Privacy Policy

Choice Exposure Marketing (“Company” or “we” or “us” or “our”) respects the privacy of its users (“user” or “you”) that use our website located at, including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively, the “Website”). The

following Company privacy policy (“Privacy Policy”) is designed to inform you,

as a user of the Website, about the types of information that Company may gather

about or collect from you in connection with your use of the Website. It also

is intended to explain the conditions under which Company uses and discloses

that information, and your rights in relation to that information. Changes to

this Privacy Policy are discussed at the end of this document. Each time you

use the Website, however, the current version of this Privacy Policy will

apply. Accordingly, each time you use the Website you should check the date of

this Privacy Policy (which appears at the beginning of this document) and

review any changes since the last time you used the Website.

The Website is hosted in the United States of

America and is subject to U.S. state and federal law. If you are accessing our

Website from other jurisdictions, please be advised that you are transferring

your personal information to us in the United States, and by using our Website,

you consent to that transfer and use of your personal information in accordance

with this Privacy Policy. You also agree to abide by the applicable laws of

applicable states and U.S. federal law concerning your use of the Website and

your agreements with us. Any persons accessing our Website from any

jurisdiction with laws or regulations governing the use of the Internet,

including personal data collection, use and disclosure, different from those of

the jurisdictions mentioned above may only use the Website in a manner lawful

in their jurisdiction. If your use of the Website would be unlawful in your

jurisdiction, please do not use the Website.





Users of the Website Generally

“Non-Personally-Identifying Information” is

information that, without the aid of additional information, cannot be directly

associated with a specific person. “Personally-Identifying Information,” by

contrast, is information such as a name or email address that, without more,

can be directly associated with a specific person. Like most website operators,

Company gathers from users of the Website Non-Personally-Identifying

Information of the sort that Web browsers, depending on their settings, may

make available. That information includes the user’s Internet Protocol (IP)

address, operating system, browser type and the locations of the websites the

user views right before arriving at, while navigating and immediately after

leaving the Website. Although such information is not Personally-Identifying Information,

it may be possible for Company to determine from an IP address a user’s

Internet service provider and the geographic location of the visitor’s point of

connectivity as well as other statistical usage data.

Company analyzes Non-Personally-Identifying Information gathered from

users of the Website to help Company better understand how the Website is being

used. By identifying patterns and trends in usage, Company is able to better

design the Website to improve users’ experiences, both in terms of content and

ease of use. From time to time, Company may also release the

Non-Personally-Identifying Information gathered from Website users in the

aggregate, such as by publishing a report on trends in the usage of the


Web Cookies

A “Web Cookie” is a string of information which

assigns you a unique identification that a website stores on a user’s computer,

and that the user’s browser provides to the website each time the user submits

a query to the website. We use cookies on the Website to keep track of services

you have used, to record registration information regarding your login name and

password, to record your user preferences, to keep you logged into the Website

and to facilitate purchase procedures. Company also uses Web Cookies to track

the pages that users visit during each Website session, both to help Company

improve users’ experiences and to help Company understand how the Website is

being used. As with other Non-Personally-Identifying Information gathered from

users of the Website, Company analyzes and discloses in aggregated form

information gathered using Web Cookies, so as to help Company, its partners and

others better understand how the Website is being used. COMPANY USERS WHO DO






Web Beacons

A “Web Beacon” is an object that is embedded in

a web page or email that is usually invisible to the user and allows website

operators to check whether a user has viewed a particular web page or an email.

Company may use Web Beacons on the Website and in emails to count users who

have visited particular pages, viewed emails and to deliver co-branded

services. Web Beacons are not used to access users’ Personally-Identifying

Information. They are a technique Company may use to compile aggregated

statistics about Website usage. Web Beacons collect only a limited set of

information, including a Web Cookie number, time and date of a page or email

view and a description of the page or email on which the Web Beacon resides.

