White Horse Advertising Co., Ltd. HeFei and Left & Right Advertising Co. ("WH & LRAdv," "we," "us," "our") have jointly created this site (the "Site") in order to advise you of our privacy policy ("Privacy Policy"), which shall govern the type of information that we may (i) collect in connection with the email offers made by us and (ii) gather through your interaction with the Site. The Privacy Policy also indicates how such information may be used and/or shared with others. Please return to this Site and review this Privacy Policy from time to time, as it may be amended without notice. Any changes to this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy on this Site. Your use of the Site or the products and/or emails associated with it constitutes your agreement to the terms and conditions set forth in this Privacy Policy.
YOUR INFORMATION AND HOW WE USE IT: We collect two kinds of information: (i) information that personally identifies you (such as your name and e-mail address); and (ii) information that does not personally identify you (such as the number of users who visit the Site on a daily basis).
PERSONALLY IDENTIFIABLE INFORMATION: As a general policy, no personally identifiable information is automatically collected when you visit this Site or open one of our emails. However, in certain circumstances (e.g., when you enquire about the services offered by us), we may require contact information (such as your name, phone number and email address), and other information from you. From time to time, we may also present you with the opportunity to provide us with general demographic information about yourself (e.g. gender, date of birth, marital status, education, occupation and/or household income). The personal information you submit will be used (i) to carry out your requests and respond to your inquiries, (ii) as disclosed at the time such information is provided, and/or (iii) as disclosed in this Privacy Policy. We may share your personally identifiable information with third parties that perform functions on our behalf, such as companies or individuals that process credit card payments, fulfill orders, deliver merchandise, provide marketing or promotional assistance, analyze data or provide customer service. We may also share your information with our partners, sponsors, advertisers, service providers and marketers, lookup and reference services, unaffiliated third parties, and any other entities that we believe are able to provide you with special offers and opportunities. We may also share your personally identifiable information in aggregate, non-personal form with certain companies so that they can provide you with select offers.
Although we advise all parties that receive personally identifiable information from us of this Privacy Policy, we do not have control over such parties and are not responsible for their failure to adhere to this Privacy Policy.
NON-PERSONALLY IDENTIFIABLE INFORMATION: From time to time, we may collect non-personally identifiable information from you through the standard operation of our servers. Such information can include the type of browser being used (e.g., Netscape Navigator, Internet Explorer), the operating system you are using (e.g., Windows 9x, Windows 2000, Windows XP, Macintosh), the domain name of your Internet service provider (e.g., Netvigator, i-Cable), and the number of clicks in an email sent by us. This information may be used to help analyze site traffic and improve our services. We may also aggregate such information to create statistical data and share it with potential advertisers, partners, affiliates and other third parties. We may collect non-personally identifiable information through various methods, including (without limitation) through:
IP ADDRESSES: An IP address is a 32-bit number (based on Internet Protocol Version 4) that's automatically assigned to your computer whenever you're surfing the Web. Web servers, the big computers that "serve up" Web pages, automatically identify your computer by its IP address. We collect IP addresses for purposes of system administration, to report aggregate information to our advertisers, and to track the use of the Site and the opening of our emails. When you enter the Site or open one of our emails, our servers log your IP address.
COOKIES: "Cookies" are small text files from a Web site and/or email that are stored on your hard drive. These small text files make using Web services more convenient by saving your passwords and preferences for you. Cookies themselves do not contain any personally identifiable information. You can have the option of deciding whether or not to accept a cookie by resetting your browser to notify you whenever a cookie is being sent to your hard drive. You may also delete a cookie manually from your hard drive. Please note, however, that some or all parts of this Site and/or our emails will not function properly, be considerably slower, or become completely disabled if you refuse to accept a cookie or choose to disable your cookies settings.
CLEAR GIFS: A Clear GIF, or "graphic interface format" is a small graphic (in fact, truly a 1x1 pixel) that we (or our partner) places on the Site or in e-mail messages. GIFs (which do not contain any personally identifiable information) provide us with important information about how users use the Site and respond to such e-mail messages. This information allows us to track the performance and effectiveness of certain promotions and e-mail presentations. We may also permit our advertisers and promotional partners to use GIFs on the Site and in emails to you solely to track users who link to their respective sites. However, their ability to track such activity does not grant them access to your personally identifiable information.
RIGHT TO DISCLOSE INFORMATION: We reserve the right to disclose any personally identifiable or non-personally identifiable information if we are required to do so by law or if we reasonably believe that such action is necessary in order to: (a) fulfill a government request; (b) conform with the requirements of the law or to comply with legal process served on us; (c) to protect or defend the legal rights or property of WH & LRAdv, our clients, this Site, or users of our Site and/or emails ("Users"); or (d) in an emergency to protect the health and safety of our Users or the general public.
LINKING OF INFORMATION: Please note that we may combine information provided by a User with information obtained from other sources. This allows us to provide you with more relevant services and promotional offers.
PERSONS UNDER 18: Our Site does not knowingly market or collect information from children under 18. If you are under 18, please do not provide any personal information to us and please do not attempt to enquire about the services offered by us.
OPT-OUT OF EMAIL PROMOTIONS: Our Users will be automatically registered to receive promotional offers and sales offers, via emails, from us and other associated email brands, and emails from our partners, sponsors and advertisers. You may choose not to receive emails from us or our partners by following the "unsubscribe" instructions in the applicable e-mail. Note that unsubscribing from one email list does not automatically unsubscribe you from other email lists that you may be on.
THIRD PARTY SERVICES: Certain activities and services available via email may be provided by third parties. For example, if you choose to purchase a product or service or participate in a promotion presented by one of our partners, the information you provide in connection with such purchase or promotion may be made available to that partner to satisfy that purpose. As noted above, we advise all of our partners of this Privacy Policy, however, we have no control over such partners and are not responsible for their failure (or the failure of unaffiliated third parties) to adhere to this Privacy Policy.
THIRD PARTY COOKIES: We may permit third-party advertisers or ad servers to place or recognize a unique cookie on your browser in connection with certain advertisements served via email. The use of cookies by such third party advertisers or ad servers is not subject to this Privacy Policy, but is subject to their own respective privacy policies.
KEEPING YOUR INFORMATION SECURE: We strive to protect your personally identifiable information and privacy, and take reasonable and appropriate security measures in place to protect against the loss, misuse and alteration of the information under our control. However, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your personally identifiable information.
OTHER SITES: This Site and the emails sent by WH & LRAdv may contain links to other web sites that we do not control or maintain. We encourage you to note when you enter those sites and to read the privacy statements of such other web sites before submitting any personally identifiable information. We are not responsible for the privacy practices employed by these other web sites.
CONSENT TO PROCESSING: Users fully acknowledge and agree that the information provided to us may be collected and processed in, and transferred to, the Hong Kong SAR, China and other countries or territories, in accordance with the terms of this Privacy Policy.
TRANSFER OF ASSETS: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all or substantially all of our assets, personally identifiable information, non-personally identifiable information, and any other information that we have collected about the Users will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
UNSUBSCRIBE: You may unsubscribe from our emails by following the "unsubscribe" instructions in the applicable email. You must communicate all inquiries regarding the use of personally identifiable information or other information by a third party to such third party.
QUESTIONS/CONTACT INFORMATION: If you have questions or comments about our privacy practices, or if you wish to review or amend any personally identifiable information you have provided, you can contact us at:
White Horse Advertising Co., Ltd. HeFei and Left & Right Advertising Co., Flat B 23/F, Lucky Plaza, 315-321 Lockhart Road, Wan Chai, Hong Kong
Last Updated: December 28, 2004
