The TRUSTe Model Privacy Statement

Developing your company’s privacy statement is a critical stage in understanding and articulating your corporate policies. For many companies, drafting a privacy statement kick starts a corporate-wide understanding of how individual data is used and, more importantly, initiates a conversation about how to build trust with consumers.

 

Unfortunately, there is no single “ideal” privacy statement – by definition, they vary from company to company and must be tailored to highlight specific practices. That being said, TRUSTe has identified several common themes that, in our experience, have emerged as “best practices” for a privacy statement.

 

The following Model Privacy Statement serves as a template, prompting you to consider important points in your information gathering policy and practices. Before we begin, keep in mind a couple of key points:

 

1.Say what you do; Do what you say – The Golden Rule in privacy statements is “Do Not Lie.” The only thing worse than not posting a privacy statement is to fraudulently claim a certain business practice. State and federal governments do not look kindly on companies that claim one set of practices, and follow another.

 

1.Tailor the Model Privacy Statement – The following model will provide you with resources to begin developing your own privacy statement, but you should be sure not to simply cut and paste. Use it as a starting point to create a statement tailored to your specific practices.

 

1.Privacy Statements are not Disclaimers – The communication of your company’s privacy practices should express what is actually happening on the site, not what may happen, has happened or is planned for the future. In some cases, informing your users of the information gathering your company’s site does not practice may be more effective.

 

1.Re-visit your privacy statement frequently – A privacy statement is a living document, designed to clearly communicate your company’s privacy practices, which, for many companies, change over time. Make sure you revisit your posted privacy statement to make sure it truly reflects your current practices.

 

1.Communicate your privacy practices to your entire company – In order to avoid information spills it is important to make sure that your entire company is aware of the policies within your privacy statement.

 

Throughout this model privacy statement TRUSTe uses [bracketed] language in order to provoke thought on a specific privacy practice or present language options that will help you ensure your privacy statement matches your business model and actual practices.

 

Creating a clear and accurate statement helps your company in its efforts to build loyal relationships with its users by providing your customers with the information they need to trust you with their personal information. We hope you find this Model Privacy Statement useful in your quest to build trust with your customers. If you have any specific questions, do not hesitate to contact us by email at businessdevelopment@truste.orgbizdev@truste.org.

 

Additional Steps for Protecting Children Online

There are additional requirements and elements needed beyond a model privacy statement, in order to address children’s online privacy issues. Please visit the Children’s Privacy Seal section of our Web site for more information on how to make your Web site safer for kids and compliant with the Children’s Online Privacy Protection Act.

 

 

 

 

MODEL PRIVACY STATEMENT

[NAME OF COMPANY/SITE] is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to enable individuals and organizations to establish trusting relationships based on respect for personal identity and information by promoting the use of fair information practices. This privacy statement covers the site [WWW.URL OFSITE.COM].  Because this Web site wants to demonstrate its commitment to our users' privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe. 

Your privacy is very important to us, and we will treat your data with care and respect. We know that you care how information and data about you is collected, used and shared. This Privacy Statement describes our privacy policy and details how we collect, use, and/or disseminate the information you provide. We reserve the right change this Statement at any time and urge you to review our Statment regulary to familiarize yourself with any changes.

 

By visiting our website, using our online products/services, and/or by voluntarily submitting information to us via online forms, advertisement responses, and/or electronic mail, you are accepting the practices described in this Privacy Statement.

 

Who We Are

 

Create My Future has developed and licenses a system software product called Create My Future which allows Network Marketers to promote a legal and ethical network marketing opportunity and/or Client program and/or opportunities or programs of their choice. The Create My Future system is designed to be used exclusively to promote the products and Services offered by the system. However, due to the fact that each Create My Future account is controlled by an independent representative, we cannot guarantee how the system and privacy information will be managed by these representatives.

Create My Future operates and manages the Create My Future System to assist network marketers in the building of their business on the Web. Individuals that subscribe to the Create My Future System do so in one of two forms: prospects (sometimes referred to as Pre-Enrollees), and Members. Individual subscriptions to the Create My Future System are referred to as a "Member" in the Create My Future System.

 

To cater to both you (the Customer) and our Members, we may be required to collect, use, and share certain information. The type of information we collect, together with a description of how we use and/or share it, is described below.

