Privacy Policy
The Blocks Company, LLC ("TBC") is committed to protecting your privacy. As a customer,
you supply us with certain personally identifiable data. We want you to understand
how such personally identifiable data is collected and used. We also want you to
make informed choices as to whether and to what extent you may restrict the manner
in which your personally identifiable data is used. This Privacy Policy is in addition
to any user, or other, agreements you have entered in to with TBC and nothing in
this Privacy Policy shall be construed as superceding or replacing any other such
agreement.
Set forth below is TBC's Privacy Policy. Please read it carefully.
1. Scope and Nature of Policy
As a current or prospective customer of our business, this Privacy Policy covers
personally identifiable data collected from and about you. "Personally Identifiable
Data" means any data about an identified or identifiable individual recorded in
any form.
This Privacy Policy complies with the requirements of the Safe Harbor Privacy Principles
issued by the U.S. Department of Commerce on July 21, 2000 (the "Safe Harbor Principles").
Because we comply with the Safe Harbor Principles, our transfers of data from countries
in the European Union to the United States meet the adequacy requirements of the
European Union Data Protection Directive.
This Privacy Policy includes examples of the types of information we may collect.
These examples are illustrative and should not be considered a complete inventory
of our information collection practices. Accordingly, the words "include" and "including"
mean inclusion without limitation.
This Privacy Policy does not cover personally identifiable data we collect from
and about our employees. We have different corporate policies for those types of
data. It also does not cover data collected by us for statistical purposes from
which the personally identifiable characteristics have been removed. We retain the
right to use such data for statistical purposes for our own business use. We do
not knowingly solicit personally identifiable data from persons under the age of
13 years.
2. Types and Sources of Data Collected
In the ordinary course of our business, we gather personally identifiable data about
you, including:
- Information you provide, such as your name, address(es), company
and other telephone number(s), fax number(s), e-mail address(es), date and place
of birth, driver's license number, credit card information, membership reward program
information and affiliations with companies or associations;
- Information about your
transactions with us, our licensees or distributors or others, such as your order
activity; and
- Information we receive from consumer reporting agencies, such as your
creditworthiness and credit history. We gather personally identifiable data about
you from a variety of sources, including websites we operate, websites operated
by others through which you can transact with us or our licensees or distributors,
customer support center, enrollment forms for our programs, and consumer reporting
agencies.
We gather personally identifiable data about you from a variety of sources, including
websites we operate, websites operated by others through which you can transact
with us or our licensees or distributors, customer support center, enrollment forms
for our programs, and consumer reporting agencies. We also gather personally identifiable
data about you from other companies with whom we maintain business relationships.
3. Use of "Cookies"
One way we collect
information about you when you use our websites is through the use of cookies. A
"cookie" is a set of data that a website server stores on your computer. Cookies
enable websites to recognize your computer and to "remember" your entries as you
move from page to page, or even when you revisit the site from time to time using
the same computer. Cookies stored on your computer by our websites are encrypted.
This means that they cannot easily be read by anyone other than us.
We use two different
types of cookies in our websites:
- "Session cookies" track the user's progression
through our sites in a single visit. These cookies enable us to remember things
as the user progresses from one page to another. Your session cookies are deleted
as soon as you close your browser. In addition, if you leave your browser open for
a prolonged period, they are set to automatically erase themselves after a short
period (typically less than one hour).
- "Persistent cookies" remember a user at the
user's next visit. Your persistent cookies are not automatically erased, and they
remain on your computer until you erase them. (If you do not want these cookies
to remain on your computer, you can erase them through use of your browser settings.)
Your browser or other software you install may permit you to restrict the use of
session cookies, persistent cookies or all cookies. If you elect not to permit the
use of session cookies, you will not be able to use our websites. If you elect not
to permit the use of persistent cookies only, you may still enjoy the full functionality
of our websites; however, if you do so, you will need to re-enter some data when
starting a new session.
