, use, disclosure and safeguarding of personal information you provide us on our Web site. We will never knowingly share this personal information with anyone, except as described in this Statement or as otherwise authorized or required by law. Our Statement describes why we gather information from customers and members, what information we collect, what we use the information for, and how you can limit the use of this information should you choose to.

SITE SECURITY

Our Site encrypts your confidential information prior to transmission over the internet using 128 bit, secure socket layer (SSL) encryption technology. This technology works best when the Site is viewed using internet browsers maintained with the latest security updates. Our Site also has security measures in place to protect the loss, misuse and alteration of the information under our control. We use industry-standard security protocols, such as (if and where appropriate) firewalls, and place restrictions on which employees can access member data. Furthermore, all of the customer information we collect is protected against unauthorized access by physical security means. Furthermore, we encourage our partners and service providers to adopt and follow stringent privacy policies.

As a customer, you also play an important role in maintaining the privacy of your information. When you become a member of our Site, you are required to create an account password. We recommend using a combination of letters and numbers to provide the best security possible. This password should be protected at all costs and never shared with anyone! We also encourage you to change your password frequently as an additional security measure. Changes to your password may be performed through the account management area of the Site.

Notwithstanding these efforts, we caution you that “perfect security” does not exist on the internet. No transmission of data over the internet or any other public network can be guaranteed to be 100% secure. Although we make reasonable efforts to safeguard your personal information once we receive it, we cannot warrant the security of information you transmit to us.

A SPECIAL NOTE ABOUT CHILDREN

We do not knowingly solicit data from children, nor do we knowingly market to children. You must be 18 years or older to submit an application through the Site or to become a member.

WHY WE COLLECT INFORMATION

CLEARROOT.COM gathers information in order to process your orders, provide you with a pleasurable customer experience, to inform you of special offers and discounts, to improve our services and the Site, and to otherwise analyze and understand our business. Our Site collects two types of information about its visitors: Personally Identifiable Information and Non-Personally Identifiable Information. Our primary goal in collecting information from our customers and members is to provide you with a consistently enjoyable, efficient and customized experience while using our Site.

PERSONALLY IDENTIFIABLE INFORMATION

Personally Identifiable Information refers to information about an identifiable individual. Personally Identifiable Information is requested when you register with us, place an order for a product or service, correspond with us, fill out surveys, or otherwise volunteer information. Information you enter may be collected even if you cancel or do not complete an order. Personally Identifiable Information might include your name, mailing address, telephone number, email address and other identification and contact information. We may also collect certain financial information, like your banking information, credit card information, and billing address. By collecting this information, we can fill your product and service orders effectively. From time to time, you may receive telephone calls from us with information regarding an application you have submitted, or to request additional information regarding an application you have submitted. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities on our site, we may collect such information. We may use that information and other information that we obtain from your use of our site to resolve disputes, troubleshoot problems and enforce our agreement for Terms of Use.

NON-PERSONALLY IDENTIFIABLE INFORMATION

Non-Personally Identifiable Information refers to information that does not by itself identify a specific individual. This information may include the website's Uniform Resource Locator ("URL") that you just came from, which URL you next go to, the pages of our Site that you viewed during your visit, what browser you are using, and your Internet Protocol ("IP") address. Non-Personally Identifiable Information is gathered throughout the duration of your stay at our Site. This information is compiled and analyzed on both a personal and an aggregated basis. For example, we may perform statistical analyses of aggregate customer behavior to measure relative customer interest in the various areas of our Site for product development purposes. We also use this information to trace inappropriate applications.

COOKIES/CLEAR GIFS

Our Site utilizes two common technologies called cookies and clear GIFs to collect information about how our Site is used.

A cookie is a small data text file that is stored on your computer's hard drive to help websites identify you as a customer. A cookie cannot retrieve data from your hard drive, pass on a computer virus, or capture personal information from your computer. We use cookies to let us know that you are an existing member on our site. We do not store Personally Identifiable Information in cookies. Most web browsers automatically accept cookies, but most also allow you to prevent the use of cookies. Should you disable this feature, certain aspects of our Site, such as our online enrollment, will not function properly.

Clear GIFs (also known as pixel tags, single pixel GIFs, web beacons or action tags) are used to help us measure the effectiveness of our website, advertisements, and HTML-based emails. Clear GIFs allow us to better manage content on our Site by informing us of 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 our users. Clear GIFs are not tied to your Personally Identifiable Information.

