Active Date: June 04, 2018

Lead Generation Member Privacy Policy

This Member Privacy Policy governs information collected from Members, both active and prospective, of the Websponsors.com Lead Generation Network ("Lead Generation Network").

Front Street Marketing ("Company," "we" or "us"), located in the United States, reserve the right to revise this Member Privacy Policy at any time simply by posting such revision, so we encourage you to review it periodically.

This Member Privacy Policy will tell you, among other things:

• What Member information Company collects.
• How Company may use Member information.
• How Company may share Member information.
• How you can correct or update your Member information.

Click on any of the above links to go directly to the corresponding section of this Member Privacy Policy.

ACKNOWLEDGEMENT/YOUR AGREEMENT

The Lead Generation Network is intended for use by individuals 18 years of age or older. By applying to join the Lead Generation Network or submitting information to Company, you consent to Company’s use and sharing of the information collected or submitted as described in this Member Privacy Policy. If you are not 18 years of age or older or you do not agree with the terms of this Member Privacy Policy, do not provide Company with any information or use any of the products or services offered or provided on Company websites or through the Lead Generation Network.

If you have questions or concerns regarding this Member Privacy Policy, you should contact us by clicking here.

INFORMATION COLLECTION

We collect and combine personally identifiable information ("PII") and non-personally identifiable information ("Non-PII") through various sources, including those discussed below. For your reference, PII is data collected with an intention to specifically identify, contact or locate a person, including but not limited to name, address, telephone number, or e-mail address. Conversely, Non-PII is data that is not used to specifically identify, contact or locate an individual, including but not limited to zip code, gender, age, or IP address. Collection and storage of PII and Non-PII complies with all laws, rules and regulations of any country with respect to data protection and privacy.

Application Information

You must apply to join the Lead Generation Network. On the Member application, you may be asked to provide the following information: (1) website information, including but not limited to title, URL, privacy policy, type of website, number of daily page views, category of website, content language, whether the website is incentivized, website description, and keywords; (2) contact information, including but not limited to name, job title, telephone number, fax number, e-mail address, and mailing address; (3) payment information, including payee name, address, telephone number, and type, tax ID, social security number, and minimum payment amount; and (4) account information, including but not limited to account name and password. After you have submitted your application, Company may request that you submit additional information to verify your identity or account, including but not limited to your driver’s license and social security card.

Automatic Information/Digital Identifiers

Company uses "persistent cookies," which are unique alphanumeric identifiers that store information on your computer, to track transactions, simplify Member login and to facilitate secure navigation through the password protected areas of the website. These cookies remain in your browser once you have left our website, until deleted or expired. These cookies are strictly necessary to enabling the functionality of our website, as well as fulfilling our obligation to properly credit our Members. If you choose, there are utilities available for purchase from independent software providers to install on your computer as well as tools/preferences you can choose through most web browsers to make website visits anonymous. Members who choose to reject all cookies may have difficulty navigating the password protected areas of the website depending on the nature of their connection (dynamic IP, proxy server, etc.).

We also collect information through our web server applications. This information includes your Internet Protocol or "IP" address, date/time stamp, browser type, and referring URL.

Additionally, we may use pixel tracking technology to track the completion of transactions with us or our advertisers, the source information for those transactions, and your IP address, date/time stamp, browser type, and referring URL.

Further, you may be asked to provide all IP addresses that you will use to submit consumer leads so they can be white listed by Company.

Consumer Lead Information

We collect consumer "lead" information, for consumers located in or outside the European Economic Area (EEA), that is submitted by Members who run offers through the Lead Generation Network. A consumer lead may be comprised of a consumer’s: IP address, e-mail address (or MD5 hashed email address when marketing to Users that reside in the EEA), name, mailing address, telephone number, date of birth, gender, and payment information; information about a consumer’s background, interests, health, education, career goals, and shopping preferences; and any other personal information or unique preference information the consumer provided to the Member. We may require Members to submit a referring URL and/or sub-affiliate identifier with each lead, along with a date/time stamp. Collection, storage, and transfer of consumer lead information comply with all applicable laws.

Tax Forms

We may be required to create, collect, maintain, and submit certain information required by the government, such as IRS Forms W-8, W-9 and 1099.

INFORMATION USE

We may use the collected PII and Non-PII for any legally permissible purpose in our sole discretion, including but not limited to: verify your application, establish your account, service your account, deliver media, provide suppression or unsubscribe information or services, calculate and make payments, contact you for sales or inventory acquisition purposes, resolve disputes, and to defend Company, its advertisers or consumers.

