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PRIVACY
POLICY

Last Updated: April 3rd, 2012

CPO, CPO ("CPO") is committed to upholding the integrity, privacy, and security of customer and/or user ("Customer") information. In addition, CPO complies with the U.S.-EU Safe Harbor and the U.S.-Switzerland Safe Harbor Framework as set forth by the United States Department of Commerce, the European Union, and Switzerland (for more information on the Safe Harbor Program please visit http://export.gov/safeharbor/). This Privacy Policy serves to establish our commitment to Customer privacy and security, as well as explain the policies and procedures CPO adheres to regarding the collection and use of Customer data.

Privacy: CPO is devoted to creating and nurturing a trusting relationship with its Customers, built on the knowledge that any personal information collected is kept private and secure. In undertaking this commitment, CPO will do everything in its capacity to ensure that the integrity of its Customer's privacy is upheld.

Information Collected: CPO uses various methods of data collection for ordering and support purposes. These methods include voluntary collection methods, such as through online registration forms, online and offline customer communications, and sales transactions, as well as automated collection systems such as communication protocols and cookies.

The personal information collected by CPO from Customers varies depending on the method of collection. Personal Identifying Information is collected voluntarily through the use of forms and for the use of the registration and billing of the Customer. This information may include name, title, address, phone number, and e-mail address, as well as information necessary for any financial transactions, such as credit card, CVV, and payment information. Automated means of collection, such as cookies and/or log files, are used to collect information about the use of CPO as well as user preferences and privileges.

Automated Information Collection: CPO uses common automated information collection systems such as cookies and log files to facilitate the connection between the Customer's computer and the CPO servers. There are two types of cookies (pieces of data stored on the user's computer) used by CPO: Session cookies and Persistent cookies. These cookies serve to uniquely identify each user, as well as store session and user-specific settings and preferences in or between user sessions. Cookies do not contain personally identifiable information, and, while CPO doesn't offer an option to opt-out of cookies, browsers provide tools to monitor and control the acceptance, duration, and use of cookies.

CPO also makes use of log files in order to track information such as internet protocol (IP) addresses, browser type, internet service provider (ISP), platform type and date/time stamps. Included in the log files, CPO gathers information that can be used in trend analysis, administration of the site, and overall demography tracking; this information is gathered through the counting of clicks and not linked to personally identifiable information.

Use of Information: CPO uses collected information for a variety of purposes. These purposes include completing transactions for service, to best respond to user support or sales inquiries, to notify or alert customers of events relevant to their service, and to better accommodate the overall needs of CPO customers. To this end, CPO may need to share some of the data collected with banking institutions, outside contractors, or trusted affiliates. This information will not be transferred to any of the aforementioned parties unless they are proven to subscribe to the Safe Harbor Principles or are, themselves, subject to the EU Directive on Data Protection and thereby provide the same level of privacy protection required by the Safe Harbor Principles.

Information collected by CPO may also be used to evaluate the adequacy of current systems of marketing and sales, as well as provide insight into the effectiveness of potential changes within these systems. Under no circumstances will CPO share this information with a third party for compensation or for free, unless the Customer specifically authorizes the disclosure.

Aggregate, anonymous data collected may be used by CPO in discussion and/or correspondence with investors and potential partners. This data is statistical in nature, and will not include personally identifiable information. If the ownership is changed, information collected by CPO may be transferred to the new owners.

Security: Because CPO considers the security of Customer's information paramount, CPO utilizes industry standard security measures to protect Customer Data from unauthorized access. These measures, which include policies, employee training, and physical access, as well as system protocols and mechanisms, contribute to the secure exchange and transmission of sensitive data. Particularly sensitive information, such as credit card numbers collected for financial transactions, is encrypted before its transmission to CPO by the Customer.

While CPO takes the utmost care in preserving the security of its Customer's information, it is important to note that we cannot guarantee that the loss, misuse, or alteration of this data will not occur. In the event of such an occurrence CPO will notify the affected individual of the transgression by email, fax, or, if necessary, U.S. Mail. Notification will be provided promptly, unless it stands to impede on a criminal investigation, in which case CPO may have to wait until such a notification is not foreseen to compromise the investigation.

Special Offers and Updates: From time to time CPO Customers may receive promotions for new products, services, or deals. CPO respects the privacy of its Customers, and has included an opt-out option for these emails.

Service Announcements: In the event that a Customer's service is going to be effected by scheduled or unscheduled maintenance, it may be necessary to send out a strictly service-related announcement. These emails are not optional, however they are intended to act as a professional notification rather than promotional.

Legal Disclaimer: While CPO is dedicated to maintaining the integrity of its Customer's privacy, in the event of suspected or reported fraudulent and/or illegal behavior while using the services of CPO resulting in, or probable to result in, a subpoena, court order, or another applicable legal process it may be necessary to disclose personal information. In the case of the aforementioned, CPO will notify the Customer of the information request and, if deemed necessary, submission.

It is important to note that the websites linked to by CPO are not, nor should they ever be assumed, associated with or regulated under the Privacy Policy held by CPO. This Privacy Policy is only to be applied to Customer data collected by CPO, and we encourage the further inspection of the Privacy Policies of any website collecting your personal information.

Customer Responsibility: It is the responsibility of the Customer to securely store their login information, such as usernames and passwords, or any other information necessary to access their private information maintained within the CPO systems.

It should be noted that there are programs, such as key-loggers and viruses, that can intercept this information from the computers used to access your CPO account. Caution should be taken when using computers other than your own, especially on those used by a number of other users, such as in public.

Safe Harbor: CPO complies with the U.S.-EU Safe Harbor and U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries or Switzerland. CPO has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. We are committed to resolving any complaints about the privacy, collection, or use of your personal information, as such, anybody with inquiries or complaints regarding this privacy policy should first contact CPO at privacy@CPO.com.

CPO has further committed to refer unresolved privacy complaints under the U.S.-EU and U.S.-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU and Switzerland Safe Harbor Program, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by CPO, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Questions: Questions regarding the CPO Privacy Policy may be directed to privacy@lsyf.com.

Contact Us: Feel free to contact us by calling our toll free number 1-800-438-6894 or at  p.o.box 2301, Suwanee GA 30024.

 

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