Privacy Policy
Effective Date: June 11, 2013
 
 

SUMMARY

This privacy policy describes how Ingenio, LLC, which owns and operates Keen.com, Ingenio.com, ether.com, liveadvice.com, healthyrelationshipscenter.com and other Ingenio, LLC sites and services (individually and collectively referred to as "Ingenio"), collects, uses, shares, and secures information on our owned and operated websites, mobile applications and other properties. Although you, as a member, should read through the entire policy for complete information, the following provides a summary of some of the most important aspects of our privacy practices:

  • We use your personal information to provide you with products, services, and information.
  • We may share your personal information with third parties in some situations such as credit card information to process payment for products or services which you order through Ingenio or its Affiliates.
  • We are committed to working with you to reach the right balance of what information we collect, use, and share, and provide you with some ways to control information that we collect or provide, through our opt-out mechanisms.
  • We take reasonable measures to secure your sensitive personal information, but we cannot promise, and you should not expect, that your sensitive personal information will remain secure in all circumstances.
WHAT INFORMATION DO WE COLLECT?

When we use the term "information" we are referring to both personal information and non-personal information that we collect about you.

"Personal information" refers to information that personally identifies you, or can reasonably be linked to you by us. Personal information can either be "sensitive" or "non-sensitive."

"Sensitive personal information" refers to information that is generally considered confidential such as your financial account number, billing information, social security number, and precise location.

"Non-sensitive personal information" refers to information that is generally not considered confidential such as your name, date of birth, mail or email address, telephone number, friends' name or email address if you choose to refer them to us, general geographic information (e.g., your city or state), account preferences, and business information.

"Non-personal information" refers to information that does not specifically identify you.

HOW DO WE USE INFORMATION?

Our primary purpose in collecting information about you is to provide you or connect you with products, services, information, members and advisors match your interests and preferences. For example, we may use this information to fulfill your request to speak to an advisor or member, fulfill an order, respond to your inquiries, administer your account, send marketing, assess your needs and interests in order to better tailor offers and/or advertising, improve our website and marketing, conduct research, display content based upon your interests, allow you to search information on our site, and/or list you in our search and directory services.

HOW DO WE COLLECT INFORMATION FROM YOU?

We collect information from you by asking that you provide it to us on-line, through a mobile application or via other means by which we communicate with you. This may include, for example, your name, address, email address or telephone number.

We may also collect information from you automatically. For instance, we, like many websites and applications, automatically collect information including the computer you use, the type of browser and operating system that you use, the webpages you view, the time and duration of your visits, the search queries that you enter, and how you interact with advertising. Among other things, we use the following technologies to automatically collect information:
  • "Cookies" are small data files placed on your computer by the websites you visit and the emails you read and can be used to help recognize you when you return to a website, or when you visit other sites. We, or third party service providers, may use cookies to, among other things, measure activity, personalize your experience, remember your viewing preferences, or track your status or progress when accessing our site. For some of these purposes our cookies may be tied to personal information. If you choose, you can set your browser to reject cookies or you can manually delete individual or all of the cookies on your computer by following your browser's help file directions. If your browser is set to reject cookies or you manually delete cookies, you may have trouble accessing and using some of the pages and features that are currently on our website, or that we may put on our website in the future. We do not operate the cookies or tracking technology used by our third party service providers.
  • "Unique Identifiers" are unique strings of characters that are used to identify you, your computer, or your mobile device. Such identifiers may be preset on your computer or mobile device. We may use unique identifiers to recognize you when you visit our sites or use our mobile applications.
  • "Local Shared Objects," "LSO's," or "Flash Cookies" are data files similar to cookies, except that they can store more complex data. These are used to remember settings, preferences, and usage, particularly for video, interactive gaming, and other similar services. Cookie management tools provided by your browser will not remove them. To learn how to manage privacy and storage settings for LSO's or Flash Cookies click here.
  • "Telephone Caller ID" refers to information automatically transmitted about you when you place a call using the Ingenio website. If you call an advisor's or another member's telephone number that we have provided to you, your caller ID will be recorded by us, but not by the person you are calling. If you call a telephone number not provided by Ingenio, your number may in that instance be recorded by the person called and the use of your phone number by that person will not be controlled by Ingenio or this privacy policy.
  • "Web beacons" or "clear pixels" are small graphic images on a Web page or in an e-mail that can be used for such things as recording the pages and advertisements clicked on by users, or tracking the performance of e-mail marketing campaigns.
  • "A "web server log" is a record of activity created by the computer that delivers the webpages you request to your browser. For example, a web server log may record the search term you entered or the link you clicked to bring you the webpage. The Web server log also may record information about your browser, such as your IP address and the cookies set on your browser by the server.
  • A "widget" is a small program or application that can be embedded in a web page. Widgets can provide real-time information, such as stock quotes or weather reports, or other functionality, such as an availability button, buy now, call now button. Widgets are often provided by a third party, and may allow that third party to collect data about users viewing that page. We may also use Social Media Features such as the Facebook Like button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly.
  • You can log in to our site using "sign-in services" which we may have now or offer in the future such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us, such as your name and email address to pre-populate our sign up form, or to post information to your account.
  • "Geo-location technologies" refers to technologies that permit us to determine your location. We may ask you to manually provide precise location information on our website, or to enable your mobile device to send us precise location information. We may also automatically use information from your web server or computer to determine general location information, such as the city in which you live.
In addition to information that we collect from you, we may collect information about you from third parties for purposes such as personalization, ad/listing targeting, optimization and reporting.

