BY VISITING THIS WEBSITE
AND REQUESTING
INFORMATION, PRODUCTS OR
SERVICES THERON, YOU
AGREE TO BE BOUND BY THE
TERMS AND CONDITIONS OF
THIS PRIVACY POLICY. IF
YOU DO NOT AGREE WITH
THE TERMS OF THIS
PRIVACY POLICY, PLEASE
DO NOT PROVIDE ANY
INFORMATION OR USE ANY
OF THE SERVICES OR
PRODUCTS OFFERED OR
PROVIDED ON ANY OF THE
WEBSITES REFERRED TO IN
THIS PRIVACY POLICY.
PLEASE NOTE: THIS
PRIVACY POLICY CHANGES
FROM TIME TO TIME AND
CHANGES ARE EFFECTIVE
UPON POSTING. PLEASE
CHECK BACK FREQUENTLY
FOR UPDATES AS IT IS
YOUR SOLE RESPONSIBILITY
TO BE AWARE OF CHANGES.
WE DO NOT PROVIDE
NOTICES OF CHANGES IN
ANY MANNER OTHER THAN BY
POSTING THE CHANGES AT
THIS WEB SITE.
This policy describes
the information
collection, use, and
dissemination practices
of CPALead, LLC,
("CPALead") and applies
to CPALead's collection,
use, storage and
disclosure of
information by CPALead
on its (a) websites,
including all its
divisions, subsidiaries
and related companies
(collectively, the
"Websites"), (b) on
various Third Party
websites, and (c) to
CPALead 's other
information collection,
including the purchase
of customer lists from
Third Parties. CPALead
is not responsible for
the information
collection or privacy
practices of Third Party
websites or
applications.
CALIFORNIA
RESIDENTS PRIVACY RIGHTS
Companies that collect
personally identifiable
information ("PII") from
California residents and
disclose such
information to Third
Parties (including
affiliated entities) for
marketing purposes must,
in response to a request
by a consumer, either
(1) provide a list
detailing the categories
of information shared
and the entities to
which such information
was provided, or (2)
provide a mechanism by
which a consumer may
opt-out of having their
information shared with
Third Parties. We have
elected the second
option and you may
request that your PII
not be shared with Third
Parties by sending your
request, including your
full name, email address
and postal address to:
CPALead, LLC., 1660 S. Church St.,
Suite #262, Watertown, WI
53094. In accordance
with California Civil
Code Sec. 1789.3,
California resident
users are entitled to
know that they may file
grievances and
complaints with
California Department of
Consumer Affairs, 400 R
Street, Suite 1080,
Sacramento, CA 95814; or
by phone at 916-445-1254
or 800-952-5210; or by
email to
dca@dca.ca.gov
THE INFORMATION
COLLECTION, USE AND
DISSEMINATION PRACTICES
OF CPALead.
1. Collection of
Information.
1.1 Survey
Information
CPALead collects
information from
individuals by various
methods, including, but
not limited to, when an
individual voluntarily
completes a survey,
order form, or a
registration page either
online or offline, or by
means of online or
offline surveys, order
forms, or registration
pages operated by Third
Parties (collectively, a
"Survey"). (As used
herein, "online" means
using the Internet,
including the Websites,
and related
technologies, and
"offline" means by
methods other than
online, including in
person, in the postal
mail, using telephones
and cell phones, and
other similar means.) In
the Surveys, CPALead or
a Third Party (a "Third
Party") may ask an
individual to provide
various information to
CPALead, which may
include his or her name,
email address, street
address, zip code,
telephone numbers
(including cell phone
numbers and carriers),
birth date, gender,
salary range, education
and marital status,
occupation, social
security number,
employment information,
personal and online
interests, and such
other information as may
be requested from time
to time (together,
"Survey Information").
CPALead may also collect
information concerning
an individual from
another source and uses
that information in
combination with
information provided
from this web site.
Completing the Surveys
is completely voluntary,
and individuals are
under no obligation to
provide Survey
Information to CPALead
or Third Party, but an
individual may receive
incentives from CPALead
or a Third Party in
exchange for providing
Survey Information to
CPALead.
