SWAPALEASE INC.
PRIVACY STATEMENT
LAST UPDATED: 01/31/2007 |
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Swapalease Inc. is a licensee of the TRUSTe Privacy
Program. This privacy statement discloses the privacy practices
for www.swapalease.com of Swapalease Inc.'s Website. |
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TRUSTe is an
independent, non-profit organization whose mission is to build users'
trust and confidence in the Internet by promoting the use of fair
information practices. 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. By displaying the TRUSTe trustmark, this web site has agreed
to notify you of:
- What personally identifiable information of
yours or third party personally identifiable information is collected
from you through the web site
- The organization collecting the information
- How the information is used
- With whom the information may be shared
- What choices are available to you regarding
collection, use and distribution of the information
- The kind of security procedures that are in
place to protect the loss, misuse or alteration of information under
Swapalease Inc. control
- How you can correct any inaccuracies in the information.
If you feel
that this company is not abiding by its posted privacy policy, you
should first contact Scot Hall, of the Swapalease Client
Services Department by emailing Mr. Hall at shall@swapalease.com.
If you do not receive acknowledgment of your inquiry or your inquiry
has not been satisfactorily addressed, you should then contact TRUSTe
at http://www.truste.org/consumers/watchdog_complaint.php.
TRUSTe will then serve as a liaison with the Web site to resolve
your concerns.
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Information
Collection and Use
Swapalease Inc. is the sole owner of the information collected
on this site. We will not sell, share, or rent this information
to others in ways different from what is disclosed in this statement.
Swapalease Inc. collects information from our users at several different
points on our website.
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Registration
General Perspective:
It is not necessary for a user to register in order to browse the
Swapalease Inc. Web Site; however, it is recommended so that the
staff at Swapalease Inc. can keep users posted of new listings and
special events. It will also allow personalization of the web site
when the user returns in the future.
Lease
"Seller's" Perspective:
In order to list a leased vehicle on this website, a user must first
complete the required listing sections. During registration a user
is required to provide sensitive information (such as social security
number and credit card number including expiration date), in addition
to contact information (such as name and email address), and demographic
information (such as zip code). This information is principally
used for verification of lease account information from a particular
leasing company and the collection of any listing fee due Swapalease
Inc.. Secondarily, this data is used for contacting the user as
well as making the sight more personalized for a particular user.
Lease
"Buyer's" Perspective:
We request information from the user on our credit statement form.
Here a user must provide sensitive information (such as social security
number and credit card number including expiration date), in addition
to contact information (such as name and email address), and demographic
information (such as income and age level). This information is primarily
used for credit assessment purposes and collection of processing fees specifically
pertaining to the lease transfer process. Creditors receiving this information will
retain the user's application whether or not it is approved and will handle this
information in accordance with their privacy policy. Secondarily, this data is used for
contacting the user as well as making the site more personalized for a
particular user.
Regardless,
of your perspective when using the Swapalease Inc. web site you
have probably noticed that blue question marks exist on many of
the data entry pages. These icons linked with help pages are provided
to explain why certain sensitive information is requested and necessary
to complete Swapalease, Inc. transactions.
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Cookies
A cookie is a piece of data stored on the user's hard drive
containing information about the user. Usage of a cookie is in no
way linked to any personally identifiable information while on our
site. Swapalease uses cookies to enhance the users experience on
the site and to track user behavior while visiting the site.
If a user rejects
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.
Some of our
business partners use cookies on our site (for example, advertisers).
However, we have no access to or control over these cookies.
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Log
Files
We use IP addresses to analyze trends, administer the site,
track user's movement, and gather broad demographic information
for aggregate use. IP addresses are not linked to personally identifiable
information. We do collect log files pertaining to domain names,
access times, pages visited, and browser type. These files are not
linked to personally identifiable information and are only used
for the sole purpose of site management.
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Sharing
We will share aggregated demographic information with our partners
and advertisers. This is not linked to any personal information
that can identify any individual person.
We use an outside credit card processing company to
bill users for services. This company does not retain,
share, store or use personally identifiable information
for any secondary purposes.
For users completing the "Publisher Application",
a 3rd party, Commission Junction Inc. is collecting
user data and storing this information outside of the
Swapalease website.
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Links
This web site contains links to other sites. Please be aware
that Swapalease Inc. is 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.