WITH WHOM DO WE SHARE INFORMATION?

We may share information about you with third parties in certain circumstances including in the following situations.

Third Party Partners/Networks. A third party may use technology (e.g., a cookie) to collect non-sensitive personal information about your use of our website or mobile applications so that they can provide advertising about products and services tailored to your interests. If you would like to opt-out of having third party networks use information that Ingenio has shared with them to target advertising to you please see the instructions in the section titled "What Privacy Choices Do I Have" below.

Affiliates. We may share all types of information with the Ingenio family of companies, including but not limited to companies doing business under the Keen® brand, or Ingenio® brand, LiveAdvice TM brand or other Ingenio products or services for the purpose of fulfilling the services that we provide to our customers and to customize your experience.

Blogs, Forums, Online Postings, and Testimonials. We may share with the public any information that you publish in conjunction with an on-line review, comment, forum, blog, or message board. This may include non-sensitive personal information that identifies you.

Business Transition. In the event that we, or part, or all, of our assets are acquired, we may share all types of information with the acquiring company. You will be notified via email or a notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

In-line Applications & Tools. We may offer applications, tools, or widgets on our website or in our applications that indicate that they are "powered by" a third party. If you use those applications and tools we may share non-sensitive personal information and any additional information you provide as part of that use with that third party. The third party's use of that information is subject to their privacy policy.

Law Enforcement. We may report to law enforcement agencies any activities that we reasonably believe to be unlawful, or that we believe may aid a law enforcement investigation. In addition, we reserve the right to release all types of information to law enforcement agencies if we determine, in our sole judgment, that either you have violated our policies, or the release of information about you may protect the rights, property or safety of us or another person.

Legal Processes. We may share all types of information with others as required by, or permitted by, law. This may include sharing all types of information with governmental entities, or third parties in response to subpoenas, court orders, other legal process, or as we believe is necessary to exercise our legal rights, to defend against legal claims that have been brought against us, or to defend against possible legal claims that we determine in our sole discretion might be brought against us.

Service Providers. We share all types of information with people and companies that provide us with services. These services may include, among other things, helping us provide products or services that you request, create or maintain our databases, research or analyze the people who use our websites, and/or process payment card information. Unless you consent, we do not permit our service providers to market their own products or services to you directly. We also require our service providers to agree to take reasonable steps to keep the personal information that we provide to them secure. In some instances, we may maintain the look and feel of our site while you are on our service provider's site. You should look for the "privacy policy" link of any page on which you are submitting information to determine if this privacy policy, or another company's privacy policy, governs.

Other Third Parties (without your consent). We may share non-personal information with other third parties that are not described above. When we do so we endeavor to either aggregate or de-identify the information so that a third party would not be likely to link data to you, your computer, or your device. Aggregation means that we combine the non-personal information of numerous people together so that the data does not relate to any one person. De-identify means that we remove or change (e.g., hash) certain pieces of information that might be used to link data to a particular person.

Other Third Parties (with your consent). We may share any information, including sensitive personal information, with other third parties that are not described above if you give us consent to do so.