You may not decline Web Beacons. However, they can be rendered ineffective by

declining all Web Cookies or modifying your browser setting to notify you each

time a Web Cookie is tendered, permitting you to accept or decline Web Cookies

on an individual basis.


We may partner with selected third parties to

allow tracking technology on the Website, which will enable them to collect

data about how you interact with the Website and our services over time. This

information may be used to, among other things, analyze and track data,

determine the popularity of certain content and better understand online


Aggregated and Non-Personally-Identifying


We may share aggregated and Non-Personally

Identifying Information we collect under any of the above circumstances. We may

also share it with third parties and our affiliate companies to develop and

deliver targeted advertising on the Website and on websites of third parties.

We may combine Non-Personally Identifying Information we collect with

additional Non-Personally Identifying Information collected from other sources.

We also may share aggregated information with third parties, including

advisors, advertisers and investors, for the purpose of conducting general business

analysis. For example, we may tell our advertisers the number of visitors to

the Website and the most popular features or services accessed. This

information does not contain any Personally-Identifying Information and may be

used to develop website content and services that we hope you and other users

will find of interest and to target content and advertising.

Mobile Device Additional Terms


Mobile Device. If you use a

mobile device to access the Website or download any of our applications, we may

collect device information (such as your mobile device ID, model and

manufacturer), operating system, version information and IP address.


Geo-Location Information. Unless

we have received your prior consent, we do not access or track any location-based

information from your mobile device at any time while downloading or using our

mobile application or our services, except that it may be possible for Company

to determine from an IP address the geographic location of your point of

connectivity, in which case we may gather and use such general location data.

  Push Notifications. We

send you push notifications if you choose to receive them, letting you know

when someone has sent you a message or for other service-related matters. If

you wish to opt-out from receiving these types of communications, you may turn

them off in your device’s settings.


Mobile Analytics. We

use mobile analytics software to allow us to better understand the

functionality of our mobile software on your phone. This software may record

information, such as how often you use the application, the events that occur

within the application, aggregated usage, performance data and where the

application was downloaded from. We do not link the information we store within

the analytics software to any Personally-Identifying Information you submit

within the mobile application.


We may use hyperlinks on the Website which will redirect

you to a social network if you click on the respective link. However, when you

click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet”

button or the Google+, that particular social network’s plugin will be

activated and your browser will directly connect to that provider’s servers. If

you do not use these buttons, none of your data will be sent to the respective

social network’s plugin provider. So for example, when you click on the

Facebook’s “Like” button on the Website, Facebook will receive your IP address,

the browser version and screen resolution, and the operating system of the

device you have used to access the Website. Settings regarding privacy

protection can be found on the websites of these social networks and are not

within our control.



Website Registration

As defined above, Personally-Identifying

Information is information that can be directly associated with a specific

person. Company may collect a range of Personally-Identifying Information from

and about Website users. Much of the Personally-Identifying Information

collected by Company about users is information provided by users themselves

when (1) registering for our service, (2) logging in with social network

credentials, (3) participating in polls, contests, surveys or other features of

our service, or responding to offers or advertisements, (4) communicating with

us, (5) creating a public profile or (6) signing up to receive newsletters.

That information may include each user’s name, address, email address and telephone

number, and, if you transact business with us, financial information such as

your payment method (valid credit card number, type, expiration date or other

financial information). We also may request information about your interests

and activities, your gender, age, date of birth, username, hometown and other

demographic or relevant information as determined by Company from time to time.

Users of the Website are under no obligation to provide Company with

Personally-Identifying Information of any kind, with the caveat that a user’s

refusal to do so may prevent the user from using certain Website features.





Company Communications

We may occasionally use your name and email

address to send you notifications regarding new services offered by the Website

that we think you may find valuable. We may also send you service-related

announcements from time to time through the general operation of the service.

Generally, you may opt out of such emails at the time of registration or

through your account settings, though we reserve the right to send you notices

about your account, such as service announcements and administrative messages,

even if you opt out of all voluntary email notifications.

