ATTORNEY BUSINESS COLLECTION SERVICES
PRIVACY STATEMENT OF RESPONSIBLE ONLINE MARKETING
The Attorney Business Collection Services (ABCS) marketing information
usage practices are based on two beliefs: first, that protecting user
privacy is essential to the growth and prosperity of the Internet;
second, that a personalized web experience can provide significant
benefits to Internet end users if done properly. In accordance with
these beliefs, the ABCS Network creates results for advertisers and
publishers in revolutionary ways without compromising individual
privacy.
CONSUMER PRIVACY
I. INFORMATION WE COLLECT: INDIVIDUAL INTERNET CONSUMERS
A. Personally Identifiable Information (PII).
The ABCS Network sites are designed to promote and facilitate the
business of the ABCS companies with advertisers and marketers. These
sites are not directed towards individual Internet consumers nor do they
seek any PII from such consumers. PII may be collected should a consumer
contact a ABCS company on his/her own initiative or respond to a ABCS
advertisement and provide any PII. Under no circumstances does the ABCS
Network request or collect sensitive PII such as an Internet user's
medical/health conditions; racial or ethnic origin; political, religious
or philosophical beliefs or affiliations; trade union membership or sex
life.
B. Non-Personally Identifiable Information (Non-PII).
When a consumer responds to or views an Internet advertisement served by
a ABCS company (such as through third-party Web sites or email
solicitation) or visits a ABCS Network site, we send a cookie and/or gif
file ("Cookies") to assign an anonymous, unique identifier to the end
user's Internet browser. Cookies are small data files commonly used on
the Internet to help optimize and personalize the Internet end user
experience and identify repeat visitors to Web sites.
The function of these Cookies is to provide ABCS with information for
the purpose of paying third-parties commissions when an Internet user
clicks on a link, creates a lead, or makes a purchase on an advertiser's
Web site; and also to optimize and personalize the Internet user's
experience. If the Internet user re-visits the advertiser's site
directly, ABCS is able to continue to track the user's activities on the
advertiser's site and reward the third-party Web site that referred the
user. We reserve the right to retain all ad delivery and reporting data
as long as may be reasonably necessary for accounting and audit
purposes.
Like most standard Web site servers, we use log files to collect
Internet protocol (IP) addresses, browser type, Internet service
provider (ISP), referring/exit pages, platform type, and date/time
stamp. We use the information to analyze site usage, administer the
site, understand usage and navigation trends in aggregate, and determine
the relevance of content. This information, however, is not linked to
any personally identifiable information.
We also may use Internet browsing and online purchase data associated
with an anonymous identifier to develop a predictive statistical user
profile of the end user's needs and interests. ABCS does not use Cookies
or log files to collect end users' names, physical addresses, email
addresses, phone numbers, credit card numbers, social security numbers,
or any other information which can be used to identify a specific
person. We may match the IP address and user profile with email address
data obtained separately in order to better target campaigns to meet
user's interests, but will not share this information with third
parties.
For improved audience targeting, some ABCS Network sites use marketing
technology that allows advertisers to add non-personally-identifying
demographic information, such as age, gender, area code, or ZIP code, to
the non-identifiable profile data. Thus, there is no direct connection
between an end user's online choices and his or her personal identity.
In some cases, ABCS receives and records partial email addresses of
Internet users, only in circumstances where the user voluntarily
provided its identity and contact information through the Advertiser's
site or third-party marketer's site. This partial email address does not
enable ABCS to personally identify an Internet User.
II. INFORMATION SHARING
The ABCS Network may make any PII provided in responding to an
advertisement available to the company sponsoring the advertisement, as
well as to other trusted third parties in accordance with the terms of
this privacy policy. As a result, you may receive information on
additional products, services and offers that may be of interest to you.
The ABCS Network and/or our marketing partners may enhance and/or merge
PII about consumers who have opted-in to receive marketing
communications with commercially-available third party data collected
from other sources in an effort to ensure that the messages being sent
to the consumer in online and/or offline marketing programs are relevant
to their interests. In the event we enhance and/or merge such personally
identifiable information with data collected from other sources, we will
take reasonable steps to maintain the integrity and quality of that
information.
The ABCS Network may share PII (including information that has been
enhanced with information from other sources) with advertisers, third
party marketers, our affiliated entities for their online and/or offline
marketing programs or in connection with the sale, merger,
consolidation, change in control, transfer of substantial asset,
reorganization or liquidation of any of the ABCS Network companies.
