NOTICE: UPDATED December 24, 2019

This Privacy Policy is applicable to www.marquiswhoswho.com and any affiliated site that may be operated by or for Marquis (the “Website”). The Website is an Internet property of Marquis Who’s Who Ventures, LLC (“Marquis”). It explains how we collect information from users of the Website and how we use such information. Your continued use of the Website and our services constitutes your acceptance of this Privacy Policy. Please also read our Terms and Conditions, which govern the basic operation of the Website.

Definitions

• Service
  Service is the www.marquiswhoswho.com website operated by Marquis Who’s Who Ventures LLC
• Personal Data
  Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
• Usage Data
  Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Cookies
  Cookies are small pieces of data stored on your device (computer or mobile device).
• Data Controller
  Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
• Data Processors (or Service Providers)
  Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
• Data Subject (or User)
  Data Subject is any living individual who is using our Service and is the subject of Personal Data.
• Listee
  An individual that is the subject of biographical record by Marquis Who’s Who.

The Information We Collect and Use

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Cookies and Usage Data
• IP address

We may collect and use certain information and data when you visit the Website. When you visit the Website, we may collect certain data that does not tell us specifically who you are. This is “Non-Personally Identifiable Information.” It includes things like your Internet Protocol (IP) address, browser type, and the last domain you visited before coming to the Website or the domain you go to when you leave. It also includes various statistical data regarding your use of the Website such as which pages you visit, how long you stay on them, and what you click. We collect some Non-Personally Identifiable Information through “cookies.” Cookies and web tags also let us learn how people use our Website, which in turn helps us improve our Website for you to use. We reserve the right to use your IP address to help diagnose problems with our server, and to administer the Website. Your IP address may be used to gather broad and specific demographic information as well as for validation purposes. We may use “cookies” to recognize you as you use or return to our Website. This is done so that we can provide a continuous and more personalized experience for you. A cookie is a small text file that a website or e-mail may save to your browser and store on your hard drive. Cookies are text files that we place in your computer’s browser to store your preferences. To find out more about cookies, please visit www.cookiecentral.com. Even in the case where a user rejects a cookie, he or she may still use the Website. We may also use web beacons. Web beacons allow us to know if a certain page was visited, an email was opened, or if ad banners on our Website and other sites were effective. Web beacons utilize certain tracking software to capture your domain name address (the address of your Internet service provider) for purposes of tracking statistics at our Website. The capture of your domain name is a common practice among websites for measuring the number of hits, pages visited, and length of user session. We use this information to measure the effectiveness of the applicable Website offerings in order to service you better.

We also may collect information that can be used to identify you (“Personally Identifiable Information”). This might include your name, email address, mailing address, telephone number or credit card number. We only collect Personally Identifiable Information when you specifically provide it to us. This might happen, for example, when you register for a user account, log on with your user name and password, order a publication or service, participate in a promotional offer or submit content to the Website. We may use Personally Identifiable Information to offer you products and services from Marquis, to enhance your experience at the Website, and, if applicable, to enhance your experience as a subscriber to Marquis’ products and services.

Use of Data

Marquis Who’s Who Ventures LLC uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR) effective May 25, 2018

If you are from the European Economic Area (EEA), Marquis Who’s Who Ventures LLC legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Retention of Data

Marquis Who’s Who Ventures LLC will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Also, as professional biographers, the information being collected will be retained for the purposes of constructing the most complete biographical history for our listees.

Marquis Who’s Who Ventures LLC will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Marquis Who’s Who Ventures LLC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Legal Requirements

Marquis Who’s Who Ventures LLC may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Marquis Who’s Who Ventures LLC
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

“Do Not Track” Signals

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Privacy Notice for California Residents (Effective January 1, 2020) 

This Privacy Notice for California Residents supplements the information contained elsewhere in this Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our websites, software applications (apps), emails (with your consent, where required by law), and other products, services and platforms collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our websites, apps, emails, and other products, services and platforms may have collected the following categories of personal information from its consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a newsletter or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we or our third-party service providers will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product or service orders and requests.
• To provide, support, personalize, and develop our websites, apps, emails, and other products, services and platforms.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses.
• To personalize your website, apps, emails, or other product, service or platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, apps, emails, and other products, services and platforms.
• To help maintain the safety, security, and integrity of our websites, apps, emails, and other products, services and platforms, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our websites, apps, emails, and other products, services and platforms.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.

The Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

The Company may disclose your personal information to a third-party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see ‘Sales of Personal Information’ below). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales (see ‘Sales of Personal Information’ below).  

We may share your personal information with the following categories of third parties:

• Subsidiaries and affiliates.
• Contractors and service providers.
• Data aggregators.
• Third parties with whom we partner to offer products and services to you.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:

[Category A: Identifiers.] 

