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Privacy Policy for Members

Date Last Revised: January 1, 2012

Targeted Shopping Solutions, Inc. ("SMN", "we" or "us") values the privacy of our users and is committed to maintaining the confidentiality, integrity and security of all Member Data (as defined below) in its administration of the ShopMyNeighborhood^® website located at www.ShopMyNeighborhood.com (the "Site"). This privacy policy ("Privacy Policy") describes the data collection, use, and disclosure practices of SMN in connection with the Site. Any capitalized terms not defined in this Privacy Policy shall have the meaning assigned to them in the Terms of Use.

Information SMN Collects

We are committed to limiting the type and nature of Member Data collected online. When you access the Site, we collect information from your visit in order to personalize and improve upon your experience with us and to provide you the Service as defined in the Terms of Use.

Certain areas and features of the Site are available without registration or the need to provide any information to us. However, other features of the Site or the Service do require registration which involves providing SMN with your name, a valid email address, telephone or cell phone number, physical address, age range and a user-selected password (collectively, the "Member Data"). SMN collects two types of information on the Site (1) Member Data which is personally identifiable as it allows someone to identify or contact you, such as your name and e-mail address, as well as any information about you that is associated with or linked to any of the foregoing information and (2) Aggregate data which is data not associated with or linked to your Member Data ("Aggregate Data"). Aggregate Data cannot be used to identify you.

We don't knowingly collect, maintain, or use information from individuals under the legal age to form a binding contract with SMN. If we find out we have unknowingly collected such information we will take commercially reasonable measures to delete that information from our system as soon as possible. We are not responsible for the collection and use of information by companies or individuals unaffiliated with us whose Sites may contain links to ours, including vendors where you may shop.

Use of Member Data and Aggregate Data

We do not and will not sell or rent your Member Data to anyone, for any reason, at any time. SMN may disclose your Member Data to selected Merchants or Community groups and business partners (e.g. card processor vendors or banks issuing the Member Card) for purposes of rendering the Services and to assist Merchants in assessing the types of Transaction (defined below) for which you may be eligible.

SMN uses and discloses your Member Data only as follows:

• to analyze site usage and improve the Service;
• to determine your eligibility for discounts, coupons, frequency offers and other rewards ("Transactions");
• to process Transactions or for purposes of providing the Service to you;
• to deliver to you any administrative notices and communications relevant to your use of the Service;
• for market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity; to third-party contractors that provide services to SMN and are bound by these same privacy restrictions;
• to enforce SMN's Terms of Use; and
• as otherwise set forth in this Privacy Policy.

SMN may disclose Aggregate Data (only in a non-personally identifiable manner) for research or promotional purposes. Access to the Member Data you provide (which does identify you personally) is strictly restricted to SMN employees and contractors, on an as-needed basis and in accordance with specific internal procedures and safeguard governing access, in order to operate, develop or improve the Service. These individuals have been selected in accordance with our security policies and practices and are bound by confidentiality obligations. They may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

SMN may enter into agreements with one or more third-party contractors pursuant to which SMN provides access to certain of your Member Data in order to provide the Service to you and other Members or to run our business. For example, we may use a third-party vendor to handle settlement of Transactions for Members including Shoppers, Merchants and Community Groups. All such contractors will adhere to privacy and security standards equivalent to those practiced by SMN. All Member Data that is transferred outside of SMN's secure production environment will be encrypted prior to transfer using industry-standard encryption protocols and will be transferred only over secure data connections.

Please note that when you shop with a vendor who is linked to the Site, even though you may have started your visit with us, and even though our pages may still appear, your transactions are completed with a separate organization, not with us. We don't share your information with them, but information you choose to share with them will fall under their privacy policies, which we encourage you to review. We carefully select other organizations in an effort to bring you value, but we cannot guarantee your satisfaction with these organizations.

Changes to Member Data

If your Member Data changes while you are a Member, you may update it any time via the Site. If your Member Data is outdated, incomplete or incorrect you may not be able to take full advantage of the Service, including receiving discounts, coupons and other loyalty offers in respect of rewards you may have accrued. If you submit reviews or send messages to other users, you should be aware that any information you include can be read, collected or used by others and could be used to send you unsolicited messages in violation of our Terms of Use. We are not responsible for the Member Data you choose to submit using these features. If you receive any messages that you believe to be spam, abusive or otherwise in violation of SMN's Terms of Use please notify us immediately at Notices@ShopMyNeighborhood.com.

Cookies

The Site may use cookies in several applications for navigational purposes. A cookie is a small text file placed on your hard drive (not on the Site) by a Web page server. Cookies make your Internet experience quicker and more convenient. You are always free to decline our cookies if your browser permits, but some parts of the Site may not work properly if you do. Accepting a cookie from the Site does not give us access to any of your Member Data.

