Privacy Policy – The Marketing Arm

The Marketing Arm Inc. ("The Marketing Arm") respects the privacy interests of individuals when using our website and our mobile services.  We have therefore established this Privacy Policy to clearly explain how we collect, use and disclose certain information.

This Privacy Policy applies to:

• "Website" - Our website located at www.themarketingarm.com; and

• "Mobile Marketing Services" - Our mobile marketing services provided on the Website and through third parties.

A.        PRIVACY ON THE WEBSITE

Personally Identifiable Information collected on the Website.  We will never collect Personally Identifiable Information directly from you on the Website unless you have voluntarily provided it to us.  When using the Website, you may choose to provide certain personally identifiable information about yourself, such as your name, email address, physical address and other information that specifically identifies you ("Personally Identifiable Information").

Non-Personally Identifiable Information collected on the Website.  In addition, we may also collect non-personally identifiable information on the Website which does not specifically identify you ("Non-Personally Identifiable Information"), such as IP host address, pages viewed and similar data.  Non-Personally Identifiable Information may be automatically collected by us from you without any separate notice other than this Privacy Policy, often times through cookies, as described below.

Cookies.  The Marketing Arm may use cookies, web beacons, clear gifs and similar technology to customize your visit to the Website, enable certain functions on the Website and collect Non-Personally Identifiable Information.  "Cookies" are pieces of information that may be placed on your device by a site or application for the purpose of facilitating and enhancing your communication and interaction with that site or application and collecting certain data.  Cookies may also be used to help store login or registration information to help you avoid having to re-type such information upon every use.

You may stop or restrict the placement of cookies on your device or flush them from your browser by adjusting your browser preferences, but this may interfere with some functionality of the site or application. Please see the help section or instruction manuals for your browser and device to do so.  We do not use cookies to automatically retrieve Personally Identifiable Information from you without your knowledge. 

Use of Personally Identifiable Information collected on the Website.  Except as described below, we do not share your Personally Identifiable Information with any third party.

• If you choose to send a text message through functionality on the Website, we will use your Personally Identifiable Information for that purpose, but will not otherwise use the Personally Identifiable Information you provided in connection with that specific message.
• The Marketing Arm may use your Personally Identifiable Information from time to time to send you newsletters and other information about The Marketing Arm. 
• The Marketing Arm may provide your Personally Identifiable Information to our contractors; however they are only permitted to use such information in connection with services they are performing on our behalf.
• The Marketing Arm may use your Personally Identifiable Information to respond to your questions or to provide you with a service that you have specifically requested. 
• The Marketing Arm may transfer your Personally Identifiable Information in connection with the sale, merger or reorganization, in whole or in part, of The Marketing Arm, its assets or the division responsible for the applicable services. 
• The Marketing Arm reserves the right to access and/or disclose any information we gather as required by courts or administrative agencies and to the extent required to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, the Website’s policies, or the rights of third parties or to investigate any suspected conduct which we deem improper. 

Use of Non-Personally Identifiable Information collected on the Website.  We may use and share Non-Personally Identifiable Information to improve and enhance your experience on the Website and for any other business activities.  For example, we may share Non-Personally Identifiable Information with unaffiliated third parties, such as business partners. 

B.        PRIVACY THROUGH THE MOBILE SERVICES

Through the performance of the Mobile Marketing Services, The Marketing Arm may engage in SMS/text campaigns and other mobile promotions on behalf of our advertising clients (each a "The Marketing Arm Client").  We are therefore acting as a service provider to The Marketing Arm Clients.

Collection and Use of Personally Identifiable Information through the Mobile Marketing Services.  Personally Identifiable Information is only collected through the Mobile Marketing Services when you affirmatively elect to provide such information in connection with a campaign for a The Marketing Arm Client.  For instance, we may encourage you to send a text message to a short code to join a promotion.  We only collect such information for the benefit of The Marketing Arm Client and will pass it on to The Marketing Arm Client.  You should review The Marketing Arm Client’s posted privacy policy to understand how they will use the information.  We will not permanently store or use such information for our own benefit.

However, we may access and/or disclose such information as required by courts or administrative agencies and to the extent required to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, The Marketing Arm Client’s policies, or the rights of third parties or to investigate any suspected conduct which we deem improper.

Collection and Use of Non-Personally Identifiable Information through the Mobile Marketing Services.  When you interact with our Mobile Marketing Services, we may collect Non-Personally Identifiable Information such as the time spent viewing an ad, the number of messages you have sent or received and other information about your interaction with the campaign.

We may also place cookies on your device, to the extent possible, to collect Non-Personally Identifiable Information.  You may remove cookies from your device by following the process described above in the section entitled "Cookies."

We use such Non-Personally Identifiable Information to provide reports to our The Marketing Arm Clients and to share such information for any other business reason. 

C.        GENERAL PRIVACY PRACTICES

Security Practices.  We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect.  However, due to the inherent open nature of the mobile web and our lack of control over wireless carriers, we cannot guarantee that all information will be completely free from unauthorized access by third parties.  Your use of the Website and Mobile Marketing Services demonstrates your assumption of this risk. 

No Children under age 13.  We have no intention of collecting Personally Identifiable Information from children under the age of 13.  When we become aware that Personally Identifiable Information from a child under 13 has been collected without such child’s parent or guardian’s consent, we will use all reasonable efforts to delete such information from our database. 

Changes to policy; Opt-Out Process.  We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time.  However, if at any time in the future we plan to use Personally Identifiable Information in a way that differs from this policy, we will post such changes here and provide you the opportunity to opt-out of such differing uses.  Your continued use of the Website and Mobile Marketing Services following the posting of any changes to this policy means you accept such changes. 

We give you the option to remove your Personally Identifiable Information from our list of active users completely. All unsubscribe or opt-out requests should be sent to us at privacy@themarketingarm.com and we will process your request within a reasonable time after receipt.  However, we are not responsible for removing your Personally Identifiable Information from the lists of any third party (such as a The Marketing Arm Client) who has previously been provided with your information in accordance with this policy.

Contact.  For questions or concerns relating to privacy, we can be contacted at:

The Marketing Arm
Attn: Website Management
1999 Bryan St., Ste. 1800
Dallas, Texas 75201
privacy@themarketingarm.com  

Effective Date.  This Privacy Policy was last updated on July 25, 2011.