FocalPoint Marketing, LLC d/b/a FocalPoint ("FocalPoint", "we", or "us") is committed to protecting users' privacy. Keeping the information you share with us secure, and making sure that you understand how we collect, use, and maintain information about you, is important to us. This notice (this "Privacy Policy") describes: (i) what information we collect about you, how we collect it, how we use it, with whom we may share it, and what choices you have regarding it; (ii) how you can access, update, or delete information we have collected about you; and (iii) what steps we take to protect personally identifiable information about you. To make it easier for you to review, we have made this Privacy Policy into a separate document, however, it is still part of our agreement with you, and incorporated by reference into the Terms & Conditions of Use, regarding our Web site (www.FocalPointEMarketing.com)together with any replacement, substitute or backup Web sites controlled, owned or operated by us or on our behalf, the "Website"). We encourage you to become familiar with the terms and conditions of both this Privacy Policy and the Terms & Conditions of Use. By accessing and using the Website, you agree that you have read and understand this Privacy Policy and you accept and consent to the privacy practices (and any uses and disclosures of information about you) that are described in this Privacy Policy.

CHANGES TO THIS PRIVACY POLICY
From time to time, we may change our privacy practices, and this Privacy Policy, because of changes in relevant and applicable legal or regulatory requirements, our business practices, or in our attempts to better serve your needs and those of our other customers. Notice of such changes to our privacy practices will be given in the manner described in our Terms & Conditions of Use, and in the event of any such change, a revised Privacy Policy will be posted on the Website. We remind you to check back here often, to be sure you are up-to-date with our privacy practices.

WHAT INFORMATION DO WE COLLECT?
You may visit our Website and, among other things, learn about our company and its products and services. We make general information available on our Website, and you may access it and find out how to contact us, all without your giving us any personally identifiable information. When we use the term "personally identifiable information," we mean information such as your name, street address, town or city, state, zip code, telephone number, instant-messenger nickname, date of birth, e-mail address, and any other information that would allow someone to identify you or contact you. Personally identifiable information might also include information about your transactions or relationship with us.

For example, if you wish to order any of our products or services or otherwise do business or communicate with us, you will be required to provide us with certain personally identifiable information. In addition to your name and contact information, we will collect and maintain your billing address, shipping address, product selections, and credit card number and other payment information. We collect this information to fill your order and receive payment for it, to communicate with you about your order and your registration, and to send you promotional materials.

If you choose to register as a "Subscriber" on our Web site, if you choose to take advantage of other features and opportunities that we make available on our Website, you will also be asked to provide, and we will collect, personally identifiable information about you. For example, during registration on our Website, you will be asked to be provide us with certain information about you and then to select a user name and password. Among other things, your user name and password and help us identify you as a registered or authorized user of the features and functions that you register for or subscribe to. Keep in mind that whenever you enter or input information on the Website, whether you are registering as a Subscriber, signing up for promotions, ordering or purchasing products or services, or otherwise exchanging information or performing transactions or other activities, you choose to provide us with certain information, which we then collect and save. You should be mindful of the information that you choose to submit to us and make sure that this information is complete and accurate.

While not personally identifiable, we may collect information about your computer's Internet protocol (or "IP") address and any Web site that may have referred or directed you to our Website. We use your IP address to help diagnose problems with our server and to administer our Website. Your IP address is also used in analyzing demographic information, none of which is personally identifiable, such as the states or countries that our Website's visitors come from.
We may also track the numbers of visitors to our Website and similar or related information, but no personally identifiable information is collected or obtained in this process. We use this tracking information in the aggregate to help us operate and improve the Website, to improve our products and services, and to select and display advertising and marketing information.
We may also use "cookies" (small text files stored on your computer) to help track and customize your access and use of the Website. Cookies store and retain information that helps us recognize you when you return to the Website following a previous visit. Most popular Internet browser packages allow you to configure the browser so as not to accept cookies. However, setting your browser to reject cookies may, in certain instances, prevent you from taking full advantage of our Website and the materials, products, and services that we make available on the site. We do not currently use cookies to collect any personally identifiable information, although we may use cookies at some point in the future to correlate information that you previously supplied with other information about you, for personalization and tracking purposes.

