ANSIRA PARTNERS, INC.

Privacy Policy

Last updated: July 1, 2018

This is the privacy policy ("Privacy Policy") that governs how Ansira Partners, Inc. ("Ansira", "we", "our" or "us"), uses Personal Data (defined below) that we collect, receive and store about you in connection with your use of our website (the "Site"). By choosing to participate in one or more marketing programs (each a "Program" and collectively, the "Programs") administered by Ansira, you will have access to this Site that is operated by Ansira. We operate this Site to facilitate business-to-business transactions between you and us as part of the Program." Certain content/functionality on this Site may require that you provide "Personal Data" which includes any information that may be used, either alone or in combination with other information, to personally identify an individual. We have adopted this Privacy Policy to explain what information may be collected on this Site, how we may use this information and under what circumstances we may disclose the information to third parties.

You may choose whether or not to provide or disclose Personal Data in connection with your use of our Site. If you choose not to provide the Personal Data we request, you may still visit and use parts of our Site, but may be unable to access or use certain features, options, programs, and services." Our Site may contain links to third-party websites and services that are not owned or controlled by Ansira. We are not responsible for the privacy practices or the content of third party websites, services and advertisements, and you visit them at your own risk.

1. Introduction. 

We are committed to respecting privacy and recognize the need for appropriate protection and management of any Personal Data that is shared with us as part of using our Site.

2. Changes to this Privacy Policy.

We reserve the right, at our discretion, to change the terms of this Privacy Policy at any time. You can see when this Privacy Policy was last updated by reviewing the "Last Updated" legend on the top of this page. We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING TO THE SITE."

3. Personal Data Collected. 

3.1. Personal Data You Provide To Us On Our Site.

a) Types of Personal Data. We and our service providers collect the Personal Data set forth below in order to provide the Site to you, and to enable your participation in one or more Programs, "or because we are legally required to do so." If you do not provide the Personal Data we request, we may not be able to provide you with the Site, and you must find an alternative method to complete your request to participate in the Program. The Personal Data we and our service providers may collect includes but is not limited to:

-         Your name;

-         Email address;

-         Address;

-         Credit card information;

-         Company name;

-         Job title;

-         Phone;

-         Communications you send to us.

b) When Personal Data is Collected. You may be required to provide us with certain information that may constitute Personal Data in the following ways:

-         Program Participation

As part of the Program, we may share Personal Data with the entity for which we serve as the Program administrator (i.e., the Program"s namesake). We may, however, disclose some information if we believe in good faith that it is necessary to prevent a crime or an injury to, or interference with, Ansira"s rights or property, or the rights or property of a third party. We may also disclose information if we believe in good faith that the law requires it, to take precautions against legal liability and/or to comply with a judicial proceeding, court order or legal process.

-         Payment Information

 

To facilitate a transaction on the Site, it may be necessary for you to provide credit card information." This information is not collected by Ansira, but instead collected by and processed through a third party Authorize.net. To see what information may be collected, how that information is used, and how this information is disclosed, please go to http://www.authorize.net/company/privacy/.

 

3.2. Information Collected Automatically. Certain information on our Site is collected automatically by means of various software tools. We have a legitimate interest in using such information to assist in log-in, systems administration purposes, information security and abuse prevention, to track user trends, and to analyze the effectiveness of our Site and our Programs. Alone or in combination with other information, such automatically collected information may constitute Personal Data. Some of our service providers may use cookies or other methods to gather information regarding your use of our Site. Such third parties may use these cookies or other tracking methods for their own purposes by relating information about your use of our Site with any Personal Data about you that they may have. The use of such information by a third party depends on the privacy policy of that third party."

a) Log Files On Our Site. The information inside the log files includes internet protocol ("IP") addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us.

b) CookiesWe use cookies to make interactions with our Site easy and meaningful. When you visit our Site, our servers may send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your web browser. Unless you choose to identify yourself to us, either by responding to a promotional offer, opening an account, or filling out a web form, you remain anonymous to us.

We may use cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your web browser"s ability to accept cookies, you will not be able to navigate our Site.

The following sets out how we may use different categories of cookies and your options for managing cookies" settings:

Type of Cookies

Description

Managing Settings

Required cookies

Required cookies enable you to navigate our Site and use its features, such as accessing secure areas of our Site and using our services.

If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. Each time you log into our Site, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow us to uniquely identify you when you are logged into our Site and to process your online transactions and requests.

Because required cookies are essential to operate our Site, there is no option to opt out of these cookies.