Company Disclosures

Company will disclose Personally-Identifying

Information under the following circumstances:

  By Law or to Protect Rights. When we believe disclosure is appropriate, we

may disclose Personally-Identifying Information in connection with efforts to

investigate, prevent or take other action regarding illegal activity, suspected

fraud or other wrongdoing; to protect and defend the rights, property or safety

of Company, our users, our employees or others; to comply with applicable law

or cooperate with law enforcement; to enforce our Terms of Use or other

agreements or policies, in response to a subpoena or similar investigative

demand, a court order or a request for cooperation from a law enforcement or

other government agency; to establish or exercise our legal rights; to defend

against legal claims; or as otherwise required by law. In such cases, we may

raise or waive any legal objection or right available to us.

•   Marketing Communications. Unless users opt-out from receiving

Company marketing materials upon registration, Company may email users about

products and services that Company believes may be of interest to them. If you

wish to opt-out of receiving marketing materials from Company, you may do so by

following the unsubscribe link in the email communications, by going to your

account settings (if applicable) or contacting us using the contact information



 Third-Party Service Providers. We may share your Personally-Identifying

Information, which may include your name and contact information (including

email address) with our authorized service providers that perform certain

services on our behalf. These services may include fulfilling orders, providing

customer service and marketing assistance, performing business and sales analysis,

supporting the Website’s functionality and supporting contests, sweepstakes, surveys

and other features offered through the Website. We may also share your name,

contact information and credit card information with our authorized service

providers who process credit card payments. These service providers may have

access to personal information needed to perform their functions but are not

permitted to share or use such information for any other purpose.

 Business Transfers; Bankruptcy. Company reserves the right to transfer all

Personally-Identifying Information in its possession to a successor

organization in the event of a merger, acquisition, bankruptcy or other sale of

all or a portion of Company’s assets. Other than to the extent ordered by a bankruptcy

or other court, the use and disclosure of all transferred Personally-Identifying

Information will be subject to this Privacy Policy, or to a new privacy policy

if you are given notice of that new privacy policy and are given an opportunity

to affirmatively opt-out of it. Personally-Identifying Information submitted or

collected after a transfer, however, may be subject to a new privacy policy

adopted by the successor organization.

Changing Personally-Identifying Information;

Account Termination

You may at any time review or change your

Personally-Identifying Information by going to your account settings (if

applicable) or contacting us using the contact information below.  Upon

your request, we will deactivate or delete your account and contact information

from our active databases. Such information will be deactivated or deleted as soon

as practicable based on your account activity and accordance with our

deactivation policy and applicable law. To make this request, either go to your

account settings (if applicable) or contact us as provided below. We will

retain in our files some Personally-Identifying Information to prevent fraud,

to troubleshoot problems, to assist with any investigations, to enforce our

Terms of Use and to comply with legal requirements as is permitted by law.

Therefore, you should not expect that all your Personally-Identifying

Information will be completely removed from our databases in response to your

requests. Additionally, we keep a history of

changed information to investigate suspected fraud with your account.

General Use

Company uses the Personally-Identifying

Information in the file we maintain about you, and other information we obtain

from your current and past activities on the Website (1) to deliver the products

and services that you have requested; (2) to manage your account and provide you

with customer support; (3) to communicate with you by email, postal mail,

telephone and/or mobile devices about products or services that may be of

interest to you either from us, our affiliate companies or other third parties;

(4) to develop and display content and advertising tailored to your interests

on the Website and other sites; (5) to resolve disputes and troubleshoot

problems; (6) to measure consumer interest in our services; (7) to inform you

of updates; (8) to customize your experience; (9) to detect and protect us

against error, fraud and other criminal activity; (10) to enforce our Terms of

Use; and (11) to do as otherwise described to you at the time of collection. At

times, we may look across multiple users to identify problems. In particular,

we may examine your Personally-Identifying Information to identify users using

multiple user IDs or aliases. We may compare and review your

Personally-Identifying Information for accuracy and to detect errors and

omissions. We may use financial information or payment method to process

payment for any purchases made on the Website, enroll you in the discount,

rebate, and other programs in which you elect to participate, to protect

against or identify possible fraudulent transactions and otherwise as needed to

manage our business.



