EmailCash2.com by Direct Wealth Management LLC, (DWM) is committed to protecting the
privacy of all individuals who provide their personal information. DWM does not collect, use or disclose the
personal information of individuals without their knowledge and consent.
It is DWM'S policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the
privacy legislation and / or an individual's right to privacy are different from one jurisdiction to another.
This policy describes the information collection, use, and dissemination practices of DWM and applies to DWM'S collection, use,
storage and disclosure of information by DWM on its (a) websites, including all its divisions, subsidiaries and related
companies and websites (collectively, the "Websites"), (b) on various Third Party websites, and (c) to DWM's other information
collection, including the purchase of customer lists from Third Parties. DWM is not responsible for the information collection
or privacy practices of Third Party websites or applications.
By visiting this website and requesting information, products or services, you agree to be bound by
the terms and conditions of this Privacy Policy. If you do not agree with the terms of this Privacy Policy,
please do not provide any information or use any of the services or products offered or provided on any of the
websites referred to in this Privacy Policy.
Please Note: DWM from time to time, may make changes to this privacy policy to reflect changes in its legal or
regulatory obligations or in the manner in which we deal with your personal information. Changes are effective upon posting.
It is your sole responsibility to be aware of changes. We do not provide notices of changes in any manner other than by positing
the changes at this web site. We encourage you to refer back to this policy on a regular basis.
Last updated: December 5, 2008
THE INFORMATION COLLECTION, USE AND DISSEMINATION PRACTICES OF DWM.
1. COLLECTION OF INFORMATION
1.1 Survey Information
DWM collects information from individuals by various methods, including, but not limited to, when an individual voluntarily completes a survey, order form,
or a registration page either online or offline, or by means of online or offline surveys, order forms, or registration pages
operated by Third Parties (collectively, a "Survey"). (As used herein, "online" means using the Internet, including the Websites,
and related technologies, and "offline" means by methods other than online, including in person, in the postal mail, using
telephones and cell phones, and other similar means.) In the Surveys, DWM or a Third Party (a "Third Party") may ask an individual
to provide various information to DWM, which may include his or her name, email address, street address, postal/zip code,
telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status,
occupation, social insurance/security number, employment information, personal and online interests, and such other information
as may be requested from time to time (together, "Survey Information"). DWM may also collect information concerning an individual
from another source and uses that information in combination with information provided from this web site. Completing the Surveys
is completely voluntary, and individuals are under no obligation to provide Survey Information to DWM or Third Party.
1.2 Site Membership or Registration
To the extent registration is required to receive email and possibly postal communications from DWM, this Privacy Policy also applies to consumers that have
agreed to receive e-mail marketing from DWM, whether at our Website, via email, on Third Party websites or otherwise.
We collect information in certain portions of our Website, where guests provide content submissions and suggestions or participate
in interactive online activities (i.e., by way of responding to questions and surveys, community listings, ratings, searches and
comparison searches, bidding, purchasing, chat, games, or bulletin boards, etc.). The personal profile information you submit to
DWM remains your property, but by submitting that information to DWM, you grant DWM, the right to use that information for marketing
purposes. DWM may also use such information for content improvement and feedback purposes. We may sell the personal information that
you supply to us and we may join together with other businesses to bring selected retail opportunities to our members.
These businesses may include providers of direct marketing services and applications, including lookup and reference, data
enhancement, suppression and validation. In addition, DWM reserves the right to release current or past member information in
the event DWM believes that the membership is being or has been used in violation of the Rules or to commit unlawful acts, if
the information is subpoenaed, if DWM is sold or acquired, or when DWM deems it necessary or appropriate. By agreeing to these
terms, you hereby consent to disclosure of any record or communication to any Third Party when DWM, in its sole discretion,
determines the disclosure to be appropriate
"Subscription" occurs when an end-user registers for DWM's services, either via registration at our website, via co-registration at a
marketing partner's website, or via a permission pass / opt-out / no-opt mailing. DWM collects personally identifiable
information about our subscribers, based on: information gathered at the time of registration, subscriber interaction and
response to subsequent electronic mailings and website use, information provided by marketing partners, and information appended
from data aggregators. Information collected may include, but is not necessarily limited to: name, email address, postal address,
gender, birth date, telephone number, activity, interests, user behavior and other demographic information.