1.2 Site
Membership or
Registration
To the extent
registration is required
to receive email and
possibly postal
communications from
CPALead or a Third Party
Advertiser, this Privacy
Policy also applies to
consumers that have
agreed to receive e-mail
marketing from CPALead
or a Third Party
Advertiser, whether at
our Website, via email,
on Third Party websites
or otherwise. We collect
information in certain
portions of our Website,
where guests provide
content submissions and
suggestions or
participate in
interactive online
activities (i.e., by way
of responding to
questions and surveys,
community listings,
ratings, searches and
comparison searches,
bidding, purchasing,
chat, games, or bulletin
boards, etc.). The
personal profile
information you submit
to CPALead or Third
Party Advertisers
remains your property,
but by submitting that
information to CPALead
or Third Party
Advertisers, you grant
CPALead and/or Third
Party Advertisers, the
right to use that
information for
marketing purposes.
CPALead or Third Party
Advertisers may also use
such information for
content improvement and
feedback purposes. We
may sell the personal
information that you
supply to us and we may
join together with other
businesses to bring
selected retail
opportunities to you.
These businesses may
include providers of
direct marketing
services and
applications, including
lookup and reference,
data enhancement,
suppression and
validation. In addition,
CPALead reserves the
right to release current
or past information in
the event CPALead
believes that the
information is being or
has been used in
violation of the Rules
or to commit unlawful
acts, if the information
is subpoenaed, if
CPALead is sold or
acquired, or when
CPALead deems it
necessary or
appropriate. By agreeing
to these terms, you
hereby consent to
disclosure of any record
or communication to any
Third Party when CPALead
in its sole discretion,
determines the
disclosure to be
appropriate.
"Subscription" occurs
when an end-user
registers for CPALead's
and/or Third Party
Advertisers' services,
either via registration
at our website, via
co-registration at a
marketing partner's
website, or via a
permission pass /
opt-out / no-opt mailing
CPALead collects
personally identifiable
information about our
subscribers, based on:
information gathered at
the time of
registration, subscriber
interaction and response
to subsequent electronic
mailings and website
use, information
provided by marketing
partners, and
information appended
from data aggregators.
Information collected
may include, but is not
necessarily limited to:
name, email address,
postal address, gender,
birth date, telephone
number, activity,
interests, user behavior
and other demographic
information. This
information enables us
to better tailor our
content to subscribers'
needs and to help our
clients to promote and
sell their products and
services.
1.3 Third Party
List Information
CPALead collects
information from
individuals when an
individual provides
information to a Third
Party and CPALead
subsequently purchases,
licenses, or otherwise
acquires the information
from the Third Party
(the "Seller"). Such
purchased information
may include, but is not
limited to, an
individual's name, email
address, street address,
zip code, telephone
numbers (including cell
phone numbers and
carriers), birth date,
gender, salary range,
education and marital
status, occupation,
industry of employment,
personal and online
interests, and such
other information as the
individual may have
provided to the Seller
(together, "Third Party
List Information"). When
acquiring Third Party
List Information,
CPALead seeks assurances
from the Seller that the
Seller has a right to
transfer the Third Party
List Information to
CPALead and that the
Seller has a right to
provide offers from
Advertisers to the
individuals whose
personal information is
included on the Seller's
list.
1.4 Other
Information.
Other occasions when
CPALead obtains
information from
individuals include (1)
when an individual is
making a claim for a
prize or seeking to
redeem an incentive
offered by CPALead or by
a Third Party, (2) when
an individual requests
assistance through
CPALead's customer
service department, (3)
when an individual
voluntarily subscribes
to a service or
newsletter; (4) when
private information is
provided by means of a
referral by a third
party to CPALead or a
Third Party Advertiser
(together, "Other
Information").
1.5 Cookies, Web
Beacons, and Other Info
Collected using
Technology.
CPALead currently uses
cookie and web beacon
technology to associate
certain Internet-related
information about an
individual with
information about the
individual in our
database. Additionally,
CPALead may use other
new and evolving sources
of information in the
future (together,
"Technology
Information").
a.Cookies.
