A. Information Collected
(1) Personally Identifiable Information
"Personally Identifiable Information" is information that identifies you personally, such as your name, address, telephone number, email address, or company name. ICTV Brands, Inc. collects and stores the personally identifiable information that you have provided to us. Here are some examples of manners in which we may collect your personally identifiable information on the Site:
- We may collect your name, phone number and email address if you contact us with a question;
- We may collect your first and last name, date of birth and email address if you choose to participate in a contest or sweepstakes; and
- We may collect your first and last name, your address, your phone number, and your credit card and billing information if you make a purchase of a product.
- The above list provides an example of the personally identifiable information that may be collected on the Site. If you do not want ICTV Brands, Inc. to collect your personally identifiable information, please do not provide it to us.
(2) Non-Personally Identifiable Information
"Non-Personally Identifiable Information" can be technical information or it can be demographic information, such as your age, gender or interests. Non-personally identifiable information does NOT identify you personally. Here are some examples of the non-personally identifiable information that is collected via the Site and a description of how this information is used:
- Internet Protocol (IP) address -- Your IP address is a number that lets computers attached to the Internet know where to send you data -- such as the webpages you view. We use this information to deliver our webpages to you upon request, to tailor our Site to the interests of our users and to measure traffic within our Site.
- Cookie -- Like most e-commerce websites, we use "cookie" technology. A cookie is a very small text file that a website can save onto your computer's hard disk to store your information and settings. When you log on, the cookie tells us whether you have visited us before or are a new visitor. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but if you do, you may not be able to take advantage of the personalized features enjoyed by other users to our Site. Some of the cookies we use may be "Flash" cookies. A Flash cookie is a data file placed on a computer via the Adobe Flash plug-in that may be built-in to or downloaded by you to your computer. While they are harmless, depending on your browser, these cookies may not be deleted when your cookies are deleted or disabled and, in some instances, they may cause your cookies to reappear in your browser. Please check your browser to determine where these types of cookies are stored and how they may be deleted or disabled.
- Web Beacons (also known as "clear gifs," "web bugs" or "pixel tags") -- "Web Beacons" are tiny graphics with a unique identifier, similar in function to cookies, and are used to allow us to count users who have visited certain pages of the Site and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, web beacons can tell the sender whether and when the email has been opened. In contrast to cookies, which are stored on a user's computer hard drive, web beacons are embedded invisibly on web pages.
- Demographic Information -- "Demographic Information" may be your gender, age, zip code and interests, which you voluntarily provide to us on the Site. We use this information to provide you with personalized services and to analyze trends to ensure the information provided by the Site meets your needs.
Please note that we also consider aggregated information, which is not personally identifiable, to be non-personally identifiable information. The above list provides an example of the non-personally identifiable information that is collected via the Site.
B. Use of Information Collected Via the Site
(1) Personally Identifiable Information
We use your personally identifiable information that is collected on the Site primarily for the following purposes:
- To deliver services, such as products, information, or newsletters you request or purchase;
- To alert you to special offers, updated information and other new services from ICTV Brands, Inc., or other third parties, or to forward promotional materials;
- To complete a transaction or service requested by you;
- To fulfill the terms of a promotion;
- To ensure the Site is relevant to your needs;
- To contact you in response to sign up forms such as "Contact Us" or "Order Now".
(2) Non-Personally Identifiable Information Non-personally identifiable information is used as described above and in other ways as permitted by applicable laws, including combining non-personally identifiable information with personally identifiable information.
C. Sharing and Disclosure of Information
(1) Personally Identifiable Information
We may share or disclose your personally identifiable information in the following instances:
(i) To fulfill a service to you. For example, we may hire companies to help provide products or services, like a shipping company that may deliver packages or any other third party that is needed to assist in the completion of transactions requested by you. In addition, if you email us a question, we may use your email address to process your request and respond to your question. Also, if you are entering a sweepstakes or contest, we may use your personally identifiable information in order to fulfill the terms of that promotion. This means that we may share the information for prize fulfillment purposes or mail carriers. We also may share your information with the co-sponsor of that promotion.
(ii) To affiliates, strategic partners, agents, third party marketers or other unaffiliated parties who are offering products or services that we believe may be of interest to you or who require your personally identifiable information for research, administrative and/or internal business purposes. These parties may use your personally identifiable information to contact you with an offer or advertisement related to a product or service, or they may use such information for their own research, administration or business purposes. If you do not want us to share your personally identifiable information in this manner, please do not provide us with this information.
