By visiting our website, using our online products/services, and/or by voluntarily submitting information to us via online forms, advertisement responses, and/or electronic mail, you are accepting the practices described in this Privacy Statement.
Who We Are
MLMpublicity has developed and licenses an online website system called GelFreedom.com which allows distributors of Agel to promote the company, product and opportunity. The GelFreedom.com System is used exclusively to promote the products and Services offered by Agel.
MLMpublicity operates and manages the GelFreedom.com System to assist distributors of Agel in the building of their business via the Internet and Email marketing. Individuals that subscribe to the GelFreedom.com System are known as "Members" and pay a monthly subscription fee for use of the system.
To cater to both you (the Customer) and our Members, we may be required to collect, use, and share certain information. The type of information we collect, together with a description of how we use and/or share it, is described below.
Information Collection and Use
MLMpublicity is the sole owner of the information collected from the Member for use of the GelFreedom.com System. GelFreedom.com collects information from our on several pages throughout our website.
A Members is required to register in order to use the GelFreedom.com System. During registration the Member is required to give contact information (such as name and email address). We use this information to contact the Member about services on our site for which he has expressed interest and to track his account in the system.
We request information from the Member on our order form when registering a new account. A Member must provide contact information (such as name, email, and shipping address) and financial information (such as credit card number, expiration date). This information is used for billing purposes. In addition, this information may be given to the network marketing company for the purpose of tracking and measuring success of the system. If we have trouble processing a payment, the information is used to contact the Member.
We will use personal information that we gather about you to provide the services that you have requested. In addition, we will use the information you have supplied to encourage you to buy the products and services offered by our company.
We store information that we collect through cookies, log files, clear gifs, and/or third parties to create a profile of our users. A profile is stored information that we keep on individual users that details their viewing preferences. Consequently, collected information is tied to the users personally identifiable information to provide offers and improve the content of the site for the user. This profile is used to tailor a user’s visit to our Web site, and to direct pertinent marketing promotions to them. We do share your profile with other third parties. Your profile is shared together with your personally identifiable information. YOUR PAYMENT INFORMATION, SOCIAL SECURITY OR EIN NUMBER IS NEVER SHARED FOR ANY REASON WITH ANY OUTSIDE THIRD PARTY UNLESS REQUIRED BY LAW, EXCEPT FOR THE PURPOSE OF ENROLLMENT IN OUR MLM OPPORTUNITES.
A cookie is a piece of data stored on the user’s computer tied to information about the user. We use both session ID cookies and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the user’s hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions.
By setting a cookie on our site, users would not have to log in a password more than once, thereby saving time while on our site. If users reject the cookie, they may still use our site. The only drawback to this is that the user will be limited in some areas of our site. Persistent cookies enable us to track and target the interests of our users to enhance the experience on our site. See the “Profile” section.
However, we have no access to or control over these cookies, once we have given
permission for them to set cookies for advertising.
Like most standard Web site servers we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information. IP addresses are tied to personally identifiable information to enable our Web-based service.
Clear Gifs (Web Beacons/Web Bugs)
We employ [or our third party advertising company employs] a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. Clear gifs are tied to users’ personally identifiable information.
Clear Gifs can "work with" existing cookies on a computer if they
are both from the same Web site or advertising company. That means, for example,
that if a person visited “www.companyX.com”, which uses an advertising
company's clear gif, the Web site or advertising company would match the clear
gif's identifier and the advertising company's cookie ID number, to show the
past online behavior for that computer. This collected information would then
be given to the advertising company or Web site.
In addition, we use clear gifs in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, please see the Opt-out section.
Communications from the Site
Special Offers and Updates
We send all new members a welcoming email to verify password and username. Established members will occasionally receive information on products, services, special deals, and a newsletter.
If a user wishes to subscribe to our newsletter, we ask for contact information such as name and email address.
On rare occasions it is necessary to send out a strictly service related announcement. For instance, if our service is temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.
We communicate with users on a regular basis to provide requested services and in regards to issues relating to their account we reply via email or phone, in accordance with the users wishes.
Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our Web site.
Aggregate Information (non-personally identifiable)
We share aggregated demographic information with our partners and advertisers. This is not linked to any personally identifiable information.
