Sheena's Club-G-Spot
Privacy Policy
Last
modified: February 6, 2009
At Sheena's Club-G-Spot we recognize
that
privacy is important. This
Policy applies to all of the products, services and websites offered by
Sheena's Club-G-Spot or its subsidiaries or affiliated companies
(collectively,
Virago,
Inc.'s "services"). In addition, where more detailed information is
needed to explain our privacy practices, we post separate privacy
notices to
describe how particular services process personal information, which
are
accessible from the navigation bar to the left of this notice.
Sheena's
Club-G-Spot, subsidiaries, and affiliates adheres to the US
safe harbor privacy principles of Notice, Choice, Onward Transfer,
Security,
Data Integrity, Access and Enforcement, and is registered with the U.S. Department of
Commerce's safe
harbor program.
If
you have any questions about this
Policy, please feel
free to contact
us through our
website or write to us at Privacy Matters, c/o Sheena's Club-G-Spot,
subsidiaries, and affiliates PO
Box 784, Rainier, Oregon
97048.
Information
we collect and
how we use it
We
offer a number of services that do
not require you to
register for an account or provide any personal information to us, such
as Sheena's Club-G-Spot, subsidiaries, and affiliates Search. In order
to provide our full range of services, we may
collect the
following types of information:
Information you provide - When you
sign up for a Sheena's Club-G-Spot, subsidiaries, and affiliates
Account or other Sheena's Club-G-Spot, subsidiaries, and affiliates
service or promotion that requires
registration, we ask you for personal information (such as your name,
email
address and an account password). For certain services, such as our
advertising
programs, we also request credit card or other payment account
information
which we maintain in encrypted form on secure servers. We may combine
the information
you submit under your account with information from other Sheena's
Club-G-Spot, subsidiaries, and affiliates
services
or third parties in order to provide you with a better experience and
to
improve the quality of our services. For certain services, we may give
you the
opportunity to opt out of combining such information.
Sheena's
Club-G-Spot, subsidiaries, and affiliates cookies - When you
visit Sheena's Club-G-Spot, subsidiaries, and affiliates, we send
one or more cookies - a small file containing a string of characters -
to your
computer that uniquely identifies your browser. We use cookies to
improve the
quality of our service by storing user preferences and tracking user
trends,
such as how people search. Most browsers are initially set up to accept
cookies, but you can reset your browser to refuse all cookies or to
indicate
when a cookie is being sent. However, some Sheena's Club-G-Spot,
subsidiaries, and affiliates features and
services
may not function properly if your cookies are disabled.
Log
information - When you use Sheena's Club-G-Spot, subsidiaries, and
affiliates services, our
servers automatically record information that your browser sends
whenever you
visit a website. These server logs may include information such as your
web
request, Internet Protocol address, browser type, browser language, the
date
and time of your request and one or more cookies that may uniquely
identify your
browser.
User
communications - When you send
email or other
communication to Sheena's Club-G-Spot, subsidiaries, and affiliates, we
may retain those communications in
order to
process your inquiries, respond to your requests and improve our
services.
Affiliated
sites - We offer some of
our services in
connection with other web sites. Personal information that you provide
to those
sites may be sent to Sheena's Club-G-Spot, subsidiaries, and affiliates
in order to deliver the service. We
process
such information in accordance with this Policy. The affiliated sites
may have
different privacy practices and we encourage you to read their privacy
policies.
Links -
Sheena's Club-G-Spot, subsidiaries, and affiliates may present
links in a format that
enables us to keep track of whether these links have been followed. We
use this
information to improve the quality of our search technology, customized
content
and advertising. For more information about links and redirected URLs,
please
see our FAQs.
Other sites -
This Privacy Policy
applies to web sites and
services that are owned and operated by Sheena's Club-G-Spot,
subsidiaries, and affiliates. We do not
exercise
control over the sites displayed as search results or links from within
our
various services. These other sites may place their own cookies or
other files
on your computer, collect data or solicit personal information from
you.
Sheena's
Club-G-Spot, subsidiaries, and affiliates only processes
personal
information for the
purposes described in the applicable Privacy Policy and/or privacy
notice for
specific services. In addition to the above, such purposes include:
Providing our
products and services
to users, including the
display of customized content and advertising;
Auditing,
research and analysis in
order to maintain,
protect and improve our services;
Ensuring the technical functioning of
our network; and
Developing new services.
You can find
more information about
how we process personal
information by referring to the privacy notices for particular
services.
Sheena's
Club-G-Spot, subsidiaries, and affiliates processes personal
information on our servers
in the United States of
America
and in other countries. In some cases, we process personal information
on a
server outside your own country. We may process personal information to
provide
our own services. In some cases, we may process personal information on
behalf
of and according to the instructions of a third party, such as our
advertising
partners.
Choices
for personal
information
When you sign up for a particular
service that requires
registration, we ask you to provide personal information. If we use
this
information in a manner different than the purpose for which it was
collected,
then we will ask for your consent prior to such use.
If we propose to use personal
information for any purposes
other than those described in this Policy and/or in the specific
service
notices, we will offer you an effective way to opt out of the use of
personal
information for those other purposes. We will not collect or use
sensitive
information for purposes other than those described in this Policy
and/or in
the specific service notices, unless we have obtained your prior
consent.
