This Policy tells you, among other things, what information we gather from you through our Site, how we may use or disclose that information, and our efforts to protect it.
Notice of Information Collected and Disclosed
We may request such information from you when you:
- Log-on to certain areas of our Web site that require your user name and password as a condition to gaining access to the information, materials or services in that area.
- Register or sign-up to subscribe to a service.
- Subscribe to a newsletter or ask to be added to our mailing lists.
- Purchase a product or service.
- Provide feedback in an online survey.
In connection with your use of our Site, we may collect the following information:
- Information volunteered by the user, such as information provided if they become members of ICPA, which may include name, address, e-mail, phone number, fax number, username, password, e-mail address, company name, information provided in response to our Member Survey, information posted if you participate in any of our discussion boards, and general requests for information and other personal information.
Providing the voluntary data described above is at your sole discretion. If you submit personally identifiable information to us through the Site, then we use your personal information to operate, maintain, and provide to you the features and functionality of the Site. We use both your personally identifiable information and certain non-personally-identifiable information (such as anonymous usage data, cookies, IP addresses, browser type, clickstream data, etc.) to improve the quality and design of the Site and to create new features, functionality, and services by storing, tracking, and analyzing user preferences and trends.
ICPA is the owner of the information collected on this Site. The information is not collected for sale to third party marketers and we do not sell or distribute the information collected from the site for commercial marketing purposes. Except as provided in this Policy, we do not disclose any nonpublic personal information about you to anyone except as permitted by law, however, we may choose to disclose all of the information we collect, as described above, to companies that perform services on our behalf, such as payment processors, data processors, technical systems consultants and programmers and the advertising firms that we use to promote our Site. Additionally, this information may be shared with ICPA partners. We may use the personal identifying information you provide to monitor usage and traffic-levels, analyze trends, administer the Site, track user movement, and gather broad demographic information for aggregate use. We may also use your information to contact you regarding improvements we can make to our Site and our services. ICPA may also share aggregate information about our users with advertisers, sponsors and other third parties, though such summary information will not identify any specifics directly related to your identity. We may also provide analysis based on the information we collect, to our strategic alliance partners and other risk sharing partners. As we develop our business, we may buy or sell some or all of our assets and, depending on the transaction, your personally identifiable information may be one of the transferred assets. Similarly, if ICPA should ever merge with or be acquired by another company, we may share your personal information with any entity resulting from such transaction and if ICPA should ever file for bankruptcy, the bankruptcy trustee has the right to sell the information you provide to us to a third party.
We may use your e-mail address to assist you if you forget your log-in information. We may also use your e-mail address to contact you directly regarding services, products or information that we believe might interest you. Only ICPA (or agents working on behalf of ICPA or with the permission of ICPA) will send you these direct mailings. If you do not want to receive such mailings, you can easily opt-out of receiving further marketing from ICPA as provided in Choice/Opt Out below.
You authorize us to disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, violation of obligations to us under our Terms of Service Agreement or any other agreement or policy, or other illegal activity.
We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement.
State Specific Disclosures
For California residents: Under California Civil Code Section 1798.83, also known as Senate Bill 27, if you are a California resident and ICPA has an established business relationship with you, you have the right to request information from ICPA, free of charge, regarding the manner in which ICPA shares certain categories of your personal information with third parties (whether collected online or offline), for the third parties’ direct marketing purposes. California law provides that you have the right to submit a request to ICPA at its designated address and receive the following information: 1) the categories of information ICPA disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year; 2) the names and addresses of third parties that received such information; and 3) if the nature of a third party’s business cannot be reasonably determined from the third party’s name, examples of the products or services marketed, subject to certain exceptions. You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. For purposes of this paragraph:
•“ICPA” means ICPA stores and the Site, and
•“Third Party” means:
○a business that is outside the ICPA family, and
○affiliates of ICPA.
At the time of this Policy’s adoption, ICPA does not have any affiliates.
This same California law permits ICPA to provide you, in response to your written request, with a cost-free means to choose not to have your information shared rather than providing the above described information.
ICPA’s designated email address for such requests is firstname.lastname@example.org. You may also request this information by writing to: P.O. Box 1544, Springtown, TX 76082. Additionally, you may request that ICPA not share your personal information with third parties for their direct marketing use by following the Choice/Opt-Out procedures outlined below.
For Vermont residents: Vermont law places additional limits on sharing information about Vermont residents. As long as a user remains a resident of Vermont, we will not share information we collect about Vermont residents to companies outside of ICPA or to ICPA affiliates, except:
•To companies that perform marketing or other services on our behalf;
•Contact information (like name and address), and transaction information (such as your payment history) with which we have joint marketing agreements;
•With the authorization or consent of the Vermont resident; or
•As permitted or required by law.
