YOUR ONLINE PRIVACY—THE INFORMATION WE GATHER

The type of information we gather online falls into five general categories:

• Aggregate Site Usage Information
• Online Order Information
• Voluntary Registered Shopper Information
• Click-Stream Data

AGGREGATE SITE USAGE INFORMATION

We collect and store information about the pages viewed by all of our website visitors. We then use this data in aggregate form to identify overall visitor behavior patterns. Our objective in using this information is to improve our site by making it more responsive to the needs and preferences of our users.

Our data servers automatically collect anonymous information about every visitor to our site/sites, including your computer’s internet protocol (IP) address. This IP address allows us to identify your computer on the internet so that the online content you request can be sent back to your computer.

We analyze this information to determine the level of processing power we need in order to meet visitor expectations. From time to time, we may also provide portions of this aggregate, anonymous site behavior information to suppliers, consultants and or advertisers. Our purpose is to ensure maximum purchasing power through the demonstration of site ‘traffic’.

YOUR ONLINE ORDER INFORMATION AND VOLUNTARY REGISTERED SHOPPER INFORMATION

If you choose to purchase products from the My Secret Drawer web site, we require the following information in order to fulfill your order: We request an e-mail address during the order process so that we can send an e-mail confirmation message acknowledging the receipt of your order. This message contains your name, address, My Secret membership number (if applicable), the list of items you purchased, an order reference number, a confirmation of your shipping method, and the total amount of items requested. Please note that this confirmation e-mail does NOT contain your credit card number.

CLICK-STREAM DATA

On a Web site, click-stream data (also called click-stream analytics and/or click-stream analysis) is the process of collecting, analyzing and reporting aggregate data about which pages a website visitor visits — and in what order. The path the visitor takes though a website is called the click-stream. We track this data in order to improve, in-aggregate, your onsite experience.

OUR USE OF COOKIES

To register on, subscribe to or to purchase items from My Secret Drawer websites, your browser must accept “cookies.” Note that all modern browsers are set to accept cookies by default. A cookie is a small piece of data held by your browser that allows us to recognize you when you visit our sites. Cookies have a single function. They cannot read or remit any data from any other file on your computer. Full technical information about how cookies work is available at http://www.cookiecentral.com.

If you have disabled cookies in your browser you will not be able to place an order with us. If you are concerned about information contained in your My Secret Drawer cookie, you can easily delete the cookie at the end of each browser session. While each browser brand is slightly different, you will find the option under the settings section of your browser. View your browser’s help file for more information on cookies.

Types of Cookies We Use on Our Websites
We use first party and third party cookies for several reasons. Some cookies are required for technical reasons in order for our site to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users and to enhance the experience on our sites. Third parties also serve cookies through our sites for advertising, analytics and other purposes. The specific types of first and third party cookies served through our sites and the functions they perform are described in more detail below.

First-party Cookies
These cookies are created by My Secret Drawer/Now 4 Group. They allow you to browse our sites and use their features.

Essential Cookies: These cookies are strictly necessary to allow you to move around the sites and use their features, such as accessing your subscriptions. Without these cookies, we cannot enable appropriate content based on the type of device you are using. Therefore, these cookies cannot be disabled.

Functional Cookies: These cookies allow us to remember choices you make on our websites (such as your preferred language or the region you are in). To refuse these cookies, please follow the instructions below under the section Cookie Management. Note that by disabling functional cookies, you may not be able to use some of our features or those features may not function properly.

Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with our sites, such as the links you click on. The code is temporarily downloaded onto your computer or other device, is active only while you are connected to that site and is deactivated or deleted immediately thereafter.

Analytics Cookies: We use cookies and other identifiers (such as web beacons) to see how you use our sites in order to enhance their performance and develop them according to the preferences of our customers and visitors. For example, cookies and web beacons may be used to maintain a consistent look and feel across our sites, track and provide trend analysis on how our users interact with our sites, track errors, and measure the effectiveness of our promotional campaigns. To refuse these cookies, please follow the instructions below under the section Cookie Management.

Cross-Device Cookies: My Secret Drawer/Now 4 Group may use cookies in combination with the information we collect — for instance, IP addresses and unique mobile device identifiers — to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with service providers that do this, in order to save your preferences across devices and analyze usage of our sites. To refuse these cookies, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Third-Party Cookies
Some of our third party partners (including advertisers and marketing services companies) may set and access cookies on your computer as well, or we may do so on their behalf. We do not have control over how these third parties use such cookies and similar technologies or the information derived therefrom, and this Privacy Policy does not cover any use of information that such third parties may have collected from you or the methods used by the third-parties to collect that information. These types of cookies include:

Advertising Cookies: These cookies, defined exclusively by third parties, collect several types of data about your browsing habits, as well as your preferences for products and services. This information allows us to serve you relevant advertisements on our sites. To refuse these cookies, please follow the instructions below under the section Cookie Management. Some advertisements may also contain an icon that you may click on to find out more about how to manage your advertising preferences.

Third-Party Functional Cookies: These cookies are defined by third parties who support our sites and allow you to use useful services and features. To refuse these cookies, please follow the instructions below under the section Cookie Management.