 

1. What personally identifiable information [NAME OF COMPANY] collects.

2. What personally identifiable information third parties collect through the Web site.

3. What organization collects the information.

4. How [NAME OF COMPANY] uses the information.

5. With whom [NAME OF COMPANY] may share user information.

6. What choices are available to users regarding collection, use and distribution of the information.

7. What types of security procedures are in place to protect the loss, misuse or alteration of information under [NAME OF COMPANY] control.

8. How users can correct any inaccuracies in the information.

If users have questions or concerns regarding this statement, they should first contact [NAME OF INDIVIDUAL, DEPARTMENT OR GROUP RESPONSIBLE FOR INQUIRIES] by [CONTACT INFORMATION: EMAIL, PHONE, POSTAL MAIL] If they do not receive acknowledgment of their inquiry or their inquiry is not satisfactorily addressed, they should then contact TRUSTe through the TRUSTe Watchdog Dispute Resolution Process (http://www.truste.org/users/users_watchdog.phphttp://www.truste.org/users/users_watchdog_intro.html). TRUSTe will serve as a liaison with the Web site to resolve users concerns.

 

[Include this Software Disclaimer as the last sentence in the TRUSTe opening statement if the site has a downloadable software application or applet: The TRUSTe program covers only information that is collected through this Web site, and does not cover information that may be collected through software downloaded from the site. By displaying the TRUSTe trustmark, [NAME OF SITE] has agreed to notify users of:]

Information Collection and Use

 

Information Collection


Create My Future, our partners, and the independent representative who are Members are the owners of the information collected on createmyfuture.com.

 

Registration

In order to use this Web site, a user MAY first complete the registration form. During registration a user [is required to] give[s] contact information (such as name and email address). We use this information to contact the user about services on our site for which he has expressed interest. It is optional optional for the user to provide demographic information (such as income level and gender), and unique identifiers (such as, username and password), but encouraged so we can provide a more personalized experience on our site. If a person or company chooses to enroll in our network marketing business opportunity, we are require to collect the persons/user's social security number and if a company, we are required to collect their EIN number. These numbers are required to comply with IRS requirements and to provide this information to our associated network marketing business. [include service type here.] [TRUSTe recommends you only collect a social security number when it is a required identifier for performing the site’s service.]

 

Order

We request information from the user on our order form. A user must provide contact information (such as name, email, and shipping address) and financial information (such as credit card number, expiration date). This information is used for billing purposes and to fill customer's orders. In addition, this information is given to the network marketing company for the purpose of enrollment and processing orders. If we have trouble processing an order, the information is used to contact the user.

 

Information Use

 

[This paragraph should elaborate on the actual ‘use’ of the information. For instance, the service the site performs should be incorporated here. Also, a discussion of the use of aggregate information should be disclosed here as well. Be as specific as possible, without being contingent. Avoid ‘we may do this’ ‘we might do that’ type of language.]

We will use personal information that we gather about you to provide the services that you have requested. In addition, if you have a free trial account with Create My Future, then we will use the information gathered about you to share more information about our business in an attempt to convince you to make a purchase from us or our associated companies. Create My Future and the person/affiliate who sent you to this site will be granted access to your personal contact (name, phone number, and email) information so that they can communicate with you in an attempt to "sell" various products, services, and memberships to you.

 

Profile

We store information that we collect through cookies, log files, clear gifs, and/or third parties to create a profile of our users. A profile is stored information that we keep on individual users that details their viewing preferences. Consequently, collected information is tied to the users personally identifiable information to provide offers and improve the content of the site for the user. This profile is used to tailor a user's visit to our Web site, and to direct pertinent marketing promotions to them. We [do not] share your profile with other third parties. [Your profile is shared in aggregate form only.] [Your profile is shared together with your personally identifiable information. YOUR PAYMENT INFORMATION, SOCIAL SECURITY OR EIN NUMBER IS NEVER SHARED FOR ANY REASON WITH ANY OUTSIDE THIRD PARTY UNLESS REQUIRED BY LAW, EXCEPT FOR THE PURPOSE OF ENROLLMENT IN OUR MLM OPPORTUNITES.]

