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POSH ON PENNIES® (“POSH ON PENNIES,” POSHONPENNIES.COM,” or “POP”) is deeply committed to respecting and protecting the privacy and security rights of users and the information you share with us at the POP website (the “Website”). POP created this Privacy Policy to give you (“You” or “Your”) assurance of POP’s commitment to fair information practices and to the protection of Your privacy as You visit and use the Website (the “Privacy Policy”).

We believe YOU have the right to know everything regarding the information we collect about YOU, how this information benefits You, and how you can say “no” to the use of any of this information. This Privacy Policy explains what we do with your information and what You can expect from POP. By using the Website, You indicate your acceptance of POP’s Privacy Policy.

POP’s data collection and retention practices are designed to provide transparency, accountability and choice regarding the management and use of Your personal information (“Personal Information”). If You have questions or complaints regarding our Privacy Policy or practices, please contact us at via e-mail at [email protected] This Privacy Policy is only applicable to the Website and not to any websites of third-parties (“Third-Party Websites”), which may have data collection, storage and use practices and policies that differ materially from this Privacy Policy. You should consult privacy policies for all other sites, as POP has no control over information submitted to or collected by such third-parties.

You may visit POP at any time without providing Your identity or revealing any personal information about yourself. However, when You visit our Website, we may collect and store Your computer and connection information, statistics on page views, traffic to and from POP, ad data, IP address and standard web log information, and information from other companies, such as demographic and navigation data. In order to be approved as registered user with POP, You will be required to choose a user-name. This user-name may be displayed throughout POP and therefore provided to the public. Unless You associate your user-name with Your Personal Information, users will not be able to personally identify Your activities on POP.

When visiting POP from a public or shared computer, certain information about You, such as Your user-name, may also be visible to others who may use the computer after Your use.

BY USING THE WEBSITE, YOU REPRESENT AND WARRANT THAT YOU HAVE READ AND UNDERSTOOD, AND AGREE TO THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT UNDERSTAND OR DO NOT AGREE TO BE BOUND BY THIS PRIVACY POLICY, YOU MUST IMMEDIATELY LEAVE THE WEBSITE.

POP 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:(http:/ /www.truste.com/privacy_seals_and_services/consumer_privacy/privacy- programs- requirements.html) 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. 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 [PUT SOMETHING ERE: COMPANY CONTACT INFO]. If you are not satisfied with our response you can contact TRUSTe at http://www.watchdog.truste.com/pvr.php?page=complaint.

1. CHILDREN’S PRIVACY

We care about the safety of children. POP does not solicit or knowingly collect Personal Information from children under the age of 13. Children should always get permission from their parents before sending any information about themselves (such as, their names, e- mail addresses, and phone numbers) over the Internet to us or to anyone else. We encourage You to become involved in Your children’s on-line experience and to share Your interest in our Website with Your young ones. If POP obtains actual knowledge that it has collected Personal Information from a child under the age of 13, POP will immediately delete such information from its database.

2. INFORMATION COLLECTION PRACTICES

POP collects Personal Information from you only if you voluntarily submit such information to us on the Website and through e-mail. When visiting the Website, we collect user-specific information on what pages are visited.

Personal Information

When You register for our service, You will be asked to provide POP certain Personal Information. Personal Information includes, without limitation: Your first name, last name, user-name, password, e-mail address, gender, date of birth, city, state, and zip code. The Website will not gather Personal Information surreptitiously.

In general, once You provide us with Your required Personal Information, You are no longer anonymous. In providing us with Your Personal Information, You consent to the transfer and storage of such information on our servers. In addition to the foregoing Personal Information in connection with your registration and use of POP, we may collect and store the following Personal Information:

  • all transactional information based on your activities on POP;
  • any correspondence sent to us; and
  • other supplemental information from third-parties.

     

Our primary purpose in collecting Personal Information is to provide You with a safe, smooth, efficient, and customized experience. You agree that we may use Your Personal Information to:

provide the services and customer support You request;

resolve disputes;

troubleshoot problems;

prevent potentially prohibited or illegal activities;

enforce our Terms and Conditions;

customize, measure and improve our services, content and advertising; and

inform you about our services, targeted marketing, service updates, and promotional offers.

Without limiting the above, in an effort to respect Your privacy and our ability to keep the community free from bad actors, POP will maintain an e-mail database, in-house, and will never sell Your data, to include postal and/or e-mail address(es). Further, we will not otherwise disclose Your Personal Information to law enforcement, other government officials, or other third-parties without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.

Traffic Data

Like most website operators, POP automatically gathers information of the sort that browsers automatically make available, including: (i) IP addresses; (ii) domain servers; (iii) types of computers accessing the Website; and (iv) types of Web browsers accessing the Website (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify You.

Cookies

POP uses so-called “Cookies,” which are files that are stored on Your computer that can be retrieved to assist in customizing Your experience with the online service. A “Cookie” is a string of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website. The purpose of a “Cookie” is to (1) support the functionality of the Website, for example by keeping track of Your visual preferences or controlling the frequency of “pop-up” windows, and (2) identify the user as a unique user of the Website.

POP uses “Cookies” to customize Your experience on the Website to Your interests, to ensure that You do not repeatedly see content or informational messages that may be of no interest to You, and to store Your password so You do not have to re-enter it each time You visit the Website.

If You want to disable “Cookies,” there is a simple procedure in most Internet browsers that allows You to turn-off “Cookies.” Please remember, however, that “Cookies” may be required to allow You to use certain features of the Website.

For additional information on POP’s uses of “Cookies,” see the section concerning Information Use and Disclosure Practices, below.

IF YOU DO NOT WISH TO HAVE “COOKIES” PLACED ON YOUR COMPUTER, YOU SHOULD ADJUST THE CORRESPONDING SETTING IN YOUR BROWSER TO REFUSE “COOKIES” BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN OF THE SERVICES AND CERTAIN

FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF “COOKIES.” IF YOU REFUSE “COOKIES,” YOU ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

Web Beacons/Web Bugs

POP utilizes 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 customer’s Personal Information. Rather, we use clear gifs in our HTML-based e-mails to let us know which e-mails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

Some of our Third-Party Websites (e.g., Third-Party Advertising Promotions) use “Cookies” and Web Beacons on the Website. We have no access to or control over these third-party tracking technologies.

You are under no obligation to provide Personal Information, with the caveat that Your refusal to do so may prevent You from using certain of the Services.

3. INFORMATION USE AND DISCLOSURE PRACTICES

(a) Traffic Data and Information Gathered Using “Cookies”

POP analyzes Traffic Data and information gathered using “Cookies” to help POP better understand who is using the Website and how they are using it. By identifying patterns and trends in usage, POP is able to better design the Website to improve Your experience, and to serve You more relevant and interesting content and third-party advertising promotions. From time to time, POP may release Traffic Data and information gathered using “Cookies” in the aggregate, such as by publishing a report on trends in the usage of the Website. POP does not attempt to link information gathered using “Cookies” to Personal Information.

(b) Personal Information

Generally, POP uses Your Personal Information to send You information about POP and POP’s- products and services, and to contact You when necessary in connection with the Services.

POP uses Your Demographic Data to customize and tailor Your experience on the Website.

Except under the following circumstances, POP will keep Your Personal Information private, and will not share it with third-parties.