4. Linked Websites
Our websites may contain links to third
party websites, which may or may not be operated in conjunction with our websites.
We do not monitor or control the information collected when you choose to "click
through" links to these websites. The treatment of user data by the operators of
third party websites may be different from ours. For details regarding their treatment
of personally identifiable data about you, you will need to read their privacy policies
or contact them
5. Data Retention
While we generally retain personally identifiable
data about you as long as we believe it will be useful to us, we do not retain personally
identifiable data about you longer than the law of the country and state in which
it is being retained permits. Currently, the principal place in which we retain
personally identifiable data about you is the State of Florida , U.S.A.
6. Data Security
We maintain reasonable physical, electronic, and procedural safeguards
to protect personally identifiable data about you from loss, misuse and unauthorized
access, disclosure, alteration and destruction. As part of those precautions, we
seek to protect personally identifiable data about you through technologies designed
to safeguard the data during its transmission. We restrict access to personally
identifiable data about you to those employees we determine need to know that information
for us and our licensees and distributors to provide services to you. We also have
adopted a policy under which employee misuse of personally identifiable data about
you is treated as a serious offense for which disciplinary action may be taken.
You should, however, be aware that there is no method of transmitting or storing
data that is completely secure. Although their physical characteristics are different,
postal mail, telephone calls, faxes and transmissions over the Internet all present
possibilities of loss, misrouting, interception and misuse of the data being transmitted.
When we decide what data to seek from or send to you, or how to seek or send it,
we try to attain reasonable balance between the security of your data and your convenience.
We do this because we believe our customers attach value to both. As a result, we
sometimes use a method of communication that is less secure than some of its less
convenient alternatives. An important example of this occurs in the case of e-mail.
When we send e-mail to you, we send it as plain text without encrypting it. We do
this because we believe that many of our customers do not currently have the capability
to receive encrypted e-mail. As a consequence, though, if our unencrypted e-mail
intended for you were misrouted or intercepted, it could be read more easily than
encrypted e-mail.
To protect personally identifiable data about you effectively,
we need your help. Please do not divulge your TBC user number or any similar program
membership number to anyone who is not employed by us or one of our licensees or
distributors. In addition, because e-mail to and from us is not encrypted, please
do not include your user number, or any other information you regard as confidential,
in any e-mail you send us. [A more secure way to communicate with us over the Internet
is to click on the "Contact Us" link on the home page of our website www.blocks.com
and complete the form that you are presented.] Finally, if you have obtained a personal
identification number, or "PIN", in order to utilize portions of our websites, do
not divulge your PIN to anyone - not even one of our employees.
7. Parties to Whom We Disclose Data
Our general policy is to not disclose personally identifiable data
about you to any third party. This policy is not applicable to our licensees and
distributors.
We generally use personally identifiable data about you to make and
process your orders, give you access to our services, provide you with customer
assistance, prepare your account statements and maintain and develop software. We
may use licensees and distributors from time to time to perform such services for
us. We also may disclose information in response to requests from law enforcement
agencies or government regulators. A more detailed description of those uses appears
below. Such uses are called "Normal Uses."
By purchasing our products, whether from
us or through one of our licensees or distributors, you are consenting to our use
and limited disclosure of personally identifiable data about you for Normal Uses.
If you do not wish to consent to such use and disclosure of personally identifiable
data about you, please do not purchase our products, whether directly or through
a licensee or distributor.
8. Normal Uses Internal Uses
We may initially use the
personally identifiable data that we collect from you to make your initial purchase
with us or our licensees or distributors; to process your transactions with us and
our licensees or distributors; to provide you with access to our services, including
any enhanced services you request; and to bill and collect amounts owed to us for
continuing service. If you seek to pay charges by a debit, charge or credit card,
we may disclose personally identifiable data about you to the company issuing the
card and to other companies that assist in processing the charges. Similarly, if
you seek to have your charges invoiced to a third party, we may disclose personally
identifiable data about you to that third party and to any companies that assist
the third party in processing invoices. Further, if you participate in a membership
rewards program operated by a third party and seek to receive a reward based on
a transaction with us or our licensees or distributors, we may disclose personally
identifiable data about you to the program's operator, as well as to companies assisting
the operator in the operation of the program, to permit you to receive your membership
rewards.
