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PRIVACY STATEMENT

ProGrowth understands your concerns as to how your information is used and shared, and we wish, by providing you with this Privacy Statement, to gain your trust and confidence in how we care for your personal information.

DOES PROGROWTH COLLECT PERSONAL INFORMATION?

Information provided by users

ProGrowth’s purpose is to help Group members achieve their full potential in developing their business. ProGrowth helps its members develop their relationship systems, facilitates communication among members, and assists networking and mutually-beneficial relationship building among members and their contacts. To help accomplish these objectives, ProGrowth collects personally identifiable information when individuals provide the information on a voluntary basis. For example, such personally identifiable information may be gathered from registering with ProGrowth, applying to join a ProGrowth Premier, or from submitting the information on the ProGrowth website. ProGrowth may also gather information through a contest or sweepstakes registration, the registration process for subscription or services and in connection with content submissions, community postings (e.g., chat and forums), suggestions, voting/polling activities and transactional areas, and referrals from members and others. Individual Group members may also submit personally identifiable information about other individuals (not members of a ProGrowth Premier) potentially interested in meeting or networking with other Group members. This information may include name, employer, business market segment, phone and fax and fax numbers, and e-mail address. Group members are not to upload confidential or non-public information about other persons.

This information may be stored on the ProGowth website and made available to ProGrowth Premier members or users interested in ProGrowth. We use this information for such purposes as responding to Group members’ requests or inquiries, improving our services, informing you of activities and offers of our business partners, facilitating the exchange of business between and among Group members and their contacts, communicating with you regarding your account status, changes to the ProGrowth Premier agreement and other matters relevant to the underlying service and/or the information collected. We may share your contact information (name, employer, business market segment, phone and fax and fax numbers, e-mail address) among other ProGrowth Premier members that may be interested in contacting you or exchanging business with you.

Upon request, ProGrowth will use reasonable efforts to allow ProGrowth Premier members or website users to update or correct personal information previously submitted by them to the extent such activities will not compromise privacy or security interests. If you are not a ProGrowth Premier member and your contact information has been submitted to ProGrowth by another person, and you would like it removed, please contact ProGrowth. Upon the request for your contact information to be deleted from the ProGrowth website, ProGrowth will use commercially reasonable efforts to functionally delete the user and his or her personal information from its database; however, it may be impossible to delete a user's entry without some residual information being retained by ProGrowth because of the nature in which backups of data are maintained. Requests for updating, correcting, or deletion of your information should be submitted to ProGrowth at ken@progrowthpremier.com

Information automatically provided

We track user behavior on our website automatically. That information may include your IP address, your domain server, your type of computer, your type of web browser and statistical information regarding the pages you visit. We use this information to perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of the site and to inform advertisers of such information as well as the number of users that have been exposed to or clicked on their advertising banners.

Use of Cookies

Users also should be aware that non-personal information and data may be automatically collected through the standard operation of ProGrowth's internet servers or through the use of cookies. Cookies are small text files a web site can use to recognize repeat users, facilitate the user's ongoing access to and use of the site and allow a site to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising. Cookies are not programs that come onto a user's system and damage files. Generally, cookies work by assigning a unique number to the user that has no meaning outside the assigning site. Users should be aware that ProGrowth cannot control the use of cookies or the resulting information by advertisers or third parties hosting data for ProGrowth. If a user does not want information collected through the use of cookies, there is a simple procedure in most browsers that allows the user to deny or accept the cookie feature; however, users should note that cookies may be necessary to provide the user with certain features (e.g., customized delivery of information) that may be available on the ProGrowth site.

DOES PROGROWTH SHARE THE INFORMATION IT COLLECTS?

Companies offering promotions, products or services

Except as noted below, personally identifiable information on individual user will not be sold or otherwise transferred to unaffiliated third parties without the approval of the user at the time of collection. At such points of collection, the user will have the opportunity to indicate whether he or she would like to "opt out" of receiving promotional and/or marketing information about other products, services and offerings from ProGrowth and/or any third parties. In addition, ProGrowth may occasionally send e-mail promotions out to its Group members on behalf of third-party sponsors. In this instance, unless you have given us your permission to do so, we will not send these types of promotions to you and we don't share your personally identifiable information with these third parties. Upon request, ProGrowth will allow any user to opt out of promotional contacts at any time.

As noted above in the section “Information Provided by Users,” contact information (name, employer, business market segment, phone and fax numbers, e-mail address) about ProGrowth Premier members and other potentially interested individuals may be shared among ProGrowth Premier members. Those persons (or others with whom they may directly or indirectly share such information) may contact you concerning the sale or exchange of business products or services. ProGrowth does not have control over any third parties with whom they may share your information. If you believe your contact information is being shared through the ProGrowth website, and would like it removed, please contact ProGrowth at ken@progrowthpremier.com.

