ETF Privacy Policy

July 19, 2008, Revision 1.0

PLEASE READ THIS CAREFULLY BEFORE YOU USE THIS WEB SITE.

1. Overview

This Privacy Policy (”Policy”) is intended to clarify treatment of any personal information collected from you while visiting ETF.com (”the Site”). Please read the following carefully so that you may understand our practices regarding your personal information and how these practices may affect you as you use the Site and its services. ETF Media, Inc. takes protecting and respecting user privacy seriously.

2. Policy Changes

This policy discloses our current privacy practices; however, we reserve the right to change this policy at any time, without notification. It is the users’ responsibility to check for changes to this policy prior to using the Site or the Site’s services at anytime and if they do not agree with the Policy to immediately leave the site and not use it. If a change occurs, we will make note of this at the top of the policy. If you have any questions or concerns regarding this Policy, you should contact us at legal@ETFMedia.com.

3. Information Collection

ETF Media, Inc. (ETF.com, “we,” our, or “us”) collects information about our users (”you” or “your”) so that we may continually improve our services and advertising.

Personal

While on the Site, we may ask for your name, e-mail address, and other personal information when you register to receive or use certain functions or features of the Site. We do this so we can provide you, the user, with the best and most personalized experience possible and to provide our advertisers with an efficient way to reach a targeted audience. We also may ask for this information at other times, such as when you enter contests or other promotions sponsored by ETF Media, Inc. and/or our partners. Surveys are sometimes conducted as well; however, you are not required at anytime to respond to them, but if you do, you agree to be bound by this Privacy Policy and the Sites Terms of Use.

When you submit content to our Site, we may collect your e-mail address; however, your email address will never be displayed without your permission.

When an order is placed for a product or service on our Site, we collect information typically used for credit card transactions, such as your name, mailing, billing addresses, and shipping address, if different, telephone number, and credit card number, CVV/CVC number, and expiration date. This information allows us to process and fulfill your order and notify you of your order status. All of this information is encrypted using Secure Socket Layers (SSL) technology.

We conduct research on our users’ demographics, interests, and behavior based upon the information you provide to us when you register or participate in contests or other promotions on our Site, or based upon the information kept on our server log files. This research is compiled and analyzed on an aggregated basis. We may also notify you of products, services, or areas of our Site that we think may be of interest you based on the information we’ve received. If you would prefer us not to contact you for these purposes, simply opt-out of future mailings by clicking on the “unsubscribe” link found in our e-mail messages or send an e-mail to us with “unsubscribe” in the subject line and include the e-mail address to be unsubscribed in the body of the message, and you will no longer be contacted for this reason.

Sometimes we ask for personal information when providing special features, products, and services. You do not have to give us that information, but without it, you may not be able to take advantage of those special features, products, or services.

We do our best to protect your personal information; however, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk and you are ultimately responsible for protecting yourself. You are responsible for maintaining the secrecy of any password and/or account information. Please be careful and responsible whenever you are online, especially when using a computer that other people can use also.

IP Addresses

When you use the Site, we receive and may store Internet Protocol (IP) addresses each time you view one of our Web pages. We may also store your IP address when you register with ETF.com, post a message, or buy anything from the Site.) IP addresses are collected for Site security, advertiser statistics, and to help us understand how the Site is being used so that we can improve users’ experience. We may use IP addresses for other purposes, such as: maintaining Site and system security, diagnosing service or technology problems, displaying appropriate content or advertising, studying and improving Site use, and reporting aggregate usage information to advertisers.

Cookies

Cookies are used on our Sites in a variety of ways. These are stored and used so that we can access stored account information automatically when you log on to our Site, estimate our audience size and usage patterns, better target content and ads based upon user interests, help users more easily access their account information automatically and make changes to your personal information, expedite search for content or products with our search engines, and better serve ads to the Site.

Most browsers are set up to accept cookies, but they can be configured to refuse cookies or notify you when one is received. Please note that if you reject cookies on our Site, you will not be able to access all areas of the Site or use many of the Sites features.

Single-pixel GIFs

Electronic images called “single-pixel GIFs” or “Web beacons,” which allow us to count users who have visited specific pages or have accessed certain cookies. We may use single-pixel GIFs to recognize and count and users, to collect and aggregate information about users, including demographic and usage information, to conduct research on behalf of advertisers or partners on their Web sites, for advertiser and partner auditing purposes, and / or to determine which e-mail messages were opened and/or acted upon when we send HTML-formatted e-mail messages (messages resembling Web pages that include graphics). Advertising networks that serve ads on our Site may also use single-pixel GIFs in their advertisements. In general, any electronic image viewed as part of a Web page, including an ad banner, can act as a Web beacon.

Advertisers, Third-Party Networks, Others

Some of our advertisers use third-party networks to serve their advertisements on our Site and in our HTML-formatted newsletters. Often, these third-party advertising companies use cookies, Web beacons, and similar technologies to measure advertisement effectiveness. We do not control, nor do we have access to, their cookies or the information they obtain. Use of their tracking technology is subject to their own privacy policies.

If you use our e-mail recommendation service to send information from the Site to another person, you will be required to provide us the intended recipients e-mail address as well as your e-mail address so that we can use it as a return address. Upon your submittal of this information to us, we will automatically send the intended recipient a one-time e-mail, with the recommended information attached. An invitation to the person to visit and register at our Site will also be sent; however, we will not use the recipients e-mail addresses for any other purpose.