We may share personally identifiable data about you among ourselves and
with our licensees and distributors to enable us to perform the functions described
above. In the event that personally identifiable data about you is shared among
ourselves or with our licensees or distributors, the party with which such information
is shared will be required to agree to observe the relevant provisions of our Privacy
Policy with respect to personally identifiable data about you (including any choices
you have made under our Privacy Policy to limit the use of your data).
Blocks Community
Forum Uses. If you use the Blocks Community Forum, additional disclosures and disclaimers
apply. Blocks Community Forum users may publish information on electronic bulletin
boards generally accessible to other Blocks Community users and anyone browsing
the forum. We do not assume any responsibility for the privacy or security of any
such communications, and you assume all risks of publishing such information on
the system for examination by others, including our employees and persons who gain
unauthorized access to the site ("hackers"). Furthermore, any such information published
by you will pass through and be stored upon one or more of our servers. We will
access the information stored on our server(s) for three purposes: first, to verify
that the Blocks Community Forum is operating properly; second, to police the content
of publications in response to any customer complaints about inappropriate content,
and, third, to gather information for statistical purposes. No information published
by a Blocks Community Forum customer is to be considered an expression of opinion
or fact by us. We do not adopt, ratify, guarantee or endorse the contents or accuracy
of any such publications. If you believe a communication published through the .BLOCKS
Community Forum violates your privacy, you may report the same to us [by e-mailing
us for investigation at www.blocks.com ("Contact Us" link) or] by mail to Privacy
Services, The Blocks Company, LLC, 5370 NW 35th Ter # 113, Fort Lauderdale, FL 33309.
Compliance Uses. We may use and disclose personally identifiable data about you
as we reasonably believe is necessary to protect our business; to comply with applicable
law; to protect the rights, privacy, safety or property of you or others; and to
permit us to pursue available remedies or limit the damages that we may sustain.
For example, if you breach a license agreement or other agreement with us or any
of our licensees or affiliates, personally identifiable data about you may be used,
disclosed to third parties or publicly disclosed to the extent necessary to enforce
the agreements and recover any amounts owed. As another example, we may, to the
fullest extent the law allows, disclose personally identifiable data about you to
law enforcement agencies to assist them in identifying individuals who have been
or may be engaged in illegal activities.
Transactional Uses. We may acquire or sell
assets, including ownership interests in our company, and other companies may acquire
financial interests in us. In those transactions, personally identifiable data about
you may be among the transferred business assets. We may disclose personally identifiable
data about you to any company in connection with a proposed or actual sale, merger,
transfer, or exchange of all or a portion of a business or operating unit if you
do business or have done business with that business or operating unit, but only
if that company agrees to use the data solely for the purpose of making its acquisition
decision and to observe the relevant provisions of our Privacy Policy with respect
to the data. In the event that personally identifiable data about you is transferred
to a company acquiring assets from us, we will require that company to agree to
observe the relevant provisions of our Privacy Policy with respect to personally
identifiable data about you (including any choices you have made under our Privacy
Policy to limit the use of your data).
Independent Agency Uses. We may disclose
personally identifiable data about you to any individual or company that we retain
to assist us in the conduct of our business, including an individual or company
that performs marketing services on our behalf, but only if that individual or company
agrees to use the personally identifiable data about you solely for the purposes
of performing the tasks on behalf of, and under the instruction of, us and to observe
the relevant provisions of our Privacy Policy with respect to the data.
Use of Data
from Others. We may obtain personally identifiable data about you from our licensees
and distributors and from other companies with whom we have business relationships.
