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Veterans Commerce Foundation
VETS Services Company
Effective July 4, 2017
Modifications to the Policy are effective upon our posting of the amended Policy to our Site. The terms of the current Policy supersede all previous notices or statements regarding our privacy practices and the terms and conditions that govern the use of the Services. You may determine the date the Policy was last amended and the current Terms by referring to the “Effective” date shown at the top of this Policy.
4. Who Is Eligible To Use The Services?
Because of the nature of our business and related operations, our Services are not directed to minors. Consistent with the Children’s Online Privacy Protection Act of 1998 (COPPA), VETS does not knowingly collect personally identifiable information from children under the age of 13 without parental consent. If we learn that personally identifiable information of a child under the age of 13 has been submitted via or appears on or within Services, VETS will take all action necessary to comply with our responsibilities under applicable legal requirements, which may include deletion of any such information.
HOW WE COLLECT & USE YOUR INFORMATION
1. What Information Does VETS Collect About Me, And How Is It Used?
VETS may collect information about you in a variety of ways, including: (i) information you submit to us; and (ii) information we collect about you through your use of the Services.
We may use the information we collect from and about you in a number of ways, including: (i) to provide and operate the Services; (ii) to provide customer services such as support; (ii) to deliver VETS member benefits; (iii) to improve the Services for you and other users; (iv) to provide support and notify you about updates to the Services; (v) to inform you about VETS and related events, benefits, and opportunities; (vi) for marketing purposes; (vii) for internal review; and (viii) to fulfill and provide Services at your direction.
We may store the information we collect about you indefinitely, but information generally will be retained only for as long as necessary to fulfill the purposes for which the information was collected or as required by law. Except as described herein, we do not share, sell, rent, or otherwise disclose your private, Personally Identifiable Information to third parties. We do not provide the Services to minors, and we do not knowingly attempt to solicit or receive any information from children.
VETS may collect the following types of information about you:
A. Personally Identifiable Information
“Personally Identifiable Information” refers to information about you that, with reasonable efforts, may be used to identify you, such as your: first name, last name, gender, birth date, city, state, zip code, addresses, locations, email address, social media profiles and associated use o social media, mobile applications and phone numbers.
Personally Identifiable Information may also include your computer or mobile device’s Internet Protocol (“IP”) address or other unique device IDs. VETS may link the information it records about you using your IP address and tracking technologies to Personally Identifiable Information VETS collects about you via the Services. VETS may use this information for its own marketing and advertising purposes.
In addition, VETS reserves the right to use IP addresses and other tracking technologies to identify a user when VETS: (i) feels it is necessary to enforce compliance with VETS Terms & Conditions of Use; (ii) to protect VETS, the Services, or our websites, software, customers, or others; or (iii) when VETS believes in good faith that the law so requires.
In order for us to provide you with certain Services, it may be necessary for VETS to obtain and share Personally Identifiable Information with others. You are not required to provide us with Personally Identifiable Information, and you can decline this transfer of information to VETS at any time. However, if you choose to withhold Personally Identifiable Information, please be aware VETS may not be able to provide you with Services that may be dependent upon the collection of Personally Identifiable Information, such as certain personalized or enhanced services.
B. Registration & Services Account Information
In order for you to take advantage of certain Services, we may require you to complete a registration form and create a user account (“VETS Services Account”). As part of this registration form, we may require you to provide certain Personally Identifiable Information, including details about your military service, name, city, state and email address. To allow you to express yourself beyond just the information collected during registration; you may also provide additional information, such as an account screen name. In addition, you may choose to include photos of yourself or other images of your choosing in your VETS Services Account profile. You can control how this information is displayed and used by accessing your VETS Services Account profile on our website.
C. Payment Information
VETS may request information from you when you make purchases through the Services, including your contact information (such as name and shipping address) and financial information (such as credit card number, expiration date). This information is used for billing purposes and to fulfill your order. If we have trouble processing an order, your purchase contact information is used to get in touch with you.
