Tipsteria™ Privacy Policy

Last Updated: September 24, 2012

Tipsteria LLC ("Tipsteria™," "we" or "us") operates the Tipsteria™ website located at www.tipsteria.com (the "Website"), and the Tipsteria™ service that includes the provision of mobile tips available via text messaging ("Service"). This Privacy Policy ("Privacy Policy") outlines the privacy practices associated with the Website and the Service and covers our treatment of personally identifiable information that identifies you, such as your name, mobile telephone number, mobile device ID, IP address, email address, home address and your billing history ("PII") that we collect when you: (a) visit the Website; and/or (b) register for the Service ( "Members"). By visiting the Website, and/or subscribing to the Service, you agree to be bound by the terms of this Privacy Policy. It is important that Website visitors and Members are fully informed about the use of their PII. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY IN ITS ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE WEBSITE AND/OR SERVICE.

Personally Identifiable Information We Collect From You

Registration. When you sign-up for our Service, we require that you provide your mobile telephone number and provide and retain the PIN number that we supply to you. If you sign-up via mobile web (which includes WAP), we will acquire your mobile telephone number and the device ID of your mobile telephone. We also collect your IP address when you register.

Website Visitors We automatically collect non-PII when you visit the Website through cookies, clear gifs and other means such as your IP address, browser type, ISP, referring/exit pages, operating system, date/time stamp and clickstream data, (collectively, "Log File Information"), as more fully described below. We collect and store this Log File Information automatically on secure servers.

How We Use Personally Identifiable Information

Any PII that you submit to us or we acquire remains your property. However, we may use this PII to administer the Website and the Service as more fully described below.

Text Messages and Other Communications.   By providing your mobile telephone number on our Website, via a WAP page (a browser page on your mobile telephone), in response to television or print ads or any other means of initiating Membership sign-ups for the Service that we may develop, you expressly consent to receive a sign-up text message from us. If you sign-up on our Website, the first text message that you receive in connection with the sign-up process will contain a unique, four digit personal identification number ("PIN") which is used to set up your account.

If you sign-up on our Website or via any other method, you expressly consent to receive a confirmation text message confirming your subscription and to receive weekly text message alerts from Tipsteria≴. Notwithstanding that your mobile telephone number may be listed on state and/or federal Do-Not-Call registries, we retain the right to contact you via text-messaging as set forth herein.

Service-Related Announcements. We will send you service-related text message announcements when it is necessary to do so. For instance, we send text messages monthly to remind you that your membership is being renewed. If you cancel your membership, we may send you a confirmatory text message or an email. In general, you may not opt-out of these service-related communications.

 If you are not a Member but send us a text message such as “HELP” or “STOP,” you expressly consent to receive a reply “error” text message from us, which we are required to send under guidelines applicable to our service.

Customer Service. Based upon the PII that you provide to us, we will send you a welcoming confirmation text message. We will also communicate with you in response to your inquiries, to provide the Services that you request and to manage your account. In general, you may not opt-out of these service-related communications.

We also collect your: (a) email address and mobile telephone number when you contact us for online support; and (b) name, address, email address and mobile telephone number when you contact us for dispute resolution, using online forms on the Website. This PII will be used to identify your Member account and to help us answer your questions and/or address your concerns.

Supplementation Information.  Using information provided by third parties, we verify that the mobile telephone numbers submitted or acquired during registration are valid mobile phone numbers.

Log File Information. When you visit our Website and use our Service, we use Log File Information to create a “profile” of your preferences.  We may tie your PII to information in the profile to improve the content of the Website. We may also use this Log File information to analyze trends, administer the Website, track users’ movements around the Website and gather demographic information about our user base as a whole.  

Information Sharing and Disclosure

Aggregate Information (Non-PII). Aggregate or group data is data that describes the demographics, usage or other characteristics of Members and/or Website users as a group, without disclosing PII. We compile aggregate or group data about our Members to better focus our Service to meet our Members' needs, preferences and to assist in our marketing efforts. We may also share aggregate data about our Member base, including the number of Members that we have.