[Category B: California Customer Records personal information categories.] 

[Category F: Internet or other similar network activity.]

[Category G: Geolocation Data.]

[Category K: Inferences drawn from other personal information.]

Sales of Personal Information

Except with respect to our Institutional Services, in the preceding twelve (12) months, the Company has sold the following categories of personal information collected through our ad-supported Services:

[Category A: Identifiers.] 

[Category F: Internet or other similar network activity.]

[Category G: Geolocation Data.]

[Category K: Inferences drawn from other personal information.]

The Company and our advertising partners collect the personal information identified above (such as the cookies stored on your browser, the advertising identifier on your mobile device, or the IP address of your device) when you visit our websites, apps, and other products, services and platforms, or open our emails. We, and our partners, use this information to tailor and deliver ads to you on our websites, apps, emails, and other products, services and platforms, or to help tailor ads to you when you visit others’ sites (or use others’ apps). To tailor ads that may be more relevant to you, we and/or our partners may share the information we collect with third parties.

If you do not wish for us or our partners to sell your personal information to third parties for advertising purposes, click the “Do Not Sell My Info” link accessible from the pages of our websites, apps, and other products, services and platforms. Note that although we will not sell your personal information after you click that button, we will continue to share some personal information with our partners (who will function as our service providers in such instance) to help us perform advertising-related functions such as, but not limited to, measuring the effectiveness of our ads, managing how many times you may see an ad, reporting on the performance of our ads, ensuring services are working correctly and securely, providing aggregate statistics and analytics, improving when and where you may see ads and/or reducing ad fraud. If you access our websites, apps, and other products, services and platforms from other devices or browsers, visit our “Do Not Sell My Info” link from those devices or browsers to ensure your choice applies to the data collected when you use those devices or browsers. Additionally, although clicking the “Do Not Sell My Info” link will opt you out of the sale of your personal information for advertising purposes, it will not opt you out of the use of previously collected and sold personal information (except for personal information sold within 90 days prior to your exercising your right to opt out) or all interest-based advertising. If you would like more information about how to opt out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#. You may download the AppChoices app athttp://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that the Company disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that the Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at (844) 394-6946; Monday-Friday, 9:00 a.m. to 5:00 p.m. (U.S. Eastern Time)
• Emailing us at datarights@marquisww.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing in accordance with CCPA requirements.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

 Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

 We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing optout@marquisww.com .

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by clearing cookies from your browser or emailing optout@marquisww.com.

 You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for like-goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of like-goods or services.
• Suggest that you may receive a different price or rate for like-goods or services or a different level or quality of like-goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.  Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.  We currently provide the following financial incentives:

COMING SOON

Other California Privacy Rights

 California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites, mobile applications, and other products, services and platforms that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email todatarights@marquisww.com or write us at: Marquis Who’s Who Ventures, LLC, 100 Connell Drive, Suite 2300, Berkeley Heights, NJ 07922.

Changes to Our Privacy Notice

The Company reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website at https://www.marquiswhoswho.com/pages/privacy-policy update the notice’s effective date. Your continued use of our websites, mobile applications, and other products, services and platforms following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which the Company collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Your Data Protection Rights Under General Data Protection Regulation (GDPR) effective May 25, 2018

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Marquis Who’s Who Ventures LLC aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Marquis Who’s Who Ventures LLC relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Dissemination of Your Information

We use information about how you interact with our Website in order to personalize it for you, to keep both you safe from harm, and to improve the Website and our services. We use your information to provide requested services and to support core business functions such as: (i) fulfilling your requests for services and communicating with you about those requests; (ii) confirming registration at the Website and servicing your account; (iii) providing customer service and alerting you to the services we provide; (iv) helping us improve and customize our service offerings, Website, and advertising; (v) sending you information about our services; (vi) protecting the security or integrity of our Website and our business; and (vii) analyzing and underwriting your requests for our services. To accomplish these purposes, we may combine personal and non-personal information we collect online with offline information, including information from third parties. We may also share Personally Identifiable Information with third parties, who may contact you to offer products and services. At any time, you can contact Marquis by sending an email to optout@marquisww.com(or call 1-908-279-0100) to request that we not share your Personally Identifiable Information with third parties.

We may employ other people or firms (“Outside Contractors”) to provide services and products, such as credit card processing, fraud screening, order fulfillment and shipment, and website hosting or development. Outside Contractors may sometimes have access to Personally Identifiable Information to the extent necessary to do their work for us, however, we require Outside Contractors to protect the privacy of your Personally Identifiable Information. We also require them not to use or disclose your Personally Identifiable Information for any purpose other than providing us with products or services for which we contracted.