D. Promotions & Sweepstakes Information
If you register for our promotions or sweepstakes, VETS and our partners may send you emails or other correspondence regarding the contest for which you registered, and other contests, promotions, and sweepstakes. Further information regarding your choices as to how we collect, use, and share your Personally Identifiable Information is provided below.
E. Newsletters & Correspondence Information
If you elect to receive any of our publications, including our newsletters, or if you provide your email address to us, we may send you emails about a variety of topics such as VETS events, new products, sales, promotional offers from our affiliates or other selected business partners, and employment opportunities.
If you send us correspondence via email, text, the postal service, or other form of communication, we may retain such correspondence and the information it contains and use this information to respond to your inquiry and/or provide notifications to you.
Except as described in this Agreement, VETS does not share, sell, rent, or otherwise disclose your Personally Identifiable Information to third parties. If you do not wish to receive notifications from VETS or our partners, you may unsubscribe according to information provided within the correspondence, or by contacting us using the information below.
F. Public Sources & Other Information
We may also receive information about you from other sources, such as VETS’s agents, vendors and service providers, and from publicly available sources. For example, we may receive information from third parties when we process credit card payments made by you for events or membership.
In addition, all information about you made available in any public or open forum, such as in a member forum or on a social network, will be considered public information for the purposes of this Policy. Any content or information you choose to share with or provide to third parties using or related to your use of the Services is neither private, nor confidential. You should not hold any expectation of privacy with respect to information you share to third parties, and should review applicable policies pertaining to such third parties, if any. VETS is not responsible for any content or information you share with third parties. If you do not want the information to be public, please do not post it.
G. Unique Identifiers
VETS may obtain information from you via a Unique Identifier, whether or not you establish a VETS Services Account with us. When you install Services on a mobile device, Services may initiate a unique identifier account which it may associate with that mobile device (the “Unique Identifier”). VETS may associate the Unique Identifier with your mobile device and may link the Unique Identifier to you.
H. Analytics & Aggregate Information
We may also collect general, non-personal, statistical information about you through your use of the Services. This information may include: (i) website traffic data detailing how many visitors access specific content within Services; (ii) for how long you access certain content; and (iii) hyperlinks and other information you access via the Services. This information presents an overview of our users’ aggregated demographic, preference, and usage habits and allows us and third parties to modify our Services and to offer and optimize the provision of targeted information, promotions, offers, or discounts on products and services based on user traffic, geographic location and behavior. We may group this information into aggregate data in order to describe the use of the Services to third parties, such to reveal website traffic data or in response to government requests.
Information generated by cookies about your use of the Services (including your IP address) may be transmitted to and stored by Google on servers. Google may use this information for the purpose of evaluating your use of the Services, compiling reports on Services activity for Services operators and providing other services relating to Services activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.
I. Third-Party Advertisements
VETS may utilize the services of third-party advertising companies, including Google and others, to serve ads to you when you use our Services or other sites across the Internet, or to perform remarketing services. These third parties may collect information about your visits to certain pages of our Services and may use technology like cookies to store information about your use of the Services. The information collected may be reported back to us, and we may link this information to Personally Identifiable Information we have collected about you. This information allows us to track which other websites have linked visitors to our Services, what pages of our Services are used by and are of interest to visitors, so we may provide better, more targeted advertising regarding our business and Services. More information about interest-based advertising and similar practices may be available at http://www.networkadvertising.org/consumer/opt_out.asp.
J. Cookies, Web Beacons, And Other Tracking Technologies
As with many other websites, software services, and mobile applications, VETS may automatically collect certain non-personally identifiable information and data through the use of “cookies,” “web beacons,” and other tracking technologies. Cookies are small pieces of data used by websites and software services to identify repeat users, facilitate the user’s ongoing logins and access to a software service or website, and facilitate use of the software service or website. Web beacons are transparent pixel images that are used in collecting information about website usage, email response and tracking.
