PRIVACY AND SECURITY POLICY

This Privacy and Security Policy is provided for the benefit of customers and clients of TannersWay LLC ("TannersWay") as well as other consumers and parties who seek information from or about TannersWay and/or its Web site(s), particularly TannersWay.com.

1. OPENING STATEMENTS

1.1 Definitions. Across its various policies, applications, and Web site, TannersWay strives to use the same definitions for particular terms. By doing so, TannersWay seeks to make its policies and governing documents consistent and user-friendly. For this reason, TannersWay provides the definitions for these terms in one location and directs you to our Terms of Use for such definitions.

1.2 Our Commitment to Privacy. At TannersWay, we respect the privacy and the confidentiality of our customers’ information, particularly our customers’ Personally Identifiable Information ("PII"). We are committed to keeping confidential the PII you share with us. This Privacy and Security Policy explains how TannersWay collects, uses, discloses and protects the information we obtain.

1.3 Applicability of Privacy and Security Policy. Our Privacy and Security Policy applies to all individuals and entities from whom or for the benefit of whom we receive PII, whether it be collected through our Web sites; traditional mailing and/or faxing channels; telephone or electronic communications; from some other medium; and/or from our clients.

1.4 Web site Not Directed to Minors. An individual must be aged eighteen (18) or over to create an account through the Web site. As such, the Web site is not directed toward anyone below that age.

2. PERSONAL INFORMATION COLLECTED AND HOW IT IS USED

2.1 Personally Identifiable Information or PII is any information that would, by itself, identify you or tend to identify you as a particular individual or entity. This PII may include, but not be limited to, your name, your address, credit card number, bank account information, and/or personal identification number (such as a social security number or driver’s license number).

2.1.1 PII does not include any public information that is readily attainable through federal, state or local public record distribution channels.

2.1.2 PII does not include any information that, by itself, could not identify you as a particular individual or entity.

2.1.3 PII also does not include raw data that becomes aggregated for statistical purposes and cannot, thereafter, be identified with you as a unique individual or entity.

2.1.4 TannersWay does consider your Internet Protocol ("IP") address to be PII and will treat it as such.

2.2 Information Collected

2.2.1 TannersWay collects information that is considered PII and other information that, by itself, would not be considered personally identifiable information ("Non-PII").

2.2.2 When you create an account and register for any of our TannersWay Services (whether through its Web site or other portal), it collects information submitted by you including, but not limited to, your username, your full name, company name (if applicable), email address, and zip code. TannersWay uses this information to identify its customers and send notifications related to the use of TannersWay Services. TannersWay reserves the right to request additional information from you.

2.2.3 TannersWay shall also collect information to one or more of your financial accounts for purposes of processing payments to provide you with TannersWay Services. This information may likely contain both PII and Non-PII.

2.3 Collecting and Using Personally Identifiable Information

2.3.1 TannersWay will explain how it intends to use PII either before it collects the information (such as in this Privacy and Security Policy) or contemporaneously with the solicitation of such information. Exceptions may exist where the intended use is obvious to a reasonable person.

2.3.2 Generally, TannersWay collects personal identifiable information when an individual registers with or uses any of the TannersWay Services. This information typically includes, at a minimum, a full name, username, company name (if applicable), physical address, email address, phone number, zip code, and any additional information provided by the account holder that could identify that account holder.

2.3.3 We will use the PII collected only for the purposes explained to you. Further, we limit the collection of PII to only that information which is necessary for the purposes explained to you.

2.3.4 Generally, TannersWay uses the PII collected and/or received about you in connection with its Web site, TannersWay Services, and their various features. We also use information collected and/or received about you in connection with other users and advertisers that purchase ads on the Web site.

For example, we may use the information we receive about you (a) as part of our efforts to keep TannersWay safe and secure; (b) to measure or understand the effectiveness of ads you and others see; (c) to provide TannersWay Services including merchant processing; (d) to make suggestions to you and other users on TannersWay; and (f) provide support.

Granting us this permission not only allows us to provide TannersWay as it exists today, but it also allows us to provide you with innovative features and services we develop in the future that use the PII we receive about you in new ways.

We may use your PII to communicate with you for the foregoing and other reasons by email, text message, phone call, or other electronic, written or oral communication method, unless you expressly indicate to TannersWay not to use a particular method of communication.

While you are allowing us to use the PII we receive about you, you always own all of your information. Your trust is important to us, which is why we don't share PII we receive about you with others unless we have: (a) received your permission; (b) given you notice, such as by telling you about it in this policy; or (c) removed your name or any other PII from it.

Additionally, we may use aggregated information derived from PII to improve the TannersWay Services and any related matters thereto.

2.3.5 Unless we are required to do so by law, we shall not obtain your consent before collecting PII about you from parties other than TannersWay. Rather, TannersWay shall presume that you have previously provided such consent to any such third party from whom TannersWay obtains such information.

2.3.6 In the normal course of its business operations, TannersWay restricts the use of your PII to TannersWay’s personnel and its Strategic Partners as explained below.

2.3.7 We shall not sell your PII in the normal course of business operations. Should all or any part of TannersWay’s business operations be sold, this paragraph shall not restrict the transfer of your PII as part of the Web site sold to a third party.

2.3.8 We may also use the PII you provide in registering with and using TannersWay to inform you by electronic mail, phone, text or other communication method of additional products and services about which you might be interested, which may include our periodic electronic newsletters and other promotional communications from TannersWay

2.4 Disclosing Personal Information

2.4.1 We do not share PII we obtain from your use of our TannersWay Services with others except as described in this Privacy Policy and the Terms of Use.

2.4.2 TannersWay may use PII in the normal course of providing the TannersWay Services; to operate or improve the Web site and/or TannersWay Services; to outsource certain services to Strategic Partners; to complete a transaction that has been requested; to develop aggregate information; and/or as otherwise disclosed to you.

2.4.3 TannersWay may provide PII to other persons where (a) we have your consent; (b) the disclosure is necessary to complete a transaction requested; (c) we have obtained information from a third party (TannersWay will assume that you have previously provided such consent to any such third party from whom TannersWay obtains such information.); (d) we are required or permitted to do so by law; (e) the Web site and/or TannersWay Services are used in a manner that violates the Terms of Use or uses for purposes other than those for which they were specifically intended; and/or (f) the terms of this Privacy and Security Policy and/or the Terms of Use otherwise permit and/or provide for such disclosure.

2.4.4 Strategic Partners. TannersWay may employ, engage, contract or retain certain trusted third parties ("Strategic Partners") to perform functions and/or provide services on its behalf. TannersWay will share PII with these Strategic Partners only to the extent necessary to perform the functions and/or provide the services for which they have been employed, engaged contracted or retained. TannersWay shall also secure contractual obligations from our Strategic Partners to maintain the privacy and security of the PII shared with them.

2.4.5 Business Transfers. TannersWay reserves the right to sell, transfer or otherwise share some or all of its assets, including PII, in connection with a sale of assets; a merger, acquisition, or reorganization; or, filing for bankruptcy. TannersWay will make commercially reasonable efforts to give you the opportunity to opt out of any such transfer if the planned processing of your information by the purchaser differs materially from that set forth in this Privacy and Security Policy.

2.4.6 Legal Compliance. TannersWay may disclose any information about you and/or Content created by you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to: (1) comply with an order from a court of competent jurisdiction, regulatory agency, and/or other governmental authority; (2) respond to claims, court orders, or other legal process (including subpoenas); (3) to enforce the terms of this and other TannersWay agreements as well as to protect the property and rights of TannersWay, its Strategic Partners or other third parties; (4) to protect, in TannersWay’s sole discretion, the public or any person from harm; (5) to investigate, prevent, stop, or take other action regarding any action perceived to be fraudulent, illegal, unethical, or legally actionable in TannersWay’s sole discretion; and/or, generally, (6) to comply with the law.

2.4.7 Notice. Unless restricted from doing so, TannersWay will make commercially reasonable efforts to notify you before it releases any of your PII or Content pursuant to (1) and (2) in Paragraph 2.4.6 only. In such cases, TannersWay will also provide you with general information on how you may seek to block such a release of information and/or direct you to resources that can provide such general information. The provision of such general information to you is not and should not be construed as providing you with legal advice. Additionally, TannersWay is under no other obligation to assist you in challenging or opposing a release of your information.

2.5 Non-Personally Identifiable Information. In addition to collecting PII as previously described, TannersWay also collects other non-PII. Non-PII collected by TannersWay may be utilized without restriction. Although non-PII can be used in a number of ways, you can be assured that the use of the non-PII cannot identify you as a particular individual. Because non-PII cannot be used to identify you, TannersWay may in its discretion provide non-PII to other persons or entities.

2.6 Information Obtained From Use of TannersWay’ Web sites

2.6.1 Cookies.

Cookies are bits of data stored on your computer that allow Web site(s) to identify your browser and session.

If you reject all cookies, you may not be able to use the TannersWay Services or products that require you to "sign in" and you may not be able to take full advantage of all offerings.

Most web browsers automatically accept and collect Cookies. However, most browsers also allow you to configure them to accept all cookies, reject all cookies, or notify you when a cookie is set.  Depending upon your web browser’s security settings, you may have the ability to reject all cookies.

