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VERTICALRESPONSE POLICIES & TERMS


VERTICALRESPONSE, LLC. PRIVACY POLICY

Effective Date: January 20, 2017
Your privacy is important to us. As a result, we’ve developed this Privacy
Policy that provides a description of how we collect, use, disclose, transfer,
and store your information, as well as your choices regarding the use, access,
and correction of your Personal Data. Please take a moment to familiarize
yourself with our privacy practices and let us know if you have any questions.


I. INTRODUCTION & NOTICE


    A. INTRODUCTION

VerticalResponse, LLC. (“VerticalResponse”), owns and operates,
VerticalResponse.com (“VerticalResponse”), and makes reasonable efforts to
protect the privacy of your Personal Data. This Privacy Policy was created to
demonstrate our commitment to fair information practices. Our policies and
procedures address applicable U.S. and international privacy requirements
concerning the collection, use, and cross-border transfer of personal data.

This Privacy Policy covers the use of Personal Data that VerticalResponse
collects when you visit and use www.verticalresponse.com. In the event that
Personal Data is provided to us, whether in electronic, paper, or verbal format,
it will be collected, used and disclosed by VerticalResponse in accordance with
this Privacy Policy.

As described more fully below, VerticalResponse participates in and has
certified its compliance with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy
Shield Frameworks as set forth by the U.S. Department of Commerce regarding the
collection, use, and retention of Personal Data from European Union member
countries the United Kingdom and Switzerland, respectively. VerticalResponse has
certified that it adheres to the Privacy Shield Principles of Notice, Choice,
Accountability for Onward Transfer, Security, Data Integrity and Purpose
Limitation, Access, and Recourse, Enforcement and Liability. If there is any
conflict between the policies in this Privacy Policy and the Privacy Shield
Principles, the Privacy Shield Principles shall govern. To learn more about the
Privacy Shield program, and to view our certification page, please visit
https://www.privacyshield.gov/list. With respect to personal data received or
transferred pursuant to the Privacy Shield Frameworks, VerticalResponse is
subject to the regulatory enforcement powers of the U.S. Federal Trade
Commission. In certain situations, we may be required to disclose personal data
in response to lawful requests by public authorities, including to meet national
security or law enforcement requirements. Under certain conditions, more fully
described on the Privacy Shield website here, you may be entitled to invoke
binding arbitration when other dispute resolution procedures have been
exhausted. Other than as described in this Privacy Policy, we will not disclose
Personal Data about you to others without your express consent.

IF YOU DO NOT AGREE WITH THE TERMS IN THIS PRIVACY POLICY, DO NOT USE THE
SERVICES AND SITES. CONTINUED USE OF THE SERVICES AND SITE.


    B. DEFINITIONS

 * The terms “we”, “our”, and “us” in this Privacy Policy refer to
   VerticalResponse delivering the services and products herein.
 * “You” means the individual to whom any given Personal Data covered by this
   Privacy Policy refers.
 * “Personal Data” means any information relating to an individual that can be
   used to identify that individual either on its own or in combination with
   other readily available data.


   C. REGULATORY OVERSIGHT

For this Privacy Policy and its content, VerticalResponse is subject to the
investigatory and enforcement powers of the Federal Trade Commission (FTC). If
VerticalResponse becomes subject to an FTC or court order based on
non-compliance with this policy or EU-U.S. and Swiss-U.S. Privacy Shield
frameworks, VerticalResponse shall make public any relevant Privacy Shield
related sections of any compliance or assessment report submitted to the FTC, to
the extent consistent with confidentiality requirements.


II. COLLECTION OF PERSONAL DATA

VerticalResponse Sites collect different personal information based upon how you
use them. The legal basis for us processing your Personal Data for these
purposes are because the processing is: (i) necessary to fulfill the services
you have requested; and / or because it is necessary for the purposes of our
legitimate interests.


