INTRODUCTION

This Privacy Policy tells you the types of information we collect when you use our Sites or Services, how we use that information

 and the instances in which we share your information.

SUMMARY OF KEY PRINCIPLES

We thought it would be helpful to set out briefly the key ways in which we use your information and how we seek to protect privacy.

 Of course, you should read the terms of our full Privacy Policy.  

    We typically collect two kinds of information about you: (a) information that you provide that personally identifies you
     (e.g., full name or phone number); and (b) information that does not personally identify you (e.g., your IP address or type of browser);
    This information is transmitted to, held and processed by us in the United States of America;
    We typically use this information to provide you with our website and related services, and to produce reports and data about online shopping;
    We may disclose this information to authorized third parties including our merchants, advertising and promotional
    partners and third party service providers for these purposes;
    Through the use of “cookies,” we work with and permit advertising networks to collect anonymous information about
     you to send you their ads and use the same information to send you our ads (see section III below);
    You may at any time opt-out of certain activities as set out below (see section VI);
    We encrypt any information you input using Secure Sockets Layer (SSL) software and take reasonable security measures to safeguard information;
    If you register with us, you have the ability to update or correct the information you previously provided via the account section;
    This Privacy Policy may change from time to time so please check this policy regularly.
    Any material changes will be notified to you by email as appropriate.

I.         WHAT INFORMATION DO WE COLLECT?

We collect two kinds of information related to you: (a) Personally Identifiable

 Information (“PII”); and (b) Non-Personally Identifiable Information (“Non-PII”).  

 

(a) Personally Identifiable Information:  PII includes any information that identifies you as person.   We collect your PII

 when you choose to register with us or when you choose to participate in an interactive feature of our Sites such as a review, survey or promotion.

  You may: (a) provide your name, mail/shipping address, email address, credit card number and phone number when registering with our Sites or

in connection with a contest entry; (b) provide certain demographic information about you (e.g., age, gender, shopping interests and preferences, etc.)

when participating in a survey or poll; or (c) post a general comment and/or recommendation on our Sites.  

 

(b)  Non-Personally Identifiable Information:   Non-PII is any information that does not identify you

 as a person including PII which has been rendered anonymous.   

We obtain non-PII either separately or together with your PII as described above. We collect certain

 non-PII from you when you access our Sites including

IP addresses and information relating to your browser, operating system, ISP, the third party website

 from which your visit originated and how you use our Sites such as the web pages you visit, and the duration of your visits.


II.       HOW WE USE & SHARE THE INFORMATION COLLECTED

PII and Non-PII is used to provide, or improve, our Sites and Services to you and to carry out your requests,

 respond to your inquiries, better serve you and understand

your needs, or is used in other ways naturally associated with the circumstances in which you provided the information.    

We may disclose PII and Non-PII to:

(1) our third party service providers who perform functions on our behalf in connection with the operation of the Sites or Services e.g., providers who

 host and manage data, process credit card orders, deliver our merchandise, etc;   

 (2) participating sponsors to a program or promotion you enter through our Sites or Services;

(3)our parent company, subsidiaries or other affiliated companies (“ affiliated companies”) for operational, marketing and promotional purposes;

(4) co-promotional partners and others with whom we have marketing or other relationships ;

(5) participating merchants where you consent at the time you submit PII to us when using the interactive features of our Sites such as surveys

 and reviews concerning our participating merchants; and

(6) our other users where you choose to publicly post reviews, comments or other information relating to products or services, communicate with

other users via public forums (e.g., forums, message boards, bulletin boards, etc.).

In addition, we use non-PII to help analyze site traffic, understand customer needs and trends, carry out targeted

promotional activities (see “Preference Based Advertising” below).  

 We may use your non-PII by itself or aggregate it with information we have obtained from others to produce

research reports and other information and data about online shopping

 for participating merchants and other customers, as well as media and other interested parties.

 

III.      COOKIES AND PREFERENCE BASED ADVERTISING

  (a) Cookies and Web Beacons: We and the third parties we authorize automatically receive and store certain types

of non-PII whenever you interact with us by using "cookies" and analogous technology. "Cookies" are small files that are placed on your computer or your internet

 browser memory to enable the owner of the cookie to recognize your browser and to provide convenience and other features to you.

So, for example, our cookies may allow us to show you the past products you have searched for on our Sites.

It is important to note that the cookies that we use, or permit others to use, do not contain and are not tied to PII about you.   

You may be able to direct your internet browser not to allow cookies and you can typically delete existing cookies from your computer at any time.

 Please note, however, some elements of our Sites will not function properly or be available to you.   

(b)  Preference Based Advertising: We also work with and permit certain third

parties, including advertising networks and website analysis firms, to place cookies on your computer/browser when you visit our Sites.

These third party cookies are used to gather non-PII about your activities on our Sites and third party sites to serve

you with advertisements while you are on third party sites (“Third-Party Ads”).    

