HMG AMERICA, LLC, and each of its related web sites (“HMG America”) Privacy Policy
Last updated Oct 10, 2011
This Privacy Policy outlines important information regarding the use and disclosure of information collected via this Website. HMG America provides this Privacy Policy to help users make an informed decision as to whether to use or continue using the Website.
PLEASE NOTE: OUR 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. HMG AMERICA DOES NOT PROVIDE NOTICES OF CHANGES IN ANY MANNER OTHER THAN BY POSTING THE CHANGES AT THIS WEB SITE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY PLEASE DO NOT PROVIDE ANY INFORMATION TO HMG AMERICA OR USE ANY OF THE SERVICES OR PRODUCTS OFFERED OR PROVIDED ON ANY OF THE WEB SITES REFERRED IN THIS PRIVACY POLICY.
This Privacy Policy applies to HMG America’s collection, use, storage and disclosure of information by HMG America on its (a) websites, including all its divisions, subsidiaries and related companies (collectively, the “Website”), (b) on various third party websites, and (c) to HMG America’s other information collection, including the purchase of customer lists from third parties. HMG America is not responsible for the information collection or privacy practices of third web sites or applications. By reference, this Privacy Policy is incorporated into and is subject to the Website Terms of Use. Your use of the Website and any personal information you provide via the Website or through other official HMG America contact remains subject to this Privacy Policy, as well as the Terms of Use and/or other stated policies.
1. Collection of Information.
1.1 Survey Information.
HMG America collects information from individuals by various methods, including, but not limited to, when an individual voluntarily completes an HMG America 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 Website, 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, HMG America or a third party (a “Third Party”) may ask an individual to provide various information to HMG America, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), SMS messaging details (e.g. date, time and content of the SMS message), 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”). HMG America may also collect information concerning an individual from another source and use 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 HMG America or Third Party, but an individual may receive incentives from HMG America or a Third Party in exchange for providing Survey Information to HMG America.
1.2 Other Information.
Other occasions when HMG America obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by HMG America or by a Third Party, (2) when an individual requests assistance through HMG America’s customer service department, and (3) when an individual voluntarily subscribes to a HMG America service or newsletter (together, “Other Information”).
1.3 Cookies, Web Beacons, and Other Info Collected Using Technology.
HMG America 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, HMG America 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 HMG America to identify the individual with his or her corresponding data that resides in HMG America’s database. You may read more about cookies at http://cookiecentral.com. Individuals who use the Website need to accept cookies in order to use all of the features and functionality of the Website.
(b) Web Beacons. A web beacon is programming code that can be used to display an image on a web page (by using an 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 HMG America to track certain web sites 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.
(c) New Technology. The use of technology on the Internet, including cookies and web beacons, is rapidly evolving, as is HMG America’s use of new and evolving technology. As a result, HMG America strongly encourages individuals to revisit this policy for any updates regarding its use of technology.
1.4 Outside Information.
HMG America may receive information about individuals from Third Parties or from other sources of information outside of HMG America including information located in public databases (“Outside Information”).
1.5 No Information Collected from Children.
HMG America will never knowingly collect any personal information about children under the age of 13. If HMG America obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from our database. Because it does not collect such information, HMG America has no such information to use or to disclose to Third Parties. HMG America has designed this policy in order to comply with the Children's Online Privacy Protection Act (“COPPA”).
1.6 Credit Card Information.
HMG America does not collect Credit Card information from any affiliate for third party for any kind of transation.
2. Use of Individual Information.
2.1 Discretion to Use 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 HMG America currently uses Individual Information, but HMG America may change or broaden its use at any time. As noted, HMG America may update this policy from time to time. HMG America 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.
HMG America uses Individual Information to provide promotional offers by email to individuals. HMG America 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 HMG America’s email lists, a person must send an email to unsubscribe@hmgamerica.com.
2.2(a) Content of Email Messages.
In certain commercial email messages sent by HMG America, an advertiser's name will appear in the “From:” line but hitting the “Reply” button will cause a reply email to be sent to HMG America. The “Subject:” line of HMG America email messages will usually contain a line provided from the advertiser to HMG America.
2.2(b) Solicited Email.
HMG America only sends email to individuals who have agreed on the Website to receive email from HMG America or to individuals who have agreed on Third Party websites to receive email from Third Parties such as HMG America. HMG America does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable to HMG America’s email messages.
2.3 Targeted Advertising.
HMG America uses Individual Information to target advertising to an individual. When an individual is using the Internet, HMG America uses Technology Information to associate an individual with that person's Individual Information, and HMG America 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. HMG America may, at its discretion, target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers.
2.4 Direct Mail and Telemarketing.
HMG America uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones.
2.5 Use of Technology Information.
HMG America 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 HMG America’s web sites are most frequently visited. This information helps HMG America to better understand the online habits of individuals so that HMG America can target advertising and promotions to them.
2.6 Profiles of Individuals.
HMG America 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 information obtained from public databases.
2.7 Storage of Individual Information.
HMG America stores the Individual Information in a database on HMG America computers. Our computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under HMG America’s control. Notwithstanding such measures, HMG America cannot guarantee that its security measures will prevent HMG America 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.
HMG America MAY SELL OR TRANSFER INDIVIDUAL INFORMATION TO THIRD PARTIES FOR ANY LEGALLY PERMISSIBLE PURPOSE IN HMG AMERICA’S SOLE DISCRETION.
3.2 Order Fulfillment.
HMG America 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 HMG America web sites or when responding to offers provided by HMG America.
3.3 Legal Process.
HMG America may disclose Individual Information to respond to subpoenas, court orders, and other legal processes.
3.4 Summary Data.
HMG America 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 contact@hmgamerica.com. HMG America 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 Website and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. HMG America does not control Advertisers' use of such technology and HMG America has no responsibility for the use of such technology to gather information about individuals.
4.2 Links.
The Website and email messages sometimes contain hypertext links to the web sites of Third Parties. HMG America is not responsible for the privacy practices or the content of such other web sites. Linked web sites may contain links to web sites maintained by Third Parties. Such links are provided for your convenience and reference only. HMG America does not operate or control in any respect any information, software, products or services available on such Third Party web sites. 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.
HMG America may disclose, transfer, and sell Individual Information to entities affiliated with HMG America in HMG America’s discretion. Should HMG America be subject to an acquisition, merger, sale or other change of control or business entity status, HMG America reserves the right to transfer or assign the Information collected from the Website.
5. Individuals Outside of the United States.
Anyone using the Website outside of the United States acknowledges that personal information will be collected and stored by HMG America in the United States. By using the Website, you consent to the transfer of information to and/or storage of information outside of your country and in the United States.
6. Unsubscribe Procedures.
6.1 If you wish to discontinue receiving email messages from HMG America, you have several options:
1.Unsubscribe from one email list. To unsubscribe from a particular list, either (1) send an email to unsubscribe@hmgamerica.com or (2) follow the instructions in each promotional email message sent by HMG America.
2.Unsubscribe from all of HMG America's email lists.
We reserve the right to add Individual Information to multiple lists maintained by HMG America. To globally unsubscribe from all of HMG America’s lists, send an email to unsubscribe@hmgamerica.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 legalnotices@hmgamerica.com.
© 2007 HMG America, LLC.