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GLEEDEN’S Privacy Policy

(as of December 1, 2009)

Gleeden is committed to preserve and secure the Privacy of its Members.

Gleeden has applied for certification to the US-EU Safe Harbor Rules on Privacy which is a streamlined process for US companies to comply with the EU Directive 95/46/EC on the protection of personal data. The Safe Harbor Principles are intended for organizations within the EU or US that store customer data and are designed to prevent accidental information disclosure or loss.

Gleeden will abide by the seven Safe Harbor Principles:

Notice – Gleeden informs its Members that their data is being collected and about how it will be used.

Choice – Gleeden gives its Members the ability to opt out of the collection of data and forward transfer of the data to third parties.

Onward Transfer - Transfers of data to third parties may only occur to other organizations that follow adequate data protection principles.

Security – Gleeden undertakes reasonable efforts to prevent loss of collected information.

Data Integrity – Gleeden represents that the collected data is relevant and reliable for the purpose it was collected for.

Access – Gleeden provides its Members to access information held about them, and correct or delete it if it is inaccurate.

Enforcement – The present Privacy Policy informs Gleeden’s Members of their rights and how to exercise their rights.

Where does Gleeden collect information ?

Gleeden’s servers are located in the United States. By providing any Personal Information to Gleeden, all Members, including, without limitation, Members in Canada and in the European Union, fully understand and unambiguously consent to this Privacy Policy and to the transfer of such Personal Information across international borders in accordance with Gleeden’s standard operations, including the collection, storage, and processing of such information in the United States of America.

Why does Gleeden collect information on me?

We need your personal information (including without limitation, your name, age, sex, telephone number, e-mail address, and credit card number) necessary to provide a high quality service. . We also retain details of your specific product purchases and transactions, interests or preferences. We may collect non-personal information about how Members navigate through the site.

Gleeden shall not sell or provide any personal data to anyone except in the following circumstances: (1) to financial institutions providing financial or related services (to process payment), (2) to governmental authorities (for data protection), (3) in connection with a corporate re-organization, a merger or an amalgamation of Gleeden with another company or a sale of all or a substantial portion of Gleeden's assets, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information, (4) to a third party without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other website users or anyone else that could be harmed by such activities, or (5) if required by law.

Gleeden may share non-personal information (including but not limited to hits to our server, the types of browsers used to access our Site, page views, and navigational patterns) with consultants for statistical reasons, or to enhance the Service. The information that is collected in this manner does NOT provide us with any personally identifiable information about our Members. It helps us track “where” our Members come from, allows us to identify high traffic areas and determine the most effective ways to communicate with our Members. Gleeden may also uses devices called “web beacons” to help us identify when emails sent to you have been received and read. In order to prevent the introduction of viruses and hackers into our Service we may collect information, such as IP addresses, into a log file to be used to identify potential hackers of our site.

How secure are my personal information on Gleeden?

Your personal information is very important to Gleeden. Gleeden uses various technical and management practices to help protect your confidentiality, security and integrity of the information you share with us.

The site encrypts your credit card number and other personal information using secure socket layer (SSL) and Triple DES technology that allows for the secure transmission of information from your computer to our servers. In addition, only those employees and third parties who require this information in order to process your request are allowed access to this information.

What information will Gleeden ask me to provide?

When you create a free profile, you will be asked to provide a certain number of information that will allow our search engines to generate the best results.

We will save your personal information (email address…), and demographic data (your city, you age, your gender…) on our servers. Gleeden may share only demographic data with our consultants to improve our Service.

When you register your profile, you may use a pseudonym for username, indicate the city where you live and provide a description of yourself and of your preferences. Your real name never appears on the website, but be aware that personal pictures that you post may identify you.

How will Gleeden use my personal information?

Gleeden will use your personal information to process your purchase transactions, to send you marketing and promotional materials by e-mail, to keep you apprised of updates and to help us improve our services for you. Any notifications will be sent by email only.

Your personal information enables Gleeden to provide you with a personalized environment, and allow other members to find you through our advanced search monitor.

How long will Gleeden keep my personal information?

We will keep your personal information as long as your profile remains active. Once you cease to be a Member, Gleeden will not archive your personal information on our servers but will automatically delete all your personal information from our servers. We may keep however non-personal information (sex, age, city, etcetera) for statistical reasons and such information shall be considered as fungible.

How can I access my personal information and manage it?

You can access and manage your information from the page “manage my profile” while you are a Member. When you cease to be a Member, you may contact us at any time to access the non-personal information in our possession.

Can I Opt Out of the Collection of Data?

You may do so at any time by contacting us at info@gleeden.com. However, if you choose not to provide requested personal information, you may not be able to use certain features of the Service and you will not be able to use the Service. This may cause us to stop to offer you the Service and terminate your Membership. If your request is that we not disclose non-public personal information about you to nonaffiliated third parties, you can direct us not to make those disclosures. If you wish to opt out of disclosures to nonaffiliated parties, contact us at info@gleeden.com.

What information do you gather from visitors?

We use your IP address to maintain our site and be able to react quickly to any problem with our server.

We use cookies to identify traffic generated and to provide you with a very personal environment. Cookies are pieces of information placed on your hard drive so we can recognize you when you visit us. Cookies enable us to provide you with a friendly environment and a very personalized access. Using cookies is very common. If you are not comfortable with this, you can disable the cookies through your Internet browser options. Gleeden will function the same way if you disable cookies.

Unsolicited emails?

Gleeden does not send unsolicited mail. Gleeden will send you e-mails only if you consent to receiving such e-mails. You can disable this function in your account settings.

If you have any questions or requests about the privacy of your information, please contact us at info@gleeden.com.

If you reside in California?

Pursuant to California Civil Code Section 1798.83, a California resident who has provided Personal Information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California Customer”) is entitled to request information about whether the business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of Personal Information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom Personal Information was disclosed in the preceding calendar year, as well as a list of the categories of Personal Information that were disclosed.

However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy) a policy of not disclosing customer’s Personal Information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of Personal Information and providing a cost free means to exercise that right.

As stated in this Privacy Policy, we do not share information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure -- typically by opting in to receive information from a third party that is participating in some activity describes on our site. If you do ask us to share your information with a third party for its marketing purposes, we will only share information in connection with that specific activity, as we do not share information with any third party on a continual basis. To prevent disclosure of your Personal Information for use in direct marketing by a third party, do not opt in to such use when you provide Personal Information on our site. Please note that whenever you opt in to receive future communications from a third party, your information will be subject to the third party's privacy policy. If you later decide that you do not want that third party to use your information, you will need to contact the third party directly, as we have no control over how third parties use information. You should always review the privacy policy of any party that collects your information to determine how that entity will handle your information.

California customers may request further information about our compliance with this law by emailing info@gleeden.com. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address.

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USA