Service providers

ProGrowth may disclose information about individuals in its system to third parties who provide services to ProGrowth and who agree to maintain the confidentiality of such information in accordance with this Privacy Statement. These third parties may provide a variety of services to ProGrowth, including, without limitation, fulfilling product orders, managing or hosting the website, helping create new content and promotions for the site, and sending or coordinating the sending of marketing communications to users who have consented to receive such materials. In situations where a user has supplied his or her information in connection with a question or request for information about a product or service offered by one of our business partners, we may also send the information he or she has supplied to the business partners that offer such products or services.

Aggregate information

We may share aggregated demographic information about our user base as well as aggregated user behavior data with third parties, such as potential advertisers. We do not link, however, this data with personally identifiable information.

Content, partners and links to other websites

We may provide or link to content that is created by a third-party partner website that offers products and services. Such third-party sites may collect information in order to facilitate that transaction process or make the use of the content more productive and efficient. In these circumstances, the information collected may be shared between ProGrowth and these third parties. Users should consult the privacy policies posted on these third party websites as well. In addition, our website may contain links to third party websites to which we have no affiliation. ProGrowth does not share your personal information with those websites and is not responsible for their privacy practices. We suggest you read the privacy polices on these third party websites.

Subscription and/or registration-based services

Users should be aware that ProGrowth may sometimes permit third parties to offer subscription and/or registration-based services through a ProGrowth site. ProGrowth is not responsible for any actions or policies of such third parties and users should check the applicable privacy policy of such party when providing personally identifiable information.

Information you publicly post

Users should be aware that when they voluntarily disclose personally identifiable information (e.g., user name, e-mail address) on the ProGrowth website section that is open to the general public (for example, any public forums, classifieds or chat areas that may be provided on the ProGrowth website, that information, along with any substantive information disclosed in the user's communication, can be collected and correlated and used by third parties and may result in unsolicited messages from other posters or third parties. Such activities are beyond the control of ProGrowth. Please do not post any personal information on any public section of the ProGrowth website that you expect to keep private.

Disclosures required by law

ProGrowth will disclose information to governmental or judicial authorities or law enforcement agencies, or to other individuals or entities in response to subpoenas, court orders, or other legal processes. Further, ProGrowth may share information in order to investigate, prevent, or take action regarding illegal activities or suspected fraud, or to enforce or apply the terms and conditions of this Statement.

Business transfers

If ProGrowth is acquired by or merged with another company, or if ProGrowth decides to sell all or substantially all of its assets or shares to another company, ProGrowth may transfer personally-identifiable information about you to that company as part of that transaction. ProGrowth will notify you in the event that your personally-identifiable information is transferred under these circumstances and becomes subject to a different privacy policy.

Financial information

To the extent that we may collect personally identifiable financial information, such as credit card information, that you have volunteered to us in order to conduct a transaction through our website, such financial information would only be shared with either the government, if we are so required by law (see above), or third party service providers or partners who are assisting ProGrowth in processing your requested transaction, which transaction requires the use of your financial information, such as a sale or license of products. Under the latter circumstance, such third parties would only receive your personally identifiable financial information upon agreeing to maintain its confidentiality and to the terms of this Privacy Statement.

With your consent

Other than as explained above, ProGrowth will notify you when information about you may be provided to third parties, and you will have the option to prevent such information sharing.

WHAT SECURITY PRECAUTIONS ARE TAKEN TO PROTECT PERSONAL INFORMATION?

This website incorporates appropriate safeguards to protect the security, integrity, completeness, accuracy and privacy of the personal information we have collected, and we have put in place reasonable precautions to protect information from loss, misuse and alteration. Our security and privacy policies are periodically reviewed and enhanced as required and only authorized individuals have access to the information you provide us. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that personally identifiable information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Statement.

You hereby acknowledge that ProGrowth is not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.

CHILDREN

This website is not directed to children, and ProGrowth does not knowingly solicit information from any person under the age of 18. Should a child whom we know to be under 18 send personal information to us, we will use that information only to respond directly to that child (or a parent or guardian) to inform him or her that we must have parental consent before receiving his or her personal information.

TERMS AND MODIFICATIONS TO THIS PRIVACY STATEMENT

By using the website, you signify your agreement to the terms of our Privacy Statement. If you do not agree with these terms, you should not use the site. ProGrowth may modify this Privacy Statement at any time. If a material change is made to this Privacy Statement and/or the way we use our users' personally identifiable information, then we will post prominent notice of the nature of such change on the first page of this Privacy Statement and also on our home page. You are responsible for reviewing this Privacy Statement periodically to ensure that you are aware of any changes to it. Your continued use of the site indicates your assent to any changes to this Privacy Statement. This Privacy Statement is applicable to all web sites under ProGrowth, Inc., a California corporation.

CONTACT DETAILS

If you have any questions about this Privacy Statement, the privacy practices of this website, or if you want to exercise any of the rights that you are given under this Privacy Statement, you can contact:

ken@progrowthpremier.com

 

Effective Date:

This Privacy Statement took effect September 1, 2005 .