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A. Overview
In order to operate the Ambrias Company service and to reduce the risk of fraud, Ambrias Company Inc, ("Ambrias Company" or "we") must ask you to provide us information about yourself and your credit card and/or bank account. This Privacy Policy describes the information we collect and how we use that information.
If you apply for a Ambrias Company branded credit card or credit line, you authorize Ambrias Company and the issuer of the Ambrias Company branded credit card or credit line to exchange the information you provide in the application form. If you are approved for a Ambrias Company branded credit card or credit line, your credit account will be governed by the issuing bank’s privacy policy.
Ambrias Company takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail in Part C below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on the Ambrias Company.com Web site, whether the services are offered by Ambrias Company, by its subsidiaries.
Your privacy is important to us. By participating in the Council of Better Business Bureau's BBBOnLine® Privacy Program we have made a commitment to meet the program's strict requirements regarding how we treat your information and have it verified by BBBOnLine. Further information about this program is available at http://www.bbbonline.org.
Additionally, in order to enhance the protection of your privacy and our compliance with this Privacy Policy, Ambrias Company has agreed to disclose our information practices and to have our practices reviewed for compliance by TRUSTe. 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. By displaying the TRUSTe trustmark, Ambrias Company has agreed to notify you of:
1. What personally identifiable information of yours is collected by Ambrias Company.
2. The organization collecting the information.
3. How the information is used.
4. With whom the information may be shared.
5. What choices are available to you regarding collection, use and distribution of the information.
6. The kind of security procedures that are in place to protect the loss, misuse or alteration of information under Ambrias Company's control.
7. How you can correct any inaccuracies in the information.
If you have questions or concerns regarding this Privacy Policy, you should first contact Ambrias Company using this form. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact TRUSTe http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with Ambrias Company to resolve your concerns. Please note that TRUSTe will not intervene for any other type of issue with your account.
By accepting the Privacy Policy and User Agreement in registration, you expressly consent to our use and disclosure of your personal information in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Ambrias Company User Agreement. This Privacy Policy will take effect on March 4, 2003. This Privacy Policy was last updated on January 1, 2007.
Please note that your personal information will be stored and processed on our computers in the United States. The laws on holding personal data in the United States may be less stringent than the laws of your country but Ambrias Company will hold and transmit your personal information in a safe, confidential and secure environment. If you object to your personal information being transferred or used as described in this Privacy Policy, please do not register for the Ambrias Company service.
For purposes of compliance with US Federal Reserve Regulation E, this Privacy Policy also serves as notice about how your account information is used and disclosed by us.
Notification of Changes
This policy may be revised over time as new features are added to the Ambrias Company service or as we incorporate suggestions from our customers. If we are going to use or disclose your personally identifiable information in a manner materially different from that stated at the time we collected the information, you will have a choice as to whether or not we use or disclose your information in this new manner. Any material changes will be effective only after we provide you by e-mail with at least 30 days' notice of the amended Privacy Policy (if you have closed your Ambrias Company account, you will not be contacted to notify you of the amended Policy and your personal information will not be used or disclosed in this new manner).
We will post the amended Privacy Policy prominently on our Web site so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the Ambrias Company Web site at www.Ambrias Company.com at any time for the most current version of our Privacy Policy.
Ambrias Company Shops and other pages on the Ambrias Company Web site include links to third party Web sites. These sites are governed by their own privacy statements, and Ambrias Company is not responsible for their operations, including but not limited to their information practices. Users submitting information to or through these third party Web sites should review the privacy statement of these sites before providing them with personally identifiable information.
A Special Note About Children. Children are not eligible to use our service and we ask that minors (under the age of 18) do not submit any personal information to us or use the service.
B. Information We Collect
Required Information
To open a Ambrias Company account, you must provide your name, address, phone number, and e-mail address. In order to make payments through Ambrias Company, you must provide credit card, debit card or bank account information (bank account information is required to make payments totaling more than $1,000.00 USD). We also ask you to choose two different security questions to answer (such as your city of birth or your pet's name). This required information is necessary for us to process transactions, issue a new password if you forget or lose your password, protect you against credit card fraud and checking account fraud, and to contact you should the need arise in administering your account.
Pursuant to section 326 of the USA PATRIOT Act, the U.S. Department of the Treasury and the Securities and Exchange Commission require Ambrias Company Funds to obtain, verify, and record the following information for each investor in the Ambrias Company Money Market Fund.