You can
decline to submit personal
information to any of our
services, in which case Sheena's Club-G-Spot, subsidiaries, and
affiliates may not be able to provide those
services
to you.
Information
sharing
Sheena's
Club-G-Spot, subsidiaries, and affiliates only shares personal
information with other
companies or individuals outside of Sheena's Club-G-Spot, subsidiaries,
and affiliates in the following
limited
circumstances:
We have your
consent. We require
opt-in consent for the
sharing of any sensitive personal information.
We provide
such information to our
subsidiaries, affiliated
companies or other trusted businesses or persons for the purpose of
processing
personal information on our behalf.
We require
that these parties agree
to process such
information based on our instructions and in compliance with this
Policy and
any other appropriate confidentiality and security measures.
We have a good
faith belief that
access, use, preservation
or disclosure of such information is reasonably necessary to (a)
satisfy any
applicable law, regulation, legal process or enforceable governmental
request,
(b) enforce applicable Terms of Service, including investigation of
potential
violations thereof, (c) detect, prevent, or otherwise address fraud,
security
or technical issues, or (d) protect against imminent harm to the
rights,
property or safety of Sheena's Club-G-Spot, subsidiaries, and
affiliates, its users or the public as required
or
permitted by law.
If Sheena's
Club-G-Spot, subsidiaries, and affiliates becomes involved in a
merger, acquisition,
or any form of sale of some or all of its assets, we will provide
notice before
personal information is transferred and becomes subject to a different
privacy
policy.
We may share
with third parties
certain pieces of
aggregated, non-personal information, such as the number of users who
searched
for a particular term, for example, or how many users clicked on a
particular
advertisement. Such information does not identify you individually.
Please contact
us at the address
below for any additional
questions about the management or use of personal data.
Information
security
We take
appropriate security measures
to protect against
unauthorized access to or unauthorized alteration, disclosure or
destruction of
data. These include internal reviews of our data collection, storage
and
processing practices and security measures, as well as physical
security
measures to guard against unauthorized access to systems where we store
personal data.
We restrict
access to personal
information to Sheena's Club-G-Spot, subsidiaries, and affiliates
employees, contractors and agents who need to know that information in
order to
operate, develop or improve our services. These individuals are bound
by
confidentiality obligations and may be subject to discipline, including
termination and criminal prosecution, if they fail to meet these
obligations.
Data
integrity
Sheena's
Club-G-Spot, subsidiaries, and affiliates processes personal
information only for the
purposes for which it was collected and in accordance with this Policy
or any
applicable service-specific privacy notice. We review our data
collection,
storage and processing practices to ensure that we only collect, store
and
process the personal information needed to provide or improve our
services. We
take reasonable steps to ensure that the personal information we
process is
accurate, complete, and current, but we depend on our users to update
or
correct their personal information whenever necessary.
Accessing
and updating
personal information
When you use
Sheena's Club-G-Spot, subsidiaries, and affiliates services,
we make good faith
efforts to provide you with access to your personal information and
either to
correct this data if it is inaccurate or to delete such data at your
request if
it is not otherwise required to be retained by law or for legitimate
business
purposes. We ask individual users to identify themselves and the
information
requested to be accessed, corrected or removed before processing such
requests,
and we may decline to process requests that are unreasonably repetitive
or
systematic, require disproportionate technical effort, jeopardize the
privacy
of others, or would be extremely impractical (for instance, requests
concerning
information residing on backup tapes), or for which access is not
otherwise
required. In any case where we provide information access and
correction, we
perform this service free of charge, except if doing so would require a
disproportionate effort. Some of our services have different procedures
to
access, correct or delete users' personal information. We provide the
details
for these procedures in the specific privacy notices or FAQs for these
services.
Enforcement
Sheena's
Club-G-Spot, subsidiaries, and affiliates regularly reviews
its
compliance with this
Policy. Please feel free to direct any questions or concerns regarding
this
Policy or Sheena's Club-G-Spot, subsidiaries, and affiliates's
treatment of personal information by
contacting us
through this web site or by writing to us at Privacy Matters, c/o
Sheena's Club-G-Spot, subsidiaries, and affiliates PO
Box 784,
Rainier, Oregon
97048.
When we receive formal
written complaints at this address, it is Sheena's Club-G-Spot,
subsidiaries, and affiliates's policy to
contact the
complaining user regarding his or her concerns. We will cooperate with
the
appropriate regulatory authorities, including local data protection
authorities, to resolve any complaints regarding the transfer of
personal data
that cannot be resolved between Sheena's Club-G-Spot, subsidiaries, and
affiliates and an individual.
Changes
to this policy
Please note
that this Privacy Policy
may change from time to
time. We will not reduce your rights under this Policy without your
explicit
consent, and we expect most such changes will be minor. Regardless, we
will
post any Policy changes on this page and, if the changes are
significant, we
will provide a more prominent notice (including, for certain services,
email
notification of Policy changes). Each version of this Policy will be
identified
at the top of the page by its effective date, and we will also keep
prior
versions of this Privacy Policy in an archive for your review.
If you have
any additional questions
or concerns about this
Policy, please feel free to contact us any time through this web site
or at
Privacy Matters, c/o Virago Inc. PO
Box 784, Rainier,
Oregon 97048.
Copyright © 2009 Virago Inc.