Performance cookies

These cookies collect information about how you use our Site, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information these cookies collect is aggregated and anonymous. It is only used to improve how our Site functions and performs.

From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit our Site. We may also utilize Flash cookies for these purposes.

To learn how to opt out of performance cookies using your browser settings click here.

To learn how to manage privacy and storage settings for Flash cookies visit (http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html)

Functionality cookies

Functionality cookies allow our Site to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of our Site after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.

We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on our Site to personalize your visit.

To learn how to opt out of functionality cookies using your browser settings click here.

To learn how to manage privacy and storage settings for Flash cookies visit (http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html).

c) Other Tracking Technologies. When you visit our Site, we may collect your IP address for purposes of monitoring the regions from which you navigate our Site.

We may also use web beacons alone or in conjunction with cookies to compile information about your usage of our Site and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our Site. We may use web beacons to operate and improve our Site and email communications.

4. The Purposes For Which We Use Personal Data. 

The Personal Data you submit to us is used to carry out your requests as a participant in the Program.

As part of the Program, we may share this information with the entity for which we serve as the Program administrator (i.e., the Program"s namesake). We may, however, disclose some information if we believe in good faith that it is necessary to prevent a crime or an injury to, or interference with, Ansira"s rights or property, or the rights or property of a third party. We may also disclose information if we believe in good faith that the law requires it, to take precautions against legal liability and/or to comply with a judicial proceeding, court order or legal process.

5. How We Disclose Personal Data. 

We do not sell, lease, rent or otherwise disclose the Personal Data collected from our Site to third parties unless otherwise stated below or with your consent.

5.1. In the Event of Merger, Sale, or Change of Control. We may transfer or assign this Privacy Policy and any Personal Data to a third party entity that acquires or is merged with us as part of a merger, acquisition, sale, or other change of control.

5.2. Other Disclosures. We may disclose Personal Data about you 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 or security issues; or (iv) protect against harm to the rights, property or safety of Ansira, our users, or the public.

6. Retention of Personal Data.

We reserve the right to retain any Personal Data as long as the Personal Data are needed to: (i) fulfill the purposes that are described in Section 4 (The Purposes For Which We Use Personal Data), and (ii) comply with applicable law.

7. Your Rights.

7.1 Personal Data. If you have an account on our Site, we provide access to " and the ability to edit or delete " certain categories of Personal Data through the account.

If you would like to access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Data collected via our Site, you may submit a request to privacy@ansira.com or write to us at:

Ansira

2300 Locust Street

St. Louis, MO 63103

Attn: Privacy

We will promptly review all such requests in accordance with applicable laws."

Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Data about you." We encourage you to first reach out to us at privacy@ansira.com so we have an opportunity to address your concerns directly before you do so.

8." Personal Data Transferred from the EU or Switzerland To The United States.

Ansira complies with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework" (collectively, "Privacy Shield") as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data from European Union (the "EU") member countries and Switzerland. Ansira has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. A violation of our commitment to Privacy Shield may be investigated by the Federal Trade Commission and/or the United States Department of Commerce. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, to the extent available, please visit https://www.privacyshield.gov.

In compliance with the Privacy Shield Principles, Ansira commits to resolve complaints about your privacy and our collection or use of Personal Data about you. Persons from the EU or Switzerland who have inquiries or complaints regarding this Privacy Policy should first contact us via email at: privacy@ansira.com.

Ansira has committed to refer unresolved privacy complaints under the Privacy Shield Principles to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint.

These recourse mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the Privacy Shield, Ansira is potentially liable.

9. Data Security. 

The security of Personal Data is important to us. We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Data, we cannot guarantee its absolute security.

10. Children's Privacy. 

Our Site is not intended for children under the age of 18. Accordingly, we do not intend to collect Personal Data from anyone we know to be under 18 years of age.

11. How We Respond to Do Not Track Signals. 

Ansira does not track Site users over time and across third party websites to provide targeted advertising. Accordingly, we do not currently respond or take any action with respect to web browser "do not track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Data about an individual consumer's online activities over time and across third-party web sites or online services.

12. Your California Privacy Rights.

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of Personal Data about you by Ansira to third parties for the third parties" direct marketing purposes. To make such a request, please send an email to privacy@ansira.com or write to us:

Ansira

2300 Locust Street

St. Louis, MO 63103

Attn: Privacy

 

13. Contacting Us and our Privacy Officer. 

Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to the Ansira Privacy Officer at privacy@ansira.com.