Privacy Policy

ConnectsMail2.0 Privacy and Security Policy

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ConnectsMail2.0 (CM2.0) is a cloud-based direct mail marketing technology platform intended to automate, report on, and enhance the effectiveness of direct mail marketing campaigns(“Services”). The primary use of information via CM2.0 is to identify for Customers when direct mail campaigns have been received, opened, and when direct mail campaigns actually generated a response from recipients. This enables Customers to have access to useful information about the effectiveness of their direct mail campaign efforts.

 

Third-Party Platforms. The delivery of CM2.0 Services is fulfilled through various digital technologies that are owned and operated by third parties (“Third Party Platforms”) and made accessible in one platform through CM2.0 for the benefit of CM2.0 partners and their clients (“Customers”). Users of CM2.0 should note that each Third Party Platform has its own end user license agreement (“EULA”), privacy/security policies, and terms of use (collectively “Third Party Requirements”) that apply to the Customer’s use of these Third Party Platforms through CM2.0. A complete list of current Third Party Platforms can be obtained by contacting CM2.0 at wbrennan@connects360.net.

 

CM2.0 has no control over Customer information maintained in Third Party Platforms. As a result, Customers should be aware of how information is collected and maintained in Third Party Platforms and the steps Customers can take to further protect their information when using CM2.0. Customers must also ensure that website privacy policies adequately describe the use of Third Party Platforms as required by applicable law.

 

CM2.0 Not Intended for Protected Information. Customers of CM2.0 should understand that CM2.0 is not intended to be used to create, receive, maintain or transmit protected health information (“PHI”) governed by HIPAA, or other highly sensitive information about individuals that are afforded special protections under State and/or Federal Laws (collectively “Protected Information"). While CM2.0 and Third Party Platforms have practices and systems in place intended to protect the privacy and security of information, Customers agrees not to store Protected Information in DM2.0 or Third Party Platforms. www.connectsmail20.com

 

Customers that anticipate Protected Information being disclosed over the phone should not utilize the CM2.0 Call Tracking Service. Customer also agrees to ensure that each of its users is aware of the requirements of this Privacy & Security Policy. While this Privacy & Security Policy is intended to summarize the privacy and security practices related to the Services offered through CM2.0, Customers are responsible for reviewing and complying with the applicable Third Party Requirements as well.

 

Customer Tools for Managing Privacy & Security. In CM2.0, Customers have the ability to select and/or deactivate certain functions to further ensure the privacy and security of Customer information. Customers seeking to afford extra levels of privacy and security to their information should contact wbrennan@connects360.net for more information about these features. For example, in the CM2.0 portal, CM2.0 offers a “privacy restricted campaign” feature that users can select to add an additional layer of privacy/security for a specific mail campaign. Customers should configure their accounts based on the state laws applicable to their campaign. Customers should also ensure that users are managed by Customer to ensure that only authorized users have access to Customer information.

 

General Data Collection, Storage & Use. CM2.0 Services are offered to provide Customers with tracking and reporting metrics on the status of direct mail campaigns. Unlike mail houses or similar services, CM2.0 has very little interaction with actual communications between Customers and their mailing recipients. Rather, CM2.0 is intended for and configured to only collect and store postal mailing information and in limited situations, email addresses when provided by Customers. Customers should understand that if Customer or its end users choose to maintain or transmit Protected Information in CM2.0 platforms, CM2.0 cannot guarantee the privacy of such information and the information may be accessible by Third Party Platforms, whose policies shall apply.

 

How CM2.0 Uses Mailing Addresses. Postal mailing addresses are used by CM2.0 on behalf of Customers to initiate digital campaigns and mailings as needed to fulfill the advertising services CM2.0 has been engaged to perform.

 

Third-Party Platform Disclaimer. CM2.0 specifically disclaims any and all warranties related to Third Party Platforms and makes no representations about the privacy or security of such Third Party Platforms. However, Third Party Requirements describe a range of privacy and security controls in place that are intended to protect Customer information. https://www.connectsmail20.com

 

Customer Provided Data. All data involving mailing campaign(s), including but not limited to mailing lists, designs, and customer information provided to CM2.0 as needed to receive services from CM2.0 (“Customer Data”), may be used by CM2.0 as needed to fulfill the services DM2.0 has been engaged to provide. CM2.0 does not use Customer Data to solicit new customers without prior written approval. However, CM2.0 may use de-identified aggregated data that does not specifically identify individuals or the Customer (“Aggregated Anonymous Data”). By using CM2.0, the Customer acknowledges and agrees that CM2.0 may obtain and use Aggregated Anonymous Data it captures or comes in contact with through use of its Services. CM2.0 may use the Aggregated Anonymous Data to analyze, improve, support, and operate the Services, CM2.0 may also use Aggregated Anonymous Data for any business purpose, during and after the term of any Customer agreement, including without limitation, to generate industry benchmarks or best practices guidance, recommendation or similar reports for distribution to and consumption by Customer and other CM2.0 customers and prospects. In all cases, the Customer will not be identified unless prior approval has been obtained.

