National Platinum Shopping

Effective Date: November 17, 2010

OUR PLEDGE TO YOU

Because Your Trust Is So Important
Because Your Trust Is So Important One of our top priorities at NATIONAL PLATINUM™ is ensuring that the personal information we store is protected and secure. We value our relationship with you and work hard to preserve your privacy and ensure that your preferences are honored. At the same time, the very nature of our relationship may result in us collecting and/or sharing certain types of information. Therefore, we are providing you with this NATIONAL PLATINUM™ Privacy Policy ("Privacy Policy") because we are committed to respecting the individual privacy of our customers. In accordance with applicable federal and state laws, rules and regulations, we make this Privacy Policy available to you to inform you of how we may collect and use your personal information. This Privacy Policy also advises you of your right, under certain circumstances, to keep your personal information from being shared with third parties that we do business with or other non-affiliated third parties.

For purposes of compliance with the California Financial Privacy Act, the Vermont Consumer Protection Act, 8 V.S.A. 10202 and North Dakota Century Code §§ 6.08.1-01 to 6-08.1-08, if you are a resident of the State of California, North Dakota or Vermont and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please Click Here. Please be advised that where California, North Dakota or Vermont residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with the law.

As our customer, we endeavor to supply our service to you in a prompt and efficient manner, provide you with the best customer service and inform you of selected opportunities that may be of interest to you. In order to accomplish these goals, we reserve the right to share the personal information that we collect, but only as described herein below. You have the right to know how your personal information is collected, used and protected. Most of your personal data remains with NATIONAL PLATINUM™ and is used to administer your account and effectuate your purchase choices. Some data is shared with third parties to process your account and/or for marketing purposes. We explain how we collect, use and share your personal information in this Privacy Policy.

Personal Information We Collect

The personal information that we collect about you comes from the following sources:

Information that we receive from you, such as information on your account application or other forms, which may include, without limitation, your: (a) full name; (b) mailing address; (c) e-mail address; (d) telephone number; (e) driver’s license number; (f) credit card number and associated information; (g) bank account number and associated information; and (h) Social Security Number; and (i) any other information requested on the applicable application form. For purposes of this Privacy Policy, items (e) through (h) in the preceding sentence shall be considered “Sensitive Information.”
Information associated with the transactions that you enter into with us, our affiliates or other third parties, such as your payment history, payment method and account usage.
Other demographic information obtained about you provided by third parties to make sure that the data that you provide is both accurate and up-to-date.

Use of Personal Information

Any personal information that you supply to us remains your property. However, by submitting that information to NATIONAL PLATINUM™, you grant to us the right to use your personal information for (other than your Sensitive Information) any legal purpose including, without limitation: (a) marketing purposes such as sharing your information with third party advertisers; (b) providing promotional offers to you by means of e-mail advertising, telemarketing, direct mail marketing, mobile marketing (where and to the extent permitted by applicable law) and/or online banner advertising; (c) transferring your personal information (including your Sensitive Information, where required) to a third party, when necessary, to receive a product or service that you may have ordered from such third party while using the NATIONAL PLATINUM™ Website (the “Website”) or when responding to offers provided by NATIONAL PLATINUM™; (d) tracking compliance with our NATIONAL PLATINUM™ Terms and Conditions (“Terms and Conditions”); and (e) for validation, suppression, content improvement and feedback purposes. In addition, you agree that we may contact you with updates and/or any other information that we may deem appropriate for you to receive in connection with your account and the Website.

By submitting your e-mail address at the Website, you agree to receive e-mail marketing from NATIONAL PLATINUM™ and our third party advertisers. We may maintain separate e-mail lists for different purposes. If you wish to end your e-mail subscription to a particular list, you must follow the instructions contained in any e-mail correspondence that you receive from NATIONAL PLATINUM™ or a third party advertiser, in order to unsubscribe from a particular list. We only send e-mail marketing to individuals that have agreed to receive e-mail from NATIONAL PLATINUM™ and to individuals that have otherwise agreed, on third party websites, to receive e-mail marketing from other companies, such as NATIONAL PLATINUM™. NATIONAL PLATINUM™ does not send unsolicited commercial e-mail. As a result, certain statutes requiring particular formatting for unsolicited commercial e-mail may not be applicable to the commercial e-mail that is sent by NATIONAL PLATINUM™. Notwithstanding the foregoing, we will not send you any e-mail marketing, or allow any third party to send you e-mail marketing, from which you cannot unsubscribe.

