759 Bloomfield Avenue #403

West Caldwell, NJ 07006

You have a right to know how information about you is used and protected.  This policy explains how Route72 Systems, LLC (hereinafter called “Company” or “We”) collects, uses and disseminates information about individuals.

Collection of Information

Non Personal Information.  As part of the standard operation of our Web sites and the Web pages that you access via hyperlinks in our online marketing campaigns ("Other Web Pages"), we may collect certain non-personal information from visitors including, but not limited to, their browser type (e.g., Netscape or Internet Explorer), operating system (e.g., Windows or Macintosh), IP address, and the domain name from which they accessed the site (e.g., lycos.com).  In addition, we may collect information about visitors' browsing behavior, such as the date and time they visit our Web sites or Other Web Pages, the areas or pages of our Web sites and Other Web Pages that they visit, the amount of time spent viewing our Web sites and Other Web Pages, the number of times the visitor returns to our Web sites and Other Web Pages, and other click-stream data. We may use cookies (small text files that are stored on the hard drives of visitors computers when they access our Web sites) to collect this information, which may be combined with visitors' personal information and shared with our marketing partners, advertisers, and other third parties. We may also use cookies for other purposes, including, but not limited to, retrieving information previously provided by recipients of our marketing campaigns and visitors to our Web sites and remembering the passwords of visitors' to our Web Sites and Other Web pages.

Survey, Order Form, Registration Pages.   We collect information from individuals when an individual voluntarily completes an order form, a Company survey, or a registration page online or by means of online order forms or registration pages operated by third parties (collectively, a "Survey"). (As used herein, "online" means using the Internet and related technologies.) In the Surveys, the Company or the third party (the "Third Party") may ask an individual to provide various information, which may include his or her name, email address, street address, zip code, telephone numbers, cell phone numbers and carriers, birth date, age, gender, salary range, education, marital status, occupation, employment information, personal and online interests, and such other information as may be requested from time to time (together, "Survey Information"). Completing a Survey is completely voluntary, and individuals are under no obligation to provide Survey Information to the Company or Third Party, but an individual may receive incentives from the Company or a Third Party in exchange for providing Survey Information, including but not limited to software programs, screensavers, sweepstakes entries etc.

Co-Registration Partners.  The Company collects information from subscribers when an individual provides information to a third party, and the individual subsequently is given the opportunity to subscribe to The Company's email marketing lists. Such subscriptions are provided at no cost to the individual. When acquiring subscribers through the "co-registration" process, the Company seeks assurances from the Third Party that the Third Party has provided a conspicuous option for the individual to choose not to become a subscriber of Company's lists and that a hyperlink to this privacy policy is available for each individual to read before deciding to become a subscriber of Company's lists.

Other Information.  The Company may request personal information on other occasions, including (1) when an individual makes a claim for a prize or seeks to redeem an incentive offered by the Company or by a third party; (2) when an individual requests assistance through Company’s customer service department; and (3) when an individual voluntarily subscribes to a Company service or newsletter (together, "Other Information").

Outside Information.  The Company may receive, store and disseminate information about individuals from third parties ("Outside Information").

No Information Collected from Children.  The Company does not intentionally collect personal information from children who are younger than age 13. The Company therefore has no such information to disclose to third parties or to use.

Use of Individual Information.

Individual Information.  As used in this Policy, Individual Information means Survey Information, Third Party List Information, Other Information, and Outside Information, and any other information the Company gathers or receives about individuals.

Discretion to Use Information.  We may use Individual Information for any legally permissible purpose in the Company’s sole discretion. The following paragraphs describe how the Company currently uses Individual Information, but we may change or broaden its use at any time, and we may update this Policy from time to time. The Company 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.

Targeted Advertising.   Based on the Individual Information, we sometimes attempt to customize and target advertising to an individual, and attempt to show advertising for products and services in which the person has expressed an interest in the Surveys and otherwise. We may, at our discretion, target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers.

Email.   The Company uses Individual Information to provide promotional offers by email to individuals. The Company may maintain separate email lists for different purposes and may send promotional offers from more than one list. If email recipients wish to be removed 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 Company email lists, a person may send an email to abuse@route72.com.

Direct Mail and Telemarketing.   We may use Individual Information to advertise, directly or indirectly to individuals using direct mail marketing or telemarketing using telephones and cell phones.

Profiles of Individuals.   The Company may gather Individual Information to make a profile of a person. A profile is created by associating the various sources of Individual Information.

Storage of Individual Information and Security.   The Company has 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.  We store the Individual Information on Company computers. However, we cannot guarantee that our security measures will prevent the Company computers from being accessed without authorization and the Individual Information stored on them stolen, deleted or changed, and the Company assumes no responsibility for such actions.

Dissemination of Individual Information.

Sale or Transfer to Third Parties.   The Company may sell or transfer Individual Information to third parties for any purpose in the Company’s discretion.

Order Fulfillment.   We 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 Company web sites or when responding to offers provided by Company.

Legal Process.   The Company may disclose Individual Information to respond to subpoenas, court orders, and other legal process.

Summary Data.   We may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons, for any purpose in the Company’s discretion.

Privacy Practices of Third Parties.

Advertiser cookies.   Advertising agencies, advertising networks, and other companies (together, "Advertisers") who place advertisements on Company web sites may use their own cookies on your computer and collect information from such cookies. The Company does not control the Advertisers’ use of their own cookies and the Company has no responsibility for such cookies and the use of information gathered from them.

Links.   The Company’s web sites and email messages sometimes contain hypertext links to the web sites of third parties. The Company is not responsible for the privacy practices or the content of such other web sites.

Affiliated Companies.   We may disclose, transfer and sell Individual Information to entities affiliated with Company in Company’s discretion.

Deleting Individual Information.   Individuals have the ability to request deletion of their Individual Information by sending an email to abuse@route72.com in which they clearly request to have their Individual Information deleted from the Company database.

Information Exchanges.   Individuals may opt-out of information exchanges with Third Parties by sending an email to abuse@route72.com in which they clearly request to have their Individual Information deleted from the Company’s Information Exchange database.

Standard Operating Procedure (SOP).

Data Protection and Process.  

Our organization has a procedure in place for determining what procedures and processes need to be documented. The SOP has been written by individuals who are knowledgeable with the activity of the organization from a technical and business perspective. These individuals are subject matter experts who created the data platform, perform the work and use the process.

We protect all data records within a highly secure redundant infrastructure with architectural layers such as proven Bug Free UNIX OS, MySQL, ACID, SNORT between multiple locations. We have contracted experienced vendors to test our intrusion detection system from both internal and external locations with no Issues.

Other SOP Documentation Contents.

• Quarterly Checklists and Documentation Control
• Data Hygiene Process and Models
• Review of Potential Intrusion Attempts to our External & Internal IP Addresses
• Review of Replication and MySQL Clustering Model
• Quality Assurance (Stress Testing, Manual Testing, Power Fail Over, Release / Change Control)
• Redundancy between Multiple Data Centers
• Review and Approval of Infrastructure Changes / Releases
• Proper User Entitlements for Employees
• Continuity of Business
  

Miscellaneous.

Privacy Policy Updates.   This Privacy Policy was last updated on January 6, 2007.  We reserve the right to revise this policy from time to time without prior notice, so please review this Privacy Policy regularly.

More Information.   If you have questions about this Policy, please contact us at info@route72.com.