Except as noted above, we do not link aggregate user data with PII.

PII We do not sell, rent or share your PII with non-affiliated parties without your prior consent.. We may also share your PII with third party service providers who assist us in providing the Service to you.

By submitting your PII at the Website or via your mobile device, or by enabling us to acquire same via your mobile device, you agree that such act constitutes a purchase, an inquiry and/or an application for purposes of the Amended Telemarketing Sales Rule, 16 CFR §310 et seq. (the "ATSR"). Even if your telephone number is listed on the Federal Trade Commission's Do-Not-Call List, we retain the right to contact you via telemarketing in accordance with the ATSR. Moreover, if you register or make a purchase or request information from a third party seller at or through our Website, this will also constitute a purchase, an inquiry and/or an application with the respective third party seller for purposes of the ATSR and you may be contacted via email, direct mail and/or telephone by that third party seller in accordance with the ATSR.

Service Providers. For Members, we share your mobile telephone number with third party billing companies, mobile carriers and our third party customer care call centers to facilitate billing, to process credits and refunds, for customer service and to communicate with you via text messaging. We may, from time-to-time, supplement the information we collect from you with outside records (e.g., information we obtain from other companies, including wireless providers) to enhance our ability to serve you.

Service providers may also include: (a) providers of the service that you requested by and through one of our Websites and/or Services; and (b) providers of direct marketing transactional services and applications, including lookup and reference, data enhancement, analytics, suppression list management and data validation.

Service providers are prohibited from using your PII for their own purposes without your separate and informed consent.

Third Party Marketing. We do not, sell, rent, lease and/or otherwise distribute your PII with or to any third party marketers.

Legal Disclaimer. We reserve the right to disclose your PII: (a) as required by law and/or to comply with a judicial proceeding, court order or legal process served on the Website or Tipsteria™ provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any PII pursuant to that subpoena; and for compliance purposes with the requirements of the CAN-SPAM Act of 2003; (b) when we believe that disclosure is necessary to protect our rights; (c) if we believe that you are in violation of the terms and conditions of this Privacy Policy, our Member Terms or any other of our operating rules, policies and other supplemental terms and conditions or documents that may be made available by us from time to time; and/or (d) if Tipsteria™ is, or its assets are, sold, merged or acquired; provided, however, that if Tipsteria™ is involved in a merger, acquisition or sale of all or a portion of its assets, you will be notified via text message, email and/or a prominent notice on the Website of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.

Unsubscribing/Opting Out

At your request, we will cease sending text messages to you. You may do so by contacting us using the telephone or postal contact information listed below, using the support contact form or texting STOP to 45259. To opt-out of receiving all other forms of communication from us, you can follow the instructions at the end of the applicable message, contact us using the telephone or postal contact information listed below, using the support contact form.

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for the Service, as well as to respond to any inquiry or request made by you. To opt-out of receiving Service-related and inquiry response-related messages from Tipsteria≴, you must cease requesting and/or utilizing the Service, and cease submitting inquiries to Tipsteria≴, as applicable.

Unsubscribe requests can only be processed if you have registered with us in the first instance. If you have not registered with us and wish to opt out of receiving emails and/or text messaging, as applicable, from a particular sender, please consult that sender’s opt out policies or contact that sender.

Cookies and Pixel Tags

“Cookies" are small pieces of information that are stored by your web browser software on your computer. The use of cookies is now an industry standard and used by most major websites. We use cookies to recognize you and personalize your viewing experience on the Website. For example, we use cookies to recognize user access privileges to the Website, to track Website usage and traffic patterns and to estimate our Website traffic. Although most web browsers are initially set up to accept cookies, if you prefer, you can decline the placement of a cookie on your hard drive by using the appropriate feature(s) of your web browser software (if available) to delete the cookie. Please note, however, that certain areas of the Website may not function properly if your web browser does not accept cookies.