You agree that by submitting your e-mail address at the Website, such act constitutes a purchase, an inquiry and/or an application for purposes of the Amended Telemarketing Sales Rule, 16 CFR 310 et seq. (the "ATSR"). Notwithstanding that your telephone number may be listed on the Federal Trade Commission's Do-Not-Call List, NATIONAL PLATINUM™ retains the right to contact you via telemarketing in accordance with the ATSR. Moreover, by registering with, or requesting information from, a third party advertiser at or through the Website, such action shall constitute a purchase, an inquiry and/or an application with the respective third party advertiser for purposes of the ATSR and you may be contacted via e-mail, direct mail and/or telemarketing by such third party advertiser in accordance with the ATSR.

In addition, you agree that by submitting your personal information at the Website, you agree to receive mobile marketing including, but not limited to, text-message based marketing, from us and our third party advertisers and marketers (where, and to the extent that, such marketing is permitted by applicable law). As such, notwithstanding that your mobile telephone number may be listed on state and/or federal Do-Not-Call registries, we retain the right to contact you via text-message based marketing in accordance with applicable state and federal law. Further, you agree that we reserve the right to share, sell, rent, lease and/or otherwise distribute your mobile telephone and other mobile data with/to any third-party for any and all non-marketing uses permitted by this Privacy Policy and applicable law.

NATIONAL PLATINUM™ reserves the right to release current or past user information: (i) in the event that we believe that the Website is being or has been used in violation of our Terms and Conditions or to commit unlawful acts; (ii) if the information is subpoenaed or requested pursuant to a judicial proceeding or legal investigation, provided, however, that (where permitted), NATIONAL PLATINUM™ shall provide you with e-mail notice, and the opportunity to challenge the subpoena, prior to disclosure of your information pursuant to a subpoena; (iii) if NATIONAL PLATINUM™ is sold or acquired; or (iv) when we deem it necessary or appropriate including, without limitation, sharing your e-mail address with other third parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time, and Federal Trade Commission implementing regulations.

Aggregate Information

NATIONAL PLATINUM™ reserves the right to transfer and/or sell aggregate or group data about our customers for lawful purposes. Aggregate or group data is data that describes the demographics, usage and/or other characteristics of our customers as a group without disclosing personally identifiable information. By submitting your personal information to, and/or using, the Website, you agree to allow NATIONAL PLATINUM™ to transfer and/or sell such aggregate data to third parties.

Cookies

NATIONAL PLATINUM™ uses a feature of your Internet browser called a "cookie" to assign a unique identification to your particular computer used to access the Website. Cookies can be used to help save and retrieve passwords used on the Website, to save information on past activities and other preferences. Through use of cookie technology, you do not have to reenter information upon every visit to the Website. We create and then use these cookie files to track your clicks as you go through the Website. The cookie may help ensure that you do not receive an offer that you have already completed. Cookies also notify us of repeat visitors and if the Website is delivering quality offers to our customers. We use both session ID cookies and persistent cookies. For the session ID cookie, once you close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on your hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions. More information on cookies can be found at www.cookiescentral.com . If you reject cookies, you may still use the Website. However, certain features may not be available to you."

Bank Account and/or Credit Card Information

In connection with setting up your account, we may collect your bank account and/or credit card-specific information. Without limiting any of the provisions regarding Sensitive Information, to the extent that such bank account and/or credit card-specific information is collected, we will use such information to bill you for your purchases and we may share such information with third parties for the sole purpose of effectuating any transactions that you enter into at the Website. In addition, by submitting your credit card information to us, you authorize NATIONAL PLATINUM™ to periodically verify that your credit card account continues to be a valid and active one by charging and, thereafter immediately crediting, a small sum to the card. Such verification may be conducted through a third party service provider and, in that case, we will share your specific credit card information with this third party for verification purposes. Apart from the foregoing uses, NATIONAL PLATINUM™ reserves the right to share with other third parties the fact that we have credit card information on file for specific individuals, but we will not share the actual credit card information with other third parties without the applicable individual's prior informed consent.

