REVISED – February 10, 2011
1. Introduction. The Toilet Paper Entrepreneur (hereinafter “TPE”) publishes its information services in print and various electronic media, including Web-based formats. We are continually adapting to changes in technology to bring you the information you rely on faster and more efficiently than ever before.
* What information we collect
* How we collect the information
* How we use the information
* How we provide choice to Users about how we use the information we collect
* Whether we disclose the information we collect to third parties
* Whether third parties collect information through our Products
2. TPE’s Privacy Pledge. TPE makes the following pledge to you:
* TPE is committed to protecting the privacy of Users at all times.
* TPE maintains security standards and procedures designed to protect Customer Information and other Personally Identifiable Information. We will continue to test and update our technology to improve our ability to protect Customer Information and other Personally Identifiable Information.
4. Our Policies Regarding the Collection of Information. At TPE, our goal is to provide Users with quality information, products, and services. We are also committed to providing Users with responsive, personalized service, and keeping Users informed about new information, products, and services that may be of immediate interest to Users or that can help Users derive the greatest value from the Products.
A visitor who browses the TPE Web site is not required to reveal any Personally Identifiable Information, such as name, address, or telephone number, unless subscribing to a product. Nor is such information collected passively by electronic means. TPE Web servers collect other information such as the make of a visitor’s browser software and the Internet domain name of the location from which the visitor enters. This information helps us diagnose technical problems and manage our sites by tracking user interests.
The primary reason that we collect and maintain Customer Information and other Personally Identifiable Information is to serve Users and administer our customer relationships. TPE may collect Customer Information and other Personally Identifiable Information from a variety of sources, such as the following:
* Information Users provide to us, such as information Users provide to us in the registration process.
* Information we receive from a Customer that purchases Subscriptions for Users, such as registration information.
* Information about transactions by Users as part of the Products or other User experiences with TPE, such as the information we receive when a User submits a question through a search box in a Product. We collect Customer Information and other Personally Identifiable Information in a number of ways, such as the following:
* Registration Process:
- In order to use our Products, each User may be asked to complete a registration process, which requires providing certain registration information to TPE.
* Credit Cards:
- We collect credit card information for billing purposes. For convenience of our customers, we do not store, use, or share credit card information for any other purpose
* Log Files:
- We track information about each User’s usage of the Products in log files. We use this information as follows:
+ To analyze trends
+ To administer the Products
+ To track statistical information about how Users use the Products
+ To gather broad demographic information for aggregate use
- TPE does link information regarding a User’s usage of the Products to the User’s Personally Identifiable Information
+ Contrary to reports about cookies and online privacy, cookies do not contain viruses and most cannot reveal any Personally Identifiable Information about you unless you willingly provide it as a user on a Web site.
+ You will find that cookies are an industry standard and are used at most major Web sites in much the same way we use them here at TPE. You can learn most everything there is to know about cookies at www.cookiecentral.com. We also encourage you to read the privacy policies of all Web sites you visit before you accept cookies from these Web sites.
+ You can set your browser to reject or to accept cookies. You have the option to reject cookies when you are just browsing the Web and accept cookies when you want to use the Products.
+ Each Product places a cookie on the hard drive of each User’s computer. If a User rejects any cookie offered by a Product, that User may not use the features of the Product.
+ TPE stores your User ID in your cookie.
+ TPE uses your cookie to make your experience with the Products more efficient and effective. For instance, by setting a cookie for a Product on a User’s hard drive, the User does not have to log in to the Product more than once, which saves time.
+ Setting cookies also enables TPE to track and target the interests of Users.
- Surveys and Promotional Activities:
+ From time to time TPE may request information from Users via voluntary participation in promotional or market research activities.
+ The information that we request may include contact information (such as name and business address), and demographic information (such as zip code and age level).
5. Our Policies Regarding the Use and Disclosure of Information.
a) Information Use and Sharing. We may use and share the Customer Information and other Personally Identifiable Information that we collect among various departments within TPE and its subsidiaries that perform functions such as servicing User accounts, preparing reports regarding Product use, market research, and promotional activities. The reasons that we share this Customer Information and other Personally Identifiable Information include the following:
* To protect Users.
- We use the Customer Information and other Personally Identifiable Information we maintain about Users and their use of the Products, including registration information, as follows:
+ To help us identify Users.
+ To help us prevent unauthorized persons from accessing Customer Information and other Personally Identifiable Information and the Product features that we make available to specific Users for their use.
* To provide superior service.
- We use Customer Information and other Personally Identifiable Information to respond quickly and efficiently to User needs.
* To tell you about new or enhanced services and/or products.
* By understanding more about Users and their use of the Products, we can better meet User needs and determine how other Product features could be of value to Users.
* E-mail Updates:
- Once a User completes the registration process, TPE may keep the User updated by e-mail on important news and events concerning TPE, Product features, and other information that TPE deems relevant.
* To improve and develop our information, products and services.
* Every Product feature that we offer is designed to reflect the ways Users actually use the Products.
- We collect and analyze information about Product use so that we can tailor new types of information, products and services to meet User needs.
- When it comes to sharing Customer Information and other Personally Identifiable Information outside TPE, we do so only for specific purposes. We share Customer Information and other Personally Identifiable Information with third parties as follows:
- We reserve the right to share with TPE subsidiaries and/or other reputable organizations the following information, for purposes of permitting those organizations to sell their products and services to our Customers:
- With respect to each Customer, the following current information: company name, industry, business mailing address, and primary contact information (name, e-mail address, street address, mailing address, and telephone number).
- With respect to each User, the following current information: name, industry, job title, business e-mail address, office name (branch and main office), and mailing address.