 

Feedback & Campaign Results Utilization. If the Customer provides suggestions, comments, and feedback regarding the Services, including but not limited to usability, bug reports and usage results, (collectively, “Customer Feedback”), CM2.0 may make, use, copy, modify, sell, distribute, sub-license, and create derivative works of the Customer Feedback as part of any of CM2.0’s products, technology, services, specifications or other documentation. In addition, CM2.0 may, in its sole discretion, use Customer’s campaign results and analytics, to include the number of calls received and website visitors, for both internal product development purposes, as well as marketing materials to be published to third parties. If CM2.0 uses Customer Data or Customer Feedback for such purposes, DCM2.0 will not identify the Customer as the source of the information.

 

USPS/Informed Delivery. Processed mailing lists are shared with USPS Informed Visibility and Informed Delivery. CM2.0 only discloses IMDB digits with the USPS for these services. No personal information is disclosed. The USPS Privacy Policy can be viewed here: https://faq.usps.com/s/article/Informed-DeliveryPrivacy-Security-Concerns.

 

Call Tracking. CM2.0 partners with Twilio and WhitePages for call tracking. The information returned by Twilio and WhitePages is password protected and stored on the CM2.0 AWS servers. The Call Tracking services include a feature to inform callers that the call may be recorded. Customers should confirm this feature is activated and in compliance with the state laws that apply to Customer. Recorded phone calls are ONLY accessible to the client the calls were made to. CM2.0 does not have access to recorded phone calls. The Call Tracking feature is not currently offered to Customers governed by https://www.connectsmail20.com the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and/or other similar privacy laws, and Customers should not utilize the Call Tracking service for Protected Information. Compliance with all laws applicable to the recording of calls remains Customer’s sole responsibility, including obtaining all necessary consents. Customer assumes full responsibility for compliance with all applicable laws related to the recording of calls, and fully releases and holds harmless CM2.0, its affiliates, officers, and agents for all damages, costs, third party claims related to Customer’s use of the call recording service offered by CM2.0. The CM2.0 call recording service is offered through Twilio, Inc. Customers should review Twilio’s security and privacy policy here: https://www.twilio.com/legal/privacy WhitePages: https://ekata.com/security-and-privacy/. Customer must comply with Twilio and WhitePages’ Third Party Platform Requirements, and ensure that Customer, and any clients of Customer, have included required information in any applicable privacy policies related to the use of these services.

 

Advertising & Ads. CM2.0 deploys all ad campaigns via the following Third Party Platforms: Google Network, Facebook and LinkedIn. Customer must ensure compliance with each of these Third Party Platform’s advertising policies. CM2.0 has no special rights or access to any data going to or from each of these Third Party Platforms. CM2.0 has no control over the ads these Third Party Platforms will or will not accept. CM2.0 does not give share or receive any personal information on ad targets belonging to clients of Customers in relation to advertising and ads through the Third Party Platforms described in this paragraph. Each Third Party Platform’s Privacy Policy and advertising policies can be reviewed by clicking the respective link below. The customer is responsible for ensuring that the requirements of applicable law and complied with when using these Services, including the requirement to inform individuals about how information is used in any applicable privacy policies.

Google: https://policies.google.com/privacy?hl=en-US

Facebook: https://www.facebook.com/policy.php

LinkedIn: https://www.linkedin.com/legal/privacy-policy

 

