THE ONE GROUP, LLC PRIVACY POLICY

Effective date: July 31, 2012

INTRODUCTION

This Privacy Policy applies only to the web site(s) owned (however accessed and/or used, whether via personal computers, mobile devices or otherwise) or controlled by The One Group, LLC, a Delaware limited liability company or any of its related, affiliated or subsidiary companies (“Company,” “we,” “our” or “us”) or other interactive features that are accessible or downloadable through the web sites owned or controlled by Company and that post a link to this Privacy Policy (collectively, the “Web Sites”). This Privacy Policy only covers information collected at the Web Sites, and does not cover any information collected at any other web site or offline by Company (unless specifically stated). The purpose of this Privacy Policy is to disclose to you what information we may collect on the Web Sites, how we may collect it, with whom we may share it, and certain other matters related to such information, including the choices you may have regarding our collection, use, and disclosure of such information.
Please read this Privacy Policy carefully. In addition, please review our Terms of Use, which govern your use of the Web Sites.

TYPES OF INFORMATION THAT MAY BE COLLECTED

The following are the types of information we may collect:

Web Site Usage Information & Device Identifiers

We may receive and store certain types of web site usage information whenever you visit or interact with the Web Sites. For example, we may collect the page served, the time, the source of the request, the type of browser making the request, the preceding page view, other similar information and your IP address. We also may collect your IP address or some other unique identifier for the particular device you use to access the internet, as applicable (collectively referred to herein as a “Device Identifier”). A Device Identifier is a number that is automatically assigned to your computer, your cell phone, or other device used to access the internet, and our computers identify your device by its Device Identifier. We may associate your Device Identifier with the personal information you provide. When analyzed, web site usage information helps us determine how visitors arrive at the Web Sites, what type of content is most popular, and what type of visitors are interested in particular kinds of content and advertising.

Information You Provide Us

We may ask you to provide us with two types of information: (1) personal information, which is information that could reasonably be used to identify you personally, such as your name, e-mail address, cell phone number, and physical address; and (2) demographic information, such as gender, zip code, or similar information. We may collect this information at various places and forms on the Web Sites, including registration forms for newsletters and other communications (e.g., whether by e-mail, mobile device, etc.), when you communicate or otherwise interact with us, when you submit information to us (whether or not the information is intended to be posted on the Web Sites), contests, or sweepstakes, surveys or voting or when you purchase a product or service through the Web Sites. You may also be asked to choose a user name and password in order to identify yourself during future visits to the Web Sites. Do not use your real name or the name of any other actual person as your user name. Providing us with information about yourself is your choice, and you can always choose not to provide certain information, but then you may not be able to take advantage of some of the Web Sites’ features.

Information from Other Sources

We may receive information about you from other sources; for example, we may obtain geographic or demographic information, or information regarding your possible interests, from third parties, or we may receive information from a marketing partner in connection with a co-branded web site or promotion. We may combine the information we receive from those other sources with information we collect through the Web Sites. In those cases, we will apply this Privacy Policy to any personal information received, unless otherwise specifically disclosed by us at the time you provide your personal information.

HOW INFORMATION MAY BE COLLECTED

The Web Sites use standard technology called “cookies,” which are small data files that are transferred to your computer (or other internet-accessing device) when you visit the Web Sites and allow your browser to accept cookies. Cookies automatically identify your web browser to the Web Sites whenever you visit the Web Sites, and may make navigating and using the Web Sites easier for you. Also, by tracking how and when you use the Web Sites, cookies help us determine which areas are popular and which are not. Many improvements and updates to the Web Sites are based on data obtained from cookies. Additionally, accepting cookies may allow you to, among other things, personalize your experience on the Web Sites. Cookies may also allow the Web Sites to present to you advertising that may be of interest to you as well as limit how often you see certain ads that may detract from your user experience on our Web Sites. If you do not want to allow information to be collected through the use of cookies, you can generally opt out of providing this information by setting your browser to reject cookies. However, please be aware that some areas of the Web Sites may not provide you with an acceptable user experience if you have disabled the use of cookies.

HOW WE USE THE INFORMATION COLLECTED

The information you provide to us may be used to:

  • Send you newsletter and/or other communications for which you have registered;
  • Contact you about the Web Sites, including, without limitation, in our discretion to notify you of changes to this Privacy Policy, the Web Site’s Terms of Use, or other policies that affect your use of the Web Sites;
  • Confirm or fulfill an order you have made, including without limitation any purchase orders for any of the Company products;
  • Provide special offers, coupons and/or promotional materials to you on behalf of us or third parties;
  • Contact you with regard to a sweepstakes, contest or promotion in which you have participated;
  • Authorize a purchase or complete a transaction that you have requested, i.e., to deliver the products or other services that you ordered, and, if necessary, to invoice you;
  • Monitor or improve the Web Sites;
  • Administer the Web Sites’ systems and for other internal business purposes;
  • Customize the advertising and content you see;
  • Comply with and monitor compliance with our Terms of Use and other applicable agreements and polices; and/or
  • For other purposes disclosed when you provide your information.

Moreover, if you submit to Company and/or the Web Sites comments, photographs, videos, music, text or other content, it maybe published online or offline (including on-air, on a CD or DVD, through wireless distribution, and transmission of soft copies, or any other media or format currently existing or hereafter developed), and we may publish your name, voice, likeness and other personal information in connection with publishing the content or a portion of the content, and we may use the content and any excerpt from the content in connection with advertising, marketing, publicity and promotional activities. Please also see “Information You Submit” in our Terms of Use, which governs any content you submit through the Web Sites.
Please note that information submitted to the Web Sites via a “contact us,” or other similar mechanisms will not necessarily receive a response. We will not use any such information you provide to contact you for marketing purposes unrelated to your request.

WITH WHOM INFORMATION MAY BE SHARED

Except as otherwise disclosed at the time you provide your information, the following outlines the ways in which your information may be shared with others:

Third Parties Providing Services On Our Behalf

We may employ third parties to perform functions on our behalf; examples include hosting or operating Web Sites, fulfilling orders for products and services purchased through the Web Sites, sending e-mail and/or other communications, providing wireless services, removing repetitive information from customer lists, data analysis, marketing assistance, credit card payment processing, and customer service. These third parties may have access to your personal information for the purpose of performing such functions on the Web Sites’ behalf.

Non-Personal Information

We may share non-personal information, such as aggregate user statistics, demographic information, and web site usage information with third parties.

Sweepstakes, Contests and Promotions

We may offer sweepstakes, contests, and other promotions through the Web Sites that may require registration. If you choose to enter a sweepstakes, contest or other promotion, your personal information may be disclosed to third parties in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list. Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion.

Business Transfers

Company may share the information collected through the Web Sites with and among the Web Sites, and may share the information with its subsidiaries and affiliates. Company or any of it assets, including the Web Sites, may be sold, or other transactions may occur in which your personal information is one of the key business assets for the transaction. In such a case, your personal information may be one of the business assets we transfer. Hence, Company reserves the right to disclose and transfer user information, including personal information, in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our assets, or other corporate change.

Legal Protections and Law Enforcement

We may disclose information about our users, including your personal information, in the event we are required to respond to subpoenas, court orders, legal process or other valid law enforcement measures; to comply with a legal obligation; at the request of governmental authorities conducting an investigation; to verify or enforce compliance with the policies governing the Web Sites and applicable laws; or to protect the legal rights, interests, or safety of the Web Sites, our users or others. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, internet service providers or law enforcement agencies in our discretion. Such disclosures may be carried out without notice to you.

CHAT ROOMS, FORUMS, AND MESSAGE BOARDS

The Web Sites may make chat rooms, forums and message boards available to its users. If you post personal information online, it will be publicly available and you may receive unsolicited messages from other parties. We cannot ensure the security of any information you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when disclosing personal information in these areas. Your use of chat rooms, forums and message boards is subject to our Terms of Use

THIRD PARTY CONTENT AND LINKS TO OTHER WEBSITES

When you are on the Web Sites you may be directed to other sites that are operated and controlled by third parties that are beyond our control. For example, if you “click” on a banner advertisement, the “click” may take you off the Web Sites onto a different web site. These other web sites may send their own cookies to you, independently collect data or solicit personal information and may or may not have their own published privacy policies. If you visit a web site that is linked from our Web Sites, you should consult that web site’s privacy policy before providing any personal information.

CONSENT TO TRANSFER

The Web Sites are operated in the United States. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Web Sites or providing us with your information, you consent to this transfer.

SECURITY

Company incorporates reasonable safeguards to help protect and secure your personal information. However, no data transmission over the internet, or wireless transmission, or electronic storage of information can be guaranteed to be 100% secure. Please note that Company cannot ensure or warrant the security of any information you transmit to Company via its Web Sites, and you do so at your own risk.

CHILDREN

The features, programs, promotions and other aspects of the Web Sites requiring the submission of personally identifiable information are not intended for anyone under 21 years of age. The Company does not knowingly collect personally identifiable information from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personally identifiable information to us please contact the Company.  A parent or guardian of a child under the age of 13 may review and request deletion of such child’s personally identifiable information as well as prohibit the use thereof.

California Privacy Rights

Residents of the State of California may have the right to request from a business with whom the California resident has an established business relationship a list of all third parties to which the business, during the immediately preceding calendar year, has disclosed certain personally identifiable information for direct marketing purposes.  To the extent the Company is required to respond to any such request, we are only required to respond to a customer request once during any calendar year.  In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California Privacy Rights Requirements and only information on covered sharing will be included in our response.

NOTIFICATION OF CHANGES AND YOUR ACCEPTANCE OF THE PRIVACY POLICY

By using any of the Web Sites, you acknowledge your agreement to the terms of this Privacy Policy. From time to time, Company may update this Privacy Policy. However, Company will use your personal information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless you consent to the new or revised policy.