uTANGO Security & Privacy Statement

Last updated: February 15, 2008

Afiniti Ventures, Inc., d/b/a uTANGO ("uTANGO") takes your privacy seriously. We want you to understand how we handle your personal information that we may collect on www.uTANGO.com (the "Site"), and how we may and may not share it. This Privacy Statement covers all of our information handling practices for the Site. By visiting or accessing the Site, or becoming a registered member, you accept the practices described in this Privacy Statement.

What information we collect from you

How we use your information

With whom we share your information

How you can access and update your information

Your choices with respect to the collection and use of your information

Security of your information

Collection of information from children

External links

Changes to this Privacy Statement

How you can contact uTANGO

What information we collect from you

As part of providing you products or services, we may collect various types of information about you. Personally identifiable information, which we refer to as "personal information" in this Privacy Statement, is information that can be associated with a specific person and can be used to identify that person, such as full name, mailing address, email address, or phone number. This Privacy Statement describes our use, collection, and disclosure of personal information on the Site in detail.

We also collect and derive information from your use of, and interaction with, the Site that does not personally identify you as an individual. Examples of this non-personally identifiable information include aggregate data about the use of the Site (by way of example, patterns of utilization and demographic data about our user base), and account information and other personal information that is de-identified, aggregated, or otherwise modified to remove identifying elements. Non-personally identifiable data does not identify you or your spouse. All non-personally identifiable data collected and derived by uTANGO in connection with the Site is owned exclusively by uTANGO and may be used by uTANGO as it deems appropriate. As an example of uTANGO's use of non-personally identifiable data, we may provide non-personally identifiable, aggregated information about our members and their spending and purchasing habits to third parties for audit, marketing and other purposes.

Account information

To set up your membership, you will need to provide certain contact information, such as your name, spouse's name, mailing address, your email address, spouse's e-mail address, date you were married or date you intend to be married, state where you were or intend to be married, phone number, username, and password. uTANGO Members are required to maintain current contact information and can update this via their My Account page. This information will also allow us to contact you about new savings opportunities, unless you opt out of receiving these messages.

Purchase information

As a member, you can earn uTANGO LifeStage Reward points ("Points") by shopping with our contributing Merchant Partners and/or using the uTANGO Visa credit card. uTANGO is the administrator of all Point awards and as such may require additional information in order to keep track of your purchases and administer the Site and our services. For example, a phone company might require your telephone number, while an airline might require your frequent flyer account number. To take part in our grocery service, you may need to provide a grocery loyalty card number. In order to keep track of and collect your contributions, uTANGO collects from some Merchant Partners, grocery retailers or third party processors details of your transactions such as the date and amount of your transaction. It is optional to provide some types of details to uTANGO, such as a loyalty card number, but without these details you may not be able to earn points for all qualifying transactions.

Rewards account information

We will maintain records to keep track of the Points you earn from your purchases with our Merchant Partners. You can use the Site to view your uTANGO account, Point balances, LifeStage Rewards value accrual, and recent account activities, update your account profile and contact a member care representative.

Site utilization

We collect information regarding site utilization, surveys, member care contacts, link activity, and form usage. This helps us to determine how to best provide an efficient user experience, ensure proper tracking and resolution of resulting Points for click-throughs to Merchant sites, and to evaluate the effectiveness of uTANGO site features, ads, and messages.

Refer-A-Friend

If you choose to use our referral service to tell a friend about the Site and our services, we will ask you for your friend's name and e-mail address. We will automatically send your friend an e-mail inviting him or her to visit the Site. uTANGO generally uses this information for sending invitation and reminder e-mails (one per invitation) and for tracking the success of our referral program. Your friend may use the unsubscribe link included in the referral e-mail or contact uTANGO Member Care at http://www.utango.com/?id=/Help/ContactuTANGO/ to request that he or she be removed from future invitations.

Use of cookies and other technologies

Our web servers place and read "cookies" on the Site's visitors' computers for a variety of purposes. Cookies are small data files that are stored on an Internet user's computer by a web server. One important use of cookies is to help identify you while you are logged in to the Site. Consequently, if your browser does not accept session cookies, you will be unable to sign up for a membership or log in to use the Site. You will, however, be able to browse the Site as a visitor. The information uTANGO collects from cookies and web server logs is used to administer the Site and its services and to customize information you receive when visiting the Site. uTANGO may also use and share aggregated information from cookies and web server logs for various purposes, such as to analyze and improve our service offerings and to provide third parties with an understanding of the broad demographic makeup of our Site's user base. This aggregated information does not identify individual visitors or members.