This information enables us to better tailor our content to subscribers' needs and to help our clients to promote
and sell their products and services.
1.3 Third Party List Information
DWM collects information from individuals when an individual provides information to a Third Party and DWM subsequently purchases,
licenses, or otherwise acquires the information from the Third Party (the "Seller"). Such purchased information may include,
but is not limited to, an individual's name, email address, street address, postal/zip code, telephone numbers (including cell
phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, industry of employment,
personal and online interests, and such other information as the individual may have provided to the Seller (together, "Third Party
List Information"). When acquiring Third Party List Information, DWM seeks assurances from the Seller that the Seller has a right to
transfer the Third Party List Information to DWM and that the Seller has a right to provide offers from Advertisers to the individuals
whose personal information is included on the Seller's list.
1.4 Other Information
Other occasions when DWM obtains information from individuals include (1) when an individual is making a claim for a prize or
seeking to redeem an incentive offered by DWM or by a Third Party, (2) when an individual requests assistance through DWM's
customer service department, and (3) when an individual voluntarily subscribes to a DWM service or newsletter (together, "Other
Information").
1.5 Cookies, Web Beacons, and Other Info Collected Using Technology
DWM currently uses cookie and web beacon technology to associate certain Internet-related information about an individual with information about the individual in our database.
Additionally, DWM may use other new and evolving sources of information in the future (together, "Technology Information").
a) Cookies
A cookie is a small amount of data stored on the hard drive of the individual's computer that allows DWM to identify
the individual with his or her corresponding data that resides in DWM's database. You may read more about cookies
at cookiecentral.com. Individuals who use the Websites need
to accept cookies in order to use all of the features and functionality of the Websites.
b) Web Beacons
A web beacon is programming code that can be used to display an image on a web page (see http://truste.org for more information),
but can also be used to transfer an individual's unique user identification (often in the form of a cookie) to a database and
associate the individual with previously acquired information about an individual in a database. This allows DWM to track
certain websites an individual visits online. Web beacons are used to determine products or services an individual may be
interested in, and to track online behavioral habits for marketing purposes. In addition to using web beacons on web pages, DWM
also uses web beacons in email messages sent to individuals listed in DWM's database.
c) New Technology
The use of technology on the Internet, including cookies and web beacons, is rapidly evolving, as is DWM's use of new and
evolving technology. As a result, DWM strongly encourages individuals to revisit this policy for any updates regarding
its use of technology.
d) Usage Tracking
DWM tracks information related to the electronic mailings and web pages viewed by users and subscribers, as well as the
hyperlinks clicked by subscribers, while viewing our emails or visiting our websites.
e) Log Files
Log files are used to track and monitor subscriber usage
f) Optional Registration
DWM may offer free voluntary registration to potential subscribers. During such registration, the subscriber is required to supply an
email address and other personal information. This information is required if the subscriber wants to participate in Company
services.
g) Feedback and Inquiries
You have the ability to contact DWM to provide us with their feedback. DWM uses this information to respond to you and analyze customer service issues.
1.6 Outside Information
DWM may receive information about individuals from Third Parties or from other sources of information
outside of DWM including information located in public databases ("Outside Information").
1.7 Individual Information
As used herein, Individual Information means Survey Information, Third Party List Information, Other Information, Technology Information, and Outside Information, and any other information DWM gathers or receives about individuals.
1.8 No Information Collected from Children
DWM will never knowingly collect any personal information about children under the age of 18. If DWM obtains actual knowledge that it has collected personal information about a child under
the age of 18, that information will be immediately deleted from our database. Because it does not collect such
information, DWM has no such information to use or to disclose to Third Parties. DWM has designed this policy
in order to comply with the Children's Online Privacy Protection Act ("COPPA").