HOW DO WE SECURE INFORMATION?

We take our commitment to securing personal information in our possession seriously. When you provide your credit card number or a social security number we protect your information during transmission and storage through the use of encryption.

For other types of information, we use reasonable measures to help prevent the information from becoming disclosed to individuals who are not described in this policy. It is important for you to protect against unauthorized access to your password and to your computer. No security measures are perfect and we cannot promise that the information about you will remain secure in all circumstances.

WHAT PRIVACY CHOICES DO YOU HAVE?

We provide you with the following information management choices:

Revising Your Information. If your personal information changes, or if you no longer desire our services, you may correct, update, or delete information about you, or ask that it be removed from public forums such as directories, blogs, or testimonials by logging in and viewing your user profile where applicable (e.g., the "My Account" link on Ingenio.com) or by contacting us at the email address, telephone number, or mailing address indicated below. We attempt to respond to your requests within 30 days. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Behavioral Targeting. We may allow third parties to provide behavioral targeting services on our behalf. Behavioral targeting refers to the use of information about you in order to provide advertising that is tailored to your interests. If you do not want third parties who collect information about your use of our website or applications to use such information for behavioral targeting purposes, you can opt-out by visiting the Network Advertising Initiative opt-out page and/or the Digital Advertising Alliance opt-out page. Please also note that if you are using an Apple device which uses iOS6, you will need to follow the instructions provided by Apple for opting out of using the Apple Advertising Identifier.

SOME ADDITIONAL INFORMATION.

Data Retention. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is permitted by law.

Other Websites. This privacy policy does not apply to websites or applications offered by other companies or individuals, including products or sites that may be displayed in a search on our site. We encourage you to read the privacy policies of any third party website before transmitting personal information.

Other Contractual Relationships. If you enter into a separate contractual relationship with us which requires, or contemplates, collecting, using, sharing, or securing information about you in a manner that is different than that which is described in this policy, the terms of that contract will apply.

Referral Services. If you choose our referral service to tell a friend about our site, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site.

Your California Privacy Rights. Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with us are entitled to ask us for a notice describing what categories of personal customer information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to the following address:

ATTN: Ingenio, LLC. --Privacy Policy
182 Howard Street #826
San Francisco, CA 94105 Please allow 30 days for a response.

Children. Our site is intended for a general audience and we do not knowingly collect personal information from anyone under the age of 18.

Changes To The Privacy Policy. We may update this privacy policy to reflect changes to our information practices. If we make any material changes to our policy, those changes will apply to information collected after the effective date listed, and we will notify you by placing a notice on our websites prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

How Do We Communicate With You. If you have any questions or concerns regarding our privacy policy please contact us at:

Email address: privacy@ingenio.com
Telephone number: 877.529.1193
Mailing address:

Ingenio.—Privacy Policy
182 Howard Street #826
San Francisco, CA 94105

If we need, or are required, to contact you concerning any event that involves information about you we may do so by email, telephone, or mail.

COMMUNICATIONS POLICY

Ingenio may communicate with you in a variety of different ways. The following describes some of your options concerning how we communicate with you:

Email Marketing From Ingenio If you do not want to receive emails from us about products or services that we offer, you can "opt-out" from receiving such emails by clicking on the "unsubscribe" link provided at the bottom of any marketing email that you receive. Please note that if you choose to opt-out we may still send you non-marketing email. For example, we may send you email about a specific product or service that you request, we may respond to a message from you, or we may send you email about the terms and conditions of our websites. If you decide at a later time that you would like to receive commercial emails from us, you can re-add yourself to our communication list.

Telephone Marketing From Ingenio If you do not want to receive telephone calls about products or services that we offer, you can "opt-out" from receiving most telephone marketing calls by visiting the national do not call registry at https://www.donotcall.gov/.

Text Marketing From Ingenio If you do not want to receive text messages from us about products or services that we offer, you can "opt-out" from receiving such texts by text messaging the word STOP in response to a text from Ingenio containing the language " Reply STOP to cancel.". Please note that text messaging charges by your carrier may apply to these types of communications.

 

Advisors are not employees of Ingenio. Ingenio does not provide and is not responsible for any content of information
that you receive or share through the Ingenio service. Read Full Disclaimer.
Ingenio, LLC. All rights reserved.
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