You have many choices with regards to the management of cookies on your computer. All major browsers now allow you to block or delete cookies from your system. To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your browser.
K. Do Not Track
VETS does not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms that may provide consumers a choice regarding the collection of Personally Identifiable Information about an individual consumer’s online activities. As is commonly the case with many other mobile applications and websites, third parties (e.g., advertisers) may be able to collect Personally Identifiable Information about your online activities over time and across different websites or online services when you use Services.
HOW WE SHARE YOUR INFORMATION
1. How Does VETS Share My Information With Others?
If VETS becomes aware that any authorized party is improperly using or disclosing your Personally Identifiable Information, we will notify that party and take commercially reasonable steps to end or correct such improper use or disclosure.
Please note information VETS collects about you may be transferred, processed and/or accessed by us in the United States, or another country where we (or our Service Providers) operate. Please be aware Personally Identifiable Information may be transferred to, and maintained on, computers located outside of your state or country where the privacy laws may differ from and may not be as protective as those where you live. If you are located outside the United States and choose to allow us to collect information about you, please be aware that VETS may transfer your Personally Identifiable Information to the United States and process and store it there. By allowing collection your Personally Identifiable Information, you consent to having your personal data transferred to, processed, and stored in the United States.
VETS may also disclose your information for the following purposes and circumstances:
A. VETS Personnel
VETS’s personnel and authorized partners may have access to your information as needed in the normal course of business.
B. Service Providers
VETS may use third party service providers or other businesses to perform certain services for us, for example, for maintaining or modifying the Services or their data and information, maintaining or operating mailing lists, processing orders, delivering products and services, sending postal mail, providing marketing assistance, or data analysis (“Service Providers”). VETS may provide Personally Identifiable Information to Service Providers when that information is necessary for them to complete a requested transaction or otherwise perform their duties. VETS strives to ensure our Service Providers are obligated to reasonably protect Personally Identifiable Information on VETS’s behalf.
C. Services Account Information
Information collected during registration and subsequent visits to and use of the Services, such as your full name and location, may be displayed to other Services users in your Services Account profile. You may be able to control the personal information made available in your Services Account profile by changing the privacy settings available for certain Services. See VETS website, social media outlet, and mobile application settings for the Services you use for more information.
D. Member Directory
The email address that you submit to us upon registration may be searchable by other users of the Services who know you by your email address, unless you choose to opt out of this feature. This is primarily so that other users can find you and connect with you through the Services. You may opt-out of this feature by visiting the Privacy Settings section of your VETS Services Account profile.
E. Business Transfers
VETS may purchase other businesses or their assets or sell our business assets. Personally Identifiable Information is commonly a business asset involved in such transactions. Please be aware your Personally Identifiable Information may be one of the transferred assets in the event VETS or all or a portion of its assets are acquired by others.
F. Financial Institutions
For certain promotions and services, VETS may make your Personally Identifiable Information available to one or more financial institutions in order to fulfill and carry out the purchase and provision of goods and services requested. By providing your Personally Identifiable Information to us for these purposes, you authorize us to exchange your Personally Identifiable Information with such financial institutions.
G. Protection Of VETS And Others
VETS fully cooperates with law enforcement agencies in identifying those who may use our Services for illegal activities, and may in its sole discretion disclose Personally Identifiable Information or other information to satisfy any law, regulation, subpoena, proceeding, or government request, or in connection with civil litigation. VETS reserves the right to release Personally Identifiable Information or other information about users who VETS has reason to believe are engaged in illegal activities or are otherwise in violation of our VETS Terms & Conditions of Use, with or without a subpoena, warrant, or court order, if VETS believes, in its sole discretion, that such disclosure is necessary or appropriate to operate Services, or to protect the rights or property of VETS, its affiliates, or any of their officers, directors, or employees, agents, third party content providers, suppliers, sponsors, or licensors. VETS also reserves the right to report to law enforcement agencies any activities VETS reasonably believes, in its sole discretion, to be unlawful.