 

Cookies

A cookie is a piece of data stored on the user's computer tied to information about the user. [Usage of a cookie is in no way linked to any personally identifiable information while on our site.] We use [both] session ID cookies [and] and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the user's hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions. [Provide a link to information on cookies.]

 

[Explain how cookies are used on your Web site.] By setting a cookie on our site, users would not have to log in a password more than once, thereby saving time while on our site. If users reject the cookie, they may still use our site. The only drawback to this is that the user will be limited in some areas of our site. For example, [the user will not be able to participate in any of our sweepstakes, contests or monthly drawings that take place.] Persistent cookies enable us to track and target the interests of our users to enhance the experience on our site. See the "Profile" section.

 

Some of our business partners use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies, once we have given permission for them to set cookies for advertising.

 

Third Party Advertising

The ads appearing on this Web site are delivered to users by [THIRD PARTY AD SERVER NAME], our Web advertising partner. Information about users' visit to this site, such as number of times they have viewed an ad (but not user name, address, or other personal information), is used to serve ads to users on this site. For more information about [THIRD PARTY AD SERVER NAME], cookies, and how to "opt-out", please click here [LINK TO: THIRD PARTY AD SERVER PRIVACY STATEMENT].

 

This privacy statement covers the use of cookies by [NAME OF SITE] only and does not cover the use of cookies by any advertisers.

 

Log Files

Like most standard Web site servers we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user's movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information. [ IP addresses are tied to personally identifiable information to enable our Web-based service.] [We use a tracking utility called [XXXX] that uses log files to analyze user movement.][Webtrendslive users may have further obligations of particular language per their license with Webtrendslive. See your license agreement.] [See the Profile section below.]

 

Clear Gifs (Web Beacons, Web Bugs, CSS, and similar functionality)

We employ [or our third party advertising company employs] a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. [Clear gifs are tied to users' personally identifiable information.] [Clear gifs are not tied to users' personally identifiable information.]

 

Clear Gifs can "work with" existing cookies on a computer if they are both from the same Web site or advertising company. That means, for example, that if a person visited "www.companyX.com", which uses an advertising company's clear gif, the Web site [or advertising company] would match the clear gif's identifier and the advertising company's cookie ID number, to show the past online behavior for that computer. This collected information would then be given to the advertising company [or Web site]. To learn more about our advertising company’s use of clear gifs, please go to [NAME OF ADVERTISER’S SITE.]

 

In addition, we use clear gifs in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, please see the Opt-out section.

 

Communications from the Site

Special Offers and Updates

We send all new members a welcoming email to verify password and username. Established members will occasionally receive information on products, services, special deals, and a newsletter. Out of respect for the privacy of our users we present the option to not receive these types of communications. Please see the Choice and Opt-out sections.

 

Newsletter

If a user wishes to subscribe to our newsletter, we ask for contact information such as name and email address. Out of respect for our users privacy we provide a way to opt-out of these communications. Please see the Choice and Opt-out sections.

 

Service Announcements

On rare occasions it is necessary to send out a strictly service related announcement. For instance, if our service is temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature. [Users may opt-out of these communications. Please see our Choice and Opt-out section.]

 

 

Customer Service

We communicate with users on a regular basis to provide requested services and in regards to issues relating to their account we reply via email or phone, in accordance with the users wishes.

 

Sharing

Legal Disclaimer

Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our Web site.

 

Aggregate Information (non-personally identifiable)

We share aggregated demographic information with our partners and advertisers. [Describe the sharing practices of what your site does, but be specific in your relationship with these third parties.] This is not linked to any personally identifiable information.

 

Third Party AdvertisersParties:

We use the information you have voluntarily provided to cause information, offers, products, and/or services that appear to us to be consistent with your expressed interests to be directed to you. This is typically accomplished by using your information to direct to you information, offers, products, and/or services from us and/or one of our affiliated companies. Your information may, therefore, ultimately be used for marketing purposes by us, our affiliated companies, and/or any one or more the associated businesses with which we work.

 

We cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Statement. For example, we may be forced to disclose information to the government or third parties under certain circumstances, or third parties may unlawfully intercept or access transmissions or private communications. We can (and you authorize us to) disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate.

 

After we share your information with our affiliated companies and/or any of the several businesses with which we work, we lose control over how they will use, collect, and/or disseminate your information. Accordingly, we recommend that you review the Privacy Statements of the corresponding affiliated companies with whom we have shared your information in order to acquaint yourself with their information collection, use, and/or sharing policies.