Some important notes: (1) the opt-out tools for Third-Party Ads include all the advertising networks that shoes-mal works with, but also many

that Imonjealy does not work with; (2) opting out of Our Ads does not automatically serve as an opt-out from Third-Party Ads – the same is true the other way around.

 To opt-out of Our Ads and Third-Party Ads, you must use each respective opt-out tool above; (3) the opt-out tools for both Our Ads and Third-Party Ads rely on cookies

 to ensure that your non-PII is not used for online advertising purposes (“Opt-out Cookies”).  Therefore, if you buy

 a new computer, change web browsers or delete these Opt-out Cookies from your computer, you will need to perform the relevant

opt-out tasks again; and (4) the features of your internet browser and/or certain add-on software may allow you to block or

 limit the use of cookies for preference based advertising and other purposes.  

We cannot, however, promise that our Sites will work well or be compatible with these alternative methods of blocking or limiting the use of cookies.

(c) Do Not Track Features: Certain browsers may offer you the option of providing notice to websites that you do not wish for your

 online activities to be tracked for preference based advertising purposes ("DNT Notice"). Some browsers are, by default, set to provide a DNT

Notice, whether or not that reflects your preference. Providing DNT Notice is often touted as a means to ensure that cookies, Web beacons and similar

technology are not used for preference based advertising purposes - that is, to restrict the collection of non-personally identifiable information about

your online activities for advertising works, DNT Notices may not effectively accomplish this

 goal. For this and a variety of other reasons, with respect to our Website, we do not take any action based on browser based DNT Notices.

 Instead, if you do not wish to participate in preference based advertising activities, you should follow the simple opt-out process identified above.

 

IV.       SALE OF BUSINESS AND DISCLOSURE BY LAW

(a) Business Transactions: We may disclose PII and Non-PII held by us : (a) to a prospective seller or actual seller of any business or

assets we acquire;   (b) if all or any of our assets are acquired by a third party, in which case, PII and Non-PII may be one of the transferred assets.    

(b)  Required disclosures : We may disclose and use any PII or non-PII if we are required to do so by law, with respect to

copyright and other intellectual property

infringement claims, or if we believe that such action is necessary to: (a) fulfill a government request; (b) conform with the requirements

of the law or legal process; (c) protect or defend our legal rights or property, our Sites, or other users; or (d) in an emergency to protect

the health and safety of our Sites's users or the general public.

 

V.        SECURITY OF INFORMATION

We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.

We also use a secure server hosting location in the US, firewall protection, controlled access and encryption technology to protect your data.  

 Please be advised, however, that while we strive to protect your PII, we cannot guarantee or warrant the security of any information you

disclose or transmit to us online and are not responsible for the theft, destruction, or inadvertent disclosure of your PII.  

 In the unfortunate event that your personally identifiable information is compromised, we will notify you by e-mail to the last e-mail address

you have provided us as soon as feasible under the circumstances (delays in notification may occur while we take necessary

measures to determine the scope of the breach and restore reasonable integrity to the system, as well as for the legitimate needs of law

 enforcement if notification would impede a criminal investigation.)


VI.       YOUR OPTIONS & OPT-OUTS

(a) W hat Information Can I Access?  If you register as a shoes-mal member, you will typically have access to an account section that includes

 the registration information you previously provided which you can update or correct at any time.   If there is any inaccurate information that you

 are not able to correct, just let us know.  Also, if you wish, you can delete your membership account entirely although we may retain certain

information in limited circumstances – e.g., to resolve disputes, troubleshoot problems and enforce our Terms of Use . Furthermore, some

information is never completely removed from our databases due to technical (e.g., information that is stored in our “back-up” systems) and certain legal constraints.   

(b) What Choices Do I Have (Opt-Out)?  You have many choices regarding how we use information about you, including:

(1) To stop our emails ;

 (2) To opt-out of preference-based ads;

(3) To stop the sharing of PII with our participating merchants ;

(4) as discussed above, the choices we offer you anytime you submit information through our Sites or Services.


(c) You May Contact Us With Questions: If you have any questions or concerns about privacy at shoes-mal, please contact us by contect us.     

VII.     CHILDREN

As neither our Sites nor our Services are intended for use by children under 13, children under 13 may not submit any PII to us.

 Also, i f you are under 18, you should use shoes-mal and submit information only with involvement of a parent or guardian.


VIII.   REVISIONS

This Privacy Policy may change from time to time to reflect our changing business practices. We will provide you notice of any such changes

by posting the new policy on our Sites or by email if the changes are material .

 

VII.     SOLE STATEMENT

This Privacy Policy and our Terms of Use , both as posted on our Websites and through our Services, contain all

of the material terms of regarding your use of our Websites and Services.   

No summary, modification, restatement or other version thereof, or other privacy statement or policy, in any form, is valid unless we post it to our Websites and Services.