For Nevada residents: We do not share your Customer Information with nonaffiliated third parties for purposes of their offering products and services to you. You do not need to take any action to limit this kind of information sharing. Nevada law requires that we provide you with the following contact information if you desire for ICPA to include you in our internal do not call registry:
P.O. Box 1544
Springtown, TX 76082
Bureau of Consumer Protection
Office of the Nevada Attorney General
555 E. Washington Street, Suite 3900
Las Vegas, Nevada 89101
Phone: (702) 486-3132
In addition, if other states in the future adopt privacy restrictions more restrictive than those under Federal law we will comply with those applicable provisions.
The Site utilizes public forums, which may include blogs, forums, message boards and other interactive features. Please remember that any information that is disclosed in these areas is not protected as confidential and becomes public information. You are solely responsible and should exercise caution when deciding to disclose any personal information in these areas.
Abuse of Terms of Service Agreement
We have the right to share your name and contact information with our attorneys and law enforcement officials, if needed, in the event we believe you have breached our Terms of Service Agreement.
Collection and Use of IP Addresses
We may use IP addresses to analyze trends, administer the Site, track user’s movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information. Please see Notice of Information Collected and Disclosed above for more information.
Confidentiality of Transmissions
Please remember that transmissions on the Internet are not always confidential. You are transmitting this information at your own risk. Please see Security below for more information.
To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before creating your user account. The user that created the account for a user is responsible for maintaining the secrecy of a users unique password and account information at all times.
You may, of course, decline to submit personally identifiable information through the Site, in which case ICPA may not be able to provide certain services to you.
If you prefer that we not disclose nonpublic personal information about you to nonaffiliated third parties, you may opt out of those disclosures; that is, you may direct us not to make those disclosures (other than disclosures permitted by law). If you receive communications from us that you do not want to receive, you can opt out from receiving these communications, by specifically telling us to stop sending them to you. We will generally be able to give effect to your withdrawal on 30 days’ notice. If you wish to opt out of disclosures to nonaffiliated third parties, you may e-mail your request to ICPA at email@example.com.
Onward Transfer (Transfers to Third Parties)
We will apply the Notice and Opt-out policies discussed above in the event we propose to disclose your information to a third party.
We treat data as an asset that must be protected and use lots of tools (encryption, passwords, physical security, etc.) to protect your personal information against unauthorized access and disclosure.
Our credit card processing vendors, Earthcare Technologies, Inc. and GoEmerchant.com, andLands’ End Business Outfitters, which hosts ICPA’s E-Store, eachhave their own security policies that relate to the data they process. Please click on the foregoing links to review their security policies.
Information you elect to post our the Site, e-mails and other information you send to us, except that which you send us on a secure page, is not encrypted and such transmissions cannot be considered a secure means of transmitting sensitive information. ICPA will never ask you to submit your financial data, such as your credit card account numbers, via e-mail. IF YOU RECEIVE AN E-MAIL REQUESTING THAT YOU FORWARD INFORMATION OF THIS NATURE BY E-MAIL, PLEASE CONTACT US DIRECTLY AT firstname.lastname@example.org. DO NOT REPLY DIRECTLY TO THE E-MAIL. You should be aware of the limitations of security, authentication, encryption, and privacy measures used in connection with the Internet and that any information you transmit through the Site may be damaged, corrupted, “sniffed” and/or accessed by another person without your permission.
Regardless of the precautions taken by you or by us, “perfect security” does not exist on the Internet. Third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse your personal information that they collect from the site. Therefore, although we work very hard to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private. We cannot ensure or warrant the ultimate security of any information you transmit.
Linked Sites And Third Party Vendors
The Site may contain links to other sites. Please be aware that ICPA may not be responsible for content or the privacy practices of such other sites. We encourage our users to be aware when they leave our Site and recommend that they read the privacy statements of each and every Web site they visit. This Policy applies solely to information collected by this Site.
It should be noted that ICPA utilizes third party vendors for commercial transactions. Specifically, ICPA utilizes Earthcare Technologies, Inc., GoEmerchant.com and Lands’ End Business Outfitters, all of which provide their own detailed Privacy and Terms of Service Agreements. Please review those policies carefully before you disclose any personal information.
Age Restrictions; Children’s Privacy
This Site is not directed at children under the age of 18 and does not knowingly collect personal information from children under the age of 18. If ICPA obtains actual knowledge that it has obtained personal information about a child under the age of 18, that information is immediately and permanently deleted from our records.
ICPA provides users the following options for changing and modifying information previously submitted.
- You can send e-mail to email@example.com.
- You can send mail to the following postal address:
P.O. Box 1544
Springtown, TX 76082
If you have a comment, question or request, or if you need to contact ICPA for any other reason, there are two easy ways to do so.
(a)E-mail: You can e-mail at firstname.lastname@example.org.
(b)U.S. Mail: Send mail to ICPA at:
P.O. Box 1544
Springtown, TX 76082
Acceptance of Privacy Statement
Updates to Policy
This Policy updated September 1, 2009.