IP Address

An "IP Address" is actually a number that is automatically assigned to your computer when you use the Internet. In some cases, your IP address stays the same from session to session; but if you use a consumer Internet access provider (such as Earthlink or AT&T), your IP address may vary from session to session. We track IP addresses solely in conjunction with session Cookies to improve your experience on our Site.

Action Tags

We use and allow third-party service providers to use single pixel GIFs (also known as action tags or Web beacons) on the Site and also in HTML-based e-mails to let us know whether e-mails sent by us have been opened by recipients (including by anyone to whom an e-mail has been forwarded). This information helps us assess the effectiveness of the Site and of certain communications and marketing campaigns.

Other Systems

Information is also collected from you when:

• You register as a Member with SMN on the Site.
• You interact with the message boards and post comments on the blog including Content as defined in the Terms of Use.
• You click on advertisements on the Web and via e-mails you receive from SMN.
• You use your SMN Card at a Merchant.

Also, in most instances we include certain tracking links that allow us to monitor whether you accessed specific content or advertisements. If you click on one of these links, we will record that click and certain activities on the Site page associated with that tracking link. We may use this information for various purposes, such as to conduct internal research on our Users' demographics, interests, and clicking behavior and to customize the content and advertisements you see.

When you register with SMN, we may use Member Data to:

• Present you with advertising on the Site, based on your interests.
• Improve the content and layout of SMN.
• Statistically analyze user behavior.
• Receive feedback on editorial content.
• Develop products, marketing, and promotions internally at SMN.
• Contact you regarding your account status or changes to our Terms and Conditions, including our Privacy Policy.

In addition, when you become a SMN Member, we will use your Member Data to provide other services, including:

• Providing you with personalized information via e-mail and/or postal mail.
• Sending you targeted advertising via e-mail and/or postal mail.
• Contacting you for feedback and surveys via e-mail and/or postal mail.
• Sending you general and administrative information about your SMN membership via e-mail and/or postal mail.

Like most Sites, we accept advertising and sponsorships. SMN uses your Member Data in the course of providing the Service and maintaining the Site. SMN provides Member Data to certain third-party service providers whose role is solely to provide operational support for SMN, for example, to electronically send SMN E-mails and to provide security for the data that you share with us. SMN strives to ensure that any third-party service provider to which SMN discloses Member Data is contractually obligated to use the Member Data solely for the purposes for which it was disclosed, even though such third-party service providers are independent companies over which SMN exercises no control. SMN is not responsible for, and will not be liable for, their conduct, actions, omissions, information handling, or dissemination practices.

How We Display Ads on Our Site

We think advertising is more useful when it is tailored to your interests. We display ads on our Site that are based on the Member Data provided to us and Aggregate Data. Users who do not become Members receive advertisements solely on the basis of Aggregate Data. Advertising is served on SMN in the following ways:

• By SMN directly -- in some cases, using third-party ad-serving technology controlled by SMN; in other cases, by using an advertiser's third-party ad-serving technology. However, in both cases, no Member Data is shared with or accessible by the ad-serving platform.
• By ad-serving networks that track user activity across a variety of Web sites.

Your Choices Regarding Your Personal Data

As a convenience to our Members, we provide a number of ways to review and change information in your account and for Members to subscribe and unsubscribe from the Service. As an example, you can go to the SMN Site and log on to your account page to make any desired changes. Similarly, each e-mail message you receive from us contains one or more links to SMN that allow you to conveniently access this information or unsubscribe from our e-mails.

Blogs, Videos, and Other User-Generated Postings; Social Networking

If you choose to post material to any blogs or forums, participate in our social networking channels, or in any other community features that may be offered from time to time on the Site, you will be solely responsible for all content, messages, text, files, images, graphics, photos, audio clips, sounds, videos, or other materials that you submit to the Site and agree that it shall comply with the Terms of Use including the Content Standards.

Legal Disclosure

SMN may disclose information about you and your use of the Site if SMN believes such disclosure is reasonably necessary in order to:

(i) Comply with the law or legal process where a formal request has been made, such as from an administrative oversight agency, civil suit, subpoena, court order, or judicial or administrative proceeding; (ii) Protect or defend the rights or property of SMN or others; (iii) Enforce the SMN Terms and Conditions or this Privacy Policy; (iv) Respond to claims that the content(s) of a communication violates the rights of another.

Also, circumstances may arise where, for business reasons, SMN may decide to reorganize, or divest all or part of its business through sale, assignment, merger, or acquisition. In these circumstances, Member Data may be shared with the actual or prospective purchasers or assignees. In such an event, we shall provide notice of any material change to this Privacy Policy.

A Note to Users in California

California residents have the right to know how their information may be shared with third parties who engage in direct marketing activities; this Privacy Policy explains our practices and how you can opt out of having your information shared for such purposes.

Contact Us

If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with SMN, you can contact:

Targeted Shopping Solutions, Inc.
Post Office Box 631837, Highlands Ranch, CO 8016
Notices@ShopMyNeighborhood.com