Third-Party Marketing: By submitting Your Personal Information to us and opting-in, You grant us the right, subject to applicable state and federal law, to use that Personal Information for marketing purposes. We may rent, lease and/or otherwise distribute any and all Personal Information with or to any third-party for any and all uses permitted by this Privacy Policy and applicable law. These third- parties may include: (a) providers of the products and/or service that

you requested and/or won by and through our Website; (b) providers of direct marketing services and applications; (c) e-mail marketers; (d) telemarketers; and (e) direct marketers; and

POP discloses Personal Information to those who help it provide services, including those who perform technical, administrative and data processing tasks such as hosting, fulfillment, and data storage and security. These service providers are prohibited from using this Personal Information for any other purpose including their own marketing purposes; and

POP discloses Personal Information when required to do so by law, or in response to a subpoena or court order, or when POP believes in its sole discretion that disclosure is reasonably necessary to protect the property or rights of POP, third-parties, or the public at large; and

POP reserves the right to transfer all Personal Information in its possession to a successor organization in the event of a merger, acquisition, or bankruptcy or other sale of all or a portion of POP’s assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personal Information will be subject to this Privacy Policy, or to a new privacy policy if You are given notice of that new privacy policy and an opportunity to affirmatively opt-out of it. Personal Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by a POP successor organization.

(c) Opting-In

POP does not share Personal Information with anyone, unless You “opt in” to having Your information shared with third-parties, or we have informed You of a change to our Privacy Policy so that You can then choose to opt-out. It’s that simple.

If you have opted-in to receiving information from third-parties, we will provide You with a way to tell us that You no longer want us to share Personal Information and that You no longer want to receive promotional and/or marketing information about products, services, and offerings from any third-parties. We will also provide You with a way to update the Personal Information that You share with us during registration. Once You have “opted-in” and agreed that Your information may be shared with third-parties or You have responded directly to an offer by any third-party on the POP Website, POP will not be able to update any of Your Personal Information that has been transferred to such third-parties or opt You out of such third-parties

so that You no longer receive their promotional and/or marketing information. Instead, You must either contact that third-party or refer to their individual privacy policy to update Your Personal Information, or to let them know that You no longer want to receive promotional and/or marketing information about their products, services, or offerings.

4. CONSENT TO RECEIVE E-MAIL FROM POP

By establishing an account with POP, You consent to receive periodic commercial/promotional e-mail communications from POP concerning POP – products and services. You may opt-out of receiving such communications at any time by (a) following the unsubscribe instructions contained in each e-mail; (b) sending an e-mail to [email protected]; (c) writing to us at : P.O. Box 390742 Mountain View CA 94039.

5. SECURITY OF PERSONAL INFORMATION

POP has implemented and maintains generally accepted industry standards to protect against the unauthorized access, use, modification, destruction or disclosure of Your Personal Information both during transmission and once we receive it. The security of Your personal information is important to us. When you enter sensitive information during the registration process, we encrypt that information using state-of-the-art technology.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Your personal information, we cannot guarantee its absolute security.

POP assures you that we will use Your e-mail address, with Your express consent, only for the purposes stated in the Terms of Use. We will not otherwise rent or sell Your e-mail address to third-parties, and we will prevent Your e-mail address from being recorded by “web crawlers” or “web spiders” to the best of our ability. If You believe that your e-mail address has been recorded in this way, please let us know immediately.

If You have any questions about security on our Website, You can e-mail us at [email protected]

6. LINKS TO OTHER WEBSITES

The Website includes links to other Third-Party Websites whose privacy practices may differ from those of POP. If You submit Personal Information to any of a Third-Party Website, your Personal Information is governed by their privacy statements. POP encourages You to carefully read the privacy statement of any Third-Party Website You visit.

7. USER ABILITY TO ACCESS, UPDATE, AND CORRECT PERSONAL INFORMATION

POP wants Your Personal Information to be complete and accurate. By using the Website, You represent and warrant that all information You provide on any registration form or otherwise in connection with Your use of the Website and Services will be complete and accurate, and that You will update that information as necessary to maintain its completeness and accuracy. To confirm the completeness and accuracy of, or make changes to, Your Personal Information, please email us at [email protected]

8. PROMOTIONAL ACTIVITIES

From time to time, POP may conduct contests, giveaways and other promotions (collectively, “Promotional Activities”). Any information submitted in connection with

Promotional Activities will be treated in accordance with this Privacy Policy. From time to time, POP may also ask You to participate in surveys designed to help POP improve the Website or services. Any Personal Information provided to POP in connection with any survey will be used only in relation to that survey, and may be disclosed to third-parties not bound by this Privacy Policy only in aggregated form.

