Privacy Policy

Last Updated: January 20, 2010

Track.com, LLC ("Track.com", "we", "our") is committed to protecting and respecting your privacy. This Privacy Policy describes how we collect, use and protect your Personal Information. By accepting the Privacy Policy and the Terms of Use during registration, you expressly consent to the collection, storage, use and disclosure of your Personal Information as described in this Privacy Policy.

Contents

What Information Do We Collect?

Personal Information means any information that may be used to identify an individual, including, but not limited to, a first and last name, personal profile, a home or other physical address and an email address or other contact information, whether at work or at home. Currently, we do not require you to provide Personal Information in order to have access to the free commentary, analysis and news available on the Track.com website (the "Site").

We collect information about our readers so that we can provide a more interesting and useful service, as well as more appropriate advertising. We will ask for your name, email address, and other Personal Information when you register to use certain features of the Site, or if you sign up for special or personalized services, such as our comment and messaging services.

If you use our recommendation service to email one of our articles to a friend, you will need to provide us with your friend's email address. We will automatically send this person a one-time email, with the recommended article attached, as well as invite your friend to visit and register with the Site. We will not use these email addresses for any other purpose.

We collect IP addresses for site security and to help us understand how people use the Site so that we can improve the Site and our users' respective experiences. For similar quality reasons, we use a feature known as a "cookie." Cookies contain bits of information that websites transfer to your computer's hard drive for record-keeping purposes. Cookies can make the Web more convenient by storing information about your preferences on a site. Although we may assign your browser a cookie, the cookie does not tell us who you are. Only you can tell us that.

When you place an order for a product or service, we need to know the sort of information typically used for credit card transactions, such as your name, mailing and billing addresses, telephone number, and credit card number and expiration date. Gathering this information allows us to process and fulfill your order and notify you of your order status. We encrypt all of this information using Secure Socket Layers (SSL) technology.

We may also collect your email address when you submit content to the Site however, we will not display your address with your submission.

Besides cookies, we may also use tiny electronic images (called "single-pixel GIFs" or "Web beacons"), which allow us to count users who have visited specific pages or access certain cookies. We may use single-pixel GIFs in the following ways:

To count and recognize users.

Advertising networks that serve ads on the 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.

If you choose to provide us with your Personal Information on the Site, we may transfer that Personal Information within Track.com or to our third-party service providers, but only to provide services on the Site.

How Secure Is The Information We Collect?

Track.com is committed to industry best practices concerning security to prevent the loss, misuse and alteration of the information in our possession. However, as you know, third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse 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.

Payment transactions are conducted in a Secure Socket Layer (SSL) session, which encrypts all transaction data for transmittal in a format that helps reduce the chance of theft of the information. While on a secure page, most modern browsers will let you know that you are in a secured session. Our servers are located in a secure, supervised environment.

Personalized areas of the Site are password-protected. Only you have access to these password-protected areas. Do not share your passwords with anyone. Track.com will never ask you for your password in an unsolicited phone call or email. If you are using a computer to which others have access, such as one in a computer lab, Internet cafe, or public library, always remember to log out, clear the cache and close your browser window when leaving the Site.

How Do We Use Your Information?

We will never resell or redistribute your Personal Information without your express permission. You agree that we may use your Personal Information to:

Occasionally, we may conduct user surveys to learn how we can better serve you. These surveys are optional and if you choose to respond, your responses will be kept anonymous. The demographic information we collect in the registration process and through surveys is used to help us improve our services.

Sometimes we ask for Personal Information when providing special features and services. You do not have to give us that information, but without it, you may not be able to take advantage of those products or services. For example, you may not be able to gain access to certain areas of the Site unless you register and/or subscribe.

To Whom May We Disclose Your Information?

Track.com will not disclose any Personal Information, except as set forth in this Privacy Statement. With the few exceptions that we explain here, we do not give, rent, lend, or sell individual information to our advertisers, although we may provide aggregate information.