Company contractually prohibits its contractors,

affiliates, vendors and suppliers from disclosing Personally-Identifying

Information received from Company, other than in accordance with this Privacy

Policy. However, third parties are under no obligation to comply with this

Privacy Policy with respect to Personally-Identifying Information that users

provide directly to those third parties, or that those third parties collect for

themselves. These third parties include advertisers, providers of games,

utilities, widgets and a variety of other third-party applications accessible

through the Website. Company neither owns nor controls the third-party websites

and applications accessible through the Website. Thus, this Privacy Policy does

not apply to information provided to or gathered by the third parties that

operate them. Before visiting a third party, or using a third-party

application, whether by means of a link on the Website, directly through the

Website or otherwise, and before providing any Personally-Identifying

Information to any such third party, users should inform themselves of the

privacy policies and practices (if any) of the third party responsible for that

website or application, and should take those steps necessary to, in those

users’ discretion, protect their privacy.


We take the security of your Personally-Identifying

Information seriously and use reasonable electronic, personnel and physical

measures to protect it from loss, theft, alteration or misuse.  However,

please be advised that even the best security measures cannot fully eliminate

all risks. We cannot guarantee that only authorized persons will view your

information. We are not responsible for third-party circumvention of

any privacy settings or security measures.

We are dedicated to protect all information on

the Website as is necessary. However, you are responsible for maintaining the

confidentiality of your Personally-Identifying Information by keeping your

password confidential. You should change your password immediately if you

believe someone has gained unauthorized access to it or your account. If you

lose control of your account, you should notify us immediately.


Company may, in its sole discretion, change this

Privacy Policy from time to time. Any and all changes to Company’s Privacy

Policy will be reflected on this page and the date new versions are posted will

be stated at the top of this Privacy Policy. Unless stated otherwise, our

current Privacy Policy applies to all information that we have about you and

your account. Users should regularly check this page for any changes to this

Privacy Policy. Company will always post new versions of the Privacy Policy on

the Website. However, Company may, as determined in its discretion, decide to

notify users of changes made to this Privacy Policy via email or otherwise. Accordingly,

it is important that users always maintain and update their contact information.


The Children's Online Privacy Protection Act

("COPPA") protects the online privacy of children under 13 years of

age. We do not knowingly collect or maintain Personally-Identifying Information

from anyone under the age of 13, unless or except as permitted by law. Any

person who provides Personally-Identifying Information through the Website

represents to us that he or she is 13 years of age or older. If we learn that

Personally-Identifying Information has been collected from a user under 13 years

of age on or through the Website, then we will take the appropriate steps to

cause this information to be deleted. If you are the parent or legal guardian

of a child under 13 who has become a member of the Website or has otherwise

transferred Personally-Identifying Information to the Website, please contact

Company using our contact information below to have that child's account

terminated and information deleted.


California Civil Code Section 1798.83, also

known as the "Shine The Light" law, permits our users who are

California residents to request and obtain from us, once a year and free of

charge, information about the Personally-Identifying Information (if any) we

disclosed to third parties for direct marketing purposes in the preceding

calendar year. If applicable, this information would include a list of the

categories of the Personally-Identifying Information that was shared and the

names and addresses of all third parties with which we shared Personally-Identifying

Information in the immediately preceding calendar year. If you are a California

resident and would like to make such a request, please submit your request in

writing to our privacy officer as listed below.


Most web browsers and some mobile operating

systems include a Do-Not-Track (“DNT”) feature or setting you can activate to

signal your privacy preference not to have data about your online browsing

activities monitored and collected. Because there is not yet a common understanding

of how to interpret the DNT signal, the Website currently does not respond to

DNT browser signals or mechanisms.


If you have any questions regarding our Privacy

Policy, please contact our Privacy Officer at: