This Privacy Policy applies to the United States. The
Privacy Policy below governs your online account (ICOE Shop)
and any information you provide on this site.
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A. Overview
B. Information We Collect
C. Our Use and Disclosure of Information
D. Information Security
E. Accessing and Changing Your Information
F. Contacting Us
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A. Overview
In order to operate the ICOE Shop service and to reduce
the risk of fraud, ICOE Shop must ask you to provide us
information about yourself and your credit card and/or bank
account. This Privacy Policy describes the information we
collect and how we use that information.
If you apply for a ICOE Shop branded credit card or credit
line , you authorize ICOE Shop and the issuer of the ICOE
Shop branded credit card or credit line to exchange the
information you provide in the application form. If you
are approved for a ICOE Shop branded credit card or credit
line, your credit account will be governed by the issuing
bank’s privacy policy.
ICOE Shop takes the privacy of your personal information
very seriously and will use your information only in accordance
with the terms of this Privacy Policy. We will not sell
or rent your personally identifiable information or a list
of our customers to third parties. However, as described
in more detail in Part C below, there are limited circumstances
in which some of your information will be shared with third
parties, under strict restrictions, so it is important for
you to review this Privacy Policy. This Privacy Policy applies
to all services that are hosted on the ICOE Shop.com Web
site, whether the services are offered by ICOE Shop, by
its subsidiaries, or by the ICOE Shop Money Market Fund.
Your privacy is important to us. By participating in the
Council of Better Business Bureau's BBBOnLine® Privacy
Program we have made a commitment to meet the program's
strict requirements regarding how we treat your information
and have it verified by BBBOnLine. Further information about
this program is available at http://www.bbbonline.org.
Additionally, in order to enhance the protection of your
privacy and our compliance with this Privacy Policy, ICOE
Shop has agreed to disclose our information practices and
to have our practices reviewed for compliance by TRUSTe.
TRUSTe is an independent, non-profit organization whose
mission is to build users' trust and confidence in the Internet
by promoting the use of fair information practices. By displaying
the TRUSTe trustmark, ICOE Shop has agreed to notify you
of:
What personally identifiable information of yours is collected
by ICOE Shop.
The organization collecting the information.
How the information is used.
With whom the information may be shared.
What choices are available to you regarding collection,
use and distribution of the information.
The kind of security procedures that are in place to protect
the loss, misuse or alteration of information under ICOE
Shop's control.
How you can correct any inaccuracies in the information.
If you have questions or concerns regarding this Privacy
Policy, you should first contact ICOE Shop using this form.
If you do not receive acknowledgment of your inquiry or
your inquiry has not been satisfactorily addressed, you
should then contact TRUSTe http://www.truste.org/consumers/watchdog_complaint.php.
TRUSTe will then serve as a liaison with ICOE Shop to resolve
your concerns.
By accepting the Privacy Policy and User Agreement in registration,
you expressly consent to our use and disclosure of your
personal information in the manner described in this Privacy
Policy. This Privacy Policy is incorporated into and subject
to the terms of the ICOE Shop User Agreement. This Privacy
Policy will take effect on March 4, 2003. This Privacy Policy
was last updated on May 18, 2006.
Please note that your personal information will be stored
and processed on our computers in the United States. The
laws on holding personal data in the United States may be
less stringent than the laws of your country but ICOE Shop
will hold and transmit your personal information in a safe,
confidential and secure environment. If you object to your
personal information being transferred or used as described
in this Privacy Policy, please do not register for the ICOE
Shop service.
Notification of Changes
This policy may be revised over time as new features are
added to the ICOE Shop service or as we incorporate suggestions
from our customers. If we are going to use or disclose your
personally identifiable information in a manner materially
different from that stated at the time we collected the
information, you will have a choice as to whether or not
we use or disclose your information in this new manner.
Any material changes will be effective only after we provide
you by e-mail with at least 30 days' notice of the amended
Privacy Policy (if you have closed your ICOE Shop account,
you will not be contacted to notify you of the amended Policy
and your personal information will not be used or disclosed
in this new manner).
We will post the amended Privacy Policy prominently on
our Web site so that you can always review what information
we gather, how we might use that information, and whether
we will disclose it to anyone. Please check the ICOE Shop
Web site at www.ICOE Shop.com at any time for the most current
version of our Privacy Policy.
ICOE Shop Shops and other pages on the ICOE Shop Web site
include links to third party Web sites. These sites are
governed by their own privacy statements, and ICOE Shop
is not responsible for their operations, including but not
limited to their information practices. Users submitting
information to or through these third party Web sites should
review the privacy statement of these sites before providing
them with personally identifiable information.
A Special Note About Children. Children are not eligible
to use our service and we ask that minors (under the age
of 18) do not submit any personal information to us or use
the service.
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B. Information We Collect
Required Information
To open a ICOE Shop account, you must provide your name,
address, phone number, and e-mail address. In order to make
payments through ICOE Shop, you must provide credit card,
debit card or bank account information (bank account information
is required to make payments totaling more than $1,000.00
USD). We also ask you to choose two different security questions
to answer (such as your city of birth or your pet's name)
This required information is necessary for us to process
transactions, issue a new password if you forget or lose
your password, protect you against credit card fraud and
checking account fraud, and to contact you should the need
arise in administering your account.
Pursuant to section 326 of the USA PATRIOT Act, the U.S.
Department of the Treasury and the Securities and Exchange
Commission require ICOE Shop Funds to obtain, verify, and
record the following information for each investor in the
ICOE Shop Money Market Fund.
Name
Address
Date of Birth (for Individuals)
Tax Identification Number (social security number for individuals
or employer identification number for businesses)
In order to comply with the Bank Secrecy Act, we will also
require your Tax Identification Number if you send or receive
certain high-value transactions or high overall payment
volumes through ICOE Shop. If you choose to register or
apply for certain optional features or products offered
through ICOE Shop Web sites, such as listing your business
in ICOE Shop Shops, or applying for the ICOE Shop Visa®
credit card or the ICOE Shop MasterCard® debit card,
you will be required to provide additional information to
establish that you qualify for such features or products.
Transaction Information
When you use ICOE Shop to send money to someone else or
request money from someone else, we ask you to provide information
related to each transaction, including the amount of the
transaction, the type of transaction (purchase of goods,
purchase of services, or simple money transfer ("quasi-cash"))
and the e-mail address or phone number of the third party.
We retain this information for each of your transactions
through ICOE Shop. We also collect the Internet address
(IP address) of the computer or device you use to access
your ICOE Shop account, in order to help detect possible
instances of unauthorized transactions.
Information About You From Third Parties
In order to protect all our customers against potential
fraud, we verify with third parties the information you
provide. In the course of such verification, we receive
personally identifiable information about you from such
services. In particular, if you register a credit card or
debit card with ICOE Shop, we will use card authorization
and fraud screening services to verify that your card information
and address matches the information that you supplied to
ICOE Shop, and that the card has not been reported as lost
or stolen.
If you register your online business with ICOE Shop Shops
or if you send or receive high overall payment volumes through
ICOE Shop, in some circumstances we will conduct a background
check on your business by obtaining information about you
and your business from a credit bureau or a business information
service such as Dun & Bradstreet. If you incur a debt
to ICOE Shop, we will generally conduct a credit check on
you by obtaining additional information about you from a
credit bureau, to the extent permitted by law. ICOE Shop,
at its sole discretion, also reserves the right periodically
to retrieve and review a business and / or consumer credit
report for any account, and reserves the right to close
an account based on information obtained during this credit
review process.
Additional Verification
If we cannot verify the information that you provide, or
if you request a withdrawal by check to an address other
than your verified credit card billing address, we ask you
to send us additional information by fax (such as your drivers'
license, credit card statement, and/or a recent utility
bill or other information linking you to the applicable
address), or to answer additional questions online to help
verify your information.
Web Site Traffic Information
Because of the way that World Wide Web communication standards
work, when you arrive at or leave the ICOE Shop Web site,
we automatically receive the Web address of the site that
you came from or are going to. We also collect information
on which pages of our Web site you visit while you are on
the ICOE Shop site, the type of browser you use and the
times you access our Web site. We use this information only
to try to understand our customers' preferences better and
to manage the load on our servers, so as to improve our
service and your experience with ICOE Shop. We do not track
the Web sites that you visit before or after you leave the
ICOE Shop site.
Our Use of "Cookies"
"Cookies" are small files of data that reside
on your computer and allow us to recognize you as a ICOE
Shop customer if you return to the ICOE Shop site using
the same computer and browser. We send a "session cookie"
to your computer if and when you log in to your ICOE Shop
account by entering your e-mail address and password. These
cookies allow us to recognize you if you visit multiple
pages in our site during the same session, so that you don't
need to re-enter your password multiple times. Once you
log out or close your browser, these session cookies expire
and no longer have any effect.
We also use longer-lasting cookies to display your e-mail
address on our sign-in form, so that you don't have to retype
the e-mail address each time when you log in to your ICOE
Shop account. In addition, we use cookies to process our
referral program, described in Section C below. Our cookie
files are encoded so that your e-mail address and other
information can only be interpreted by ICOE Shop. We may,
however, share cookie information regarding whether or not
a certain user is already registered with ICOE Shop with
certain merchants with whom we have an official co-marketing
relationship.
Customer Service Correspondence
If you send us correspondence, including e-mails and faxes,
we retain such information in the records of your account.
We will also retain customer service correspondence and
other correspondence from ICOE Shop to you. We retain these
records in order to measure and improve our customer service,
and to investigate potential fraud and violations of our
User Agreement. We may, over time, delete these records
if permitted by law.
Questionnaires, Surveys and Profile Data
From time to time, we offer optional questionnaires and
surveys to our users for such purposes as collecting demographic
information or assessing users' interests and needs. The
use of the information collected will be explained in detail
in the survey itself. If we collect personally identifiable
information from our users in these questionnaires and surveys,
the users will be given notice of how the information will
be used prior to their participation in the survey or questionnaire.
Non-member Recipients and Requests
When a member either sends a payment to, or requests a payment
from, an individual who is not a registered member of ICOE
Shop, we will retain the information that the member submits
to us, including, for example, the other party's email address
and/or name, for the benefit of the member who is attempting
to contact the non-member, so that the member can see a
complete record of his or her transactions, including uncompleted
transactions. Although this information is stored indefinitely,
we will not market to the non-member in any way at any time.
Additionally, these non-members have the same rights to
access and correct information about themselves (assuming
that their email addresses were correct enough to reach
them) as anyone else who uses ICOE Shop.
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C. Our Use and Disclosure of Information
Internal Uses
We collect, store and process your personal information
on servers located in the United States. We use the information
we collect about you in order 1) to provide our services
and process your transactions, 2) to provide customer service,
3) to determine your eligibility to receive offers for special
features or products, such as the ICOE Shop MasterCard®
debit card, and 4) to improve our products and services.
At your option (as indicated in your ICOE Shop Profile settings),
we use the information you provide to access specific third
party services on your behalf and perform the actions that
you request us to perform, such as invoicing winning bidders
on behalf of auction sellers.
We give access to individually identifiable information
about our users only to those employees who require it to
fulfill customer service requests.
Disclosure to Other ICOE Shop Customers
If you are a registered ICOE Shop user, your name, e-mail
address, phone number (if applicable) date of sign-up, and
whether you have verified control of a bank account are
displayed to other ICOE Shop customers whom you have paid
or who are attempting to pay you through ICOE Shop. If you
are a Business account holder, we will also display to other
ICOE Shop customers the Web site address (URL) and customer
service contact information that you provide us. However,
your credit card number, bank account and other financial
information will NEVER be revealed to anyone whom you have
paid or who has paid you through ICOE Shop, except with
your express permission or if we are required to do so pursuant
to a subpoena or other legal process.
If you are buying goods or services and paying through
ICOE Shop, the seller of the goods or services may request
that you provide a mailing address that ICOE Shop has confirmed
as matching the billing address in the credit card system.
You do not have to provide this information. If you do not
provide the information, however, the seller may choose
not to accept your ICOE Shop payment and not to complete
the transaction.
We work with third party merchants to enable them to accept
payments from you, including direct credit card payments.
Merchants who use this service will share personally identifiable
information you provide to them with ICOE Shop in order
to validate the information, assess the risks of your payment,
or confirm the existence or status of your ICOE Shop account.
You permit ICOE Shop to share information with the merchant
on the validity of the personally identifiable information
you provided to the merchant, and on the existence or status
of your ICOE Shop account.
ICOE Shop does not store the personally identifiable information
provided by these merchants to validate the existence of
your account.
Beginning in spring 2001, ICOE Shop will also disclose
to other ICOE Shop customers the number of payments you
have received from Verified ICOE Shop customers (as defined
in the User Agreement on the www.ICOE Shop.com site), or
other aggregate measures that provide an indication of your
reputation with other ICOE Shop customers.
Disclosure to Third Parties Other Than ICOE Shop Customers
ICOE Shop will not sell or rent any of your personally identifiable
information to third parties. ICOE Shop will not share any
of your personally identifiable information with third parties
except in the limited circumstances described below, or
with your express permission (and with other ICOE Shop customers
as described above). These third parties are limited by
law or by contract from using the information for secondary
purposes beyond the purposes for which the information is
shared.
We share information with companies that help us process
the transactions you request and protect our customers'
transactions from fraud, such as sharing your credit card
number with a service that screens for lost and stolen card
numbers. See "Information About You From Third Parties"
in Section B above. Additionally, if you go into a negative
balance and owe us money, we may share information with
processing companies including collection agencies.
We may disclose the information we collect, as described
in Section B above, to companies that perform marketing
services on our behalf. We may also disclose the information
we collect (but not your bank account or credit card information)
to other financial institutions with whom we have joint
marketing agreements, in order to determine whether you
are pre-approved for the products that ICOE Shop is jointly
marketing with the third party (such as the ICOE Shop Visa
credit card issued by Providian National Bank). These companies
are subject to confidentiality agreements with us and other
legal restrictions that prohibit using the information except
to market the specified ICOE Shop-related products or services,
unless you have affirmatively agreed or given your prior
permission for other uses.
If you do not want ICOE Shop to share any of your information
with our joint marketing partners, please log in to your
account to set your Notification preferences in the Profile
page of the My Account tab to indicate that you do not want
to receive Partner/Third-Party Promotions or the ICOE Shop
Periodical Monthly Newsletter and Product Updates. Use the
following URL to see your Notification preferences: https://www.ICOE
Shop.com/PREFS-NOTI.
We disclose information that we in good faith believe is
appropriate to cooperate in investigations of fraud or other
illegal activity, or to conduct investigations of violations
of our User Agreement. For example, this means that if we
conduct a fraud investigation and conclude that one side
has engaged in deceptive practices, we can give that person
or entity's contact information (but not bank account or
credit card information) to victims who request it.
We disclose information in response to a subpoena, warrant,
court order, levy, attachment, order of a court-appointed
receiver or other comparable legal process, including subpoenas
from private parties in a civil action.