We may share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy

We may disclose your Personally Identifiable Information to third parties in connection with a corporate transaction where all or a portion of our business (including our associated customer lists) is sold or transferred. We also may disclose your Personally Identifiable Information if disclosure is required by law or as part of a lawsuit or government investigation or proceeding. You may also submit information about yourself for inclusion in our directories (a “Biographical Submission”). Our use of Biographical Submissions is not governed by this Privacy Policy. Please see our Terms and Conditions instead.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

CAN-SPAM Act of 2003 Compliance

Moreover, you hereby consent to disclosure of any record or communication to any third party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with other third parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time. We also reserve the right to release current or past user or borrower and personally identifiable information in situations where we believe in good faith that the law requires it, or that the sharing is necessary to protect the safety, property, or other rights of Marquis, our borrowers, our employees, contractors, or any other person. We may also share Personally Identifiable Information with third parties, who may contact you to offer products and services. At any time, you can contact Marquis by sending an email to optout@marquisww.com (or call 1-844-394-6946, option 2) to request that we not share your Personally Identifiable Information with third parties.

You may at any time opt out of receiving communications from Marquis or third parties by contacting our Information Privacy Manager at the address below. Please note that if you decide to opt out of receiving promotional information or other communications, your change in preference will only affect future contacts; if the information already has been provided to third parties, they may continue to use it. Even if you choose to opt out, we may continue to contact you as necessary regarding any request you have made for services or products from Marquis or changes to this Privacy Policy.

Amended Telemarketing Sales Rule

We may share aggregate and statistical data that does not identify you personally. We may do this for research and marketing purposes, for instance to describe our services to prospective partners or advertisers, and for other lawful purposes. You agree that by submitting your e-mail address at the Website you may receive email marketing from us and our third party advertisers. In addition, you agree that such act constitutes a purchase, an inquiry and/or an application for purposes of the Amended Telemarketing Sales Rule, 16 CFR ยง310 et seq. (the “ATSR”). With respect to the ATSR, and notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, we or our designee retain the right and you hereby expressly authorize us and/or our designee to contact you via telemarketing in accordance with the terms of the ATSR. Moreover, by registering with, or requesting information from us or another third party advertiser at or through the Website, such action shall constitute a purchase, an inquiry and/or an application with the respective affiliated third party advertiser for purposes of their compliance with the ATSR and you may be contacted via e-mail, instant messaging, text messaging, direct mail and/or telemarketing by such third party advertiser in accordance with the terms of the ATSR.

How We Use and Share Financial Information

As set forth hereinabove, we do not collect social security information. However, to the extent applicable, for purposes of compliance with the Gramm-Leach-Bliley Act, 15 U.S.C. 6802 (the “GLB Act”), the California Financial Information Privacy Act (“CFIPA”) and the Vermont Consumer Protection Act, 8 V.S.A. 10202 (“VCPA”), we will not share nonpublic personally identifiable financial information with our affiliates or non-affiliates without providing borrowers with an annual Privacy Notice explaining that we will be sharing this nonpublic personally identifiable information with our affiliates or non-affiliates and, for purposes of the GLB Act, providing borrowers with the opportunity to opt-out from such disclosures.

For purposes of compliance with the GLB Act, the CFIPA and the VCPA, this Privacy Policy shall serve as both your initial customer relationship and annual Privacy Notice as defined under the GLB Act, CFIPA and VCPA, respectively. If you would like to opt-out from the disclosure of your personal information to any third party for marketing purposes, please email us at info@marquisww.com.

Notwithstanding the foregoing, we reserve the right to share personally identifiable financial information in accordance with the terms of the GLB Act, for California State residents only, the CFIPA and, for Vermont State residents only, the VCPA. The nonpublic personal information of California State residents shall not be shared by us with third parties unless: (i) we have obtained a fully executed consent acknowledgement from the applicable California resident; or (ii) the California resident already has a relationship with a nonaffiliated financial institution pursuant to, and as defined under, the CFIPA. If you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third party for marketing purposes, please email us at info@marquisww.com. However, where California residents opt-out from permitting their personal information to be shared with third party marketing partners, such individuals may still receive selected offers directly from us, in accordance with the law. Notwithstanding the foregoing and despite the fact that we do not collect Social Security information, we nevertheless hereby agree not to share the Social Security Number of California State residents with third parties without first obtaining their consent to do so pursuant to the terms and conditions set forth in the CFIPA. California Civil Code Section 1798.83 permits visitors to our Website, who are California residents, to request certain information regarding its disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an e-mail or write us at the address below.