HOW WE PROTECT YOUR INFORMATOIN
1. How Does VETS Secure My Information?
VETS takes reasonable efforts to secure and protect the privacy, accuracy, and reliability of your information and to protect such information from loss, misuse, unauthorized access, disclosure, alteration and destruction. Any Personally Identifiable Information VETS may collect about you is used in ways that are compatible with the purposes for which it was collected or authorized by you. The Personally Identifiable Information you provide and we collect may be stored within databases that are controlled by us or by our Service Providers. VETS implements security measures as we deem appropriate and consistent with industry standards, such as firewalls and encryption technology, to protect Personally Identifiable Information. However, since no data security protocol is impenetrable, VETS cannot guarantee the security of our systems or databases, nor can we guarantee that Personally Identifiable Information we collect about you will not be breached, intercepted, or otherwise disclosed without authorization. As a result, any information you transfer to or from Services is provided at your own risk.
2. Are My Communications With VETS Secure?
Communications that you may have with us via email or U.S. Mail generally should not be considered secure, unless we advise you that specific security measures are in place prior to your sending information. Therefore, if you choose to communicate with us through these means, you assume the risk of doing so, and we request that you do not send or post sensitive information through these means.
3. Should I Secure My VETS Services Account And Passwords?
Yes. In the event you are asked to create a VETS Services Account, your online account information will be protected by a password you select. We strongly recommend you choose a strong password and take appropriate steps to ensure your password is not disclosed to any other person. You are responsible for maintaining the confidentiality of your password and VETS Services Account, and are fully responsible for all activities that occur under your password or VETS Services Account. VETS specifically reserves the right to terminate your access to Services and any contract you have with VETS related to Services in the event it learns or suspects you have disclosed your Services Account or password information to an unauthorized third party.
4. Do I Have Access To The Information VETS Has Collected About Me?
You do. VETS welcomes you to contact us regarding whether: (i) VETS is keeping information about you, (ii) the accuracy of the information VETS is keeping, (iii) how VETS is using your information or sharing your information with others, (iv) to update or delete your information, or (v) to opt-out of the collection and use of your information. Please contact us specifying the details of your request by sending an email to VETS at firstname.lastname@example.org or using the contact information provided below. Please note we may require proof of your identity before we provide you with the requested information. Please also note that if you choose to delete your information or opt-out of the collection and use of your information, certain Services may no longer be available to you, and VETS may terminate your access to Services and any contracts you may have with us related to Services.
ADDITIONAL PROVISIONS REGARDING THE SERVICES AND YOUR INFORMATION
Please be aware that third party websites may be able to link certain information about your site visit to information they have may have collected or been provided about you. However, we are not responsible for the privacy practices of any other site, and we are not liable for their use or misuse of your information. We encourage you to carefully read the privacy policies of any other websites you may visit to better understand their privacy practices and associated risks.
2. Does VETS Warranty Information It Provides Via The Services?
No. Access to the information provided by the Services is provided by VETS as a service to its customers, website visitors, and users of its Services, without warranty of any kind. References herein to any product, process, or service do not constitute or imply endorsement or recommendation by VETS. While VETS makes every effort to present accurate and reliable information on its Services, VETS does not approve or certify such information and does not guarantee the accuracy, completeness, efficacy, timeliness, or sequencing of such information. Your use of such information is voluntary and reliance on it should only be undertaken after an independent review of its applicability, accuracy, completeness, efficacy, and timeliness with regard to your specific needs and uses. VETS (including its employees and agents) is not responsible for, and expressly disclaims all liability for, damages of any kind arising out of use, reference to or reliance on the information available through the Services. No approvals, recommendations, endorsements, guarantees, or warranties, including, but not limited to, any express or implied warranties of merchantability or fitness for any particular use or purpose of products or services named through the Services are made by VETS.
3. What Is The Governing Law And Jurisdiction Of This Agreement?
4. How Can I Contact VETS?
Attn: General Counsel
201 North Forest #221
Independence, MO 64050