DirectROI LLC, all its related web sites (“DIRECTROI”) Privacy Policy

PLEASE NOTE: OUR PRIVACY POLICY CHANGES FROM TIME TO TIME AND CHANGES ARE EFFECTIVE UPON POSTING. PLEASE CHECK BACK FREQUENTLY FOR UPDATES AS IT IS YOUR SOLE RESPONSIBILITY TO BE AWARE OF CHANGES. DIRECTROI DOES NOT PROVIDE NOTICES OF CHANGES IN ANY MANNER OTHER THAN BY POSTING THE CHANGES AT THIS WEB SITE.

IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY PLEASE DO NOT PROVIDE ANY INFORMATION TO DIRECTROI OR USE ANY OF THE SERVICES OR PRODUCTS OFFERED OR PROVIDED ON ANY OF THE WEB SITES REFERRED TO IN THIS PRIVACY POLICY.

The information collection, use, and dissemination practices of DIRECTROI

This policy applies to DIRECTROI's collection, use, storage and disclosure of information by DirectROI on its (a) websites, including all its divisions, subsidiaries and related companies (collectively, the "Websites"), (b) on various third party websites, and (c) to DIRECTROI's other information collection, including the purchase of customer lists from third parties. DirectROI is not responsible for the information collection or privacy practices of third web sites or applications.

1. Collection of Information.

1.1 Survey Information.
DIRECTROI collects information from individuals by various methods, including, but not limited to, when an individual voluntarily completes an DIRECTROI survey, order form, or a registration page either online or offline, or by means of online or offline surveys, order forms, or registration pages operated by third parties (collectively, a "Survey"). (As used herein, "online" means using the Internet, including the Websites, and related technologies, and "offline" means by methods other than online, including in person, in the postal mail, using telephones and cell phones, and other similar means.) In the Surveys, DIRECTROI or a third party (a "Third Party") may ask an individual to provide various information to DIRECTROI, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, social security number, employment information, personal and online interests, and such other information as may be requested from time to time (together, "Survey Information"). DirectROI may also collect information concerning an individual from another source and uses that information in combination with information provided from this web site. Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to DIRECTROI or Third Party, but an individual may receive incentives from DIRECTROI or a Third Party in exchange for providing Survey Information to DIRECTROI.

1.2 Third Party List Information.
DIRECTROI collects information from individuals when an individual provides information to a third party and DIRECTROI subsequently purchases, licenses, or otherwise acquires the information from the third party (the "Seller"). Such purchased information may include, but is not limited to, an individual's name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, industry of employment, personal and online interests, and such other information as the individual may have provided to the Seller (together, "Third Party List Information"). When acquiring Third Party List Information, DIRECTROI seeks assurances from the Seller that the Seller has a right to transfer the Third Party List Information to DIRECTROI and that the Seller has a right to provide offers from Merchants to the individuals whose personal information is included on the Seller's list.

1.3 Other Information.
Other occasions when DIRECTROI obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by DIRECTROI or by a third party, (2) when an individual requests assistance through DIRECTROI's customer service department, and (3) when an individual voluntarily subscribes to a DIRECTROI service or newsletter (together, "Other Information").

1.4 Cookies, Web Beacons, and Other Info Collected Using Technology.
DIRECTROI currently uses cookie and web beacon technology to associate certain Internet-related information about an individual with information about the individual in our database. Additionally, DIRECTROI may use other new and evolving sources of information in the future (together, "Technology Information").

(a) Cookies.
A cookie is a small amount of data stored on the hard drive of the individual's computer that allows DIRECTROI to identify the individual with his or her corresponding data that resides in DIRECTROI's database. You may read more about cookies at http://cookiecentral.com. Individuals who use the Websites need to accept cookies in order to use all of the features and functionality of the Websites.

