PRIVACY POLICY

FOR SHROUK, INC.

 

Effective Date: 07/20/2005 

 

Last Updated: 07/20/2005 

 

I.          Preamble and General Principles

 

A.        This Privacy Policy describes how Shrouk, Inc. (hereinafter "COMPANY") collects information from all end users of the COMPANY's Internet services (the "Services")-those who access some of our Services but do not have accounts ("Visitors") as well as those who pay a monthly service fee to subscribe to the Service ("Members")-what we do with the information we collect, and the choices Visitors and Members have concerning the collection and use of such information. The COMPANY, requests that you read this Privacy Policy carefully.

 

B.        The following information is designed to help you understand how we collect, use, disseminate and safeguard the information you provide to us while accessing and using the following network of the COMPANY's Web sites, which currently includes:http://oldspunkers.com, http://chubbyloving.com, http://jimmydiamond.com/, http://spunker.com/, (collectively, the "SITES," or individually, a "SITE" or "we/our"). If you do not agree with our information practices, please do not access or use our SITES. By accessing and using any of our SITES, you signify your assent to this Privacy Policy.

 

II.             Revisions to this Policy

 

The COMPANY reserves the right to revise, amend, or modify this policy and our other policies and agreements at any time and in any manner. The user should periodically check for any modifications of this Policy by re-visiting this web page and using the "refresh" button on the user's browser. The user should note the date of last revision to this Policy, which appears at the top of this Policy. If the "last modified" date remains unchanged after the user has clicked the "refresh" button on his/her browser, the user may presume that no changes have been made since the last reading of the policy. A changed "last modified" dates indicates that this Policy has been updated or edited, and the updated or edited version supersedes any prior versions immediately upon posting.

 

 

III.       Personal Information the COMPANY Collects and How It Is Used

 

A.        The COMPANY collects information in different ways from Visitors and Members who access the various parts of our Services and the network of Web sites accessible through our Service. We use this information primarily to provide a customized experience as you use our Services and, generally, do not share this information with third parties. However, we may disclose personal information collected if we have received your permission beforehand or in very special circumstances, such as when we believe that such disclosure is required by law or other special cases (described below).

 

B.        Registration. Members are asked to provide certain personal information when they sign up for our Services including name, address, telephone number and the type of personal computer being used to access the Services. The personal information collected from Members during the registration process is used to manage each Member's account (such as for billing purposes). This information is not shared with third parties, unless specifically stated otherwise or in special circumstances. However, in instances where the COMPANY and a partner jointly promote the Services, , may provide the partner certain personal information, such as the name, address, and username of persons who subscribed to the Services as a result of the joint promotion for the sole purpose of allowing us and the partner to assess the results of the promotion. In this instance, personal information will not be used by the partner for any other purpose. The COMPANY may also generate non-identifying and aggregate profiles from personal information Members provide during registration (such as the total number, but not the names, of Members). As explained in more detail below, we may use this aggregated and non-identifying information to sell advertisements that appear on the Services.

 

C.        COMPANY Partners and Sponsors. Some COMPANY products and services are offered to Visitors and Members in conjunction with a non-affiliated partner. To provide Visitors and Members some of these products and services, the partner may need to collect and maintain personal information. In these instances, you will be notified before any such data is collected or transferred and may decide not to use that particular service or feature. Additionally, many COMPANY, Members have co-branded Personal Start Pages that are cosponsored by nonaffiliated partners. The COMPANY will share nonidentifying and aggregate information (except as described above), but not personal information, with such partners in order to administer the co-branded products or services offered.

 

D.            Online Shopping.

 

1.         At some of our SITES, you can purchase products and services or register to receive materials. In many cases, you may be asked to provide contact information, such as your name, address, email address, phone number, and credit/debit card information. If you complete an order for someone else, such as an online gift order sent directly to a recipient, you may be asked to provide information about the recipient, such as the recipient's name, address, and phone number. The COMPANY has no control over the third parties' use of any personal information you provide when placing such an order. Please exercise care when doing so.

 

2.         If you order products directly from the COMPANY, we will use the personal information you provide only to process that order. We do not share this information with outside parties except to the extent necessary to complete that order.

 

E.         Online Advertisements.

 

The COMPANY displays online advertisements. We share aggregated and non-identifying information about our Visitors and Members collected through the registration process as well as through online surveys and promotions with these advertisers. Additionally, in some instances, we use this aggregated and non-identifying information to deliver tailored advertisements. For instance, an advertiser tells us the audience they want to reach (for example, males between 25 and 55 years of age) and provides us an advertisement tailored to the audience. Based upon the aggregated and non-identifying information we have collected, we may then display the advertisement to the intended audience. The COMPANY does not share personal information about its Visitors or Members with these advertisers.

 

F.         Responses to Email Inquiries.

 

When Visitors or Members send email inquiries to the COMPANY the return email address is used to answer the email inquiry we receive. The COMPANY does not use the return email address for any other purpose and does not share the return email address with any third party.

 

G.            Voluntary Customer Surveys.

 

1.         We may periodically conduct both business and individual customer surveys. We encourage our customers to participate in these surveys because they provide us with important information that helps us to improve the types of services we offer and how we provide them to you. Your personal information and responses will remain strictly confidential, even if the survey is conducted by a third party. Participation in our customer surveys is voluntary.