Such information may be merged with or used to enhance personally identifiable data
that we have collected previously, as permitted by applicable law.
Disclosure to
Promotional Program Sponsors. A promotional program, or "PP", is a contract or program
we establish in cooperation with a sponsoring company or organization (the "sponsor")
through which individuals with specified characteristics are entitled to license
our products or receive our service terms that differ from those generally offered
to the public. Examples of PPs include plans where our products or services are
bundled with those of the sponsor (and perhaps others). We identify PPs using unique
numbers ("PP Numbers"), and we require those who wish to transact under the terms
of a PP, to furnish us with the appropriate PP Number.
If you transact using a PP
Number, you consent to our disclosure of personally identifiable data about you
to the PP's sponsor in order to permit us and the sponsor to (i) verify your eligibility
to participate using that number; (ii) determine our compliance with the promotional
terms of the PP; (iii) determine your compliance with the sponsor's policies; and
(iv) facilitate the sponsor's reimbursement of some or all of the costs of your
transaction to the extent it has agreed to reimburse you for them. We require sponsors
to treat all personally identifiable data disclosed to them for these purposes as
confidential and not to use that data for marketing purposes.
If you do not wish
us to share personally identifiable data about you in the manner described under
this subheading, you must not use a PP Number in connection with your transaction.
If you do not use a PP Number, you will not receive the benefits of the associated
contract or program.
9. Marketing Uses
You have the right to "opt out" of Marketing
Uses in the manner described below under the heading Option to Limit Use of Data.
We may aggregate and analyze all of the personally identifiable data about you to
enable us to develop targeted marketing programs and service offerings that we believe
are tailored to the needs of particular groups of customers. We may then use the
personally identifiable data about you to contact you regarding programs and services
we believe might be of interest to you. If you wish us not to contact you for this
purpose, you may decline as set forth below under Option to Limit Use of Data.
We
may disclose all of the personally identifiable data about you among ourselves and
to our licensees and distributors for marketing purposes, provided the licensees
and distributors to which we disclose the data agree to observe the relevant provisions
of our Privacy Policy with respect to the data being disclosed (including any choices
you have made under our Privacy Policy to limit the use of your data). If you wish
us not to disclose personally identifiable data about you to our licensees and distributors
for marketing purposes, you may decline as set forth below under Option to Limit
Use of Data.
10. Unintentional Disclosure
While we have taken significant steps
to prevent the inadvertent disclosure of your personally identifiable data to persons
who, without authorization, break into and access our confidential electronic files
in violation of existing law ("hackers"), we cannot guarantee that a sophisticated
hacker will not some day penetrate the barriers we have in place to safeguard your
personally identifiable data. We will continue to evaluate and, where indicated,
update our security precautions consistent with good business practices.
11. Option to Limit Use of Data
You may elect to direct us to limit the use of personally identifiable
data about you. As stated above, it is our standing company policy not to disclose
personally identifiable data about you to third parties companies (who are not our
licensees or distributors) for their marketing purposes. However, you may direct
us not to send you any marketing offers or materials and not to provide personally
identifiable data about you to our licensees and distributors for marketing purposes.
If you do this, we will not, after your direction becomes effective, either send
you any marketing offers or materials or provide personally identifiable data about
you to our licensees or distributors for marketing purposes. (We are not, however,
responsible for any subsequent use by licensees or distributors of data disclosed
to them before we received your direction.)
How to Elect. If you are a current customer,
you may communicate your election to us by accessing the update section of your
customer profile in your program’s section of this website and make the desired
directions. You may also make your choice by writing Privacy Services, The Blocks
Company, LLC, 5370 NW 35th Ter # 113, Fort Lauderdale, FL 33309 . Any direction
made through this website will become effective within 48 hours of your making the
direction. Any direction made through the mail will become effective by the end
of the 20th business day following the date on which your direction is received
at the above addresses.