9. RULES FOR SUBMISSIONS AND MESSAGES IN CHAT ROOMS

If You use a bulletin board or chat room on the Website, You should be aware that any Personal Information that You submit there can be read, collected and/or used by other users of those forums, and could be used to send You unsolicited messages. Responsibility for what is posted in the discussion groups or other public forums lies with each user – You alone are responsible for the content of Your messages and the consequences of any such messages. We cannot and do not review every submission a user may make. We neither endorse nor guarantee the accuracy or propriety of any submission. We do, however, reserve the right but do not assume the obligation to restrict or prohibit Your use of our Website if we believe you are violating any of the terms of the agreement and to remove, edit, or relocate any submission as we see fit whether for legal or other reasons.

We are not responsible for the Personal Information that You choose to submit in the Website forums. We reserve the right to terminate the member status of anyone who uses the forums in a manner inconsistent with our Terms of Service.

10. UPDATES AND CHANGES TO PRIVACY POLICY

If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this policy, we will notify You here, by e-mail, or by means of a notice on our home page within thirty (30) days of such changes being made.

11. REVOKING CONSENT/DELETING YOUR ACCOUNT

You can delete or deactivate your POP account at any time by e-mailing [email protected] When You delete your account, Your Personal Information is removed from our database, unless we are required to save the data by applicable law, to prevent fraud, resolve disputes, troubleshoot problems, assist with investigations, and/or enforce our General Terms of Use. As a rule it takes two to three business days until Your Personal Information is completely removed from all records.

You can access, review and change most of Your Personal Information by logging on to POP at any time. However, some of your Personal Information can only be changed by contacting our Customer Service at [email protected] You are required to promptly update your Personal Information if changes occur or information is inaccurate.

Your POP account and profile and the information contained therein are password protected. Please note that You are not permitted to provide Your password to anyone else. POP will never ask for Your password in e-mails that You receive unexpectedly or that You did not request. Please remember to log-out of Your account and to close Your internet browser window when You leave the POP Website; this is especially important if you use a PC in a public location. At present, this is the safest way to ensure that no one has access to Your Personal Information. We

assume no liability for the abuse of login data and passwords used.

POP treats data as a valuable asset that must be safeguarded and protected. As set forth above, we use reasonable security measures to protect Your Personal Information against unauthorized access and disclosure.

12. Member Conduct

You understand that all information, data, text, software, music, sound, photographs, graphics, video, messages or other materials (“Content”), whether publicly posted or privately transmitted, are the sole responsibility of the person from which such Content originated. This means that You, and not POP, are entirely responsible for all Content that You upload, post, or otherwise transmit. POP does not control the Content posted and, as such, does not guarantee the accuracy, integrity, or quality of such Content. You understand that by using the Website, You may be exposed to Content that is offensive, indecent or objectionable.

You agree to not use the Website in order to:

upload, post, or otherwise transmit any Content that is unlawful, harmful, threatening, abusive, harassing, tortious, defamatory, vulgar, obscene, libelous, invasive of another’s privacy, hateful, or racially, ethnically or otherwise objectionable;

harm minors in any way;

impersonate any person or entity, including, but not limited to, a POP official, forum leader, guide or host, or falsely state or otherwise misrepresent your affiliation with a person or entity;

forge headers or otherwise manipulate identifiers in order to disguise the origin of any Content transmitted through the Website or develop restricted or password- only access pages, or hidden pages or images (those not linked to from another accessible page);

upload, post, or otherwise transmit any Content that You do not have a right to transmit under any law or under contractual or fiduciary relationships (such as inside information, proprietary and confidential information learned or disclosed as part of employment relationships or under non-disclosure agreements);