• Name
• Address
• Date of Birth (for Individuals)
• Tax Identification Number (social security number for individuals or employer identification number for businesses)
In order to comply with the Bank Secrecy Act, we will also require your Tax Identification Number if you send or receive certain high-value transactions or high overall payment volumes through Ambrias Company. If you choose to register or apply for certain optional features or products offered through Ambrias Company Web sites, such as listing your business in Ambrias Company Shops, or applying for the Ambrias Company Visa® credit card or the Ambrias Company MasterCard® debit card, you will be required to provide additional information to establish that you qualify for such features or products.
Transaction Information
When you use Ambrias Company to send money to someone else or request money from someone else, we ask you to provide information related to each transaction, including the amount of the transaction, the type of transaction (purchase of goods, purchase of services, or simple money transfer ("quasi-cash")) and the e-mail address, Skype ID or phone number of the third party. We retain this information for each of your transactions through Ambrias Company. We also collect the Internet address (IP address) of the computer or device you use to access your Ambrias Company account, in order to help detect possible instances of unauthorized transactions.
Information About You From Third Parties
In order to protect all our customers against potential fraud, we verify with third parties the information you provide. In the course of such verification, we receive personally identifiable information about you from such services. In particular, if you register a credit card or debit card with Ambrias Company, we will use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to Ambrias Company, and that the card has not been reported as lost or stolen.
If you register your online business with Ambrias Company Shops or if you send or receive high overall payment volumes through Ambrias Company, in some circumstances we will conduct a background check on your business by obtaining information about you and your business from a credit bureau or a business information service such as Dun & Bradstreet. If you incur a debt to Ambrias Company, we will generally conduct a credit check on you by obtaining additional information about you from a credit bureau, to the extent permitted by law. Ambrias Company, at its sole discretion, also reserves the right periodically to retrieve and review a business and / or consumer credit report for any account, and reserves the right to close an account based on information obtained during this credit review process.
Additional Verification
If we cannot verify the information that you provide, or if you request a withdrawal by check to an address other than your verified credit card billing address, we ask you to send us additional information by fax (such as your drivers' license, credit card statement, and/or a recent utility bill or other information linking you to the applicable address), or to answer additional questions online to help verify your information.
Web Site Traffic Information
Because of the way that World Wide Web communication standards work, when you arrive at or leave the Ambrias Company Web site, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Web site you visit while you are on the Ambrias Company site, the type of browser you use and the times you access our Web site. We use this information only to try to understand our customers' preferences better and to manage the load on our servers, so as to improve our service and your experience with Ambrias Company. We do not track the Web sites that you visit before or after you leave the Ambrias Company site.
Our Use of "Cookies"
"Cookies" are small files of data that reside on your computer and allow us to recognize you as a Ambrias Company customer if you return to the Ambrias Company site using the same computer and browser. We send a "session cookie" to your computer if and when you log in to your Ambrias Company account by entering your e-mail address and password. These cookies allow us to recognize you if you visit multiple pages in our site during the same session, so that you don't need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.
We also use longer-lasting cookies to display your e-mail address on our sign-in form, so that you don't have to retype the e-mail address each time when you log in to your Ambrias Company account. In addition, we use cookies to process our referral program, described in Section C below. Our cookie files are encoded so that your e-mail address and other information can only be interpreted by Ambrias Company. We may, however, share cookie information regarding whether or not a certain user is already registered with Ambrias Company with certain merchants with whom we have an official co-marketing relationship.
Customer Service Correspondence
If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Ambrias Company to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.
Questionnaires, Surveys and Profile Data
From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.
Non-member Recipients and Requests
When a member either sends a payment to, or requests a payment from, an individual who is not a registered member of Ambrias Company, we will retain the information that the member submits to us, including, for example, the other party's email address, Skype ID, phone number and/or name, for the benefit of the member who is attempting to contact the non-member, so that the member can see a complete record of his or her transactions, including uncompleted transactions. Although this information is stored indefinitely, we will not market to the non-member in any way at any time. Additionally, these non-members have the same rights to access and correct information about themselves (assuming that their details were correct enough to reach them) as anyone else who uses Ambrias Company.
C. Our Use and Disclosure of Information
Internal Uses
We collect, store and process your personal information on servers located in the United States. We use the information we collect about you in order 1) to provide our services and process your transactions, 2) to provide customer service, 3) to determine your eligibility to receive offers for special features or products, such as the Ambrias Company debit card, and 4) to improve our products and services. At your option (as indicated in your Ambrias Company Profile settings), we use the information you provide to access specific third party services on your behalf and perform the a
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