(iii) To unaffiliated third-party service providers, agents or independent contractors who help us maintain our Site and provide other administrative services to us (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on ICTV Brands, Inc.'s behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes and other promotions). We seek to ensure that these unaffiliated third parties will not use the personally identifiable information for any other purpose than to provide the administrative services for which they are responsible. Because such unaffiliated third-party service providers that help us administer our Site will have access to users' personally identifiable information, if you do not wish for our unaffiliated third-party service providers to have access to your information, please do not register or submit any personally identifiable information to us.
(iv) To complete your purchase. If you choose to make a purchase on the Site, we may collect from you your credit card number, billing address and other information related to such purchase, and we may use such collected information in order to fulfill your purchase. We may also provide such information, or other personally identifiable information provided by you, to unaffiliated third parties as necessary to complete your purchase (for example, to process your credit card).
(v) To comply with the law or in the good faith belief that such action is necessary in order to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property, including the rights and property of ICTV Brands, Inc. and or to act in urgent circumstances to protect the personal safety of our end users.
(vi) To third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
(vii) To track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.
(viii) To protect against potential fraud, we may verify with third parties the information collected from the Site. In the course of such verification, we may receive personally identifiable information about you from such services. In particular, if you use a credit card or debit card to purchase services with us, we may use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to us, and that the card has not been reported as lost or stolen.
(2) Non-Personally Identifiable Information We use non-personally identifiable information collected on the Site in the manner disclosed above, in the Section A (2). We may share this non-personal information with third parties.
D. Collection and Use of Information from Children Under the Age of 13
To ensure compliance with federal law, the Site does not maintain information provided by children under the age of 16. If we discover that we are in possession of information provided by a child, we will destroy such information.
E. International Transfer of Information
If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in the U.S. Your orders placed through the Site will be accepted and fully processed in and shipped from the U.S. and all information you provide will be securely maintained in our Web server and internal systems located within the U.S. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personally identifiable information to the United States which does not have the same data protection laws as the European Union and by providing your personally identifiable information you consent to:
- the transfer of your personally identifiable information to the United States as indicated above.
We communicate with users who subscribe to our services on a regular basis via email. For example, we may use your email address to confirm your request, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt-out of these communications, but they will be primarily informational in nature rather than promotional. However, we provide you with an opt-out choice if you do not want to receive other types of communications from us, such as emails or updates from us regarding new services and products offered on this Site or if you do not want us to share your personally identifiable information with third parties. On your registration form you may select whether or not you want to receive emails from us. You can unsubscribe at any time you wish to be taken off the kyrobak.com emailing list. The opt-out choice may be exercised by ticking or un-ticking the appropriate box on your registration form or by contacting us. We will process your unsubscribe as soon as possible, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed. You also may opt-out of receiving such emails by clicking on the "unsubscribe" link within the text of the email.
G. Forums, Chat Rooms and Other Public Posting Areas
Please note that any information you include in a message you post to any chat room, forum or other public posting area is available to anyone with Internet access. If you don't want people to know your email address, for example, don't include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS.
H. Third Party Websites and Links
For your convenience, our Site may contain links to other sites. The Site is not responsible for the privacy practices or the content of such websites.
I. Third-Party Ad-Servers
We may use third-party advertising companies to serve ads on our behalf. These companies may employ cookies and action tags (also known as single pixel .gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous. PLEASE NOTE THAT THIS POLICY DOES NOT COVER THE COLLECTION AND USE OF INFORMATION BY SUCH ADVERTISING COMPANIES.
J. Accessing Your Personally Identifiable Information and Privacy Preferences
We provide you with an opportunity to access your personally identifiable information to ensure it is correct, accurate and current. To edit your personally identifiable information, please contact us at: email@example.com
In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personally identifiable and non-personally identifiable information collected via the Site.
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. However, we make reasonable efforts to ensure security on our systems. Additionally, it is our policy to never send private information, such as your credit card number, via email. In fact, this is a practice we recommend you adopt in all of your Internet activities. We designed the Site to accept orders only from Web browsers that permit communication through Secure Socket Layer (SSL) technology; for example, 3.0 versions or higher of Netscape Navigator and versions 3.02 or higher of Internet Explorer. This means you'll be unable to inadvertently place an order through an unsecured connection.
If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Site or providing personally identifiable information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Site. We may post a notice on our Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
M. Contacting ICTV Brands, Inc.
N. YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please contact us:ICTV Brands, Inc.
489 Devon Park Drive, Suite 315
Wayne, PA 19087
Effective Date: 09/04/14