 

You understand and agree that Create My Future is not responsible for the privacy practices or the content of these other websites, and you agree that Create My Future is not responsible for how such information is ultimately used.

 

[NAME OF COMPANY] shares Web site usage information about users with a reputable third party [NAME OF THIRD PARTY] for the purpose of targeting our Internet banner advertisements on this site and other sites. For example, [NAME OF COMPANY] uses cookies and clear GIFs on this site, which allow them to recognize a user's cookie when a user visits this site. The information they collect and share through this technology is not personally identifiable. For more information about our third-party advertiser or for choices about not having this anonymous information used please click here [LINK TO: ADSERVER PRIVACY POLICY/OPT OUT].

 

These are the instances in which we will share users' personal information:

[We Share Personal Contact Information with third parties. If you want to ensure that your information is never shared with any third party, you must request to be unsubscribed or cancelled from our service. Failure to unsubscribe or cancel your service will imply that you are interested in having your personal information shared with various third parties.

][We DO NOT Share Personal Information with Third Parties]

 

[Specifically describe any sharing of personally identifiable information. For example, describe actual practices where the site is sharing personally identifiable information. Include sharing scenarios where the partner can dispose of the information either in the manner that they see fit, or where the partner can use the personal information for a limited circumstance or series of limited circumstances. Another example might include sharing with parent companies, subsidiaries or affiliated companies for reasons other than corporate record keeping purposes. Typically these kinds of sharing arrangements occur when the third party will then own or control the customer relationship.  Below are some examples of the different types of relationships or situations involving sharing personal information with third parties that may exist. Keep in mind that sharing personally identifiable information for secondary purposes, must incorporate an opt-out prior to the sharing.]

 

Third Party Intermediaries

We use an outside shipping company to ship orders, and a credit card processing company to bill users for goods and services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes.

 

Service Providers

We partner with other third parties [ANOTHER PARTY’S NAME]to provide specific services. [For example, XXXX] When the user signs up for these particular services, we share names, or other contact information [specify what information is being shared with the third party service provider] that is necessary for the third party to provide these services. These third parties are not allowed to use personally identifiable information except for the purpose of providing these services and for purposes referenced in their privacy policies.

 

Approved Lead Vendors

We allow carefully-screened Approved Lead Vendors to be listed in your back office. Under certain circumstances, we may share your contact information with one or more of these Approved Lead Vendors. They may use this information to contact you via telephone, email or direct mail to inform you about an upcoming lead special, conference call or other promotional opportunity which could potentially benefit you.


Business Transitions

In the event [NAME OF COMPANY]Create My Future goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, users' personal information will, in most instances, be part of the assets transferred. Users will be notified via email [email] [prominent notice on our Web site for 30 days] prior to a change of ownership or control of their personal information. If as a result of the business transition, the users' personally identifiable information will be used in a manner different from that stated at the time of collection they will be given choice consistent with our notification of changes section.

 

Choice/Opt-out

Our users are given the opportunity to 'opt-out' of having their information used for purposes not directly related to our site only by completely opting-out of our service and/or canceling a paid subscription to our service.

Our users are given the opportunity to 'opt-out' of having their information used for purposes not directly related to our site at the point where we ask for information. For example, our order form has an 'opt-out' mechanism so users who buy a product from us, but don’t want any marketing material, can keep their email address off of our lists.

 

Users who no longer wish to receive our newsletter and promotional communications may opt-out of receiving these communications by following the unsubscribe instructions sent with every email. replying to unsubscribe in the subject line in the email or email us at [EMAIL ADDRESS] [We also offer an opt-out mechanism on the [MEMBER INFORMATION PAGES] or the user may contact us at [PHONE] [EMAIL] or [POSTAL MAIL] to opt-out.]

 

 

Users of our site are always notified when their information is being collected by any outside parties. We do this so our users can make an informed choice as to whether or not they should proceed with services that require an outside party.

 

Links

This Web site contains links to other sites. Please be aware that we, Create My Future[NAME OF COMPANY], are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information. This privacy statement applies solely to information collected by this Web site. [Discuss co-branding and/or framing relations where the user may not know who is collecting the information].