    A. LEGAL BASIS FOR COLLECTION

The legal basis for us processing your Personal Data for the purposes described
in this Privacy Policy are because the processing is: (i) necessary to fulfill
the services you have requested; and / or (ii) because it is necessary for the
purposes of our legitimate interests.


    B. TYPES OF PERSONAL DATA COLLECTED

 * Customer Order Information: Name; Company Name; Mailing Address & Zip Code;
   E-Mail Address; Phone Number(s); Billing and Payment Information; Contacts
   List;
 * Visitor Information: IP address
 * Job Applicant Information: Contact Details; Resume; Prior Employment History


    C. INFORMATION FROM CHILDREN

The Site and its related services are directed at adults and businesses. We do
not knowingly collect or use information provided from children under the age of
13. If we become aware of any collection of Personal Information from children,
we will delete it immediately.


    D. COOKIES

As is true of most websites, we gather certain information automatically and
store it in log files. This information may include Internet protocol (IP)
addresses, browser type, internet service provider (ISP), referring/exit pages,
operating system, date/time stamp, and/or clickstream data. We may combine this
automatically collected log information with other information we collect about
you. We do this to improve the services we offer you, and to improve marketing,
analytics, and/or site functionality.

We and our partners use cookies and similar technologies to analyze trends,
administer the website, track users’ movements around the website, and to gather
demographic information about our user base as a whole.  A cookie is a small
data text file that our server sends to your computer and that your computer
sends back to us each time you visit our website. Most Internet browsers
automatically accept cookies.  However, you can disable and/or delete cookies by
controlling your browser settings.  If you do disable cookies, our website will
not recognize you and you will not be able to place an order or retrieve your
order status.

We also partner with third parties to provide you advertising based upon your
browsing activities and interests. Our third-party partners may use cookies or
similar technologies in order to provide such advertising. If you wish to opt
out of interest-based advertising click here, or if located in the European
Union click here. Please note you will continue to receive generic ads.

 * Advertising Network Cookies for U.S. Customers

If you are a U.S.-based customer, our business partners may place advertising
network cookies in emails we broadcast on your behalf. The cookies contain
pseudonymous information about email recipients to provide them with targeted
advertising on websites. However, if email recipients wish to not have this
information used for the purpose of serving targeted ads, they may opt-out by
clicking here.


    E. ANALYTICS

The Sites use analytical data provided by Google Analytics. You can find out
more about the types of analytical data and how that data is processed by
visiting https://www.google.com/policies/privacy/partners/


III. PURPOSE & USE OF COLLECTED PERSONAL DATA

VerticalResponse collects information from our users at several different points
on our site. No registration is required to view the VerticalResponse site.
However, if you choose to register or provide Personal Data on our newsletter
sign-up, free trial, order forms, affiliate, partner and job application pages
or other areas of our site, we will ask for information which may include your
name, mailing address, email address, billing and payment information (e.g.
credit card information), company name, and telephone number. We use this
information to create new accounts, fulfill your order, communicate with you
regarding our services, and manage our customer relationships. We may send you
service-related announcements when it is necessary to do so. Generally, you may
not opt-out of these communications, which are not promotional in nature. If you
do not wish to receive them, you have the option to deactivate your account. For
the purposes of order verification and fraud prevention, we may exchange
information about our customers internally within VerticalResponse and among our
affiliates.