When a user signs up for a co-branded version of ICOE Shop
(e.g. ICOE Shop Evite) through links to ICOE Shop from our
co-branded partner's website, ICOE Shop will share with
the co-branded partner that user's name, e-mail address
and physical address in order to provide enhanced integration
between ICOE Shop's services and the services of our co-branded
partner. If you do not want your information shared with
ICOE Shop's co-branded partner, you should sign up with
ICOE Shop directly and not through a link from our partner's
website.
If you choose to invest in the ICOE Shop Money Market Fund,
we will share your information with ICOE Shop Funds, a Delaware
business trust which is the issuer of the Money Market Fund,
and with ICOE Shop Asset Management, Inc., a wholly-owned
subsidiary of ICOE Shop that is the transfer agent for the
Money Market Fund, so that you can complete your investment
more easily and can move funds into and out of the Money
Market Fund without re-entering your personal information
for every transaction.
We disclose information to your agent or legal representative
(such as the holder of a power of attorney that you grant,
or a guardian appointed for you).
We share aggregated statistical data with our business partners
or for public relations. For example, we may disclose that
a specific percentage of our users live in California. However,
this aggregated information is not tied to personally identifiable
information.
As with any other business, it is possible that ICOE Shop
in the future could merge with or be acquired by another
company. If such an acquisition occurs, the successor company
would have access to the information maintained by ICOE
Shop, including customer account information, but would
continue to be bound by this Privacy Policy unless and until
it is amended as described in Section A above.
We share your information with our parent, subsidiaries
and joint ventures to help coordinate the services we provide
to you, enforce our terms and conditions, and promote trust
and safety.
Our Contacts with ICOE Shop Customers
We communicate with users on a regular basis via e-mail
to provide requested services, and we also communicate by
phone to resolve customer complaints or investigate suspicious
transactions. We use your e-mail address to confirm your
opening of a ICOE Shop account, to send you notice of payments
that you send or receive through ICOE Shop (including referral
payments described below), to send information about important
changes to our products and services, and to send notices
and other disclosures required by law. Generally, users
cannot opt out of these communications, but they will be
primarily informational in nature rather than promotional.
We also use your e-mail address to send you other types
of communications that you can control, including the ICOE
Shop Periodical newsletter, auction tips, customer surveys
and notice of special third-party promotions. You can choose
whether to receive some, all or none of these communications
when you complete the registration process, or at any time
thereafter, by logging in to your account on the ICOE Shop
Web site and changing your preferences in the Profile page
of the My Account tab. You can also change your choices
at any time through the same procedure.
In connection with independent audits of our financial
statements and operations, the auditors may seek to contact
a sample of our customers to confirm that our records are
accurate. However, these auditors cannot use personally
identifiable information for any secondary purposes.
Internet Address Information
We use IP addresses, browser types and access times to analyze
trends, administer the site, improve site performance and
gather broad demographic information for aggregate use.
Your Use of Information and Our Services
In order to facilitate the transactions between ICOE Shop
members, our service allows you limited access other users'
contact or shipping information. As a seller you may have
access to the User ID, email address and other contact or
shipping information of the purchaser, and as a purchaser
you may have access to the User ID, email address and other
contact information of the seller.
By entering into our User Agreement, you agree that, with
respect to other users' personally identifiable information
that you obtain through the site or through an ICOE Shop-related
communication or ICOE Shop-facilitated transaction, you
will only use this information for: (a) ICOE Shop-related
communications that are not unsolicited commercial messages,
(b) using services offered through ICOE Shop (e.g. insurance,
shipping and fraud complaints), and (c) any other purpose
that such user expressly agrees to after adequate disclosure
of the purpose(s).
In all cases, you must provide users with the opportunity
to remove themselves from your database and review any information
you have collected about them. In addition, under no circumstances,
except as defined in this Section, can you disclose personally
identifiable information about another ICOE Shop user to
any third party without our consent and the consent of such
other user after adequate disclosure. Note that law enforcement
personnel and other rights holders are given different rights
with respect to information they access.