DISCLOSURE OF INFORMATION

Except as otherwise stated in this Statement, we do not sell, trade or rent your Personally Identifiable Information collected on our Site to others without your permission. The information collected by our Site is used to process applications, to keep you informed of your membership status, to notify you of products, services, or special offers that may be of interest to you, and for statistical purposes for improving our Site. We may share data with our parent company and its subsidiaries, however, the use of this information would still be governed by the terms of this Statement. We may provide aggregated statistics about our customers, sales, traffic patterns, and related Site information to third parties, but this information will not include Personally Identifiable Information. We may release Personally Identifiable Information when we believe that such release is reasonably necessary to enforce or apply our Terms of Use, to protect the rights, property and safety of our customers and ourselves, or in connection with an investigation of fraud, intellectual property infringements, or other activity that may be illegal or may expose us to legal liability.

We will disclose your Personally Identifiable Information to third parties to approve applications, to fill orders, to deliver orders, to charge bank accounts or credit cards, and to deliver promotional emails to you from us. These third parties may not use your Personally Identifiable Information other than to provide the services requested by CLEARROOT.COM. For example, we must release information to credit bureau’s in order to obtain your credit rating.

From time to time we may disclose a limited amount of Personally Identifiable Information to direct marketing companies for trade or rental purposes. You may opt-in or opt-out to the distribution of such information to third parties by updating your preferences within the account management area of our Site. A Successor to our business is not to be considered to be a third party for these purposes. It should be noted that these preferences default to “no” when you initially become a member.

We may allow a potential acquirer or merger partner to review our databases, although we would restrict their use and disclosure of this data during the diligence phase. In the event of a merger, consolidation, or sale or transfer of all or substantially all of the assets or business of CLEARROOT.COM (a "Successor"), one of the assets which would be transferred is the information we collect from our customers and members. However, the use of this information by any Successor would still be governed by the terms of this Statement, as amended from time to time, including any amendment after such transaction, and you will continue to have the right to opt-out of sharing your information with third parties.

ENFORCEMENT OF LAW: From time to time, we may be required by law enforcement or judicial authorities to provide Personally Identifiable Information to the appropriate governmental authorities. We will disclose Personally Identifiable Information upon receipt of a court order or subpoena or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

HOW TO LIMIT THE USE OF YOUR INFORMATION

If you have become a member of our Site and chosen to receive emails from us, we may occasionally update you via email of special offers and discounts. You may opt-out or opt-in at any time from our mailing lists by editing your profile within the account management area of our Site, or by following the unsubscribe instructions in any email you receive from us.

As we only wish to send information to our opt-in customers and do not intentionally spam or otherwise distribute your information, please note that these preferences default to “no” when you initially become a member.

Please note that your instructions will not apply to account status and confirmation emails, and that such emails may also contain promotional items and offers. Your instructions to limit the use of your information will be processed as soon as reasonably practicable.

HOW TO UPDATE OR CORRECT YOUR INFORMATION

Changes to your information may be performed at anytime by accessing the account management area of the Site. Within this section you may update your shop details, email address, and distribution preferences. You may ask us in writing via email at to have the information on your account deleted, updated or corrected; however, because we keep track of all orders exchanged through our network, you cannot delete information associated with this. Note that we may retain changed or deleted information for archival purposes.

THIRD PARTY LINKS

CLEARROOT.COM wants you to be aware that when you click on links and/or banners that take you to third-party websites, you will be subject to the third parties' privacy policies, not ours. While we support the protection of privacy on the Internet, we cannot be responsible for the actions of third parties. We encourage you to read the posted privacy statement and user terms and conditions whenever interacting with, and prior to providing any personal information to, any other website.

CONSENT AND CHANGES TO THIS STATEMENT

Subject to the above provisions, by using our Site, you consent to the collection and use of information by us and the terms of this Statement. We may change our Statement from time to time and we will post those changes so that you are always aware of what information we collect, how we use it, and under what circumstances we may disclose it. Any change, modification, addition, or removal of portions of this Statement will be posted on our Site, at this location, a minimum of 5 (five) days before it is implemented. Any user who does not agree to the altered Statement should immediately discontinue use of our Site. By opening a new member account, accessing an existing member account, or otherwise using CLEARROOT.COM, after such changes and posting, you consent to the use of your personal information in the manner specified in the Statement and you agree to be legally bound and to abide by the changes and other provisions contained in the Terms of Use and Statement.

MISCELLANEOUS

The Terms of Use and the Internet Privacy Statement are collectively the Terms and Conditions of the Site. The segregation of this Internet Privacy Statement from the remaining documents is intended for convenience only, and shall not affect the construction and interpretation hereof or thereof.

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Published: January 1, 2006
Last Updated: April 15, 2008