PRIVACY POLICY

Effective as of December 22, 2016

Welcome to the 10-15 Associates web site, www.1015associates.com (the “Site”). The following Privacy Policy tells you about the information we, and our subsidiaries or affiliates, collect through the Site and in any other way, including but not limited to registering for a customer account on the site or providing contact information to receive information on upcoming seminars or new product offerings. In addition, it explains how we use that information and how you can opt out of certain uses of information we may collect. By using our services, providing your personal information and/or accessing our Site, you are consenting to the information collection and use practices described in this statement, as modified from time to time by us. If this Privacy Policy is not acceptable to you, please do not use this Site or provide your personal information. If we decide to materially change our privacy policy, we will post a new statement on our Site. Therefore, we encourage you to check the date of our privacy policy whenever you visit this Site for any updates or changes.

Reference to “we” or “us” the owner of the Site including any company it controls or which controls it (for example a parent company of the Site owner or a subsidiary of the Site owner) and its members, directors, officers, employees and agents.

Information About You

We collect several types of information about you. We collect “personal information” if you submit your contact information through the Site or register with the Site: namely, your first and last name, online contact information, such as your email address, mailing addresses, phone numbers, and a user name and password that you create. We also collect “non-personal information,” which is information about you that does not itself identify you individually. Examples of non-personal information include age range and gender. We also collect your geolocation, IP Address, operating system, hardware details, device settings, software, browser type, language, connection information, and other information which helps us improve the Site in various ways including by optimizing our software to serve you and by monitoring usage for violation of security safeguards, the Terms of Use accessible here. We also collect “aggregate information,” which is information that helps us understand how people use our Site or our services, for example, which pages are visited, frequency of usage, paths of usage, interactions between users, and interaction with other software. The information we collect depends on what services you use on our Site or otherwise. The following is a more detailed explanation of these types of information as well as when and how we collect and use them.

Registration and Transactional Data

As noted we collect personal information identifying you when you register for an account on the Site or provide your contact information on the Site. We also collect and store access information related to your account, including your user name and password.

Use of Your Personal and Non-Personal Information

Except as disclosed in this privacy policy, we do not sell, rent, lease or disclose information that identifies you individually or makes it possible for other parties to contact you directly without your consent. Unless we have your permission or are required by law, we only share your personal information with our related companies and third parties who are acting on our behalf for the uses described below. We may, however, use, sell, disclose or otherwise dispose of personal information we collect in the following circumstances:

Data Integrity

We process personal information for the purposes for which it was collected and in accordance with this Privacy Policy. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed in connection with the uses set out in this Privacy Policy.

Internal Use of Your Information

We use all the information we have to help create and improve the Site for users. For example:

Information we have is used to improve safety and security for you and your content on your Site, including for violation of our terms and policies.
We use information about you for statistical, design or operational purposes such as to estimate our audience size, to measure aggregate traffic patterns and/or to and understand demographics, customer interest, consumer insights, purchasing and other trends among our users and customers.
We conduct research about our Site, including new features, in surveys, and other testing to collect feedback for improving our Site.
We also use your personal information for the marketing and/or promotion of us and the Site.
Additionally, we use your information, to respond to your customer service inquiries.
We may outsource all of these tasks to third parties on a confidential basis. If you do not want to receive promotional email or other materials from us or the third parties we have engaged, please unsubscribe when you receive an email or send your opt-out request to clientservices@1015associates.com.

Tracking Tools

We collect personal and other information about users over time and across different websites when you use this Site or the services offered on the Site. We may use browser-based “cookies”, users’ IP addresses, and other technologies or similar technologies to help us obtain information about your visits to the Site, deliver content for us and others specific to your interests, process your requests, and/or to analyze your visiting patterns, monitor traffic patterns on the Site, and to optimize and enhance your online experience on the Site. “Cookies” are pieces of information stored within your computer’s or device’s Internet browser that automatically identify your browser to our server whenever you interact with the Site. Such technology is a common feature of many web sites and is necessary in order for certain features of our site to function properly or in order to provide an online service to you. We also use cookies to help us understand the content that you are shown while visiting our Site and identify which areas of the Site are useful or which areas may need improvement. We do not set any personally identifiable information in cookies. We may combine information which we obtain through the use of cookies with other information, including a unique identifier we have assigned to you, or with information we obtain from third party sources.

Managing Tracking Tools

You may customize the browser settings to notify you when a cookie is sent or to disable cookies altogether. Please check your browser for instructions on how to make these adjustments. Because cookies allow you to take advantage of some of the Site’s essential features, such as locating stores selling our products near to you, we recommend that you allow them on your browser. However, if you choose to disable this function, your experience on the site may be diminished and some features may not work as intended. Your browser may also have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These browser features are not uniform, so we are not currently set up to respond to those signals. If you do not want your online behavior tracked by us, then please do not use the Site.