Again, to the extent applicable, for purposes of compliance with the VCPA, we will not share nonpublic personal financial information (as defined in the VCPA) with third parties without providing Vermont State residents with an annual notice explaining that we will be sharing this nonpublic personal information with non-affiliated third parties. Notwithstanding the foregoing, the nonpublic personal financial information of Vermont State residents shall not be shared by us with nonaffiliated third-parties unless: (i) we have obtained authorization from the applicable Vermont resident; provided, however, that such authorization must be in written form, or where the applicable Vermont resident agrees, electronic form; (ii) the disclosure is made to third-parties for the sole purpose of processing transactions or other related processes on our behalf; and/or (iii) the disclosure is made to third-parties that market our own services to our borrowers.

Third Party Links

When you connect to the Website through third party websites, those websites might share information about you with us. Those third party websites may show information about you to us, however the sharing of this information is determined by their privacy policies. While we currently do not advertise on the Website, we do not endorse, nor are we responsible for the accuracy of, the privacy policies and/or terms and conditions of any third party advertisers that may advertise at the Website. The entities that may advertise and/or place banner ads at our Website including, but not limited to, these third party advertisers, are independent third parties and are not affiliated with us. We encourage our users to be aware when they leave our Website and to read the privacy policies of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by us or on our Website.

Data Security

Securing your information is a company priority. When our registration/application process requests that you provide us with sensitive information and when we store and transmit such sensitive information, that information is encrypted and is protected with SSL encryption software. While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user information off-line. However, no method of security is 100% effective and we cannot be responsible for the actions of those who may gain unauthorized access to your personal information. Marquis makes no warranties, express, implied or otherwise as to the ultimate effectiveness of these reasonable and appropriate safeguards. All collected information is stored in a technically and physically secure environment. Access to this information is strictly limited, and not accessible to the public. Only employees who need the information to perform a specific job (for example an account representative) are granted access to personal information. Our employees are dedicated to ensuring the security and privacy of all user information. Employees not adhering to our firm policies are subject to disciplinary action. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures. Your account information is protected by the password you use to access your online account. Please keep this password confidential. If your browser is capable of SSL (and most are), your account information will be protected during transport across the Internet. We comply with industry standard requirements. These standards require safeguards for handling and securing borrower information. These include using secure networks; encryption or other protection of cardholder data; physical and technical access controls; monitors and tests of security systems; and information security policies.

Minors

We are committed to protecting the online privacy of minors. In order to protect children’s personal information, and to meet the standards of the Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect personally identifiable information from children under the age of 18 on the Website.

Changes to the Privacy Policy

We reserve the right to change or update this Privacy Policy at any time by posting a notice at the Website explaining that we are changing our Privacy Policy. If the manner in which we use personal information changes, we will notify our users by posting the changes on the Website and sending out an e-mail or mail notification to our impacted customers notifying them of the changes, and providing them with the opportunity to opt-out of the provisions relating to the transfer of their personal information. Other than where the user opts-out, and other than where affirmative consent is required for California residents and Vermont residents, the user’s continued use of our Website and/or continued receipt of our e-mails constitutes an affirmative acknowledgement and acceptance by the user of the modified Privacy Policy.

Should you wish to opt-out of our privacy policy at any time, please email us at optout@marquisww.com.

Electronic Signatures and Electronic Records

By submitting your information and agreeing to the terms of this Privacy Policy, you understand and affirm that you are agreeing to be bound by the Privacy Policy and all other agreements and terms and conditions found on the Website by using your electronic signature and that your electronic signature is as legally binding as a physical signature on paper. Furthermore, you are agreeing that you will use an electronic signature to accept electronic records regarding our services and/or offered by our Website, including, but not limited to, this Privacy Policy. You further agree and consent: (i) to receive surveys, agreements, and other information that may be provided or otherwise available to you electronically. Included in those agreements, surveys and other information may be disclosures required by federal, state, and local laws and regulations, where allowed by such laws; (ii) to be bound by the terms and conditions of the agreements, applications, and other information provided to you by us electronically; (iii) to use and receive electronic records and electronic signatures in conducting business with us, including agreeing to the terms of the Privacy Policy; (iv) that to electronically receive agreements, applications, and other information, you will need a compatible operating system, web browser, and email application, and you will need access to a printer or the ability to download information to keep copies of such documents for my records. The operating systems, web browsers, and email applications identified herein are compatible. You furthermore understand that you are indicating that you have the capability to access the agreements, surveys, and other information and download or prints copies for your records; (v) for customer service or technical assistance regarding electronic records or electronic signatures, you may contact us by email at info@marquisww.com; (vi) you may obtain a paper copy of the agreements, applications, and other information at anytime by contacting us by email at info@marquisww.com. We will not charge a fee for any paper copy.

Contact Us

You may contact Marquis regarding our privacy practices at the following address:

• By email: info@marquisww.com
• By phone number: 908-279-0100
• By mail: Marquis Who’s Who Ventures, LLC,
• 100 Connell Drive, Suite 2300, Berkeley Heights, NJ 07922