1.9 Credit Card Information
DWM may in certain cases collect credit card numbers and related information, such as the expiration date of the card
("Credit Card Information") when an individual places an order from DWM. When the Credit Card Information is submitted to
DWM, such information is encrypted and is protected with SSL encryption software. DWM will use the Credit Card Information for
purposes of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to Third
Parties only as necessary to complete the purchase transaction.
1.10 Links to External Websites
DWM's emails and websites may contain links to external websites. You will be taken to external websites if you click on these links.
Your information may be passed from DWM's database to the external website, and/or external database, for your convenience
(e.g. your information may be used to pre-fill a form at a destination website). DWM is not responsible for the privacy
practices or content of any external website owner. We encourage you to review the privacy policy of any website you visit.
2. USE OF INDIVIDUAL INFORMATION
2.1 Discretion to Use Information
DWM MAY USE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN COMPANY'S SOLE DISCRETION.
The following paragraphs in Section 2 describe how DWM currently uses Individual Information, but DWM may change or broaden its use
at any time. As noted above, DWM may update this policy from time to time. DWM may use Individual Information to provide promotional
offers to individuals by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and
package stuffers, among other possible uses.
2.2 Email and Unsubscribe Policy
DWM uses Individual Information to provide promotional offers by email to individuals. DWM may maintain separate email lists for different purposes.
If email recipients wish to end their email subscription from a particular list, they need to follow the instructions at
the end of each email message to unsubscribe from the particular list. To unsubscribe from all DWM's email lists,
a person must send an email to information@DirectWealthManagement.com.
DWM's unsubscribe process impacts only the future delivery of electronic mailings disseminated by DWM on its own behalf. You may still receive electronic mailings sent on behalf of Third Parties and
your personal information may still be shared with Third Parties for use in offline marketing and data appends, including
email appends.
You should also note that unsubscribing from DWM's electronic mailings will not automatically unsubscribe the subscriber's information from any Third Party associates and licensees of the data. Since Third Party associates and licensee partners maintain separate databases from DWM, and you will need to unsubscribe from each source
individually, if desired. This allows you the freedom to pick and choose which subscriptions to maintain and which to discontinue.
2.3 Content of Email Messages
In certain commercial email messages sent by or for DWM, an Advertiser's name will appear in the "From:" line, but hitting the "Reply" button will not cause a reply email to be sent to DWM.
The "Subject:" line of DWM email messages will usually contain a line provided from the Advertiser to DWM.
2.4 Solicited Email
DWM only sends email to individuals who have agreed on the Websites to receive email from DWM or to individuals who have agreed on
Third Party websites to receive email from Third Parties such as DWM. DWM does not send unsolicited email messages.
As a result, statutes requiring certain formatting for unsolicited email are not applicable to DWM S email messages.
2.5 Targeted Advertising
DWM uses Individual Information to target advertising to an individual. When an individual is using the Internet, DWM uses Technology Information (see also Section 2.7 below)
to associate an individual with that person's Individual Information, and DWM attempts to show advertising for products
and services in which the person has expressed an interest in the Surveys, indicated an interest by means of Technology
Information, and otherwise. DWM may, at its discretion, target advertising by using email, direct mail, telephones,
cell phones, and other means of communication to provide promotional offers.
2.6 Direct Mail and Telemarketing
DWM may use Individual Information to advertise, directly or indirectly, to individuals using direct
mail marketing or telemarketing using telephones and cell phones.
2.7 Use of Technology Information
DWM uses Technology Information (1) to match a person's Survey Information and Third Party List Information to other categories of Individual
Information to make and improve profiles of individuals, (2) to track a person's online browsing habits on the Internet,
(3) to determine which areas of DWM's websites are most frequently visited. This information helps DWM to better
understand the online habits of individuals so that DWM can target advertising and promotions to them.
