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
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 firstname.lastname@example.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
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
privacy statement covers the site [WWW.URL
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.
Create My Futuresystem Create My Future Create My Future system is designed to be used exclusively to promote Create My FutureCreate My FutureCreate My FutureCreate My FutureCreate My Future
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
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_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:]
Create My Future, our partners, and the independent representative who are Members are the owners of the information collected on createmyfuture.com.
to use this Web site, a user MAY first complete the registration form. During registration a user
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 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. 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 [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. ]
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. If we have trouble processing an order, the information is used to contact the user.
[ 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 .]
Create My FutureCreate My Futurecontact (name, phone number, and email)
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
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. ]
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] 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.]
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.
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 info r mation
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
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.
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.]
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
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
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.
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.
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.
may opt-out of these communications. Please see our Choice and Opt-out
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.
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.
share aggregated demographic information with our partners and
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.
Create My FutureCreate My Future
COMPANY] shares Web site usage information about users with a reputable third
part y [NAME
OF THIRD PARTY] for the purpose
of targeting our Internet banner advertisements on this site and other
sites. For example, [NAME OF COMPANY]
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
These are the instances in which we will share users' personal information:
Share Personal Contact Information ][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
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.
partner with other third parties
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.
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.
[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]
[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.
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
who no longer wish to receive our newsletter and promotional communications may
opt-out of receiving these communications by
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.]
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.
Web site contains links to other sites. Please be aware that we, Create My Future
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 ].
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.
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 createmyfuture.com [INSERT
URL OR EMAIL ADDRESS] to request the removal of this information
from our database.
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.
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.
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
[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
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 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 createmyfuture.com
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.
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."
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 email@example.com to correct, update or delete/deactivate users' personally identifiable information.
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.