ICOE Shop does not tolerate spam. Therefore, without limiting
the foregoing, you may not add a ICOE Shop user to your
mail list (email or physical mail) without their express
consent after adequate disclosure, even if said user has
previously made a purchase from you. We strictly enforce
our Anti-Spam Policy! To report ICOE Shop-related spam to
ICOE Shop, please contact us.
Merchant Referral Program
When you sign up for a ICOE Shop account, you become eligible
to participate in our Merchant Referral Bonus program. We
provide you with a link on the Merchant Referral Bonus page
which identifies you as the referrer. If a merchant uses
that link to sign up for a Premier or Business ICOE Shop
account and completes the bonus requirements, you are eligible
for a referral bonus. If you use a referral link to sign
up, your business name (if you have a Business account)
or first and last name (if you have a Premier account) may
be listed in the referrer's ICOE Shop account, along with
the amount of bonus you have generated for the referrer,
which is calculated as a percentage of your transaction
volume, as described in the Merchant Referral Bonus Policy.
Please use our referral program responsibly. We strictly
enforce our Anti-Spam Policy! Read details on the Referral
Bonus.
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D. Information Security
Information Security
ICOE Shop is committed to handling your customer information
with high standards of information security. Your credit
card and bank account information are stored only in encrypted
form on computers that are not connected to the Internet.
We restrict access to your personally identifiable information
to employees who need to know that information in order
to provide products or services to you. We maintain physical,
electronic and procedural safeguards that comply with federal
regulations to guard your nonpublic personal information.
We test our security systems regularly and also contract
with outside companies to audit our security systems and
processes. For more information on ICOE Shop's security
practices, please visit the ICOE Shop Security Center.
The security of your ICOE Shop account also relies on your
protection of your ICOE Shop password. You may not share
your ICOE Shop password with anyone. ICOE Shop will never
ask you to send your password or other sensitive information
to us in an e-mail, though we may ask you to enter this
type of information on the ICOE Shop website, which will
always have a URL beginning with https://www.ICOE Shop.com/.
Any e-mail or other communication requesting your password,
asking you to provide sensitive account information via
email, or linking to a website with a URL that does not
begin with https://www.ICOE Shop.com/ should be treated
as unauthorized and suspicious and should be reported to
ICOE Shop immediately using this form. If you do share your
ICOE Shop password with a third party for any reason, including
because the third party has promised to provide you additional
services such as account aggregation, the third party will
have access to your account and your personal information,
and you may be responsible for actions taken using your
password. If you believe someone else has obtained access
to your password, please change it immediately by logging
in to your account at www.ICOE Shop.com/ and changing your
Profile settings, and also contact us right away as described
in Section F below.
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E. Accessing and Changing Your Information
You can review the personal information you provided us
and make any desired changes to such information, or to
the settings for your ICOE Shop account, at any time by
logging in to your account on the ICOE Shop Web site and
changing your preferences in the Profile page of the "My
Account" tab. You can also close your account through
the ICOE Shop Web site. If you close your ICOE Shop account,
we will mark your account in our database as "Closed,"
but will keep your account information in our database.
This is necessary in order to deter fraud, by ensuring that
persons who try to commit fraud will not be able to avoid
detection simply by closing their account and opening a
new account. However, if you close your account, your personally
identifiable information will not be used by us for any
further purposes, nor sold or shared with third parties,
except as necessary to prevent fraud and assist law enforcement,
or as required by law (for example, to send former Money
Market Fund investors a report of dividends paid during
the calendar year for tax reporting purposes).
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F. Contacting Us
If you have any questions about this privacy statement,
ICOE Shop information practices, or your dealings with ICOE
Shop, you can contact us using this form, call 678.715.9777
Monday through Friday between the hours of 7am and 10pm
EST, or write us at ICOE Shop, 541
Harwell Road, Atlanta, GA 30318 or e-mail us at
imhotep7@bellsouth.net.
our approach