While ABCS strongly encourages clients and partners to adopt responsible
approaches to online marketing, ABCS is not responsible for the
information practices of clients or their partners. The collection, use,
and disclosure of information by clients and partners are subject to
their respective privacy policies, which may differ from ABCS's policy.
The ABCS Network may release account and any other personal information
when we believe release is appropriate to respond to a subpoena or
otherwise comply with the law; enforce or apply our Terms and Conditions
and other agreements; or protect the rights, property, or safety of ABCS
or others. This includes exchanging information with other companies and
organizations for fraud protection.
III. CONSUMER CHOICE AND ACCESS
A. Opting Out.
Some ABCS Cookies have an "opt-out" option. This process does not remove
the ABCS Cookie from your system; it simply replaces it with an opt-out
Cookie that does not contain any unique identifiers. If this site
provides such a process it is detailed below.
Some of ABCS's Cookies do not have an "opt-out" option, yet you still
have the option of blocking the use of Cookies by changing a setting in
your Internet browser. Please see your browser supplier's Web site for
details on how to do this.
This site does not maintain a process for an individual consumer to
opt-out of a ABCS ad serving Cookie.
B. Accessing Consumer Information.
Because they are not directed towards individual Internet users, most
ABCS Network sites do not maintain a process for an individual consumer
to review and/or request changes to any PII collected.
Except as provided below, this site does not maintain a process for an
individual consumer to access his/her PII.
IV. SECURITY
The ABCS Network employs industry standard security measures to ensure
the security of all data. Any data that is stored on ABCS's servers is
treated as proprietary and confidential and is not available to the
public. ABCS has an internal security policy with respect to the
confidentiality of customer and other data, allowing access only to
those employees or third parties who have a need to know such
information for the purpose of effectively delivering ABCS products and
services by means of user login and password requirements. The ABCS
Network routinely evaluates its data security practices to identify
security threats or opportunities for improvement.
No transmission of data over the Internet is guaranteed to be completely
secure. It may be possible for third parties not under the control of
ABCS to intercept or access transmissions or private communications
unlawfully. While we strive to protect your PII, ABCS cannot ensure or
warrant the security of any information you transmit to us. You
acknowledge and assume this risk when communicating with a ABCS Network
company.
V. CONSENT AND CHANGES
The ABCS Network may find it necessary or be legally obligated to update
this Privacy Policy from time to time. When we do, we will post those
changes on this page and update the effective date so that you are
always aware of the information we collect, how we use it, and under
what circumstances we disclose it. Except as otherwise required by law,
modifications to this Privacy Policy will not affect the privacy of data
collected by ABCS prior to the effective date of the policy change.
VI. CHILDREN'S PRIVACY AND SPAM
The ABCS Network is very sensitive to the issue of children's privacy
and makes every effort to protect the privacy of children using the
Internet. ABCS's Web site, products, and services are not developed for
or directed at children. Children (persons under the age of 18) are not
eligible to do business with us and we do not collect personal
information from any person we actually know is under the age of 13.
The ABCS Network is committed to proper Internet practices and full
compliance with the CAN-SPAM Act of 2003 (15 U.S.C. § 7701). It is our
policy to prohibit the sending of unsolicited or "Spam" e-mail by ABCS
or any of its marketing partners.
Please note that under the CAN-SPAM Act, an advertiser is required to
provide an opt-out mechanism for consumers to unsubscribe from future
emails about the advertiser. Although not required to by law, many email
marketers also include an opt-out mechanism to enable consumers to be
removed from their mailing list. This has caused some confusion for
consumers in opting out. The table below clarifies which opt-out
mechanism you should use for commercial emails.
To receive no further emails . . .
Opt-Out Mechanism to Use
about the advertiser
Advertiser's
from the email marketing company
Opt-Out Mechanism to Use
from the advertiser or email marketing company
Both
VII. DATA PROCESSING/SAFE HARBOR
The European Union ("EU") maintains strict privacy laws. These rules
differ significantly from US laws. To reconcile these differences, the
US and the EU have created a Safe Harbor that defines mutually
acceptable privacy operations. ABCS, Inc. adheres to the Safe Harbor
principals. For more information see www.export.gov/safeharbor.
By providing information to ABCS Network sites, you acknowledge that
they operate in the United States and agree to (i) permit ABCS to
transmit and use your User information anywhere necessary, including
across international boundaries, to affect the services and transactions
provided by this Site; and (ii) that such use by ABCS shall be subject
to the terms and conditions stated in this Privacy Statement and our
Terms and Conditions.