Web Beacons
Small graphic images or other web programming code called web beacons (also known as “clear GIFs” or “pixel tags“) or similar technologies may be included in our web pages and messages. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our sites, to monitor how users navigate our sites, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed. A clear gif may enable us to relate your viewing or receipt of a web page or message to other information about you, including your Personally Identifiable Information. To refuse Web Beacons, please follow the instructions below under the section Cookie Management.

COOKIE MANAGEMENT

Analytics: To learn about Google Analytics’ currently available opt-outs for the Web, please visit https://support.google.com/analytics/answer/181881?hl=en.

Disabling Advertising Cookies: Some of the advertising service providers may be members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. If you opt-out of receiving targeted ads in this manner, you will continue to receive advertising messages after you opt-out, but they will not be customized to you based on your use of our sites and/or third party websites. Note that the-opt out is cookie-based and will only affect the specific computer and browser on which the opt-out is applied.

Using Browser Settings: You can disable and/or delete most types of cookies by using your browser settings. Please note that if you use your browser settings to block all cookies you may not be able to access parts of our or others’ sites. The following links provide information on how to modify the cookies settings on some popular browsers:
Apple Safari http://support.apple.com/kb/PH5042
Google Chrome https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies
Microsoft Internet Explorer http://windows.microsoft.com/en-US/windows7/How-to-manage-cookies-in-Internet-Explorer-9
Mozilla Firefox http://support.mozilla.org/en-US/kb/Cookies

COMMUNICATIONS FROM MY SECRET DRAWER / NOW 4 GROUP

When you subscribe to or purchase items from My Secret Drawer, sign up for our newsletter or participate in any promotions we may conduct, we collect and store the information that you volunteer. This may include your name, e-mail address, postal address, phone number, size and color preferences. The information you supply is added to our customer database. From time to time we may send e-mail communications introducing new items and services, savings, special promotions or upcoming events. We will never telephone you except where you have requested contact in order to discuss a product or service concern.

Under no circumstances will we ever share your information with any third party unless instructed to do so by a government entity duly authorized to do so.

Should you ever wish to delete your account details completely, you can do so within your membership area. Log in and select the option to delete your account. Note that this will not delete your purchase or subscription history but will remove all your personal information from our site.

Unsubscribing From Promotional Emails: . If you want to stop receiving promotional e-mails from us, click on the “unsubscribe” link in any promotional email from us. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. We may still communicate with you from time to time if we need to provide you with transaction information, if we need to request information from you with respect to a transaction initiated by you, or for other legitimate non-marketing reasons, for example, if we update this Privacy Policy or our Terms of Service.

EXTERNAL LINK

My Secret Drawer may provide links to websites outside of the My Secret Drawer website (external links) in order to provide you with a more complete service. There may, on occasion, also be affiliates or other introducing entities that link to My Secret Drawer. Any such link does not imply or convey endorsement of the other entity, site, product or service. My Secret Drawer / Now 4 Group cannot be held responsible for the privacy, terms of use, or other policies of any other website or entity.

ADULT MATERIAL

This site contains images and other content that is unsuitable for minors. The age of sexual consent varies from country to country and also with states and territories of those countries. If you have not reached the age of consent in your place of residence, you are prohibited from accessing this site.

EDITORIAL USE OF YOUR USER GENERATED CONTENT

User-generated content (UGC), also known as user-created content (UCC), is any form of content created by users of a system or service that is made available publicly on that system.

We may use information you provide us through emails, blog posts, forum submissions, in response to polls, or through any other user generated submission for editorial purposes. When you submit an article for publication we may use your name and any stories you provide us in those articles. If you provide us with personal anecdotes, they may be attributed to you. My Secret Drawer / Now 4 Group reserves the right to edit, rewrite, use, and reuse the content, including your name, likeness, photograph, and the biographical information you provide, with or without attribution. This specifically includes reviews submitted by you which may be used for advertising purposes. You hereby consent to this when you submit any user generated content to us.

Information You Disclose Publicly: You may submit photographs, user profiles, written material, music, video, photos, comments and other content, which may include information relating to individual users (collectively, “UGC”). We do not control who will have access to the UGC you choose to make public or how they will use it and take no responsibility for ensuring such UGC remains private or is secure. User Generated Content is not subject to this Privacy Policy. We are also not responsible for the accuracy, use or misuse of any UGC that you disclose or receive through our sites. Please see our Terms of Use for further information about the terms that govern the UGC you post.

OUR ONLINE SECURITY COMMITMENT

We understand that many consumers are concerned about Internet security. My Secret Drawer / Now 4 Group employ industry-leading technologies to store sensitive information and to protect that information while in transit over the Internet. Specifically, we use Secure Sockets Layer technology (SSL), a technology supported by all modern web browsers. SSL is used to encrypt all communications between you and our site.

All personal information you provide is secured by multiple firewalls on our server.

No credit card details are held by us. All monetary transactions are handled by specialized third party services who meet all security requirements across all regions.

REQUESTS FOR ADDITIONAL INFORMATION INCLUDING YOUR LEGAL RIGHTS:

Your local laws may permit you to request that we:

• provide access to and/or a copy of certain information we have about you;
• prevent the processing of your information for direct-marketing purposes;
• update information which is out of date or incorrect;
• delete certain information which we have about you;
• restrict the way that we process and disclose certain of your information;
• transfer your information to a third party provider of services; and
• revoke your consent for the processing of your information.

We will consider all requests and provide our response within the time period stated by applicable law. Certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.