(b) Web Beacons.
A web beacon is programming code that can be used to display an image on a web page (by using an <img src="x"> programming function -- see http://truste.org for more information), but can also be used to transfer an individual's unique user identification (often in the form of a cookie) to a database and associate the individual with previously acquired information about an individual in a database. This allows DIRECTROI to track certain web sites an individual visits online. Web beacons are used to determine products or services an individual may be interested in, and to track online behavioral habits for marketing purposes. For example, DIRECTROI might place, with the consent of a third party website, a web beacon on the third party's website where fishing products are sold. When Joe, an individual listed in DIRECTROI's database, visits the fishing website, DIRECTROI receives notice by means of the web beacon that Joe visited the fishing site, and DIRECTROI would then update Joe's profile with the information that Joe is interested in fishing. DIRECTROI may thereafter present offers of fishing related products and services to Joe. In addition to using web beacons on web pages, DIRECTROI also uses web beacons in email messages sent to individuals listed in DIRECTROI's database.

(c) New Technology.
The use of technology on the Internet, including cookies and web beacons, is rapidly evolving, as is DIRECTROI's use of new and evolving technology. As a result, DIRECTROI strongly encourages individuals to revisit this policy for any updates regarding its use of technology.

1.5 Outside Information.
DIRECTROI may receive information about individuals from third parties or from other sources of information outside of DIRECTROI including information located in public databases ("Outside Information").

1.6 Individual Information.
As used herein, Individual Information means Survey Information, Third Party List Information, Other Information, Technology Information, and Outside Information, and any other information DIRECTROI gathers or receives about individuals.

1.7 No Information Collected from Children.
DIRECTROI will never knowingly collect any personal information about children under the age of 13. If DIRECTROI obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from our database. Because it does not collect such information, DIRECTROI has no such information to use or to disclose to third parties. DIRECTROI has designed this policy in order to comply with the Children's Online Privacy Protection Act ("COPPA").

1.8 Credit Card Information.
DIRECTROI may in certain cases collect credit card numbers and related information, such as the expiration date of the card ("Credit Card Information") when an individual places an order from DIRECTROI. When the Credit Card Information is submitted to DIRECTROI, such information is encrypted and is protected with SSL encryption software. DIRECTROI will use the Credit Card Information for purposes of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to third parties only as necessary to complete the purchase transaction.

2. Use of Individual Information.

2.1 Discretion to Use Information.
THE COMPANY MAY USE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN COMPANY'S SOLE DISCRETION.
The following paragraphs in Section 2 describe how DIRECTROI currently uses Individual Information, but DIRECTROI may change or broaden its use at any time. As noted below, DIRECTROI may update this policy from time to time. DIRECTROI may use Individual Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses.

2.2 Email.
DIRECTROI uses Individual Information to provide promotional offers by email to individuals. DIRECTROI may maintain separate email lists for different purposes. If email recipients wish to end their email subscription from a particular list, they need to follow the instructions at the end of each email message to unsubscribe from the particular list. To unsubscribe from all DIRECTROI’s email lists, a person must send an email to unsubscribe@DirectROI.com.

2.2(a) Content of Email Messages.
In certain commercial email messages sent by DIRECTROI, an Merchant's name will appear in the "From:" line but hitting the "Reply" button will cause a reply email to be sent to DIRECTROI. The "Subject:" line of DIRECTROI email messages will usually contain a line provided from the Merchant to DIRECTROI.

2.2(b) Solicited Email.
DIRECTROI only sends email to individuals who have agreed on the Websites to receive email from DIRECTROI or to individuals who have agreed on third party websites to receive email from third parties such as DIRECTROI. DIRECTROI does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable to DIRECTROI's email messages.

2.3 Targeted Advertising.
DIRECTROI uses Individual Information to target advertising to an individual. When an individual is using the Internet, DIRECTROI uses Technology Information (see also Section 2.5 below) to associate an individual with that person's Individual Information, and DIRECTROI attempts to show advertising for products and services in which the person has expressed an interest in the Surveys, indicated an interest by means of Technology Information, and otherwise. DIRECTROI may, at its discretion, target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers.