As is true of most web sites, we gather certain information automatically and store it in log files. This information includes the internet protocol (IP) address, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We may use and share these types of non-personally identifiable information for various purposes. For example, we may use it to analyze trends, to administer the Site, to track users' movements around the Site and to gather demographic information about our user base as a whole.

We may employ cookies and/or small pieces of code known as "web beacons" or "clear gifs" that, on a de-personalized basis, count users that have visited a page that contains these web beacons. Similarly, third parties who host portions of our Site or assist us in sending communications may also use web beacons. We and these third parties each use web beacons to help us better manage content on our site, to determine which content is effective, to gauge the effectiveness of communications, to track transactions on the Site, and to otherwise administer our Site and our services. For example, we use these technologies to track transactions on the Site in order to make sure that our members receive proper credit for qualifying transactions.

We generally do not use information collected in log files, with cookies, Web beacons, or other technologies, or other information that we collect automatically in a manner that personally identifies individuals. We may, however, combine this information with personal information from time to time. For example, we may combine information in our log files with a member's registration data in order to prevent fraud or to verify that a transaction took place on our Site. As another example, if you have chosen to receive marketing messages from us, we may use personal information in combination with automatically-collected data tied to your user identifier (from, for example, our log files, cookies or web beacons) to help us make those communications more useful or interesting to you. If we combine the forms of automatically-collected information described in this section with personal information, we treat the combined information as "personal information" under this Privacy Statement.

We also contract with Coremetrics, a third-party service provider, which uses these technologies to assist us in tracking site usage. As a result of your accessing the Site, Coremetrics may on our behalf collect information about you. This service allows us to better provide our product or service to you. Coremetrics does not have the right to use the information it receives beyond what is necessary to assist us. For further information, including how to opt out, consult Coremetrics' privacy policies at: www.coremetrics.com/info_eluminate2.html.

How we use your information

We use personal information we collect in order to develop, offer and deliver our products and services, to process transactions in your accounts and to otherwise administer our Site and our services, to fulfill legal and regulatory requirements, to verify and enforce compliance with the policies governing the Site and our services, and to protect against misuse or unauthorized use of the Site and/or services.

Management of Your Account

When you become a member, we use your contact information and other personal information to manage your account. For example, we will send you a welcoming e-mail to verify your username and password, as well as monthly, quarterly, and annual account statements to help you keep track of your rewards. We will also communicate with you in response to your inquiries and to provide the services you request. These administrative and fulfillment communications will generally be limited to e-mail. You may not opt-out of these communications. If you do not wish to receive them, you have the option to deactivate your account by contacting uTANGO Member Care from a registered email address and confirming back to uTANGO that you want to close your account. You can always reach uTANGO Member Care through the Contact uTANGO link at the bottom of the Site or at http://www.utango.com/?id=/Help/ContactuTANGO/.

Use of Third Parties for Verification and Fulfillment Purposes

We may use third parties, including public sources, such as verification services and consumer reporting agencies (to comply with regulatory requirements), to ensure the accuracy of data and prevent fraud. We may also use certain third parties to provide marketing and administrative services, such as keeping track of your purchases, analyzing data or delivering special savings offers to you on our behalf or on behalf of our Merchant Partners. Third parties may also be used to help us administer our credit card, grocery, dining and hotel rewards programs. In order to enable these third parties to perform these services, we may need to share certain personally identifiable information about our members. However, these third parties will be bound by legal agreements to not use or disclose the information we provide them for any purpose other than to perform the requested service.

On occasion, contests, sweepstakes or surveys on the Site may be co-sponsored by uTANGO and another company, or may be sponsored by companies other than uTANGO. Some or all of the data collected through these contests, sweepstakes or surveys may be shared with the sponsor(s) or companies indicated on the entry form. If such data will be shared, then there will be a notice prior to the time of data collection or transfer. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to participate in them. To indicate your preference to opt-out of any surveys or contests you can email uTANGO Member Care through the Contact uTANGO link at the bottom of the site or at http://www.utango.com/?id=/Help/ContactuTANGO/.