 i.   Information You Upload into Vertical Response VerticalResponse will not
      sell or rent this data and only the registered account holder can gain
      access to the uploaded lists
      1. Uploading Google Contacts One feature we offer will allow you to upload
         your Google Contacts information directly into your VerticalResponse
         email marketing account using an integrated solution. Your contacts’
         email address and name (if available) will be loaded into your account
         for your email marketing campaigns. VerticalResponse does not access,
         use or share any Google user data uploaded to the registered users
         account. Google user data is stored on hosted servers in a secure data
         center.
 ii.  Customer Testimonial We post customer testimonials on our site which may
      contain personally identifiable information. We obtain the customer’s
      consent via email prior to posting the testimonial along with the
      customer’s name. If you wish to update or delete your testimonial, you can
      contact us at info@verticalresponse.com
 iii. Public Forum Our site offers publicly accessible blogs and community
      forums. You should be aware that any information you provide in these
      areas may be read, collected, and used by others who access them. To
      request removal of your Personal Data from our blog or community forum,
      contact us at info@verticalresponse.com. In some cases, we may not be able
      to remove your Personal Data, in which case we will let you know if we are
      unable to do so and why.
 iv.  Tell-A-Friend If you choose to use our referral/share service to tell a
      friend about our site, we will ask you for your friend’s name and email
      address. We will automatically send your friend a one-time email inviting
      him or her to visit the site. VerticalResponse does not store this
      information and uses this information for the sole purpose of sending this
      one-time email.
 v.   Survey From time-to-time, we may provide you the opportunity to
      participate in surveys on our site. If you participate, we will request
      certain personally identifiable information from you. Participation in
      these surveys or contests is completely voluntary and you have a choice
      whether to disclose this information. The requested information typically
      includes contact information (such as name and shipping address), and
      demographic information (such as zip code). We use this information to
      monitor site traffic or personalize the site.


IV. INFORMATION RETENTION & ACCURACY

We take reasonable steps to ensure that Personal Data we receive, process, or
maintain is accurate, complete, and reliable for its intended use. We rely on
the accuracy of the information provided directly to us but accept
responsibility for the management and confidentiality of the Personal Data
collected.
In general, we keep Personal Data only as long as we need it to provide you the
services you requested. We may also process data on behalf of third parties who
have engaged us. We keep personal information processed on behalf of third
parties for as long as needed to provide services to third party in question.
However, we reserve the right to retain Personal Data for any period required by
law or to comply with our legal obligations, resolve disputes, and enforce our
agreements. We maintain procedures for the secure disposal or destruction of
Personal Data.


V. SHARING OF PERSONAL DATA & ACCOUNTABILITY FOR ONWARD TRANSFER


A. PERSONAL DATA DISCLOSURES

There are a variety of circumstances where we may need to disclose Personal Data
to:

 * A person who, in the reasonable judgment of VerticalResponse is seeking the
   information as your agent. For example, we may provide information about your
   account to your legal representative if we are satisfied that that individual
   is requesting the information on your behalf;
 * Our parent company or affiliates to help us serve you better and provide you
   with requested services;
 * A company or individual employed by us to perform functions on our behalf,
   such as support services, information technology development and support,
   customer service or data processing, and are authorized to use your Personal
   Data only as necessary to provide these services to us; and,
 * A public authority, agent of a public authority or law enforcement agency if
   required by law.

We will share randomized, aggregated demographic information about our users
with third parties. This information is not linked to any Personal Data and
cannot identify any individual person.
VerticalResponse may also disclose your Personal Data to any other third party
with your prior consent.
Additionally, VerticalResponse may share your Personal Data, without your prior
consent, for the limited purposes noted below:


B. SUBPROCESSORS/THIRD PARTY SERVICE PROVIDERS

To provide and market our services, VerticalResponse uses subprocessors to
perform functions such as:

 1. Data Storage
 2. Marketing & Analytics
 3. Support
 4. Credit and payment Card Transactions

We only share Personal Data with third party service providers to the extent
necessary to provide the requested services. These companies are prohibited from
retaining, sharing, storing or using the Personal Data for any secondary
purposes. By contract, we hold our third-party service providers accountable for
the privacy and security of personal information in accordance with our Privacy
Policy and applicable laws and regulations. In such cases of onward transfer, we
maintain liability for your Personal Data under the EU-U.S. and Swiss-U.S.
Privacy Shield Frameworks.