A cookie is a small
amount of data stored on
the hard drive of the
individual's computer
that allows CPALead to
identify the individual
with his or her
corresponding data that
resides in CPALead's
database. You may read
more about cookies at
http://cookiecentral.com.
Individuals who use the
Websites need to accept
cookies in order to use
all of the features and
functionality of the
Websites.
a.Web Beacons.
A web beacon is
programming code that
can be used to display
an image on a web page
(by using an <img src="x">
programming function --
see http://truste.org
for more information),
but can also be used to
transfer an individual's
unique user
identification (often in
the form of a cookie) to
a database and associate
the individual with
previously acquired
information about an
individual in a
database. This allows
CPALead to track certain
websites an individual
visits online. Web
beacons are used to
determine products or
services an individual
may be interested in,
and to track online
behavioral habits for
marketing purposes. For
example, CPALead might
place, with the consent
of a Third Party
website, a web beacon on
the Third Party's
website where cosmetics
are sold. When Jane, an
individual listed in
CPALead's database,
visits the cosmetic
website, CPALead
receives notice by means
of the web beacon that
Jane visited the
cosmetics site, and
CPALead would then
update Jane's profile
with the information
that Jane is interested
in cosmetics. CPALead
may thereafter present
offers of cosmetic
related products and
services to Jane. In
addition to using web
beacons on web pages,
CPALead also uses web
beacons in email
messages sent to
individuals listed in
CPALead's database.
a.New
Technology.
The use of technology on
the Internet, including
cookies and web beacons,
is rapidly evolving, as
is CPALead's use of new
and evolving technology.
As a result, CPALead
strongly encourages
individuals to revisit
this policy for any
updates regarding its
use of technology.
a.Usage
Tracking.
CPALead tracks
information related to
the electronic mailings
and web pages viewed by
users and subscribers,
as well as the
hyperlinks clicked by
subscribers, while
viewing our emails or
visiting our websites.
a.Log Files.
Log files are used to
track and monitor
subscriber usage.
a.Optional
Registration.
CPALead may offer free
voluntary registration
to potential
subscribers. During such
registration, the
subscriber is required
to supply an email
address and other
personal information.
This information is
required if the
subscriber wants to
participate in Company
services or Third Party
Services.
a.Feedback and
Inquiries.
You have the ability to
contact CPALead to
provide us with your
feedback. CPALead uses
this information to
respond to you and
analyze customer service
issues.
1.6 Outside
Information
CPALead may receive
information about
individuals from Third
Parties or from other
sources of information
outside of CPALead
including information
located in public
databases ("Outside
Information").
1.7 Individual
Information
As used herein,
Individual Information
means Survey
Information, Third Party
List Information, Other
Information, Technology
Information, and Outside
Information, and any
other information
CPALead gathers or
receives about
individuals.
1.8 No
Information Collected
from Children.
CPALead will never
knowingly collect any
personal information
about children under the
age of 18. If CPALead
obtains actual knowledge
that it has collected
personal information
about a child under the
age of 18, that
information will be
immediately deleted from
our database. Because it
does not collect such
information, CPALead has
no such information to
use or to disclose to
Third Parties. CPALead
has designed this policy
in order to comply with
the Children's Online
Privacy Protection Act
("COPPA").
1.9 Credit Card
Information.
CPALead may in certain
cases collect credit
card numbers and related
information, such as the
expiration date of the
card ("Credit Card
Information") when an
individual places an
order from CPALead. When
the Credit Card
Information is submitted
to CPALead, such
information is encrypted
and is protected with
SSL encryption software.
CPALead will use the
Credit Card Information
for purposes of
processing and
completing the purchase
transaction, and the
Credit Card Information
will be disclosed to
Third Parties only as
necessary to complete
the purchase
transaction. Although
CPALead takes all
commercially reasonable
action to protect Credit
Card Information, you
ultimately assume the
risk of any damage or
loss as a result of
transmitting such
information to CPALead,
including but not
limited to, identify
theft, credit card fraud
or credit card loss.