Social Security Number

In connection with setting up your account, and granting you access to certain member benefits that you may request, we may collect your Social Security Number. Without limiting any of the provisions regarding Sensitive Information, to the extent that your Social Security Number is collected, we will use such information, and we may share such information with third parties, for the sole purpose of effectuating any transactions that you enter into at the Website.

Website as an Agent

Please be advised that in certain circumstances, we act as a limited agent for the actual third party provider of the products and/or services available for purchase at or through the Website. In these circumstances: (a) you will be redirected to the applicable third party service provider’s website after you have completed the applicable registration form on our Website; (b) we will collect and send your personal information to the respective third party service provider in connection with completing your request for products, services and/or information from the third party service provider; and/or (c) your application for products and/or services, and purchase of same, from any third party service provider will subject you to that third party service provider’s privacy policy.

Third Party Advertisers

We do not endorse, nor are we responsible for the accuracy of, the privacy policies and/or terms and conditions of each of the third party advertisers that may advertise at our Website. The entities that advertise and/or place banner ads at our Website including, but not limited to, these third party advertisers, are independent third parties and are not affiliated with NATIONAL PLATINUM™.

Minors

We do not knowingly collect information from individuals under eighteen (18) years of age. No information should be submitted to, or posted at, this Website by individuals under eighteen (18) years of age. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Acceptance of/Changes to this Privacy Policy

By using the Website, applying for an account and/or agreeing to receive information via e-mail from NATIONAL PLATINUM™, you hereby agree to this Privacy Policy. We reserve the right, in our sole discretion, to change, modify, add and/or remove portions of this Privacy Policy at any time. If the manner in which we use personally identifiable information changes, we will notify our users by posting the updated Privacy Policy on the Site and: (a) sending the modified policy to its Members via email; and/or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use your information in this different manner. At any time that you do not agree with the changes, you must opt out from receiving future communications from us (see the “Opt-Out” section below). Failure to opt out after notice of any such changes constitutes an affirmative acknowledgement and acceptance by you of the modified Privacy Policy.

Our Policies and Practices to Protect Your Personal Information

All collected information is stored in a technically and physically secure environment. Where our registration/application process prompts users to enter Sensitive Information, and when we store and transmit such Sensitive Information, that information is encrypted and is protected with SSL encryption software. While we use SSL encryption to protect Sensitive Information online, we also do everything in our power to protect other user information both online and off-line. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information that you transmit to us, and you do so at your own risk. Access to this information is strictly limited, and not accessible to the public.

All of our users' information, not just Sensitive Information, is restricted in our offices. Only employees that need the information to perform a specific job are granted access to personal information. Our employees are dedicated to ensuring the security and privacy of all NATIONAL PLATINUM™ user information. Employees not adhering to our written firm policies are subject to disciplinary action. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and engage in remedial measures.

Deleting and Updating Your Information

At your request, we will inform you of what personal information we have on file for you. In addition, at your request, we will remove personal information that you have provided to us, or that we have collected. You may contact us via e-mail at: service@memberservicesusa.com. Please be advised that instructing us to delete your personal information will only result in the deletion of the personal information contained in our database. This deletion will not change or delete personal information which may have already been shared with third parties, all as provided above in this Privacy Policy. You will need to contact the third parties that contact you directly to change your preferences regarding their use of your Personal Information.

Opt Out

Many of our customers appreciate receiving information and offers about products and services that may be of interest to them. However, we recognize your choice in the matter. During the application process, we provide you with an opportunity to request that we not share your personal information with third parties. If, at any time in the future, you would like to request that we not share your information with third parties, please Click Here and follow the prompts to unsubscribe your email address.

Please note that changing your preferences regarding the receipt of marketing communications from us will not prevent other companies with which we already have shared your information, including third party advertisers, from continuing to provide you with offers. When contacted by these companies, you should notify them directly of your choices regarding their use and sharing of your information. In addition, please note that if you subsequently sign up for another one of our product or service offerings, you will need to reconfirm any information sharing preferences that you have previously changed. Please be aware that if you have a joint account, a request by one party on the account will apply to all parties on the account, unless one party directs otherwise.

Contact Us

For general questions regarding this Privacy Policy, you may send your request to NATIONAL PLATINUM™, 2533 North Carson Street, Carson City, NV 89707.

Filing a Complaint with the Federal Trade Commission

To file a complaint regarding our privacy practices, please click here.

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