Notification about Products and Services

We offer you the chance to maximize your daily spending through new promotional opportunities made available to you on the Site and, unless you opt out of receiving them, through email and postal mail. Additionally, if you provide us with your mobile phone number and opt in to receive text messages from us, we will send you promotional messages and offers by text messages (uTANGO 2-Go). We may use information about you to provide you highly targeted offers tailored to your specific interests. Sometimes, we send offers to selected groups of members that advertise products or services of our Merchant Partners. When we do this, we do not give the Merchant Partner your name or contact information. If you do not want to receive offers from us regarding products and services offered by Merchant Partners, you may opt out of receiving them through managing your Communication Preferences in My Account, which can be reached at http://www.utango.com/communicationpreferences.

Service-related Announcements

We will send you service-related announcements on rare occasions when it is appropriate to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an e-mail. You may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account by contacting uTANGO Member Care from a registered email address and confirming back to uTANGO that you want to close your account. You can always reach uTANGO Member Care through the Contact uTANGO link at the bottom of the site or at http://www.utango.com/?id=/Help/ContactuTANGO/.

Use of Information from Third Parties

We may obtain information, including personal information, about you from third-party sources. To the extent that we combine non-personally identifiable information with personal information that we maintain about you, we treat the combined information as "personal information" under this Privacy Statement.

As a particular example of our collection and use of personal information from third parties, we may collect personal information about you from our Merchant Partners and other third parties in order to provide you with savings opportunities tailored to your interests. You may opt out of receiving these offers by updating your account profile at any time on the Site. We may also use information collected from our Merchant Partners and other third parties in conjunction with member account and enrollment information for analytical and audit purposes.

Use of Non-Personally Identifiable Information

As discussed at the beginning of this Privacy Statement, we may collect and derive information from your use of, and interaction with, the Site that does not personally identify you as an individual. All non-personally identifiable data collected and derived by uTANGO in connection with the Site is owned exclusively by uTANGO and may be used by uTANGO as it deems appropriate. For example, we may provide aggregated, non-personally identifiable information about our members and their spending and purchasing habits to third parties for audit, marketing and other purposes. Because aggregated data is not associated with any particular person, these third parties will not have access to any personally identifiable information about you or your spouse.

With whom we share your information

We do not share your personal information with third parties except as described below, and except as permitted or required by law:

Merchant Partners, Agents and Service Providers

We do not rent or sell (except as set forth in the Business Transfers Section below) your personally identifiable information to third parties, but we may, in order to provide our products and services to you, share your information with Merchant Partners, agents and service providers to perform functions on our behalf, such as to send email and postal mail, analyze data, provide marketing services, process applications and credit card payments, and service accounts. These service providers have access to personal information needed to perform their functions, but may not use it for other purposes without your consent.

One example of this is our sharing of personal information with financial institutions that we partner with to jointly create and offer products and services. For example, we share personal information with World Financial Network National Bank to determine whether you should receive pre-approved offers for the uTANGO Visa credit card. These financial institutions may only use this information to market uTANGO-related products, unless you have given consent for other uses. In the event that you explicitly request to apply for the uTANGO Visa Card, you will be authorizing uTANGO to share your application information with the financial institution as well as for uTANGO and the financial institution to share personal information to determine your eligibility, provide the jointly-offered card, and manage and administer your account and any resulting Point awards from your activities. In accordance with federal law, financial institutions that provide products or services to you (including, for example, the financial institution which issues the uTANGO Visa credit card to you) will also provide you with information regarding the financial institution's privacy policy.

If we ever make the decision to share customer personal information with third parties so that they may market their products and services directly to you, we will notify you before any such sharing and you will be given an option to opt out of this sharing.

Protection of uTANGO and Others

We may disclose personal information about you to third parties when we believe such disclosure is appropriate to comply with a legal requirement, such as a law, regulation, court order, subpoena or search warrant, or in the course of a legal proceeding. We may also disclose personal information as we believe appropriate to enforce or apply our rights under our agreements with members and to protect the rights, property or safety of uTANGO, our members and others (including exchanging information for fraud protection and credit risk reduction).

Business Transfers

If there is a change of control in uTANGO's business (whether by merger, sale, or otherwise), its customer information could be sold as part of that transaction and your personally identifying information potentially could be used by the purchaser. You will be notified of a change in control in uTANGO's business via email or a prominent notice posted on the uTANGO site. However, if that business materially changes this Privacy Statement or the information-handling practices as described in this Privacy Statement, you will be notified through a notice posted on the Site.