VIII. DIGITAL POLICY FORUM
ABCS, Inc. is a member of the Digital Policy Forum ("DPF"). The DPF is
made up of online marketing, analytics, advertising, publishing, and
email companies that are committed to examining and developing responses
to important privacy and consumer protection issues in emerging media.
IX. LIMITATION OF LIABILITY, THIRD PARTY INFORMATION & LANGUAGE
YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE
TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND OUR TERMS AND CONDITIONS
(INCLUDING LIMITATIONS ON DAMAGES, AND ARBITRATION OF DISPUTES). YOU
AGREE THAT ABCS'S LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL
BE LIMITED TO THE GREATER OF THE VALUE OF THE TRANSACTIONS OR SERVICES
PROVIDED TO YOU BY ABCS OR $250 TO THE EXTENT SUCH CLAIM IS NOT
OTHERWISE BARRED BY OUR TERMS AND CONDITIONS. You also agree that you
have provided notice to, and obtained consent from, any third party
individuals whose personal data you supply to ABCS with regard to: (a)
the purposes for which such third party's personal data has been
collected; (b) the intended recipients or categories of recipients of
the third party's personal data; (c) which of the third party's data are
obligatory and which data, if any, are voluntary; and (d) how the third
party can access and, if necessary, rectify the data held about them. It
is the express will of the parties that this agreement and all related
documents have been drawn up in English.
CLIENT PRIVACY
I. INFORMATION WE COLLECT: ADVERTISERS AND PUBLISHERS
A. Personally Identifiable Information (PII).
The ABCS Network collects personally identifiable information from all
Advertisers and Publishers (collectively "Clients") wishing to work with
any ABCS company. The collection of this information is a part of our
normal business practices. Advertisers or their representatives will be
asked to provide personally identifiable data through the host sign up
and registration process. Examples of personally identifiable data that
may be requested include name, address, phone number, email address, and
social security number, tax ID number, etc. The ABCS Network will never
request or collect data from a Client on subject areas including
medical/health conditions; racial or ethnic origin; political, religious
or philosophical beliefs or affiliations; trade union membership or sex
life.
B. Non-Personally Identifiable Information (Non-PII).
The ABCS Network may use cookies and log files to optimize and
personalize the Clients' experience and allow ABCS to monitor site
traffic patterns.
II. INFORMATION SHARING
The ABCS Network does not use any personally identifiable data about a
Client for profiling purposes. All PII that ABCS collects from Clients
is principally intended for administrative needs (e.g., accounting and
pay-out and performance reporting), for which purpose such data are
required.
The ABCS Network may provide email address and basic account data to an
Advertiser or Publisher to facilitate a potential or continued working
relationship between the Advertiser and Publisher. Once an affiliation
is established, Advertiser and Publisher (or their agents or other third
parties as designated by a Client) are privy to their respective
campaign information and PII, including anonymous Internet user
transaction data for Internet users referred by Publisher and any other
information that a Client may instruct ABCS to disclose. While ABCS
strongly encourages Clients to adopt responsible approaches to online
marketing, ABCS is not responsible for the information practices of
Clients or their partners. The collection, use, and disclosure of
information by clients and partners are subject to their respective
privacy policies, which may differ from ABCS's policy.
Periodically ABCS Network sites may use Clients' PII in order to
communicate with our network of hosts via email newsletters or other
avenues to offer strategic marketing information and other
communications to assist in business related activities. In the event
that a Client of the ABCS Network wishes not to have their PII used for
these purposes, they may elect to opt-out from future communications.
For more information on opting-out please see the "Client Choice
Concerning Data Collection" section below.
Except as may be agreed between a ABCS company and a Client, all PII
data provided by individual Clients will be kept in strict confidence by
ABCS Network companies and will be treated with the same level of
respect and care that they treat other proprietary information and trade
secrets. ABCS will never sell, rent, exchange or barter any personally
identifiable Client information to or with any third party for financial
gain or marketing purposes. The ABCS Network may, from time to time,
provide such information to certain third-party administrative vendors
for efficiency purposes in providing administrative or program
management services such as billing, delivery and payouts. Any
third-party vendor so used has agreed to protect the confidentiality of
information provided by ABCS.