Offers from Subsidiaries and Affiliates

We may send you (or arrange to have sent to you) our (or our subsidiaries’ and affiliates’) marketing and promotional information. We do not share your personal information with unrelated outside third parties unless such disclosure is required for transaction processing as mentioned above. If you do not want to receive these materials, please unsubscribe when you receive an email or send email your opt-out request to clientservices@1015associates.com.

Disclosures to Comply with Legal Requirements

We may disclose personal information:
(a) to conform with the law, respond to claims or comply with legal process served on us (e.g., a lawful subpoena, warrant or court order);
(b) to enforce or apply our policies or agreements (including to initiate, render, bill and collect for amounts owed to us);
(c) to protect and defend our or our users’ rights or property, the Site, our employees, users or the public, including fraudulent, abusive or unlawful use of our Site; or
(d) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

Other Professional Advisors

We may disclose your information, including information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, and account balances, where we have previously been authorized to disclose such information to your other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment advisor, account custodian).

Company Sale

Information collected through our Site is considered a trade secret owned by us. As the owner of such information, we may disclose or sell such information as an asset of the company in conjunction with the sale to a third party of our company or a portion of our assets.

Aggregate Information

We collect aggregate information about you and your use of our Site whenever you visit our Site (see “Information About You” above). For instance, we may collect various forms of “click stream” information such as entry and exit points for our Site (i.e., referring URLs or domains), site traffic statistics, page views, impressions, and operating system and browser type. In addition, when you request pages on our Site, our servers automatically log your IP addresses. An IP address is a number that is automatically assigned to your computer whenever you are surfing the internet.

We also may use third-party software that tracks traffic directed to the Site from affiliate Sites. This information is aggregated.

This aggregate information generally will not identify you or be correlated to you individually for external purposes. We may collect, compile, store, publish, promote, report, sell, or otherwise disclose or use any and all aggregate information provided that such information does not reveal your identity. When we share such information with other companies, it is not traceable to any particular user, and will not be used to contact you. If we do correlate any aggregate information to you, such information will be treated like any other personal information under this statement.

Employee Access

We only permit authorized employees and affiliates who have signed a copy of our Privacy Policy to have access to your information. Employees violating our Privacy Policy will be subject to our disciplinary process. Additionally, whenever we hire third-party vendors to provide services to our clients, we require them to sign confidentiality agreements and/or the Privacy Policy.

Links to Other Sites

Please be aware that we may provide links to third-party web sites or our promotional partners’ sites as a service to our users, and that we are not responsible for the content or information collection practices of those pages. Please note that these web sites’ privacy policies may differ from ours. We encourage you to review and understand their privacy practices before providing them with information.

Children

Our Site is intended for a general audience. However, it is not designed nor intended to collect personal information from children under the age of 13. To respect the privacy of children and to comply with the Children’s Online Privacy Protection Act, children under the age of 13 are not permitted to use the Site. We ask that parents supervise their children while online.
Security
We are committed to safeguarding and securing your personal information. To maintain data accuracy, prevent unauthorized access to or disclosure of, and ensure the appropriate use of your personal information, we have put in place physical, electronic and managerial procedures. Such procedures represent our best efforts to maintain security and we work continuously to enhance security.

Choice/Opt-Out

We will not use or share your personal information in ways unrelated to the uses described above without first notifying you and offering a choice. We will also provide you the opportunity to opt-out at any time of certain or all contact from us. You may also choose to change information associated with your account, including your registration name and address, shipping and home addresses, method of payment, and user name and password. As noted above, we may use your e-mail address and other contact information provided to us through the Site to send notifications to you. If you do not want to receive such notifications, you can change your privacy preference and remove yourself from our notification e-mail list at any time by sending an email with your request to clientservices@1015associates.com. If you have any difficulty with opting out, please call us at 800-225-1015.

Access and Accuracy

We strive to keep your personal information accurate. We will provide you with access to your personal information, including making reasonable efforts to provide you with online access to your subscription or registration data so that you may review, update or correct your information on the Site. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting you access or enabling you to make corrections. If you cannot access your information on the Site, please send your request to clientservices@1015associates.com. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required.

Notwithstanding any preference that you select, we may contact you from time to time to provide services that you have requested or for customer service matters, such as responding to service-related inquiries, updating our policies or notifying you of changes to existing services.

If you have any questions about this Privacy Policy or our use of your information, or if you need help changing or deleting your information, you can e-mail us at clientservices@1015associates.com.

California Privacy Policy

As a California resident you have the legal right to request from businesses with whom you have an established business relationship, (1) a list of the categories of personal information, such as your name, address, email address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes,

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