A "pixel tag" is an invisible tag consisting of a few lines of computer coding placed on certain pages of websites you may visit. We may use “pixel tags” to do "pixel tracking." Pixel tracking, a common practice, uses pixel tags to track an individual user's online activity in connection with online advertisements. Pixel tracking measures the effectiveness of these advertisements and compiles aggregate and specific usage statistics. For example, if you sign up for our Service or visit the Website from an advertisement on another website, or in an HTML based email, the pixel tag will allow the advertiser to track that their advertisement brought you to our designated landing page and/or the Website. If you visit our Website and we provide links to another website, we may also be able to determine that you were sent to and/or transacted with that third party website from our Website. This data is collected for use in our marketing and research. PII about you is not collected by us in connection with this process.

We use a third-party tracking service that uses cookies and pixel tags to track non-PII about visitors to our site in the aggregate to capture usage and volume statistics on our behalf to improve our Website.

Access to/Modification of/Removal of PII

At your request, we will inform you of what PII we have on file for you. In addition, at your request, we will remove, correct or update the PII that you have provided to us, or that we have otherwise collected. You may do so by contacting us using the telephone or postal contact information listed below or using our support contact; provided, however, that we ask individuals to identify themselves and the PII 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).

Please be advised that deleting your PII will terminate your access to the Service. If you wish to continue using the Service, you may not delete the personal information that we have on file for you.

We will respond to your request within thirty (30) days. Please be advised, however, that after you delete your PII, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems. In addition, this deletion will not change or delete PII which may have already been shared with third parties, all as provided above in this Privacy Policy. You will need to contact the third parties that contact you directly to change your preferences regarding their use of your PII.

Minors

Our Website and Service are not intended for any user under thirteen (13) years of age or for Florida State residents under eighteen (18) years of age. If you are between thirteen (13) and eighteen (18) years of age, a parent must subscribe on your behalf. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Security

We endeavor to safeguard and protect our users' PII. When users submit PII to us, or permit us to access same, their PII is protected both online and offline (to the extent that we maintain any PII offline). The privacy of your PII is very important to us.

Access to your PII is strictly limited, and we take reasonable measures to ensure that your PII is not accessible to the public. The servers that we store PII in are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of PII under our control. Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your PII, and technological bugs, errors and glitches may cause inadvertent disclosures of your PII; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software constitutes a crime punishable by law. For the reasons mentioned above, we cannot warrant that your PII will be absolutely secure. Any transmission of data at or through our Website, your mobile telephone or otherwise is at your own risk.

All of our users' PII is restricted in our offices. Only employees who need the information to perform a specific job are granted access to PII. Our employees are dedicated to ensuring the security and privacy of all Tipsteria™ user PII. Employees not adhering to our written firm policies are subject to disciplinary action. In compliance with applicable federal and state laws, we will notify you and any applicable regulatory agencies if we learn of an information security breach associated with your PII. We will notify you via email if there's such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

If you have any questions about the security practices of the Website, you can contact us by using our support contact form or by contacting Customer Support with the telephone or postal contact information listed below.

Data Retention

We will retain your information for as long as your account is active or as needed to provide you services.  We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce agreements.

Business Transitions

If we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your PII will likely be among the assets transferred.  You will be notified of any such change in ownership or control of your PII.

Changes to this Privacy Policy

Tipsteria™ reserves the right to change or update this Privacy Policy at any time by posting a notice on the Website that we are changing our Privacy Policy. If the manner in which we use PII changes, Tipsteria™ will notify Members by: (a) sending the modified policy to our Members via email, text message or other means; and/or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use your PII in this different manner, and we will only use your PII in this different manner where you opt-in to such use..

Contacting Us About Privacy Questions or Concerns

If you have any questions about this Privacy Policy, the Service, Alerts or the Website, you may obtain support at any time through the Website at www.Tipsteria.com/support or via telephone at 800-378-9850. You may also text “HELP” to 45259 at any time to receive summary information about your Tipsteria™ account and instructions on how to access customer service.