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Contests
From time-to-time our site requests information
from users via surveys or contests. Participation in
these surveys or contests is completely voluntary and
the user therefore has a choice whether or not to disclose
this information. Information requested may include
contact information (such as name and shipping address),
and demographic information (such as zip code, age level).
Contact information will be used to notify the winners
and award prizes. Survey information will be used for
purposes of monitoring or improving the use and satisfaction
of this site. If these surveys or contests are administered
by a 3rd party, the information you provide will be
given to the 3rd party. This information will not be
used for marketing or contacting you outside of the
Swapalease system by any 3rd parties. You may contact
Swapalease at 1-866-SWAPNOW (1-866-792-7669) if you
do not wish to have your information given to 3rd parties.
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Security
This website takes every precaution to protect our users' information.
When users submit sensitive information via the website, your information
is protected both online and off-line.
When our registration
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 unlocked,
or open, when you are just 'surfing'. To learn more about SSL, follow
this link www.verisign.com.
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 reenter their password to regain access
to your 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 customers' information is protected. Finally,
the servers that we store personally identifiable information on
are kept in a secure environment, behind a locked cage.
If you have
any questions about the security at our website, you can send an
email to security@swapalease.com.
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Supplementation
of Information
In order for this website to properly fulfill its obligation
to our customers, it may be necessary for us to supplement the information
we receive with information from 3rd party sources.
For example,
to determine if our customers qualify (meet generally accepted leasing
company credit standards) for lease transfers it may be necessary
for us to use their name and social security number to request a
credit report. Once we determine a user's creditworthiness, this
document is handled in a matter consistent with Fair Credit Reporting
Act guidelines.
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Special
Offers
We send all new members a welcoming email to verify password
and username. Established members will occasionally receive information
on products, services, and special deals. Out of respect for the
privacy of our users we present the option to not receive these
types of communications. Please see our choice and opt-out below.
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Site
and Service Updates
We also send the user site and service announcement updates.
Members are not able to un-subscribe from service announcements,
which contain important information about the service. We communicate
with the user to provide requested services and in regards to issues
relating to their account via email or phone.
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Correction/Updating
Personal Information
If a user's personally identifiable information changes (such
as your zip code), or if a user no longer desires our service, we
will endeavor to provide a way to correct, update or remove that
user's personal data provided to us. One way this can be accomplished
is at the "Managing Your Account" page after member log in. Other
avenues include emailing, phoning, or standard mailing our customer
support site (see "Contact Us" page for detailed information).
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Choice/Opt-out
Our users are notified of having their
information used for purposes not directly related to our site at
the point where we ask for the information. Users who no longer
wish to receive our memorandums or promotional materials from our
partners may opt-out of receiving these communications by replying
to unsubscribe in the subject line in the email or email us at support@swapalease.com.
Users of our
site are always notified when their information is being collected
by any outside parties. We do this so our users can make an informed
choice as to whether they should proceed with services that require
an outside party, or not.
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Tell-A-Friend
If you choose to use our referral service to tell
a friend about our site, we will ask you for your friend’s name and
email address. We will automatically send your friend a one-time
email inviting him or her to visit the site. Swapalease Inc. stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.
Your friend may contact us at support@swapalease.com to request that we remove this information from our database.
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Swapalease Inc. Blog
If you use the Swapalease Inc. Blog on this Web site, you should
be aware than any personally identifiable information you
submit there can be read, collected, or used by other users of
these forums, and could be used to send you unsolicited messages.
We are not responsible for the personally identifiable information
you choose to submit in these forums.
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Notification
of Changes
If we decide to change our privacy policy, we will
post those changes on our Homepage 30 days prior to
making the changes so our users are always aware of
what information we collect, how we use it, and under
circumstances, if any, we disclose it. If at any point
we decide to use personally identifiable information
in a manner different from that stated at the time it
was collected, we notify users by way of an email. Users
will have a choice as to whether or not we use their
information in this different manner. We will use information
in accordance with the privacy policy under which the
information was collected.
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Legal Disclaimer
Though we make every effort to preserve your 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.
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Contact Information
If you have any questions or suggestions regarding our privacy policy, please contact us at:
Phone: 1-866-SWAPNOW (1-866-792-7669)
Fax: (513) 381-1091
Email: support@swapalease.com
Postal Address: 9090 Colerain Ave
Cincinnati, Ohio 45251
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