LEADMatch Services. With permission and placement of the pixel by the client, the LEADMatch pixel placed returns to the DM2.0 LEADMatch vendor a Device ID (if available), IP address, cookie-based information, time of firing and page of firing. The LEADMatch Service collects postal addresses and matches them to website visitors. No names, phone numbers, email addresses, financial or medical information is retrieved or shared via the LEADMatch Service. other than a residential postal address of the website visitor. However, privacy laws are constantly evolving, so it is important for Customers to ensure they take appropriate steps when using LEADMatch Services. When utilizing LEADMatch, Customer represents that: (a) no terms of use, privacy policy, or https://www.connectsmail20.com representations made to Customer website visitors will be violated by such pixel use; (b) Customer will require each website (including websites of Customer’s clients) utilizing LEADMatch to display privacy policies that disclose applicable data collection practices, including the types of data collected and purposes for which data is collected by or transferred to third parties, plus working mechanisms that conspicuously enable consumer opt-outs and do-not sell requests in accordance with applicable laws; and (c) the use of pixels will not be used in conjunction with any website or application directed to children under the age of 16, or in any manner implicating the Children’s Online Privacy Protection Act. CM2.0 and Third Party Platforms reserve the right to exclude any use of pixels that does not comply with these terms. The current Third Party Platform used by LEADMatch is Claritas. InsiderData 360 may also be used. Customer must read and comply with the Third Party Requirements for these vendors. See: https://claritas.com/privacy-legal/; https://insiderdata360online.com/

 

Data Deletion, Opt-Out Requests, and Do-Not-Sell Requests. Requests for deletion, opt-outs, and do not-sell requests should be submitted to privacy@DM2.0.com.

 

Data Breaches. CM2.0 will notify Customers and partners of data breaches in accordance with applicable law.

 

Limitation of Liability. CM2.0 is not intended for Protected Information. The maximum aggregate liability of DM2.0 for any and all claims related to the use of CM2.0 and Third Party Platforms, including without limitation, data breaches and/or claims related to state and/or federal privacy laws, whether by Customer or a third party, shall be limited to the total payment the applicable Customer made to CM2.0 in the preceding three (3) months from the date of the event giving rise to the claim. No claim, regardless of form, may be brought more than the shorter of one year or the period allowed by law after the cause of action has occurred.

 

Introduction

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At Connects 360 LLC (the "Company" or "We"), we respect your privacy and are committed to protecting it through our compliance with this policy.

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This policy describes the types of information we may collect from you or that you may provide when you visit this website (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

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This policy applies to the information we collect:

• On this Website.

• In e-mail, text, and other electronic messages between you and this Website.

• Through mobile and desktop applications you download from this Website, which provides dedicated non-browser-based interaction between you and this Website.

• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

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It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or

• any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

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Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

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Children Under the Age of 13

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Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us via our contact us link.

Information We Collect About You and How We Collect It

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We collect several types of information from and about users of our Website, including information:

• by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or ANY OTHER INFORMATION THE WEBSITE COLLECTS THAT IS DEFINED AS PERSONAL OR PERSONALLY IDENTIFIABLE INFORMATION UNDER AN APPLICABLE LAW ("personal information");

• that is about you but individually does not identify you, and/or

• about your internet connection, the equipment you use to access our Website, and usage details.

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We collect this information:

• Directly from you when you provide it to us.

• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

• From third parties, for example, our business partners.

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Information You Provide to Us.

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The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website.

• Records and copies of your correspondence (including e-mail addresses), if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes.

• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

• Your search queries on the Website.

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You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies.

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As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, and other communication data and the resources that you access and use on the Website.

• Information about your computer and internet connection, including your IP address, operating system, and browser type.

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We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our Website according to your individual interests.

• Speed up your searches.

• Recognize you when you return to our Website.

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The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

• Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

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We do not collect personal Information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

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Third-party Use of Cookies and Other Tracking Technologies.

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Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

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We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

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How We Use Your Information

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We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.

• To provide you with information, products or services that you request from us.

• To provide you with information about our services

• To provide you with notices about your account/subscription, including expiration and renewal notices.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• To notify you about changes to our Website or any products or services we offer or provide through it.

• To allow you to participate in interactive features on our Website.

• In any other way, we may describe when you provide the information.

• To fulfill any purpose for which you provide it.

• For any other purpose with your consent.

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We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

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Disclosure of Your Information

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We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

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We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.

• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.

• To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• To fulfill the purpose for which you provide it. For example, if you give us an e-mail address to use the "e-mail a friend" feature of our Website, we will transmit the contents of that e-mail and your e-mail address to the recipients.

• For any other purpose disclosed by us when you provide the information.

• With your consent.

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We may also disclose your personal information:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request.

• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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Choices About How We Use and Disclose Your Information

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We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

• We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt-out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

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Accessing and Correcting Your Information

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You may send us an e-mail via our contact link to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

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If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use.

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Your California Privacy Rights

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California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us via the Contact Us link.

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Data Security

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We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure

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The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

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Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

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Changes to Our Privacy Policy

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It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

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Contact Information

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To ask questions or comment about this privacy policy and our privacy practices, contact via our Contact Us link.

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Thank You for Visiting the Website.