1.10 Links to
External Websites.
CPALead's emails and
websites contain links
to external websites.
You will be taken to
external websites if you
click on these links.
Your information may be
passed from CPALead's
database to the external
website, and/or external
database, for your
convenience (e.g. your
information may be used
to pre-fill a form at a
destination website).
CPALead is not
responsible for the
privacy practices or
content of any external
website owner. We
encourage you to review
the privacy policy of
any website they visit.
2. Use of
Individual Information.
2.1 Discretion
of Information.
THE COMPANY MAY USE
INDIVIDUAL INFORMATION
FOR ANY LEGALLY
PERMISSIBLE PURPOSE IN
COMPANY'S SOLE
DISCRETION.
The following paragraphs
in Section 2 describe
how CPALead currently
uses Individual
Information, but CPALead
may change or broaden
its use at any time. As
noted below, CPALead may
update this policy from
time to time. CPALead
may use Individual
Information to provide
promotional offers to
individuals by means of
email advertising,
telephone marketing,
direct mail marketing,
online banner
advertising, and package
stuffers, among other
possible uses.
2.2 Email and
Unsubscribe Policy.
CPALead uses Individual
Information to provide
promotional offers by
email to individuals.
CPALead may maintain
separate email lists for
different purposes. If
email recipients wish to
end their email
subscription from a
particular list, they
need to follow the
instructions at the end
of each email message to
unsubscribe from the
particular list. To
unsubscribe from all
CPALead's email lists, a
person must send an
email to
network@cpalead.com.
CPALead's unsubscribe
process impacts only the
future delivery of
electronic mailings
disseminated by CPALead
on its own behalf. You
may still receive
electronic mailings sent
on behalf of Third
Parties and your
personal information may
still be shared with
Third Parties for use in
offline marketing and
data appends, including
email appends.
You should also note
that unsubscribing from
CPALead's electronic
mailings will not
automatically
unsubscribe the
subscriber's information
from any Third Party
associates and licensees
of the data. Since Third
Party associates and
licensee partners
maintain separate
databases from CPALead,
and you will need to
unsubscribe from each
source individually, if
desired. This allows you
the freedom to pick and
choose which
subscriptions to
maintain and which to
discontinue.
2.3 Content of
Email Messages.
In certain commercial
email messages sent by
CPALead, an Advertiser's
name will appear in the
"From:" line but hitting
the "Reply" button will
cause a reply email to
be sent to CPALead. The
"Subject:" line of
CPALead email messages
will usually contain a
line provided from the
Advertiser to CPALead.
2.4 Solicited
Email.
CPALead only sends email
to individuals who have
agreed on the Websites
to receive email from
CPALead or to
individuals who have
agreed on Third Party
websites to receive
email from Third
Parties. As such CPALead
does not send
unsolicited email
messages. As a result,
statutes requiring
certain formatting for
unsolicited email are
not applicable to
CPALead's email
messages.
2.5 Targeted
Advertising.
CPALead uses Individual
Information to target
advertising to an
individual. When an
individual is using the
Internet, CPALead uses
Technology Information
(see also Section 2.7
below) to associate an
individual with that
person's Individual
Information, and CPALead
attempts to show
advertising for products
and services in which
the person has expressed
an interest in the
Surveys, indicated an
interest by means of
Technology Information,
and otherwise. CPALead
may, at its discretion,
target advertising by
using email, direct
mail, telephones, cell
phones, and other means
of communication to
provide promotional
offers.
2.6 Direct Mail
and Telemarketing.
CPALead uses Individual
Information to
advertise, directly or
indirectly, to
individuals using direct
mail marketing or
telemarketing using
telephones and cell
phones.
2.7 Use of
Technology Information.
CPALead uses Technology
Information (1) to match
a person's Survey
Information and Third
Party List Information
to other categories of
Individual Information
to make and improve
profiles of individuals,
(2) to track a person's
online browsing habits
on the Internet, (3) to
determine which areas of
CPALead's websites are
most frequently visited.