You have the choice to limit the use and disclosure of your Personal data. If
you choose to limit the data to be used, simply do not disclose that information
to VerticalResponse or use the Sites. In certain cases, limiting the use and
disclosure of your Personal Data may impact functionality or prevent the use of
VerticalResponse’s products or services. When VerticalResponse does share your
Personal Data with third party service providers and/or subprocessors,
VerticalResponse will:

 1. transfer such data only for limited and specified purposes;
 2. ascertain that the subprocessor is obligated to provide at least the same
    level of privacy protection as is required by these Principles;
 3. take reasonable and appropriate steps to ensure that the subprocessor
    effectively processes the Personal Data transferred in a manner consistent
    with the organization’s obligations under these Principles;
 4. require the subprocessor to notify VerticalResponse if it makes a
    determination that it can no longer meet its obligation to provide the same
    level of protection as is required by these Principles;
 5. upon notice, including under (iv), take reasonable and appropriate steps to
    stop and remediate unauthorized processing; and
 6. provide a summary or a representative copy of the relevant privacy
    provisions of its contract with that subprocessor to the Department of
    Commerce upon request.

VerticalResponse shall remain liable under the Principle of Accountability for
Onward Transfer if its subprocessors process your Personal Data in a manner
inconsistent with the Privacy Shield Principles, unless VerticalResponse proves
that it is not responsible for the event giving rise to the damage.


C. LEGAL OBLIGATIONS

We cooperate with government or law enforcement officials and private parties to
enforce and comply with laws applicable to our services. We will disclose
information about you to government or law enforcement officials or private
parties, as we, in our sole discretion, believe necessary or appropriate to
respond to claims and legal process, to protect our property, and the property
and rights of a third party, to protect national security, the safety of the
public or any person, or to prevent or stop activity we consider illegal or
unethical.

If you are visiting this website from a country other than the country in which
our servers are located, your communications with us will result in the transfer
of information across international boundaries. By visiting this website and
communicating electronically with us, you consent to such cross-border
transfers. In the case of data transfers from the EEA and Switzerland, the
EU-U.S. and Swiss-U.S. Privacy Shield Frameworks apply.


VI. PROTECTION OF PERSONAL DATA

In order to protect your Personal Data and your right to privacy,
VerticalResponse:

 * Takes steps to protect information from loss, misuse, and unauthorized
   access, disclosure, alteration, and destruction
 * Maintains physical, electronic, and management procedures to safeguard
   information based on its sensitivity
 * Uses Secure Socket Layer (SSL) technology to protect sensitive data
 * Uses servers that are protected by firewalls, which are frequently updated to
   enhance security
 * Protects the confidentiality of Personal Data when dealing with third parties
 * Strives to keep Personal Data as accurate and up-to-date as is necessary for
   the purposes identified above

We cannot guarantee the security of information on or transmitted via the
Internet. We rely on various security procedures and systems to ensure the
secure storage and transmission of data, including encryption and authentication
technology licensed from third parties, to effect secure transmission of
confidential information.


VII. LIMITS TO YOUR PRIVACY

Our Sites contains links to other sites that are not owned or controlled by us.
When you leave our website, we encourage you to read the privacy statements of
each website that collects Personal Data. This Privacy Policy applies only to
information collected by VerticalResponse Sites.


VIII. CHOICE REGARDING COLLECTION, USE & DISTRIBUTION OF PERSONAL INFORMATION

You can choose to opt-out whether your Personal Data is (i) to be disclosed to a
third party or (ii) to be used for a purpose that is materially different from
the purpose(s) for which it was originally collected or subsequently authorized
by the individuals. In such an event, you will be only able to access public
areas of the Sites. If you do not wish to receive promotional material from us,
you may choose to “opt-out” each time we ask you for Personal Data. In certain
cases, limiting the use and disclosure of your Personal Data may impact
functionality or prevent the use of VerticalResponse products or services.