The ABCS Network may share PII in connection with our affiliated
entities or in connection with the sale, merger, consolidation, change
in control, transfer of substantial asset, or reorganization or
liquidation of any of the ABCS Network companies. The ABCS Network may
release account and any other personal information when we believe
release is appropriate to respond to a subpoena or otherwise comply with
the law; enforce or apply our Advertiser Terms of Use*, Publisher Terms
of Use* and other agreements; or protect the rights, property, or safety
of ABCS or others. This includes exchanging information with other
companies and organizations for fraud protection.
III. CLIENT CHOICE AND ACCESS
When a Client registers for services with a ABCS Network company, PII is
required as a part of doing business. ABCS's primary intent in
collecting personally identifiable information is for administrative
purposes including accounting and payouts. However, the ABCS Network may
periodically use personally identifiable information for marketing and
communication purposes targeted to our Clients. Clients wishing not to
receive such communications from a ABCS Network company may do so by
"opting-out" during the registration and application procedure process.
A Client may change their "opt" status at anytime during their tenure
with ABCS by accessing their online account.
When a Client logs on any browser-based ABCS Network reporting system, a
"Cookie" is placed within their computer. The purpose of the Cookie is
to allow ABCS to validate the identity of the Client and maintain the
security and privacy of the Client's account data. This Cookie is
required to log into ABCS's reporting systems and there is no method to
opt-out of this Cookie.
IV. SECURITY
The ABCS Network employs industry standard security measures to ensure
the security of all data. Any data that is stored on ABCS's servers is
treated as proprietary and confidential and is not available to the
public. ABCS has an internal security policy with respect to the
confidentiality of customer and other data, allowing access only to
those employees or third parties who have a need to know such
information for the purpose of effectively delivering ABCS products and
services by means of user login and password requirements. The ABCS
Network routinely evaluates its data security practices to identify
security threats or opportunities for improvement.
No transmission of data over the Internet is guaranteed to be completely
secure. It may be possible for third parties not under the control of
ABCS to intercept or access transmissions or private communications
unlawfully. While we strive to protect your PII, ABCS cannot ensure or
warrant the security of any information you transmit to us. You
acknowledge and assume this risk when communicating with a ABCS Network
company.
V. CONSENT AND CHANGES
The ABCS Network may find it necessary or be legally obligated to update
this Privacy Policy from time to time. When we do, we will post those
changes on this page and update the effective date so that you are
always aware of the information we collect, how we use it, and under
what circumstances we disclose it. Except as otherwise required by law,
modifications to this Privacy Policy will not affect the privacy of data
collected by ABCS prior to the effective date of the policy change.
VI. DATA PROCESSING/SAFE HARBOR
The European Union ("EU") maintains strict privacy laws. These rules
differ significantly from US laws. To reconcile these differences, the
US and the EU have created a Safe Harbor that defines mutually
acceptable privacy operations. ABCS, Inc. adheres to the Safe Harbor
principals. For more information see www.export.gov/safeharbor.
By providing information to ABCS Network sites, you acknowledge that
they operate in the United States and agree to (i) permit ABCS to
transmit and use your User information anywhere necessary, including
across international boundaries, to effect the services and transactions
provided by this Site; and (ii) that such use by ABCS shall be subject
to the terms and conditions stated in this Privacy Statement and our
Advertiser Terms of Use* and Publisher Terms of Use*.
VII. DIGITAL POLICY FORUM
ABCS, Inc. is a member of the Digital Policy Forum ("DPF"). The DPF is
made up of online marketing, analytics, advertising, publishing, and
email companies that are committed to examining and developing responses
to important privacy and consumer protection issues in emerging media.
VIII. LIMITATION OF LIABILITY, THIRD PARTY INFORMATION & LANGUAGE
YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE
TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND OUR ADVERTISER TERMS OF
USE* and PUBLISHER TERMS OF USE* (INCLUDING LIMITATIONS ON DAMAGES, AND
ARBITRATION OF DISPUTES). YOU AGREE THAT ABCS'S LIABILITY FOR ANY BREACH
OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS
OR SERVICES PROVIDED TO YOU BY ABCS TO THE EXTENT SUCH CLAIM IS NOT
OTHERWISE BARRED BY OUR TERMS AND CONDITIONS. You also agree that you
have provided notice to, and obtained consent from, any third party
individuals whose personal data you supply to ABCS with regard to: (a)
the purposes for which such third party's personal data has been
collected; (b) the intended recipients or categories of recipients of
the third party's personal data; (c) which of the third party's data are
obligatory and which data, if any, are voluntary; and (d) how the third
party can access and, if necessary, rectify the data held about them. It
is the express will of the parties that this agreement and all related
documents have been drawn up in English.