Online Privacy Notice

1.     Introduction.

(a)         Web Site Owner. EXECULY™ is the owner of this web site ("EXECULY™ Web Site"). EXECULY™ can be contacted by mail at 342 N Queen St. Rear Lancaster, PA 17603, by phone at 877-675-4500, or by e-mail at info@execuly.com. This online privacy notice discloses EXECULY™ information practices for this EXECULY™ Web Site, including what type of personal identifiable information is requested in order to make a purchase, how the information is used, and with whom the in-formation is shared. [Note that other EXECULY™ web sites may be governed by privacy notices containing different information practices applicable to those sites.]

(b)        [Anonymous] Web Site Visits. In general, you can visit on the EXECULY™ Web Site without [disclosing OR revealing ] any personal information. EXECULY™ does [does OR does not] [keep track of the domains from which people visit us. OR EXECULY™ analyzes the data gathered from Web Site visits for trends and statistics, and then EXECULY™ discards the gathered data.]

(c)         Web Site Transactions. At times, EXECULY™ will need personal information regarding a customer or a prospect. For example to process an order or provide a subscription, EXECULY™ may need to know a customer's name, mailing address, e-mail address and credit card details. It is EXECULY™'s intent to inform you know before EXECULY™ collects personal information, such as user's name and/or address on the Internet. If you tell us that you do not wish to have this information used as a basis for further contact with you, EXECULY™ will respect your wishes.

(d)        Third Party Certification. EXECULY™ is a member of the [name of third party certification program], an independent, nonprofit organization that promotes privacy policies of disclosure and informed consent. [If applicable: EXECULY™ also abides by the Safe Harbor framework as set forth by the United States Department of Commerce regarding the collection, use and retention of information collected from the European Union.]

2.     Personal Information That May Be Collected.

(a)         Identifying Information. In order to make a purchase [to make a purchase OR to access designated subscriber services and /or restricted areas within the EXECULY™ Web site], EXECULY™ will request a user to provide certain personal identifying information, which may include: name, postal address, e-mail address, [screen name, password,] [daytime] telephone number, facsimile number, method of payment, and, if applicable, credit card number. EXECULY™ may request additional information necessary to establish and maintain customer's account.

(b)        Service Quality Monitoring. Some Web site transactions may require a customer to telephone EXECULY™, or EXECULY™ to call the customer. EXECULY™ will not contact you by telephone without your prior consent, except to confirm an order placed online and/or to inform a customer of the status of such order. Customer should be aware that it is EXECULY™'s practice to monitor, and in some cases record such calls for staff training or quality assurance purposes.

(c)         Information from Children. EXECULY™ does not sell products or services for purchase by children, and will not collect or post information from a child under the age of [16 OR 17 OR 18] without the involvement of a parent or guardian. EXECULY™ will notify the child's parent or guardian at the e-mail address provided by the prospective customer, alerting the parent or guardian to the child's use of the Web site and providing instructions as to how the parent or guardian can delete the child's registration from the Web site. EXECULY™ does not use personally identifying information collected from children for marketing or promotional purposes and does not disclose such information to any third party for any purpose whatsoever.]

(d)        Lost or Stolen Information. If a customer's [credit card and/or password] is lost or stolen, the customer should promptly notify EXECULY™ in order to enable EXECULY™ to cancel the lost or stolen information and to update its records with a changed [credit card and/or password].

(e)         Chat Rooms, Forums, and Bulletin Boards. If customer participates in an EXECULY™ chat room, discussion forum, or posts messages to an EXECULY™ bulletin board, customer should be aware that the information disclosed and shared will be broadly available to other persons, both inside of and/or outside EXECULY™, who have access to that chat room, forum or bulletin board. Some individual EXECULY™ chat rooms, forums or bulletin boards have additional rules and conditions regarding participation. Also, participant's expressed opinion is his or her own and should not be considered as reflecting the opinion of EXECULY™.

(f)          Links to Other Web Sites. An EXECULY™ Web site may contain links to other web sites. EXECULY™ is not responsible for the privacy practices or the content of those other Web sites.

3.     Uses Made of the Information.

(a)         Limited Uses Identified. Without customer's prior consent, EXECULY™ will not use your personal identifiable information for any purpose other than that for which it is submitted. EXECULY™ uses personal identifiable information to reply to inquiries, handle complaints, provide operational notices and in program record-keeping. EXECULY™ also processes billing and business requests related to EXECULY™ Web Site participation.

(b)        Marketing Uses. Unless customer marks an "x" on the opt-out option box herein provided, EXECULY™ reserves the right to provide customer with information about EXECULY™'s Web site, EXECULY™ products and services, and related information in which customer has indicated an interest.