How you can access and update your information

You may access and update information stored in your account profile by logging into the uTANGO site. Please keep your contact, account, and preference information up-to-date. Doing so helps ensure that your transactions are properly tracked and marketing commissions received. It also helps us inform you of new Merchant Partners and other opportunities to help you boost your Point accumulation. If you no longer desire our service, you may deactivate your account by emailing uTANGO Member Care via the Contact uTANGO link at the bottom of the site pages or at http://www.utango.com/?id=/Help/ContactuTANGO/. You may also contact Member Care via postal mail at the contact information listed below.

Your choices with respect to the collection and use of your information

Member Options Regarding the Receipt of Marketing Messages

We reserve the right to send you specific administrative notices that are required by law, regulation, or as needed to service your account. You may choose to receive messages from uTANGO regarding products and services offered by our Merchant Partners that may suit your interests based on your preferences, transaction history, and other information. If you do not wish to receive these messages, you may opt out of these messages by updating your Communication Preferences in My Account at any time on the Site. However, please know that receiving these messages may help you accumulate Points and qualify for Annual Anniversary Rewards and LifeStage Rewards more quickly and by choosing not to receive them it could make achieving uTANGO Rewards much harder.

Opting out of information sharing

If you prefer that we not share with our Merchant Partners consumer report information about you that we may receive from third parties, you may direct us not to do so by sending uTANGO Member Care an email containing your name, address, and clear instructions for this request. Please be aware that we may continue to share any other information as permitted by law. You can reach uTANGO Member Care via the Contact uTANGO link at the bottom of the site pages or at http://www.utango.com/?id=/Help/ContactuTANGO/.

TRUSTe Certification

Afiniti Ventures, Inc. (d/b/a uTANGO) is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to build the user's trust and confidence in the Internet by promoting the use of fair information practices. This privacy statement covers the web site www.utango.com. Because this web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

If you have questions or concerns regarding this statement, you should first contact uTANGO Member Care via the Contact uTANGO link at the bottom of the site pages or at http://www.utango.com/?id=/Help/ContactuTANGO/. If you do not receive acknowledgment of your inquiry, or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with uTANGO to resolve your concerns.

Security of your information

uTANGO is committed to earning and keeping your trust. We understand the need for our members' personal information to remain secure and private, and we have deployed reasonable security measures, including industry-recognized safeguards for the protection of your personal information, including: monitoring for intrusion attempts; SSL (Secure Socket Layer), data, and password encryption technology; firewalls and systems monitoring; and security audits and inspections. We only give authorized personnel access to customer information in our control.

Please remember that you also play a valuable part in data security. You should never share your uTANGO password with anyone. If you feel your password has been compromised, you should change it immediately. After you have finished using the Site, you should log out of your uTANGO account and exit your browser so that no unauthorized persons can use the Site under your name and account information.

Collection of information from children

None of the services on or available through the Site are intended for purchase by children. Accordingly, uTANGO does not knowingly collect, either online or offline, personally identifiable information from children under the age of 18.

Links to other sites and Merchant Partners' use of information

Through our various online offerings, we may provide links to third-party websites, such as those of our Merchant Partners. Each of these sites may have separate privacy and different data-collection practices from uTANGO, and we are not responsible for the actions or practices of these third parties, nor for the content on these sites. We encourage you to review the privacy policies of their sites. Finally, please remember that when you shop or do any other business with any of our Merchant Partners, any information you provide to them is subject to their own privacy and data collection practices, for which uTANGO is not responsible.

Changes to this Privacy Statement

If we materially change this Privacy Statement or our information-handling practices as described in this Privacy Statement, we will notify you by posting a notice on the Site and/or by email. Your continued use of the Site and any services will constitute your acceptance of updates to the Privacy Statement.

How you can contact uTANGO

If you have any questions about this Privacy Statement, our information-handling practices, or other aspects of privacy at uTANGO, please contact us by emailing uTANGO Member Care via the Contact uTANGO link at the bottom of the site pages or at http://www.utango.com/?id=/Help/ContactuTANGO/. You can reach us via postal mail at uTANGO Member Care - Privacy Policy Issues, 227 Bellevue Way NE, #701, Bellevue, WA 98004.