SMS

SMS, Wireless and Other Mobile Offerings: Some of the services that we provide will result in sending an SMS, wireless or other mobile offering to your cell phone. These should be obvious in the context of the offering at the time you sign up. By signing up, you are agreeing to receive these mobile offerings. You understand that your wireless carrier's standard rates apply to these messages. To unsubscribe or discontinue SMS messages, send "STOP", "END", "QUIT" to the SMS text message you have received. This process impacts only the future delivery of the particular SMS message offering, so you must send that message for each offering. This will not affect offerings sent on behalf of third parties.

IVR

Your acceptance of the terms and conditions of this website constitutes your express written consent to receive telemarketing calls from third-party marketers, including by means of a pre-recorded message and automated voice dialing. Your consent will be effective regardless of whether the number you have provided: (a) is a home, business, or cell phone line; and/or (b) is or will be registered on any state or federal Do-Not-Call (DNC) list, and shall remain in effect until you revoke your consent by clicking here to Contact Us.

INFORMATION SHARING

We may share the collected PII and Non-PII for any legally permissible purpose in our sole discretion, including but not limited to those explained below.

Within the Company

We may share Member information with affiliated companies in the European Economic Area (EEA) or abroad, including our parent company and other subsidiaries of our parent company. This Privacy Policy does not apply to affiliated companies and their collection, use and sharing of information.

Vendors

We may share Member information with various vendors, located in or outside the EEA, that are not part of Company, including but not limited to network quality consultants and financial institutions involved in making ACH direct deposits.

Governmental Agencies or Other Companies

We may share Member information with law enforcement officials or governmental agencies in or outside the EEA: (1) in response to their request; (2) when permitted or required by law; or (3) to establish our compliance with applicable laws, rules, regulations, or guidelines.

We also may share your information with third parties when: (1) trying to protect against or prevent actual or potential fraud or unauthorized transactions; (2) investigating fraud that has already taken place; (3) enforcing or applying existing terms and conditions and/or other agreements; (4) protecting the rights, property or safety of our websites, our users or others; or (5) responding to subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims.

Advertisers

We transfer consumer "lead" information that is submitted by Members who run offers through the Lead Generation Network to the applicable advertisers whose location may be in the EEA or abroad.

We also may transfer Member information, including but not limited to application information, account information and statistics, to our advertisers in response to their request or in the event of a dispute.

Right to Transfer

Should we choose to sell or transfer business assets, it is possible that the information we possess may be transferred as part of that transaction to a location outside the EEA. We may retain a copy of the information post sale or transfer as permitted by applicable law.

CORRECTING/UPDATING MEMBER INFORMATION

If your Member information changes, such as your e-mail address, you may correct or update your information by:

• making the changes online by entering the member area;
• clicking here to Contact Us or
• contacting your account manager.

WHAT HAPPENS IF I HIT A LINK TO ANOTHER SITE FROM THIS WEBSITE?

TThis website may offer links to other websites. Other websites have their own terms of use and privacy and security policies. If you choose to visit one of these sites, you should review the policies that govern that particular site.

WHAT IS THE POLICY WITH RESPECT TO COMMUNICATING WITH CHILDREN?

We recognize the unique privacy concerns regarding children. We are committed to carefully protecting privacy where children are involved no matter the point of contact. In particular, our intention is to fully comply with the Children’s Online Privacy Protection Act ("COPPA"). Per COPPA guidelines, we do not knowingly collect PII from children under the age of 13. If a parent or guardian is made aware that a child under the age of 13 has provided us with PII through any point of contact, click here to Contact Us and we will delete the information about the child referenced from our files.

SECURITY

There is no such thing as complete security on the Internet or otherwise. We use various security techniques on our websites to help protect against the loss, misuse or modification of information we’ve collected from you. When you access your account or transmit data to us, that information is stored on servers that we have taken steps to protect from unauthorized access or intrusion. While we strive to protect your information, we cannot ensure or warrant the security of any information you transmit to us. You acknowledge and assume this risk when communicating with Company, its partners and affiliates.

DATA PROCESSING

By providing information to Company, you acknowledge that it operates in the United States and you agree: (1) to permit Company to transmit and use your information anywhere necessary in accordance with all applicable laws, including across international boundaries, to affect the services and transactions provided by the Lead Generation Network; and (2) that such use by Company shall be subject to the terms and conditions stated in this Privacy Policy.

LIMITATION OF LIABILITY

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, AS WELL AS THE LEAD GENERATION NETWORK PUBLISHER AGREEMENT. YOU AGREE THAT LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE BARRED OR LIMITED AS SET FORTH IN THE LEAD GENERATION NETWORK PUBLISHER AGREEMENT.

CONTACTING US

If you have any questions, comments, or concerns, about this Member Privacy Policy please contact us, in our role as data controller at:
Websponsors.com Lead Generation
Attn: Legal Department
Front Street Marketing, 2300 Vartan Way, Ste 100, Harrisburg, PA 17110
Email: Contact Us.