If you choose to provide us with your Personal Information on the Site, we may transfer that Personal Information within Track.com or to Track.com's third-party service providers, but only to provide services on the Site. In addition, we may disclose your Personal Information if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to i) comply with any applicable law, regulation, legal process or governmental request, ii) enforce our Terms of Use including investigations of potential violations thereof, iii) detect, prevent, or otherwise address fraud, security or technical issues, or iv) protect against harm to the rights, property or safety of Track.com, its users, yourself or the public.

Notwithstanding the above, we may at a later time choose to make certain offers or services available to our users from third parties. If we do, during the registration process and at certain points thereafter in connection with specific offers we may ask you whether your Personal Information may be sent to third parties who have products, services and opportunities which may be useful to you. If you give your permission to allow third parties to contact you, your Personal Information (such as your contact information and other information collected during your visit to our Site) may be shared with data aggregators, marketers (possibly in the form of list rental), and other organizations. Track.com does not intend to transfer Personal Information without your consent to third parties who are not bound to act on Track.com's behalf unless such transfer is legally required. Regardless of your decision regarding the sharing of your Personal Information, we may share broad aggregate demographic data and related usage information with our business partners. This aggregate information does not contain any Personal Information that can identify an individual user.

How Do We Protect Children's Privacy?

We operate our sites in compliance with the Children's Online Privacy Protection Act and will not knowingly collect or use personally identifiable information from anyone under 13.

How Do We Use Cookies?

IP Addresses

Your Web browser or email application automatically provides your Internet Protocol address ("IP address") to other computers with which you communicate over the Internet, so that they know where to send you information.

We receive an IP address each time you view one of our Web pages, because the browser automatically reports it to us. We also may store the IP address when you register with Track.com, post a message, or buy something from us.

We may use IP addresses for various purposes, including:

Cookies

Cookies may be used on the Site in the following ways:

Most browsers are set up to accept cookies, but you can configure yours to refuse cookies or notify you when you've received one. Browsers differ, so check your "Help" menu to learn how to change your cookie preferences. If you reject cookies on the Site, though, you may not be able to access all areas of the Site or use many of its features, including our comment and messaging services. When you accept our cookies, we cannot use them to find out who you really are, unless you tell us.

How Can You Protect Your Account?

While we do our best to protect Personal Information, Track.com cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. You are responsible for maintaining the secrecy of any password and/or account information. If your password has been compromised for any reason, you should immediately notify us and change your password. Please be careful and responsible whenever you are online, especially when using a computer that other people can use also.

How Can You Access, Review or Change Your Personal Information?

To the extent that you do provide us with Personal Information, Track.com wishes to maintain accurate Personal Information. You may check your profile and add information, delete information or correct any incorrect information on your Profile & Settings . We do retain Personal Information from closed accounts to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Site policies, and take other actions permitted by law.

Third Parties

Many of our advertisers or partners link from the 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. Track.com has no responsibility or liability for these independent policies (and we may not even know what they are). For more information regarding a site and its privacy policies, check that site.

What Else Should You Know About Your Privacy?

When you post information on our comment or message services or in similar public features on the Site, that information, along with your screen name, is visible to the public. Please remember that whenever you disclose Personal Information publicly that information can be collected and used by others. In short, if you post Personal Information online where people can see it, people will know that information and you may receive unsolicited messages from other parties in return.

Also please be aware that when you post messages on our comment or message services, people can respond to your posts through either our "Reply to Author" or "Reply to Comment" email function. Of course, they still will not know your email address.

How Can You Deactivate Your Account or Edit the Information We Have About You?

If you want to correct or change information in your Personal Profile, or any other tidbits we have about you, please go to Profile & Settings and you will be able to make your changes right there.

If you want to make changes to your subscriptions, please either email us at subscriptions@track.com or go to My Subscription.

General

We may amend this policy from time to time. If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by e-mail, or by means of a notice on our homepage. If your questions are not answered online, you may write to us at:

Track.com, LLC
Attn: Legal Department - Privacy Policy
101 Eisenhower Blvd., Suite 300
Roseland, NJ 07068

or email us: customerservice@track.com.