 

2.         We take the information we receive from individuals responding to our Customer Surveys and combine (or aggregate) it with the responses of other COMPANY customers to create broader, generic responses to the survey questions (such as gender, age, residence, interests, hobbies, education, employment, industry sector, or other demographic information). We then use the aggregated information to improve the quality of our services to you, and to develop new services and products. This aggregated, non-personally identifying information may be shared with third parties.

 

3.         We also use our Visitors' and Members' information for market research data purposes. For example, we may use your information in order to find ways to improve sales to a group of other users, to increase you or other users (Members?) experience according to your interests, or to formulate statistical models to accomplish such goals through surveys or contests.

 

H.        Other Internet Data. The COMPANY also collects IP addresses, referral URLs, browser preferences, the user's registration forms, surveys, and communications transmitted through SITE'S applications in order to collect information from End-Users. This information is used internally for the purposes of providing additional personalized services to our Members and to track how users come to be referred to our SITES for the purpose of compensating our affiliates, advertisers, and other marketing entities. This information may be disclosed to third-parties. If we choose to disclose information to third-parties, this information shall consist of non-specific information regarding SITE traffic and statistics. The COMPANY never discloses any customer specific information to third parties unless it is reasonable to believe that doing so is required by law, a binding contract, a Court Order, or other state, local, or administrative regulation.

I.          Special Cases. It is the COMPANY's policy not to use or share the personal information about Visitors of Members in ways unrelated to those described above without also providing you an opportunity to opt out or otherwise prohibit such unrelated uses. However, the COMPANY may disclose personal information about Visitors or Members, or information regarding your use of the Services or Web sites accessible through our Services, for any reason if, in our sole discretion, we believe that it is reasonable to do so, including:

 

1.         To satisfy laws, such as the Electronic Communications Privacy Act, regulations, or governmental, or legal requests for such information;

 

2.         To disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Acceptable Use Policy http://jimmydiamond.com/legal/terms_and_conditions.html  or other user policies;

 

3.         To operate the Services properly;

 

4.         To protect the COMPANY and our Members;

 

5.         We will cooperate with law enforcement authorities, private-party litigants, and others seeking information about our end users to the extent required by applicable law. Examples of such cooperation include compliance with discovery requests, subpoenas, court orders, and writs.

 

J.         "Cookies" and How the COMPANY Uses Them. A "cookie" is a small data file that can be placed on your hard drive when you visit certain Web sites. The COMPANY may use cookies to collect, store, and sometimes track information for statistical purposes to improve the products and services we provide and to manage our telecommunications networks. We may use a cookie to save your settings and to provide customizable and personalized services to you. These cookies do not enable third parties to access any of your customer information. Additionally, be aware that if you visit non-COMPANY Web sites where you are prompted to log in or that are customizable, you may be required to accept cookies. Advertisers and partners may also use their own cookies. We do not control use of these cookies and expressly disclaim responsibility for information collected through them.

 

K.        Company Email. The COMPANY periodically sends mass email to its users. The COMPANY has an Opt-in Policy and an Opt-out Policy for unsolicited email. The only way for the user's email address to be added to our email list is for the user to provide this information to us and then state that the user wishes to be added to our email list either explicitly or by acquiescing to the conditions of an offer. Every email we send to you will have an unsubscribe link at the bottom. These unsubscribe links, when clicked, will automatically remove the customer's email address from our database without any additional action on the user's part. The COMPANY takes all reasonable steps in order to adhere with this Policy, but the COMPANY is not responsible for occasional technical malfunctions which may result in additional unwanted emails being sent. Should this occur, the user is instructed to direct an inquiry to the COMPANY's Customer Service email address, which is available here .

 

IV.       Our Commitment to Children's Protection.

 

A.        Our SITES are designed for adults, but not for use by anyone under the age of 18. In light of that fact, the Children's Online Privacy Protection Act of 1998 is not applicable to this SITE.

 

B.        We have no Web pages designed for younger users. We make every effort to ensure that our Web sites contain adequate warnings to make their content obvious and to warn users under the age of 18 that they are not welcome to view our SITES, we believe that there is no substitute for proper parental supervision of their children's internet use. Nevertheless, we will take any steps possible to discourage those under the age of 18 from visiting our Web sites. For further information about tips, tools, age-appropriate, or kid-friendly Web sites and how to report online trouble, please visit www.getnetwise.org.

 

V.        Public Forums and External Sites.

 

A.        Please remember that any information you may disclose in our Member             Directory, or other public areas of our Web sites or the Internet, becomes public information. You should exercise caution when deciding to disclose personal          information in these public areas.

 

B.        The SITE may contain links to other sites. Please be aware that we are not             responsible for the privacy practices of such other sites. We encourage our users    to be aware that when they leave our SITE they should read the privacy             statements of each and every site that collects personally identifiable information.

 

VI.       The COMPANY's Commitment to Data Security.

 

Services and Web sites we sponsor have security measures in place to protect the loss, misuse, and alteration of the information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party "hackers" from illegally obtaining this information. We take all reasonable measures to prevent such breaches of security, but given the resourcefulness of cyber-criminals we are unable to guarantee that our security is 100% breach-proof. You assume the risk of such breaches to the extent that they occur despite our reasonable security measures.

 

VII.      How to Access or Modify Your Information.

 

The COMPANY offers Members the opportunity to access or modify information provided during registration. To access or modify such information, contact our Customer Service Department at http://shrouk.com/contact/

 

VIII.    Where to Direct Questions About the COMPANY's Privacy Policy.

 

If you have any questions about this Privacy Policy or the practices described herein, you may contact:

 

Customer Service Department:

http://shrouk.com/contact/