upload, post, or otherwise transmit any Content that infringes any patent, trademark, trade secret, copyright, or other proprietary rights of any party;

upload, post, or otherwise transmit any unsolicited or unauthorized advertising, promotional materials, “junk mail,” “spam,” “chain letters,” “pyramid schemes,” or any other form of solicitation, except in those areas of the Website that are designated for such purpose;

upload, post, or otherwise transmit any material that contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications

equipment;

interfere with or disrupt the servers or networks connected to the Website, or disobey any requirements, procedures, policies or regulations of networks connected to the site;

intentionally or unintentionally violate any applicable local, state, national or international law, including, but not limited to, regulations promulgated by the U.S. Securities and Exchange Commission, any rules of any national or other securities exchange, including, without limitation, the New York Stock Exchange, the American Stock Exchange or the NASDAQ, and any regulations having the force of law;

stalk” or otherwise harass another;

collect or store personal data about other users;

promote or provide instructional information about illegal activities, promote physical harm or injury against any group or individual, or promote any act of cruelty to animals;

use Your home page (or directory) as storage for remote loading or as a door or signpost to another home page; or

engage in commercial activities without the express written consent of POP. This includes, but is not limited to, the following activities: offering for sale any products or services, soliciting for advertisers or sponsors, conducting raffles or contests that require any type of entry fee, displaying a sponsorship banner of any kind, including those that are generated by banner or link exchange services, displaying banners for services that provide cash or cash-equivalent prizes to users in exchange for hyperlinks to their websites.

13. Rights

You acknowledge that we acquire all Rights to use any posted materials as described above so that we do not violate any Rights You may have in materials You post. By submitting content to or through the Website, You grant us the non-exclusive right to reproduce, modify, and distribute it as we see fit in any medium and for any purpose in any form, media, or technology now known or later developed. You also permit any other user to access, display, and print such content for personal use. You vouch that any material you submit does not violate, plagiarize, or infringe upon the right of any third-party, including copyright, trademark, or proprietary rights. If non-original content is included in Your posting, You must obtain permission from the content owner and attribute it.

14. CALIFORNIA PRIVACY RIGHTS

A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California customer”) is entitled to request information about whether the business has disclosed personal information to any third-parties for the third-parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third-parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy) a policy of not disclosing customer’s personal information to third-parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and providing a cost free means to exercise that right.

15. Copyrights and Copyright Agent

POP respects the rights of all copyright holders. If You believe that Your work has been copied and used on our Website in a way that constitutes copyright infringement, please provide POP Copyright Agent the following information required by Section 512 of the Digital Millennium Copyright Act:

A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed;

Identification of the copyright work claimed to have been infringed, or, if multiple copyrighted works at a single on-line site are covered by a single notification, a representative list of such works at that site;

Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit us to locate the material;

Information reasonably sufficient to contact the complaining party;

A statement that the complaining party has a good-faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law; and

A statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

POP Copyright Agent may be contacted at: Copyright Agent, P.O. Box 390742 Mountain View CA 94039.

We appreciate the opportunity to serve You!

Posh On Pennies® owns and operates the PoshOnPennies.com Website. You may contact us directly if you have any questions regarding the content and material on the Website or if you have any questions about our Privacy Policies. Please contact our Privacy Officer at:

Posh On Pennies® P.O. Box 390742 Mountain View CA 94039

Additionally, You may contact your state or local consumer protection office, The Direct Marketing Association’s Committee on Ethical Business Practices, the Better Business Bureau, or The Federal Trade Commission by phone at (202) FTC-HELP (202/382-4357) and online at www.ftc.gov.

Note: This Privacy Policy applies to POP Website and to POP’sother information gathering activities.

POP complies with all the stringent standards of ethical conduct set forth by the Direct Marketing Association.

© 2010 Posh On Pennies®. All Rights Reserved.