Third Party AdvertisersParties:
We use the information you have voluntarily provided to cause information, offers, products, and/or services that appear to us to be consistent with your expressed interests to be directed to you. This is typically accomplished by using your information to direct to you information, offers, products, and/or services from us and/or one of our affiliated companies. Your information may, therefore, ultimately be used for marketing purposes by us, our affiliated companies, and/or any one or more the associated businesses with which we work.
We cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Statement. For example, we may be forced to disclose information to the government or third parties under certain circumstances, or third parties may unlawfully intercept or access transmissions or private communications. We can (and you authorize us to) disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate.
After we share your information with our affiliated companies and/or any of
the several businesses with which we work, we lose control over how they will
use, collect, and/or disseminate your information. Accordingly, we recommend
that you review the Privacy Statements of the corresponding affiliated companies
with whom we have shared your information in order to acquaint yourself with
their information collection, use, and/or sharing policies.
You understand and agree that MLMpublicity is not responsible for the privacy practices or the content of these other websites, and you agree that MLMpublicity is not responsible for how such information is ultimately used.
These are the instances in which we will share users’ personal information:
We Share Personal Contact Information with third parties. If you want to ensure that your information is never shared with any third party, you must request to be unsubscribed or cancelled from our service. Failure to unsubscribe or cancel your service will imply that you are interested in having your personal information shared with various third parties.
Third Party Intermediaries
We use an outside shipping company to ship orders, and a credit card processing company to bill users for goods and services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes.
We partner with other third parties to provide specific services. When the user signs up for these particular services, we share names, or other contact information that is necessary for the third party to provide these services. These third parties are not allowed to use personally identifiable information except for the purpose of providing these services and for purposes referenced in their privacy policies.
In the event GelFreedom.com goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, users’ personal information will, in most instances, be part of the assets transferred. Users will be notified via email prior to a change of ownership or control of their personal information. If as a result of the business transition, the users’ personally identifiable information will be used in a manner different from that stated at the time of collection they will be given choice consistent with our notification of changes section.
Our users are given the opportunity to ‘opt-out’ of having their information used for purposes not directly related to our site only by completely opting-out of our service and/or canceling a paid subscription to our service.
Users who no longer wish to receive our newsletter and promotional communications may opt-out of receiving these communications by following the unsubscribe instructions sent with every email.
This Web site contains links to other sites. Please be aware that we, GelFreedom.com, are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information. This privacy statement applies solely to information collected by this Web site.
This Web site takes every precaution to protect our users’ information. When users submit sensitive information via the Web site, their information is protected both online and off-line.
When our registration/order form asks users to enter sensitive information (such as credit card number and/or social security number), that information is encrypted and is protected with the best encryption software in the industry - SSL. While on a secure page, such as our order form, the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just ‘surfing’.
While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user-information off-line. All of our users’ information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to personally identifiable information. Our employees must use password-protected screen-savers when they leave their desk. When they return, they must re-enter their password to re-gain access to user information. Furthermore, ALL employees are kept up-to-date on our security and privacy practices. Every [quarter], as well as any time new policies are added, our employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure our users’ information is protected. Finally, the servers that store personally identifiable information are in a secure environment, in a secure facility.
If users have any questions about the security at our Web site, users can send
an email to support@GelFreedom.com.
Supplementation of Information
In order for this Web site to properly fulfill its obligation to users it is necessary for us to supplement the information we receive with information from 3rd party sources.
Enhancement of Marketing Profile
We purchase third party marketing data and add it to our existing user database to better target our advertising and provide pertinent offers we think our users would be interested in. We use this information to enhance or overlay the ‘profile’ of individual users. This aggregate marketing data is therefore tied to the users’ personally identifiable information. See also the “Profile.”
Correcting/Updating/Deleting/Deactivating Personal Information
If a user’s personally identifiable information changes (such as zip code, phone, email or postal address), or if a user no longer desires our service, we provide a way to correct, update or delete/deactivate users’ personally identifiable information. This can be done in the Member Back Office.
Notification of Changes
If, however, we are going to use users’ personally identifiable information
in a manner different from that stated at the time of collection we will notify
users via email. Users will have a choice as to whether or not we use their
information in this different manner. However, if users have opted out of all
communication with the site, or deleted/deactivated their account, then they
will not be contacted, nor will their personal information be used in this new
manner. In addition, if we make any material changes in our privacy practices
that do not affect user information already stored in our database, we will
post a prominent notice on our Web site notifying users of the change. In some
cases where we post a notice we will also email users, who have opted to receive
communications from us, notifying them of the changes in our privacy practices.