4. Information Disclosure

ETF Media, Inc. will not purposely disclose any personally identifiable information about individual users, except as described in this Privacy Policy. With the few exceptions explained below, we do not give, rent, lend, or sell individual information to our advertisers. We do provide aggregate information to advertisers to help them reach a target audience or to the general public in order to describe our services to prospective partners, advertisers, and other third parties, and for other lawful purposes.

We may disclose individually identifiable information as follows:

1. If we have your consent to disclose such information.
2. To an advertiser so they may fulfill an order or service placed or signed up for by a user. Please make note that once the advertiser receives the information, it will handle the information under its own privacy policies and you are responsible for understanding and agreeing to those policies before submitting your information. If you do not want a particular advertiser to have your personal information, then you should not sign up for that advertiser’s offer.
3. Under nondisclosure agreements, to selected partners for the purpose of marketing only ETF Media, Inc. cobranded offerings, such as an ETF newsletter published by another company. Such partners will be able to use the personal information they receive from ETF Media, Inc. only for marketing the cobranded offerings, not for marketing anything else. If you sign up for another product from one of our partners, the information you provide to that company will be subject to that partner’s own privacy policies.
4. If you provide us with a street address, we may provide that information to advertisers so that they can send you mail about their own products and services
5. If you buy something from us, we will disclose your personal information to the extent necessary to fulfill your order and charge your credit card (if applicable). We may use a fulfillment company to fill and ship your order (excluding products you download directly from our Site) and a credit card processing company to verify your card number and process the transaction. We may also give your information to a delivery or postal service so that they can deliver you order.
6. If you use our recommendation service to e-mail our information to another person, ETF we will automatically send this person a one-time e-mail, with the recommended information attached. The e-mail address you give us will appear on the “From” line of the e-mail, thereby disclosing this information to whoever opens and reads the e-mail. Similarly, if you send e-mail from our Site, by using “Reply to Author” or “E-mail this Post,” your address may appear as the return address of that e-mail.
7. We may disclose your personal information as required by applicable law, or in response to legal process, to protect the rights or property of ETF Media, Inc., or to protect the safety of ETF Media, Inc., our users, or others.
8. We may sometimes conduct mailings to other people’s lists. To make it easier for us to comply with the Federal CAN-SPAM Act of 2003, we may share our e-mail list of people who have requested not to receive promotional communications from us with the list providers (or contractors) solely so that we can avoid sending e-mails to people who have asked not to receive them (or, conversely, so that our advertisers can avoid sending e-mails to people who have requested not to hear from them). We provide these lists only to list providers or contractors that we consider to be reputable, and only under strict nondisclosure/nonuse agreements.
9. We may disclose personal information in some other limited circumstances, but we will describe them to you when we collect the information, such as in the rules of a contest or a new service. For example, if we are going to give your personal information to a contest’s sponsor, we will disclose it to you when you sign up for the contest, so that you can decide whether or not to enter the contest.
10. We may employ contractors or other third parties to help with our operations. We may give them access to databases of user information so that they can perform their services for us, including performing system maintenance, displaying personalized content (such as portfolios), performing list analysis or management, or sending mailings for us from our advertisers. These parties are all subject to confidentiality agreements that restrict their use and disclosure of information they obtain through their relationship with ETF Media, Inc.
11. Ads appearing on this Web site may be delivered by a third-party Web advertising partner. Information about your visits to ETF.com, such as the number of times you have viewed an ad (but not your name, address, or other personal information), is used to serve ads to you.

5. Protection from Accidental Loss or Disclosure

We store the information you provide to us on secure servers encrypted with SSL technology.

Personalized areas of our Site are password-protected and only you have access to these password-protected areas. Do not share your passwords with anyone. ETF Media, Inc. will never ask you for your password in an unsolicited phone call or e-mail. If you are using a computer to which others have access, always remember to log out and close your browser window when leaving our Site.

6. Direct Mail Advertising

If you register with ETF Media, Inc. or sign up for or buy any of our products or services, we may contact you to confirm your purchase, subscription, or registration, or to provide you with information about its terms or features. We may also send you information about our various products and services, or other products and services that we believe may interest you. Our partners in cobranded products may also send you information, but only for those ETF Media, Inc. com cobranded products.

We may also provide your physical mailing address (but not your e-mail address) to people who will send you promotional physical address mailings about their products and services.

If you do not want to receive such offers and mailings, you can send an e-mail to us with “unsubscribe” in the subject line and include the e-mail address to be unsubscribed in the body of the message and the offerings that you no longer wish to be subscribed to, and you will no longer be contacted for this reason., or you may send physical mail to Privacy Policy, ETF Media, Inc., P.O. Box 4165, Sedona, AZ 86340. We’ll remove your name from our lists as soon as we can.

7. Account Information

If you want to correct or change information in your Personal Profile, newsletter subscriptions, or any other tidbits we have about you, please contact us at info@ETFMedia.com.

8. Children’s Privacy

We do not direct our sites at children under the age of 13 years and we operate our Sites in compliance with the Children’s Online Privacy Protection Act. We will not knowingly collect or use personally identifiable information from anyone under 13 years of age.

9. Miscellaneous

Information posted on our Site in areas such as discussion boards or chat rooms, or in Personal Profile areas, may be visible to the public and can be collected and used by others. If you do not want other to have your information, you should not post it.

Many of our advertisers or partners, such as brokerages, merchants, or data providers, link from our Site to areas on their own Sites where they sell their own products and services. If you follow links from our Site to others, you should be aware that you are doing business with those other Sites, which have their own privacy and data collection practices. ETF Media, Inc. has no responsibility or liability for these independent policies (and we may not even know what they are).

This Privacy Policy applies to the operations of our U.S. Sites.