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Store Policies

Consumer Membership Privacy Policy

Last Updated: 10/10/2013

This Privacy Policy (“Policy”) explains how information about you is collected, used and disclosed by Inner Circle Direct and its subsidiaries and affiliated companies (collectively, “ICD”). This Policy applies to the information we collect when you use our websites, mobile applications and other online products and services (collectively, “the “Services”) or when you otherwise interact with us as described below.

Inner Circle Direct reserves the right to change this Policy from time to time. If ICD makes changes, we will notify you by revising the date at the top of the Policy, and in some cases, we may provide you with additional notice (such as adding a statement to the homepages of our websites or sending you a notification). ICD recommends you review the Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your own privacy.

Collection of Information

Information You Provide to Us

Inner Circle Direct collects information you provide directly to us. For example, ICD may collect information when you create a membership account, use the interactive areas and features of our Services, invite a friend to use our Services, communicate with us via third party social media sites, participate in a contest or promotion, request customer support or otherwise communicate with us. The types of information ICD may collect include your name, email address, phone number, billing and shipping addresses, credit card information, shopping preferences, demographic information and any other information you choose to provide. In some cases, ICD may also collect information you provide about others. For example, ICD may ask you to provide the email address of the friend who invited you to join our Services.

Information We Collect Automatically

When you access or use the Services, Inner Circle Direct automatically collect information about you, including:

Log Information: Inner Circle Direct logs information about your use of the Services, including your access times, pages viewed, Internet Protocol (“IP”) address, browser type and language and the website you visited before navigating to our Services. ICD may also infer your geographic location based on your IP address.

Device Information: Inner Circle Direct collects information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.

Information Collected by Cookies and Other Tracking Technologies: Inner Circle Direct uses various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to, among other things, improve our Services and your experience, see which areas and features of our Services are popular and count visits. ICD may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used on our Services or in our emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine if an email has been opened and acted upon. For more information about cookies, and how to disable them, please see “Your Choices” below.

Information Inner Circle Direct Collect From Other Sources: Inner Circle Direct may also obtain information from other sources and combine that with the information we collect through our Services. For example, if you create or log into your ICD membership account through a third party social media site, ICD will have access to certain information, from that site, such as your name, email address, account information and friend’s lists, in accordance with the authorization procedures determined by such social media site.

Use of Information

Inner Circle Direct may use information about you for various purposes, including to:

  • operate and improve the Sites and our services;
  • provide the products, services and information you request, and send yourelated information;
  • send you technical notices, updates, security alerts and support and administrative messages;
  • respond to your comments and questions and provide customer service;
  • track the results of invitation referrals;
  • monitor and analyze trends, usage and activities in connection with the Services;
  • personalize and improve the Services and provide advertisements, content or features that match your profile and interests;
  • communicate with you about new products, services, contests, promotions, special offers, upcoming events and other news about ICD and our selected partners;
  • link or combine with other information we receive from third parties to help understand your needs and provide you with better service; and
  • carry out any other purpose for which the information was collected.Inner Circle Direct may store and process personal information in the United States and in other countries.

Sharing of Information

Inner Circle Direct will not share your personal information with third parties other than as follows:

  • with third party vendors, consultants and other service providers who are working on our behalf and need access to your information to carry out their work for us;
  • when you give us your consent, including if we notify you on the Services that the information you provide will be shared in a particular manner and you provide such information;
  • when you sign up for and participate in the interactive areas of our Services, certain information about you may be displayed publicly;
  • with third parties for their own marketing and business purposes (if you are a California resident, please see “Your Choices” below for more information about your privacy rights with respect to this type of sharing);
  • in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
  • if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of ICD or others; and
  • in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.Inner Circle Direct may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Social Sharing Features

The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Advertising and Analytics Services Provided by Others

Inner Circle Direct may also allow others to serve advertisements on our behalf across the Internet and to provide analytics services.

Some of these entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by ICD and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity. For more information about Internet-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices and www.networkadvertising.org/managing/ opt_out.asp.

We may also work with third parties to serve ads to a customized group of users on other websites or platforms unless you notify us that you prefer not to have information about you used in this way.

Security

Inner Circle Direct takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Your Choices

Account Information

You may update, correct or delete information about you at any time by logging into your online account or sending an email with your request to info@innercircledirect.com If you wish to deactivate your account, please email ICD at info@innercircledirect.com, but note ICD may retain certain information about you as required by law or for legitimate business purposes. ICD may also retain cached or archived copies of information about you for a certain period of time.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Promotional Communications

You may opt out of receiving promotional communications from Inner Circle Direct at any time by following the instructions in those messages or by contacting info@innercircledirect.com. If you opt out, ICD may still send you non-promotional communications, such as emails about your account and our ongoing business relations. ICD will take commercially reasonable steps to implement your opt-out requests promptly, but you may still receive communications from us for up to ten business days as we process your request.