(c)         Stored Information Uses. EXECULY™ stores [and retains] [the information provided by customer OR the information entered on the EXECULY™ Web site]. [This information is used to compile a customer's purchase history in order to enable EXECULY™ to recommend products, services, or special offers that would be of interest to a customer. OR Stored information is used by EXECULY™ {and/or EXECULY™ agents}: to support customer interaction with the EXECULY™ Web site; to deliver customer purchases; and/or to contact customer again about other EXECULY™ services and products.]

(d)        Online Advertising. Some companies that help EXECULY™ deliver interactive on-line advertising, such as banner ads, may collect and use information about EXECULY™'s customers to help EXECULY™ better understand the types of advertising or promotions that are most appealing to EXECULY™'s customers. After it is collected the information is aggregated so it is not identifiable to a specific individual. If, however, customer would prefer that these companies not collect such information, please mark an "x" on the opt-out option box herein provided.

4.     Disclosure of the Information.

(a)         Within Corporate Organization. EXECULY™ is a multinational organization, with legal entities, business processes, management structures, and technical systems that cross borders. EXECULY™ may share your personal information within the EXECULY™ corporate organization, and may transfer the information to countries in the world where EXECULY™ conducts business. Some countries may provide less legal protection for customer personal information. [In such countries EXECULY™ will still handle customer personal information in the manner describe herein.]

(b)        Mergers and Acquisitions. Circumstances may arise where for business reasons, EXECULY™ decides to sell, buy, merge or otherwise reorganize its businesses in the United States or some other country. Such a transaction may involve the disclosure of personal identifying information to prospective or actual purchasers, and/or receiving such information from sellers. It is EXECULY™'s practice to seek appropriate protection for information in these types of transactions.

(c)         Agents. EXECULY™ employs or engages other companies and individuals to perform business functions on behalf of EXECULY™. These persons are provided with personal identifying information required to perform their functions but are prohibited by contract from using the information for other purposes. These persons engage in a variety of functions which include, but are not limited to, fulfilling orders, delivering packages, removing repetitive information from customer lists, analyzing data, providing marketing assistance, processing credit card payments, and providing customer services.

(d)        Affiliated Businesses. EXECULY™ works closely with affiliated businesses operating web site stores, providing services or selling products on each other's Web sites. These businesses identify themselves to customers. Customer information related to a transaction with an affiliated business is shared with that affiliated business.

(e)         Marketing Analysis by Third Parties. EXECULY™ reserves the right to disclose to third parties personal information about customers for marketing analysis; however, any information disclosed will be in the form of aggregate data that does not describe or identify an individual customer.

(f)          Disclosure to Governmental Authorities. Under certain circumstances, personal information may be subject to disclosure pursuant to a judicial or other government subpoenas, warrants or orders.

5.     Use of Computer Tracking Technologies.

(a)         No Tracking of Personal Information. EXECULY™'s Web Site(s) are not set up to track, collect or distribute personal information not entered by visitors. Through web site access logs EXECULY™ does collect clickstream data and HTTP protocol elements, which generate certain kinds of non-identifying site usage data, such as the number of hits and visits to our sites. This information is used for internal purposes by technical support staff for research and development, user analysis and business decision making, all of which provides better services to the public. The statistics garnered, which contain no personal information and cannot be used to gather such information, may also be provided to third parties.

(b)        Use of Cookies. EXECULY™, or its third-party vendors, collects non-identifiable and personal information through the use of various technologies, including "cookies". A cookie is an alphanumeric identifier that a Web site can transfer to customer's hard drive through customer's browser. The cookie is then stored on customer's computer as an anonymous tag that identifies the customer's computer, but not the customer. Cookies may be sent by EXECULY™ or its third party vendors. Customer can set its browser to notify customer before a cookie is received, giving an opportunity to decide whether to accept the cookie. Customer may also set its browser to turn off cookies; however, some Web sites may not then work properly.

(c)         Use of Web Beacon Technologies. EXECULY™ may also use Web beacon or other technologies to better tailor its Web site(s) to provide better customer service. If these technologies are in use, when a visitor accesses these pages of the Web site, a non-identifiable notice of that visit is generated which may be processed by EXECULY™ or by its suppliers. Web beacons usually work in conjunction with cookies. If customer does not want cookie information to be associated with customer's visits to these pages, customer can set its browser to turn off cookies; however, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.