2.8 Profiles of Individuals
DWM uses Individual Information to make a profile of an individual. A profile can be created by combining Survey Information and Third Party List
Information with other sources of Individual Information such as information obtained from public databases.
2.9 Storage of Individual Information
DWM stores the Individual Information in a database on its computers. Our computers have security measures
(such as a firewall) in place to protect against the loss, misuse, and alteration of the information under DWM's control.
Not withstanding such measures, DWM cannot guarantee that its security measures will prevent its computers from being
illegally accessed, and the Individual Information on them stolen or altered.
3. DISSEMINATION OF INDIVIDUAL INFORMATION
3.1 Sale or Transfer to Third Parties
DWM MAY SELL OR TRANSFER INDIVIDUAL INFORMATION TO THIRD PARTIES FOR ANY PURPOSE IN DWM'S SOLE DISCRETION.
3.2 Order Fulfillment
DWM will transfer Individual Information to Third Parties when necessary to provide a product or service
that a person orders from such Third Party while using DWM's websites or when responding to offers provided by DWM.
3.3 Legal Process
DWM may disclose Individual Information as permitted or required by applicable law or regulatory requirements,
and/or to respond to subpoenas, court orders, and other legal processes.
3.4 Summary Data
DWM may sell or transfer non-individualized information,
such as summary or aggregated anonymous information about all persons or sub-groups of persons.
3.5 Access
Individuals are entitled to access to their personal information which is in the possession of DWM. If an individual wants to see their personal information, they may contact the Privacy Officer. DWM will provide access to personal information (some exceptions might apply) and provide any assistance required in
understanding the nature of personal information that is in DWM's possession. There is no cost to gain access
to personal information.
DWM may ask that the individual put their request in writing. If DWM is unable to give access,
DWM will inform the individual within 30 days, in writing, with the reasons for not granting access.
3.6 Do Not Call Registry Waiver
Even though you may be on a National or State DO NOT CALL list, by submitting your contact information which may include your telephone number, you are expressly authorizing us and our advertising businesses
and affiliates to contact you by telephone at the number you have used regarding the information you have expressed.
4. PRIVACY PRACTICES OF THIRD PARTIES
4.1 Advertiser cookies and web beacons
Advertising agencies, advertising networks, and other companies (together, "Advertisers") who place advertisements on the Websites and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. DWM does not control Advertisers'
use of such technology and DWM has no responsibility for the use of such technology to gather information about individuals.
4.2 Links
The Websites and email messages sometimes contain hypertext links to the websites of Third Parties. DWM is not responsible for the privacy practices or the content of such other websites. Linked websites may contain links to websites maintained by Third Parties. Such links are provided for your convenience and reference only.
DWM does not operate or control in any respect any information, software, products or services available on such Third Party websites. The inclusion of a link to a web site does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.
4.3 Affiliated Companies
DWM may disclose, transfer, and sell Individual Information to entities affiliated with DWM in DWM's discretion.
5. UNSUBSCRIBE PROCEDURES
If you wish to discontinue receiving email messages from DWM, you have several options:
a) Unsubscribe from one email list
To unsubscribe from a particular list, either (1) send an email to information@DirectWealthManagement.com or (2)
follow the instructions in each promotional email message sent by DWM.
b) Unsubscribe from all of DWM's email lists
We reserve the right to add Individual Information to multiple lists maintained by DWM.
To globally unsubscribe from all of DWM's lists, send an email to information@DirectWealthManagement.com.
6. FURTHER INQUIRIES
Your privacy is important to us. If you have any questions about DWM's Privacy Policy or concerns about the way personal information is being used, please contact our Privacy Officer at:
Privacy Officer
Direct Wealth Management, LLC
305 Madison Avenue, Suite 449
New York, NY 10165
Phone: 1-877-806-5516
Email: support@emailcash2.com
Web: www.DirectWealthManagement.com