Push Notifications/Alerts

With your consent, ICD may send push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Your California Privacy Rights

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please write to Inner Circle Direct Attn: Legal, P.O. Box Norwell, MA

Contact Us

If you have any questions about this Privacy Policy, please contact ICD at:
Inner Circle Direct
P.O. Box
Norwell, MA
info@innercircledirect.com


Inner Circle Direct MANUFACTURER PROFILE PAGE POLICIES

All Manufacturers will provide information about their products on the Profile Page and abide by the following rules:

  • Manufacturer policies must abide by Inner Circle Direct’s site-wide policies.
  • Manufacturer may not use illegal photographs, text or videos.
  • Manufacturer may not infringe on another’s copyright ortrademark rights.
  • Manufacturer may not use inappropriate language, images orvideos in their Profile per the discretion of Inner Circle Direct.
  • Manufacturer may not make illegal use of photographs, writtentext or videos.
  • Manufacturer may not use inappropriate, defamatory, libelous,obscene, profane or racist language, images or videos in theirprofile.
  • Manufacturer must notify customers through on Inner CircleDirect website if the Manufacturer is on vacation and/or will not be able to ship within the designated time frameManufacturers that do not comply with Inner Circle Direct’s policies may result in suspension of account privileges and/or termination. If the cases mentioned above occur, Manufacturer remains obligated to pay Inner Circle Direct for all unpaid fees that have already been accrued.

Inner Circle Direct PRODUCTS LISTINGS POLICY

Manufacturer is not permitted to list or feature Restricted

Products on innercircledirect.com as defined below:

  • Alcohol
  • Tobacco and other smokeable products
  • Drugs, medical drug claims about an item, drugparaphernalia
  • Live animals, illegal animal products
  • Human remains or body parts
  • Pornography
  • Firearms and/or weapons
  • Hazardous materials
  • Recalled items
  • Real estate
  • Motor vehicles
  • Products that promote violence or are biased towardsothers based on race ethnicity, religion, gender, gender identity, disability, or sexual orientation;Inner Circle Direct reserves the right, at its sole discretion, to remove products that are not in compliance with the Inner Circle Direct’s reputation or image.

Inner Circle Direct MATURE CONTENT POLICY

Inner Circle Direct’s goal is to maintain a marketplace appropriate for all age groups, therefore the use of mature content must comply with the following policies. Mature content is defined as content such as pornography or violence that is not generally thought to be appropriate for viewing by children.

  • Products with mature content should be labeled “mature”
  • Manufacturer profiles, banners and products should notcontain profane language or images.
  • Images seen by general public should be appropriate for ageneral audience.For Manufacturers who do not comply with Inner Circle Direct’s policies may be subject to review, which can result in suspension of account privileges and/or termination. Suspended or terminated manufacturers remain obligated to pay Inner Circle Direct for any unpaid fees already accrued.

INNER CIRCLE DIRECT PRODUCT SALES AND DESCRIPTIONS POLICY

Manufacturer must adhere to the following rules as it relates to product sales and descriptions:

  • Product descriptions and photos must accurately describe the item for sale.
  • Each product must be available for purchase.
  • A product may not be created for the sole purpose of sharingphotographs or other information.
  • A product may not be created solely as an advertisement todrive traffic to another site. This includes notices of sales orpromotions.
  • The Manufacturer will not price the product (including theshipping) at a higher price than the product is listed on its ownwebsite or on any known third-party website.
  • A product should not be created with an inaccurate price inorder to keep it from selling.
  • The shipping price must be reasonable for the item. Eachunique item must be its own product.
  • The Manufacturer may group items as a set into a singleproduct if the items are being sold and shipped together.
  • The Manufacturer may not use Inner Circle Direct to directshoppers to another online selling venue to purchase the same items as listed at Inner Circle Direct. This includes posting links/ URLs or providing information sufficient to locate the other online venue(s).Listings that do not comply with Inner Circle Direct’s Rules and Policies may result in suspension of account privileges and/or termination. Suspended or terminated merchants remain obligated to pay Inner Circle Direct for all unpaid fees that have already been accrued.
Inner Circle Direct
P.O. Box 528 • Norwell, MA 02061
855.627.5333 • info@innercircledirect.com
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