- We reserve the right to share Customer Information and other Personally Identifiable Information with third parties that provide hot links to the TPE Web page at http://www.ToiletPaperEntrepreneur.com to promote the Products, such as web portals, or otherwise sell Subscriptions on our behalf through their own marketing channels. In certain instances, these parties will co-own certain Customer Information and other Personally Identifiable Information about Product revenue generating activity that originates from that third party. Such Customer Information and other Personally Identifiable Information may include, without limitation, the following information: company name, street address, e-mail address, contact name, lead date, first sale date, and services accessed.
- We reserve the right to share Customer Information and other Personally Identifiable Information with other third parties that perform services on our behalf, such as companies that help us market Products, renew subscriptions, or assist new customers.
- We reserve the right to share all Customer Information and Personally Identifiable Information with third parties who act as independent contractors to help us administer the Products, such as data centers that host our servers and technical system consultants who program our hardware and Software.
- We reserve the right to share Customer Information and Non-Identifying Information in the form of aggregated demographic information that is not linked to Personally Identifiable Information with our subsidiaries, advertisers, and other third parties.
- We reserve the right to disclose certain Customer Information and Personally Identifiable Information to government agencies and consumer reporting agencies as permitted or required by applicable law. TPE may make these disclosures for specific, limited purposes, such as verifying individuals’ identities (reducing fraud and identity theft).
- TPE will also disclose a User’s Customer Information and Personally Identifiable Information when and to the extent we believe, in good faith, that we are legally compelled to do so pursuant to an order of a court of competent jurisdiction or other governmental body (including, without limitation, such disclosures required by applicable securities laws as are necessary to comply therewith or with the rules and regulations of any applicable stock exchange). In such an event, TPE will use reasonable efforts to do the following:
- Give the User reasonably prompt written notice of such requirement so that the User has an opportunity to comment thereon or object thereto and to preserve the confidential nature of the Customer Information and Personally Identifiable Information that TPE is required to disclose.
- At the User’s expense, use commercially reasonable efforts to cooperate with any of the User’s efforts to preserve the confidential nature of the Customer Information and Personally Identifiable Information that TPE is required to disclose.
* User Information
- We reserve the right to share a User’s Customer Information and Personally Identifiable Information with the Customer who purchased the User’s Subscription.
* Customer Information
6. Information Confidentiality and Security. TPE is committed to prevent any unauthorized access to each User’s Customer Information and other Personally Identifiable Information. We maintain procedures and technology designed to prevent such unauthorized access.
a) Security Programs. No one can guarantee that data transmission over the Internet will be 100% secure. Nevertheless, TPE has taken technical, administrative, and physical steps to protect against unauthorized access to Customer Information and other Personally Identifiable Information used to administer its customer accounts. All such information is handled securely within TPE and is not disclosed to unauthorized third parties.
b) User IDs and Passwords. Each User is responsible for maintaining the confidentiality of his or her User ID and password, and are responsible for all Product activities that occur under his or her User ID and password, including, without limitation, all related Customer Information and other Personally Identifiable Information. Each User agrees to immediately notify TPE of any unauthorized use of his or her User ID or password or of his or her Customer Information and other Personally Identifiable Information or any other breach of security regarding the Products or his or her Customer Information and other Personally Identifiable Information. TPE will not be liable for any Loss whatsoever arising from a User’s failure to comply with these security requirements and each User agrees to hold TPE harmless from any and all Losses that arise from that failure to so comply.
7. Tips To Help You Protect Customer Information. If any User suspects that someone has had unauthorized access to his or her TPE account, or access to his or her Customer Information and other Personally Identifiable Information, such as his or her User ID or password, the User should send an email to customercare@TPE.com immediately so we can take appropriate action to protect the User and his or her Customer Information and other Personally Identifiable Information.
In addition, Users may want to consider if it is important to report the crime to local law enforcement agencies and to the Federal Trade Commission (FTC). To speak with a trained FTC telephone counselor, call toll-free 1-877-IDTheft (1-877-438-4338). Or, to enter information about any complaint into a secure FTC online database, sign onto www.consumer.gov/idtheft. The site also provides links to numerous consumer education materials.
If you have any questions or concerns regarding TPE data protection practices, please send an e-mail message to TPE’s Web site administrator at info@ToiletPaperEntrepreneur.com.
- ‘Customer Information’ means any information about a Customer, its employees, contractors, suppliers, licensors, agents, distributors, and others who have any business or personal relationship with such Customer, that (i) TPE has an obligation to keep confidential or use for limited purposes or (ii) TPE has any legal obligation to keep confidential or use for limited purposes, including under the Gramm-Leach-Bliley Act, the Health Insurance Portability and Accountability Act, any laws regarding invasion of privacy, or other privacy laws. ‘Customer Information’ does not include publicly available information.
- ‘Non-Identifying Information’ means information that, taken alone, cannot be used to identify or locate a Person, including, without limitation, age or date of birth, gender, occupation, education, ZIP code with no address, interests, hobbies, types of hardware or Software used by a Person, income. ‘Non-Identifying Information’ refers to this type of information, regardless of whether such information is collected along with, or is linked to, Personally Identifiable Information.
- ‘Personally Identifiable Information’ means information that can be used to identify or locate a Person, including, but not limited to, e-mail address, name, street address, phone number, fax number, credit card number, Social Security number, and tax identification number.
– The terms ‘we,’ ‘us,’ and other similar terms shall be deemed to refer to TPE, as appropriate.
– The terms ‘you,’ ‘your,’ and other similar terms shall be deemed to refer to Customer and all individual Users, as appropriate.