If you would like to know more about the technical aspects of the information that we collect and how we collect it, please click here to go to our Frequently Asked Questions section for more detailed information.

HOW DO WE USE THE INFORMATION THAT WE COLLECT?
In addition to the uses mentioned above or otherwise described in our Terms & Conditions of Use, we may use the information that we collect about you, including, in some cases, personally identifiable information, to tailor your experience on our Website, to display content we think may be of interest you, or to let us otherwise customize what you see when you visit the Website, according to your preferences. Personally identifiable information that you provide during registration or in purchasing any of our products or services, as well as other information created through our interactions with you, may be saved by us and, in addition to being used to fulfill your orders for our products and services, it may be used to provide you with better service and to better understand your needs and preferences. For example, we use your information to assist us in filling your orders, producing reports, and maintaining quality control, in managing the Website and our business, to contact you concerning your orders, transactions, and other activities, and for other legitimate and lawful business purposes. We may use personally identifiable information about you to contact you and advise you of products or services that are available from us or our suppliers and advertisers, and if you contact us for support or assistance in connection with using the Website, we may use information about you or your system for purposes such as verifying whether your system meets the minimum requirements needed to use the Website and our various services. By using the Website, you acknowledge and consent to our tracking of your use of our Website and related activities, as described above.

WITH WHOM DO WE SHARE THE INFORMATION THAT WE COLLECT?
FocalPoint uses good faith efforts not to disclose or provide third parties with access to personally identifiable information about you other than as expressly described in this Privacy Policy. We will, however, make personally identifiable information about you available to others when we have your consent (that is, you "opt-in" to receiving communications) and when we retain others to work with us to provide products or services that you request from us. When you use co-branded services that we make available (that is, services for which not only FocalPoint's name, but that of another company or entity is used or displayed), you are giving us permission to pass personally identifiable information that you submit or that we collect about you on to our co-branding partner in connection with our marketing relationship with them, and their use of such information then becomes subject to their privacy policies, not ours.

We may exchange information about you with others as necessary to carry out credit approvals or credit checks in connection with your purchases of products or services from us and to prevent fraud and other activities that we are required to monitor and report under applicable laws. We may disclose information about you when responding to subpoenas or court orders, in defending our interests, or when otherwise required by applicable law. Additionally, we may (and you authorize us to) disclose your personally identifiable information to such private entities and law enforcement agencies and other government officials as we, in our sole discretion, believe necessary or appropriate to investigate or resolve possible problems, to protect our business and assets, or to comply with our legal and regulatory obligations, or if we believe your actions have violated applicable law, this Privacy Policy, or our Terms & Conditions of Use, or if you threaten the rights, property, or safety of FocalPoint or its suppliers, advertisers, other customers or users, or anyone else.

We do not sell personally identifiable information that we obtain or collect about you to unaffiliated third parties. We may send you e-mail, and any e-mail that you send to us will be handled as required by any applicable laws. While some of the information that we collect may be aggregated so that it is not personally identifiable and then shared with advertising companies to improve our Website, we do not share personally identifiable information in that process. Except as otherwise provided in this Privacy Policy, we use reasonable efforts to:

• collect and use personally identifiable information only to deliver high quality service, administer our business, and inform you of our products or services;
  
• protect personally identifiable information and limit access to such information to employees who are trained and advised in the proper handling of such information (and employees who violate our security and confidentiality standards are subject to discipline);
  
• prevent disclosure of personally identifiable information to external organizations other than as described in this Privacy Policy, unless we have obtained your consent;
• advise you, in easy to understand language, how you may remove your name from marketing lists;
  
• require any other organization that we retain or engage to provide services for us to conform to our Privacy Policy and allow us to audit them for compliance; and
  
• keep personally identifiable information complete, up-to-date, and accurate, to the extent of our ability, based on information you provide, and our Website provides a convenient and easy means for you to access and update personally identifiable information that you give us and to notify us about inaccuracies (which we will use reasonable efforts to promptly correct).

We may use third parties to display or provide advertising and our Web-based publications, and in some cases, unless you tell us otherwise, your personal information may be disclosed to these third parties for such purposes. These companies may use technology to measure advertising effectiveness, and you should understand that if information about you is disclosed to these companies, it then becomes subject to their privacy practices, not ours, even if we have a business relationship with the company.