2.4 Direct Mail and Telemarketing.
DIRECTROI uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones.

2.5 Use of Technology Information.
DIRECTROI uses Technology Information (1) to match a person's Survey Information and Third Party List Information to other categories of Individual Information to make and improve profiles of individuals, (2) to track a person's online browsing habits on the Internet, (3) to determine which areas of DIRECTROI's web sites are most frequently visited. This information helps DIRECTROI to better understand the online habits of individuals so that DIRECTROI can target advertising and promotions to them.

2.6 Profiles of Individuals.
DIRECTROI uses Individual Information to make a profile of an individual. A profile can be created by combining Survey Information and Third Party List Information with other sources of Individual Information such as information obtained from public databases.

2.7 Storage of Individual Information.
DIRECTROI stores the Individual Information in a database on DIRECTROI computers. Our computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under DIRECTROI's control. Not withstanding such measures, DIRECTROI cannot guarantee that its security measures will prevent DIRECTROI computers from being illegally accessed, and the Individual Information on them stolen or altered.

3. Dissemination of Individual Information.

3.1 Sale or Transfer to Third Parties.
DIRECTROI MAY SELL OR TRANSFER INDIVIDUAL INFORMATION TO THIRD PARTIES FOR ANY PURPOSE IN DIRECTROI'S SOLE DISCRETION.

3.2 Order Fulfillment.
DIRECTROI will transfer Individual Information to third parties when necessary to provide a product or service that a person orders from such third party while using DIRECTROI web sites or when responding to offers provided by DIRECTROI.

3.3 Legal Process.
DIRECTROI may disclose Individual Information to respond to subpoenas, court orders, and other legal processes.

3.4 Summary Data.
DIRECTROI may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.

3.5 Access.
Individuals have access to their Individual Information collected to provide an opportunity for an individual to correct, amend, or delete such information. Access can be obtained by contacting info@DirectROI.com. DIRECTROI may also grant advertising clients and email services providers’ access to an individual's email address to verify the origin of the Individual Information collected.

4. Privacy Practices of Third Parties.

4.1 Merchant cookies and web beacons.
Advertising agencies, advertising networks, and other companies (together, "Merchants") who place advertisements on the Websites and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. DIRECTROI does not control Merchants' use of such technology and DIRECTROI has no responsibility for the use of such technology to gather information about individuals.

4.2 Links.
The Websites and email messages sometimes contain hypertext links to the web sites of third parties. DIRECTROI is not responsible for the privacy practices or the content of such other web sites. Linked web sites may contain links to web sites maintained by third parties. Such links are provided for your convenience and reference only. DirectROI does not operate or control in any respect any information, software, products or services available on such third party web sites. The inclusion of a link to a web site does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.

4.3 Affiliated Companies.
DIRECTROI may disclose, transfer, and sell Individual Information to entities affiliated with DIRECTROI in DIRECTROI's discretion.

5. Unsubscribe Procedures.

If you wish to discontinue receiving email messages from DIRECTROI, you have several options:

(a) Unsubscribe from one email list.
To unsubscribe from a particular list, either (1) send an email to unsubscribe@DirectROI.com or (2) follow the instructions in each promotional email message sent by DIRECTROI.

(b) Unsubscribe from all of DirectROIRealBig.com's email lists.
We reserve the right to add Individual Information to multiple lists maintained by DIRECTROI. To globally unsubscribe from all of DIRECTROI’s lists, send an email to unsubscribe@DirectROI.com.

6. California User Consumer Rights.

In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, STE 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to dca@dca.ca.gov.

With respect to security: We have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you at our site.

If you feel that this site is not following its stated information policy, you may contact us at the above addresses or phone number, The DMA's Committee on Ethical Business Practices at mgoldberger@the-dma.org.

For more information about protecting your privacy, you may wish to visit: www.ftc.gov

Close Window »