This information helps
CPALead to better
understand the online
habits of individuals so
that CPALead can target
advertising and
promotions to them.
2.8 Profiles of
Individuals.
CPALead uses Individual
Information to make a
profile of an
individual. A profile
can be created by
combining Survey
Information and Third
Party List Information
with other sources of
Individual Information
such as behavioral and
other information
obtained from public
databases. CPALead may
also publish personal
information in the form
of a testimonial if such
information is sent to
CPALead by you.
2.9 Storage of
Individual Information.
CPALead stores the
Individual Information
in a database on our
computers. Our computers
have security measures
(such as a firewall) in
place to protect against
the loss, misuse, and
alteration of the
information under
CPALead's control. Not
withstanding such
measures, CPALead cannot
guarantee that its
security measures will
prevent our computers
from being illegally
accessed, and the
Individual Information
on them stolen or
altered.
3. Dissemination
of Individual
Information.
3.1 Sale or
Transfer to Third
Parties.
CPALead MAY SELL OR
TRANSFER INDIVIDUAL
INFORMATION TO THIRD
PARTIES FOR ANY PURPOSE
IN CPALead'S SOLE
DISCRETION.
3.2 Order
Fulfillment.
CPALead will transfer
Individual Information
to Third Parties when
necessary to provide a
product or service that
a person orders from
such Third Party while
using CPALead websites
or when responding to
offers provided by
CPALead.
3.3 Legal
Process.
CPALead may disclose
Individual Information
to respond to subpoenas,
court orders, and other
legal processes.
3.4 Summary
Data.
CPALead may sell or
transfer
non-individualized
information, such as
summary or aggregated
anonymous information
about all persons or
sub-groups of persons.
3.5 Access.
Individuals have access
to their Individual
Information collected to
provide an opportunity
for an individual to
correct, amend, or
delete such information.
Access can be obtained
by contacting
network@cpalead.com.
CPALead may also grant
advertising clients and
email services
providers' access to an
individual's email
address to verify the
origin of the Individual
Information collected.
4. Privacy
Practices of Third
Parties.
4.1 Advertiser
cookies and web beacons.
Advertising agencies,
advertising networks,
and other companies
(together,
"Advertisers") who place
advertisements on the
Websites and on the
Internet generally may
use their own cookies,
web beacons, and other
technology to collect
information about
individuals. CPALead
does not control
Advertisers' use of such
technology and CPALead
has no responsibility
for the use of such
technology to gather
information about
individuals.
4.2 Links.
The Websites and email
messages sometimes
contain hypertext links
to the websites of Third
Parties. CPALead is not
responsible for the
privacy practices or the
content of such other
websites. Linked
websites may contain
links to websites
maintained by Third
Parties. Such links are
provided for your
convenience and
reference only. CPALead
does not operate or
control in any respect
any information,
software, products or
services available on
such Third Party
websites. The inclusion
of a link to a web site
does not imply any
endorsement of the
services or the site,
its contents, or its
sponsoring organization.
4.3 Affiliated
Companies.
CPALead may disclose,
transfer, and sell
Individual Information
to entities affiliated
with CPALead in
CPALead's discretion.
5. Unsubscribe
Procedures.
If you wish to
discontinue receiving
email messages from
CPALead, you have
several options:
a.Unsubscribe
from one email list.
To unsubscribe from a
particular list, either
(1) send an email to
network@cpalead.com or
(2) follow the
instructions in each
promotional email
message sent by CPALead.
a.Unsubscribe
from all of CPALead's
email lists.
We reserve the right to
add Individual
Information to multiple
lists maintained by
CPALead. To globally
unsubscribe from all of
CPALead's lists, send an
email to
network@cpalead.com.
For more information
about protecting your
privacy, you may wish to
visit: www.ftc.gov. If
you have questions about
this policy, please
contact us at
troy@cpalead.com.
CPALead may receive
information about
individuals from Third
Parties or from other
sources of information
outside of CPALead
including information
located in public
databases ("Outside
Information").
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