As part of its business, FocalPoint provides online marketing services and products to its clients. These services include database management and analysis, e-mail delivery, e-mail tracking, and e-mail campaign reporting. FocalPoint is contractually bound to its clients to keep data about their customers private, and FocalPoint may not share any of this customer data with its other clients. In providing these services to our clients through our Website, FocalPoint sometimes use cookies to help its clients better analyze the success of their e-mail and other online marketing campaigns. Data from the cookies that we use are often correlated with individually identifiable information, but this information is not shared with anyone other than the particular client to which it pertains and is not shared with other clients. Nevertheless, FocalPoint is not responsible for its clients' privacy policies or practices and makes no representations about them. If you have questions about our clients' practices, we recommend that you check their privacy policies or contact them directly.

As FocalPoint continues to grow and develop its business, it is possible that its corporate structure might change or that it might merge or otherwise combine with, or that it or portions of its business might be acquired by, another company. In any such transactions, customer information generally is, will most probably be, and should be expected to be one of the transferred business assets.

WHAT CHOICES DO YOU HAVE REGARDING INFORMATION THAT WE COLLECT?
FocalPoint provides users of its Website with the opportunity to opt-in and opt-out of receiving future promotional or marketing communications (including e-mail communications) from us that are unrelated to orders and transactions that you have submitted or otherwise entered into with us or any other matters that pertain to your status as a Subscriber. These opt-in and opt-out capabilities are provided when you register or sign-up for our e-mail lists and in e-mail messages that we send to you.

For any e-mail lists managed by FocalPoint, users can use the link that is provided in the footer of most e-mail messages to be removed from the list. Alternatively, to opt-out of receiving further messages from us, users can reply to an e-mail message according to the instructions provided at the bottom of the message.

Registered users of the Website who have requested FocalPoint e-mail communications may update, amend, or delete personal information that we store about them by following the "Profile Update" links contained in every FocalPoint e-mail communication.
Notify us in writing any time you do not wish us to share personally identifiable information with any third party. We will remove your personally identifiable information from lists we provide to third parties, generally within thirty days after we receive your notice.


HOW DO WE PROTECT INFORMATION COLLECTED ABOUT YOU?
We maintain reasonable safeguards and use commercially reasonable efforts to protect information that we collect and maintain about you. For example, we use industry standard security technologies and processes, such as Secure Socket Layer (SSL), encryption, and a physically protected data center, to protect data that we collect and store. However, no data transmission or communication over the Internet is 100% secure, and no security measures are completely impenetrable. Third parties may unlawfully intercept transmissions or access systems. We cannot and do not guarantee that any such transmissions, or that any given information, will be totally secure. You agree to immediately notify us of any breach of which you become aware of our Website's security, this Privacy Policy, or the Terms & Conditions of Use.

LINKED SITES
Our Website may contain advertisements and references and links to other Web sites and other companies. We do not control those Web sites or companies and are not responsible for their privacy practices or the content of such Web sites. We strongly encourage you to inquire directly of them in this regard, and we recommend that you check the privacy policies of each Web site that you visit, to be aware of how information obtained or collected about you may be used.

HOW CAN YOU CONTACT US FOR MORE INFORMATION?
If you have questions about our Privacy Policy you can click here to go directly to our Frequently Asked Questions section, which we hope will be helpful and is designed to answer many of your questions. If you cannot find the answer to your questions, or if you don't understand any of the information or don't understand how any particular terms apply to you, you may send us an e-mail at privacy@FocalPointEmarketing.com. Please do not use this e-mail address for any other purpose or any other type of communication with us, as we receive a high volume of e-mails and will not be able to respond if an e-mail sent to this address does not relate to our Privacy Policy or our Terms & Conditions of Use.

ACKNOWLEDGEMENT
BY ACCESSING OR USING OUR WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND CONSENT TO THE PRIVACY PRACTICES, AND TO THE USES AND DISCLOSURES OF INFORMATION WE OBTAIN ABOUT YOU, THAT ARE DESCRIBED IN THIS PRIVACY POLICY, AND YOU AGREE TO BE BOUND BY THE TERMS & CONDITIONS OF USE REFERENCED ABOVE.