IX. ACCESS & CORRECTION

We maintain processes or mechanisms to allow you to review, update, correct or
delete Personal Data held by us. You may make changes to your account
information, access, correct, or delete Personal Data held by VerticalResponse
using any of the following methods:

 * visiting the MyLounge page on our site
 * calling our toll-free telephone number at 1-866-6VERTICAL
 * emailing Customer Support at support@verticalresponse.com or
 * writing to VerticalResponse:

Attn: Account Updates
111 2nd Ave NE – Suite 1500
St Petersburg, FL 33701
If you would like your account deactivated or deleted, please state this in your
communication. We will respond to all requests within a reasonable timeframe.


X. CONTACTING VERTICALRESPONSE, DISPUTE RESOLUTION, ARBITRATION & COST

VerticalResponse will address all questions, complaints or requests concerning
this Privacy Policy within 30 days of receipt. Please see the applicable details
below:


A. EU & SWISS CITIZENS

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles,
VerticalResponse commits to resolve complaints about your privacy and our
collection or use of your Personal Data. European Union and Swiss individuals
with inquiries or complaints regarding this Privacy Policy should first contact
VerticalResponse at:

VerticalResponse, LLC.
Attn: S. Carver, Privacy Compliance Manager, Privacy Program Office
111 2nd Ave NE – Suite 1500
St Petersburg, FL 33701
United States of America
Email: privacy@verticalresponse.com

VerticalResponse has further committed to refer unresolved privacy complaints
under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent
dispute resolution provider.  If you have an unresolved privacy or data use
concern that we have not addressed satisfactorily, please contact our U.S.-based
third party dispute resolution provider (free of charge) at
https://feedback-form.truste.com/watchdog/request.

As noted above, under certain circumstances, more fully described on the Privacy
Shield website (https://www.privacyshield.gov), if your complaint remains
unresolved, you may be entitled to invoke binding arbitration when other dispute
resolution procedures have been exhausted.

If you believe that our processing of your Personal Data infringes your rights
under the General Data Protection Regulation, without prejudice to any other
administrative or judicial remedy, you also have the right under Article 77 of
the General Data Protection Regulation to lodge a complaint with a supervisory
authority located in the EU Member State: (i) where you habitually reside; or
(ii) where your place of work is located; or (iii) where the place of the
alleged infringement took place.

If, after exhausting the above remedies your complaint is not satisfactorily
addressed, you may, under certain limited conditions, invoke “last resort”
binding arbitration before a Privacy Shield Panel.


B. NON-EU/NON-SWISS CITIZENS

VerticalResponse commits to resolve complaints about your privacy and our
collection or use of your Personal Data. Non-EU/Non-Switzerland citizens with
inquiries or complaints regarding this privacy policy should contact
VerticalResponse at:

VerticalResponse, LLC.
Attn: S. Carver, Privacy Compliance Manager, Privacy Program Office
111 2nd Ave NE – Suite 1500
St Petersburg, FL 33701
United States of America
Email: privacy@verticalresponse.com


C. ARBITRATION

For information about Arbitration, please see our Terms of Service.


XI. CHANGES TO PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we decide to
change our Privacy Policy, we will prominently post those changes here and any
other place we deem appropriate, so you are always aware of what information we
collect, how we use it, and under what circumstances, if any, we disclose it. If
we make any material changes, we will notify you by way of an email (sent to the
email address associated with your account) or by means of a notice on this site
prior to the change becoming effective. We will use information in accordance
with the privacy policy under which the information was collected.

We use a self-assessment approach to address compliance with this Privacy
Policy, verifying periodically that the policy is accurate, comprehensive, and
addresses the privacy requirements applicable to the markets we serve.
Periodically, our operations and business practices are reviewed for compliance
with corporate policies and procedures governing the confidentiality of
information. These reviews are conducted by internal staff who report directly
to the VerticalResponse Board of Directors, external auditing and accounting
firms, and government regulators.



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