 

Surveys [& Contests]

[From time-to-time] our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code). Contact information will be used [shared with the contest [survey] sponsors] to notify the winners and award prizes. [Anonymous] Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site. users' personally identifiable information is not shared with third parties unless we give prior notice and choice. Though we may use an intermediary to conduct these surveys or contests, they may not use users' personally identifiable information for any secondary purposes.

 

Tell-A-Friend

If a user elects to use our referral service for informing a friend about our site, we ask them for the friend's name and email address. [NAME OF COMPANY]Create My Future will automatically send the friend a one-time email inviting them to visit the site. [NAME OF COMPANY]Create My Future stores [or does not store] this information for the sole purpose of sending this one-time email [and tracking the success of our referral program]. The friend may contact Create My Future[NAME OF COMPANY] at www.createmyfuture.com/unsubscribe[INSERT URL OR EMAIL ADDRESS] to request the removal of this information from our database.


Children's privacy

Protecting the privacy of the young is important to us. Therefore, you cannot use this site if you are not 18 years old. If you are not 18 years old you are not permitted to access this website for any reason. Because of this, we never knowingly collect or maintain information at our website from those we actually know are under 18, and no part of our website is structured to attract anyone under the age of 18.


Telecommunications privacy

Protecting the privacy of your telecommunications information is important to us. When members or prospects make phone calls to telecommunication services provided by us, we may track information about the name, phone number, and other information about the calling party. In addition, we may gather information about telecommunication services used by our members. By contacting us via telephone you are allowing us to contact you even if your phone number is on any legal DNC (do not call) lists.

 

Security


This Web site takes every precaution to protect our users' information. When users submit sensitive information via the Web site, we strive to ensure that their information is protected both online and off-line. However, please be aware that no data transmission over the Internet or information storage technology can be guaranteed to be 100% secure.

 

When our registration/order form asks users to enter sensitive information (such as credit card number and/or social security number), that information is encrypted and is protected with the best encryption software in the industry - SSL. While on a secure page, such as our order form, the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just 'surfing'. [To learn more about SSL, follow this link [INSERT LINK].]

 

While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user-information off-line. All of our users' information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to personally identifiable information. Our employees must use password-protected screen-savers when they leave their desk. When they return, they must re-enter their password to re-gain access to user information. Furthermore, ALL employees are kept up-to-date on our security and privacy practices. Every [quarter], as well as any time new policies are added, our employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure our users' information is protected. Finally, the servers that store personally identifiable information are in a secure environment, [behind a locked cage][in a secure locked facility]. [Be sure that your actual practices are reflected in this section. For example, if your employees are updated on privacy every 6 months, then state that, rather than a statement that is false. Another example, must employees use password-protected screensavers?]

 

If users have any questions about the security at our Web site, users can send an email to support@createmyfuture.com.[EMAIL ADDRESS.]

 

Supplementation of Information


In order for this Web site to properly fulfill its obligation to users it is necessary for us to supplement the information we receive with information from 3rd party sources.


Enhancement of Marketing Profile

We purchase third party marketing data and add it to our existing user database to better target our advertising and provide pertinent offers we think our users would be interested in. We use this information to enhance or overlay the 'profile' of individual users. This aggregate marketing data is therefore tied to the users' personally identifiable information. See also the "Profile."

 

Correcting/Updating/Deleting/Deactivating Personal Information


If a user's personally identifiable information changes (such as zip code, phone, email or postal address), or if a user no longer desires our service, they may contact us at support@cmfteam.com to correct, update or delete/deactivate users' personally identifiable information.


Notification of Changes


If we decide to change our privacy policy, we will post those changes to this privacy statement in places that we deem appropriate. We will use information in accordance with the privacy policy under which the information was collected.

 

If, however, we are going to use users' personally identifiable information in a manner different from that stated at the time of collection we will notify users via email. Users will have a choice as to whether or not we use their information in this different manner. However, if users have opted out of all communication with the site, or deleted/deactivated their account, then they will not be contacted, nor will their personal information be used in this new manner. In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our Web site notifying users of the change. In some cases where we post a notice we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices.

 

Contact Information


If users have any questions or suggestions regarding our privacy policy, please contact us at:

support@cmfteam.com
www.createmyfuture.com