Exposure Marketing & Promotion, Inc.
Privacy Policy
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Introduction
Exposure Marketing & Promotion, Inc. (“Exposure”) is a company that assists other businesses to operate sweepstakes, contests and promotions (“Promotions”). Such Promotions gather personally identifiable information from those individuals who choose to enter a particular Promotion and anonymous data regarding the Promotion itself. Exposure takes its privacy obligations both to its clients and to people who enter its Promotions very seriously.
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Purpose
This policy outlines our treatment of information Exposure collects on behalf of our clients.
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Information Collection
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Personally Identifiable Information
In some instances, on behalf of its clients, Exposure may collect personally identifiable information (name, address, e-mail address, telephone number, fax number, and information about your interest in and use of various products, programs and services, etc.) This information is collected by use of Exposure’s online technology, Exposure mailboxes and various points of offline entry and is only collected when volunteered by the user. Personally identifiable information collected by Exposure on behalf of a client belongs solely to the client and will be used solely in accordance with that particular client’s Privacy Policy. Exposure does not use any of the data collected itself, other than to notify potential winners and for prize fulfillment purposes in connection with a Promotion. Exposure does not consolidate data across different clients’ Promotions, does not maintain data beyond the conclusion of client Promotions (other than for back-up purposes on its client’s behalf) and does not “monetize” data collected on behalf of its clients in any manner whatsoever. Exposure strictly limits access to all personally identifiable information within its organization, and data is never shared outside of the company for any reason whatsoever (with, of course, the exception of appropriate governmental or legal requests). An individual’s desire to “opt-out” of receiving marketing or other information from a client will be handled in accordance with a particular client’s Privacy Policy. Exposure requires its clients, by contract, to use the data which Exposure collects on its behalf in accordance with generally accepted privacy standards for both offline and online data, which includes an “opt-out” method for individuals who have provided personally identifiable information. Ultimately, however, Exposure is not responsible for data collected on behalf of its clients when such data is in its client’s possession. Where Exposure operates one Promotion on behalf of multiple clients, the use of the personally identifiable information by all of the companies involved will be clearly outlined by a Privacy Policy created for that Promotion.
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Non-personally Identifiable Information
On behalf of its clients Exposure may also collect non-personally identifiable user information, such as Internet Protocol (IP) addresses, “cookies,” and Internet tags and navigational data (server log files). "Cookies" are small pieces of information that are stored by your web browser software on your computer's hard drive or temporarily in your computer's memory. The use of cookies is now an industry standard, and users will find them on most major web sites, Exposure may place and store Internet cookies on a user's hard drive. Cookies can save any of the types of information noted above. We also use cookies to store user names and information that are supplied at registration. Although most web browsers are initially set up to accept cookies, if you prefer, you can decline the placement of a cookie on your hard drive by using the appropriate feature(s) of your web browser software (if available) to delete the cookie. Please note, however, that certain areas on a client site may not function properly if your web browser does not accept cookies.
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Special Note about Children
Unless otherwise specifically indicated, Exposure Promotions are not available to anyone under the age of thirteen (13). Exposure does, however, operate some Promotions on behalf of its clients which collect personally identifiable information from children under the age of thirteen (13). In each such instance, Exposure and its clients comply fully with all aspects of the Children’s Online Privacy Protection Act (“COPPA”) in the operation of the Promotion, in the collection of the information itself and in the subsequent use of the data collected. Personally identifiable information will not be collected from children under the age of thirteen (13) without parental consent in compliance with the COPPA guidelines.
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California Privacy Rights
A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California customer”) is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy) a policy of not disclosing customer’s personal information to third parties for their direct business marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the maintains and discloses this policy. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and providing a cost free means to exercise that right.
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Contact Exposure
If you wish to contact Exposure to correct, amend, or delete information (if Exposure is holding on to your information as explained above), about privacy related issues or for any reason at all, you may do so in one of two (2) ways:
Mail the details of your request to:
Privacy Policy
c/o Exposure Marketing & Promotion, Inc.
1000 North Opdyke Road – Suite J
Auburn Hills, MI 48326
Or, send an Email to: custserv@emipromo.com -
Material Changes to Policy
Exposure may make material changes to this Privacy Policy from time to time. Therefore, you should periodically visit this page to view the current Privacy Policy. In the event of a material change to this Privacy Policy, Exposure shall send an email advising of the change to all persons whose email addresses we have collected and retained pursuant to the terms set forth above.