Subsequent Choices. If you choose no longer to limit the
use of personally identifiable data about you, then we will observe the terms of
your latest effective choice as if it were the only instruction we had received
from you with respect to the use of personally identifiable data about you.
Option
to Limit Non-Marketing Uses of Data. We will not make any non-marketing use of personally
identifiable data about you unless either: (i) we give you notice of that use and
provide you the opportunity to direct us not to make that use of the personally
identifiable data about you, or (ii) applicable law or where applicable, the Safe
Harbor Principles, authorize us to make that use of personally identifiable data
about you without providing you the opportunity to direct us not to do so. Please
note that all Normal Uses of personally identifiable data about you as described
in our Privacy Policy constitute uses that are so authorized.
12. Access to or Correction of Data
We make reasonable efforts to ensure that the personally identifiable data
we have about you is accurate, current and complete.
You have a reasonable right
to access and review personally identifiable data about you collected by us. You
may correct factual errors in that data by sending a request to us that credibly
shows the error. You should contact our main office in the country in which you
reside for information about how to exercise these rights. As an alternative, you
may obtain the information by writing to Privacy Services, The Blocks Company, LLC,
5370 NW 35th Ter # 113, Fort Lauderdale, FL 33309 . To protect your privacy and
security, we will take reasonable steps to verify your identity before granting
access or making corrections.
13. Right to Make Future Changes in Policy Reserved
We make our Privacy Policy available through a link on the home page of our website
www.blocks.com. We reserve the right to change our Privacy Policy in the future.
Subject to applicable laws, any changes to our Privacy Policy will be effective
upon posting of the revised Privacy Policy on the Internet, accessible from a link
appearing on the home page of our website www.blocks.com.
If we make changes, we
will revise the "Last Updated" date on the top or cover page of our Privacy Policy.
If we change our Privacy Policy in a way that is less protective of your privacy,
then the change will not apply to our use of any personally identifiable data about
you that was collected by us before the change was made, unless we notify you and
provide you with the opportunity to direct us not to make new uses of personally
identifiable data about you.
14. Coordination with Applicable Law
We do business
in many countries and states. Depending on where you live and where and the products
and services you purchase from us, our collection and use of personally identifiable
data about you may be governed by federal and state laws of the United States (including
the Gramm-Leach-Bliley Act), the laws of other countries or the Safe Harbor Principles.
Where applicable, we will comply with such laws and the Safe Harbor Principles regarding
our collection and use of personally identifiable data about you and will limit
any disclosures of data accordingly.
15.
Information Regarding Former Customers
We disclose personally identifiable data about former customers or customers with
inactive accounts only in accordance with our Privacy Policy.
16. Customer Questions
We hope our Privacy Policy answers your questions about our collection and use of
personally identifiable data about you. If it does not, or if you have questions
about whether we are observing our Privacy Policy, please write to us at Privacy
Services, The Blocks Company, LLC, 5370 NW 35th Ter # 113, Fort Lauderdale, FL 33309
. If, after we respond to you, you feel that we have not satisfactorily addressed
your questions or concerns, we will refer you to a neutral, independent third party
dispute resolution organization.
17. Disclaimer and Limitation of Liability
IF YOU ARE DISSATISFIED WITH THIS PRIVACY POLICY OR IF TBC FAILS TO ABIDE BY THE
TERMS OF THIS PRIVACY POLICY, YOUR SOLE AND EXCLUSIVE REMEDY IS TO STOP USING THE
SERVICES PROVIDED BY TBC. TBC WILL NOT PAY YOU ANY DAMAGES, INCLUDING BUT NOT LIMITED
TO LOST PROFITS, INDIRECT, SPECIAL, EXEMPLARY, PUNITIVE OR CONSEQUENTIAL DAMAGES,
EVEN IF NOTIFIED OF THE POSSIBILITY OF SUCH DAMAGES AND EVEN IF SUCH DAMAGES ARE
THE RESULT OF THE NEGLIGENCE OF TBC.
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