(d)        Collection of Non-Identifiable Information. EXECULY™ may collect non-identifiable information from user visits to the EXECULY™ Web site(s) in order to provide better customer service. Examples of such collecting include: traffic analysis, such as tracking of the domains from which users visit, or tracking numbers of visitors; measuring visitor activity on EXECULY™ Web site(s); Web site and system administration; user analysis; and business decision making. Such information is sometimes known as "clickstream data." EXECULY™ or its contractors may use this data to analyze trends and statistics.

(e)         Collection of Personal Information. EXECULY™ collects personal identifying information from customer during a transaction. EXECULY™ may extract some personally identifying information about that transaction in a non-identifiable format and combine it with other non-identifiable information, such as clickstream data. This information is used and analyzed only at an aggregate level (not at an individual level) to help EXECULY™ understand trends and patterns. This information is not reviewed at an individual level.

6.     Information Security.

(a)         Commitment to Online Security. EXECULY™ employs physical, electronic and managerial procedures to safeguard the security and integrity of personal information. Billing and payment data is encrypted whenever transmitted or received online. Personal information is accessible only by staff designated to handle online requests or complaints. All EXECULY™ agents and contractors with access to personal information on the EXECULY™ web site(s) are also bound to adhere to EXECULY™ security standards.

(b)        No Liability for Acts of Third Parties. EXECULY™ will exercise all reasonable efforts to safeguard the confidentiality of customer personal information. However, transmissions protected by industry standard security technology and implemented by human beings cannot be made absolutely secure. Consequently, EXECULY™ shall not be liable for unauthorized disclosure of personal information due to no fault of EXECULY™ including, but not limited to, errors in transmission and unauthorized acts of EXECULY™ staff and/or third parties.

7.     Privacy Policy Changes and Opt-Out Rights.

(a)         Changes to Privacy Policy. This privacy notice was last updated on [date]. EXECULY™ reserves the right to update its privacy policy statement at any time. A notice of such change will be posted on the EXECULY™ Web site for thirty (30) days prior to the implementation of such change. There are two boxes at the end of EXECULY™'s notice of change (1) an "I accept" box, and (2) an "I do not accept" box. If customer does not mark the "I do not accept" box, customer will be deemed to have accepted EXECULY™'s privacy policy updates.

(b)        Opt-Out Right. [Customer and/or prospective customer] has the right at any time to cease permitting personal information to be collected, used or disclosed by EXECULY™ and/or by any third parties with whom EXECULY™ has shared and/or transferred such personal information. Right of cancellation may be exercised by contacting EXECULY™ via e-mail [e-mail address], telephone or postal mail. After processing the cancellation, EXECULY™ will delete customer or prospective customer's personal information from its data base.

8.     Access Rights to Data.

(a)         Information Maintained by EXECULY™. Upon customer's request, EXECULY™ will provide a reasonable description of customer's personally identifiable information that EXECULY™ maintains in its data bank. EXECULY™ can be contacted by e-mail at [provide e-mail address], telephone [provide phone number], or postal mail [provide EXECULY™ address].

(b)        Corrections and Changes to Personal Information. Help EXECULY™ to keep customer personal information accurate. If customer's personal information changes, or if customer notes an error upon review of customer information that EXECULY™ has on file, please promptly e-mail EXECULY™ [provide e-mail address] and provide the new or correct information.

(c)         Your California Privacy Rights. Beginning on January 1, 2005, California Civil Code Section 1798.83 permits customers of EXECULY™ who are California residents to request certain information regarding EXECULY™’s disclosure of personal information for their direct marketing purposes. To make such a request, please write to: . Within 30 days of receiving such a request, EXECULY™ will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. EXECULY™ reserves its right not to respond to requests submitted other than to the address specified in this paragraph.

California’s privacy laws require a company to provide notice to California users of their rights to receive information on to which entities their information was shared for marketing purposes.

9.     Accountability.

(a)         Questions, Problems and Complaints. If you have a question about this policy statement, or a complaint about EXECULY™ compliance with this privacy policy, you may contact EXECULY™ by e-mail [provide e-mail address]. If EXECULY™ is unable to resolve your complaint to your reasonable satisfaction or if customer does not receive acknowledgment of an inquiry, customer may elect to proceed by contacting [provide name of third party privacy service organization and information on how to contact the organization].

(b)        Terms of Use. If customer chooses [to enter into a purchase order OR to subscribe to EXECULY™'s services], customer's action is hereby deemed acceptance of EXECULY™ practices described in this policy statement. Any dispute over privacy between customer and EXECULY™ is subject to the provisions of this notice and to EXECULY™'s [Terms of Use Agreement OR Conditions of Use] which is hereby incorporated herein and which can be read at www.execuly.com.