The TannersWay Web site uses its own cookies for a number of purposes including, but not limited to:

A. Requiring you to re-enter your password after a certain period of time has elapsed to protect you against others accidentally accessing your account contents;

B. Keep track of preferences specified by our users while using the TannersWay Web site;

C. Estimate and report our total audience size and traffic; and,

D. Conduct research to improve the content and services provided on the TannersWay Web site.

Many of our Strategic Partners may use Cookies. TannersWay maintains no control over the use of Cookies by our strategic partners or by third-party advertisers. For information on how these third parties utilize Cookies collected, you should examine their respective privacy policies.

2.6.2 Browser and Session Information. TannersWay may collect information about your browser and session at the Web site and/or using the Web site Services.

2.6.3 IP Addresses

TannersWay maintains a log of Internet Protocol (IP) addresses when any corporate owned computers, servers, and/or Web sites (including, the Web site) have been accessed. An IP address by itself does not allow us to collect additional PII about you.

IP addresses may be used for various purposes, including to:

A. Diagnose and prevent service or technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web company or ISP;

B. Estimate the total number of users visiting a TannersWay computer, server and/or Web site from specific geographical regions;

C. Help determine which users have access privileges to certain content, services or resources offered; and,

D. Monitor and prevent fraud and abuse.

OTHER THAN YOUR IP ADDRESS, TANNERSWAY DOES NOT DIRECTLY COLLECT ANY PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU UNLESS YOU VOLUNTARILY PROVIDE US WITH THIS INFORMATION.

2.7 Data Retention

2.7.1 TannersWay shall use commercially reasonable efforts to maintain storage information subject to the terms of this Privacy and Security Policy and the Terms of Use.

2.7.2 The length of time for which TannersWay retains PII and other information will vary depending on the nature of the services for which the information has been collected and the nature of the information.

2.7.3 Although this period may extend beyond the end of your relationship with TannersWay, it will be retained for only so long as reasonably believed necessary for TannersWay to respond to any issues arising from your relationship with TannersWay

2.7.4 When TannersWay no longer needs or requires your personal information, TannersWay will destroy, delete, erase or convert information to an anonymous form without notice to you.

2.7.5 Depending on the services purchased, TannersWay may delete information including, but not limited to, stored messages, other content, and records of your account without notice to you. TannersWay recommends that you back up on your own computer any critical and important information prior to allowing your TannersWay Services to terminate or expire.

2.7.6 Should your account be terminated, TannersWay may immediately and permanently delete all information related to your account without notice to you.

3. CONSENT

3.1 TannersWay may obtain personal information about you through a variety of sources. For each source or method, the manner of consent may differ.

3.2 In general, TannersWay operates on an "Opt-out" basis. That is, TannersWay presumes that by using its TannersWay Services and/or accessing its Web site you have read this Privacy and Security Policy and TannersWay’s Terms of Use. Moreover, by providing the personal information requested (both personally identifiable and non-personally identifiable), you have consented to its use by TannersWay for the stated purposes.

3.3 For those reasons, unless and until you expressly inform TannersWay you do not wish your information to be used, TannersWay shall presume it has your consent.

3.4 Where TannersWay obtains PII about a consumer from its customers or other third parties, TannersWay presumes that the consumer has previously provided appropriate consent to the party from whom TannersWay obtains the information. In any case, the consumer can be assured that this Privacy and Security Policy applies to any information obtained from a third party.

4. ACCESS

4.1 Subject to certain limitations imposed by applicable privacy laws, you may request that TannersWay provide you with a copy of your personal information and/or information regarding how we have used that personal information.

4.2 Any requests in writing for access to information should be directed to the contact information provided below.

4.3 We will make every effort to respond to your request in a reasonable timeframe.

5. SECURITY

5.1 TannersWay takes the issue of protecting your personal information very seriously. TannersWay protects the information it obtains about you with appropriate, commercially reasonable safeguards and security measures consistent with standard information practices. These measures include commercially reasonable technical and procedural steps to protect your data from misuse, unauthorized access or disclosure, loss, alteration, or destruction.

5.2 For security purposes, TannersWay does not disclose all of its security measures. However, be assured that TannersWay does employ commercially reasonable industry standard measures to protect your information.

6. DISCLAIMER AS TO THIRD-PARTY WEB SITES. Although our corporate owned Web sites may contain links to other third-party Web sites and/or may be advertised on such third-party Web sites, TannersWay does not control and therefore cannot be responsible for the privacy practices or the content of such Web sites and specifically disclaims any such responsibility. TannersWay does not monitor the privacy practices or content of these Web sites. If you have any questions about the privacy practices of a Web site other than a TannersWay owned Web site, you need to contact the Privacy Officer of the Web site about which you have a question.

7. INCORPORATION OF OTHER APPLICABLE TERMS. Your use of our Web site and TannersWay Services is subject to this Privacy and Security Policy as well as the Terms of Use, the terms of which are incorporated into this Privacy and Security Policy by reference. You should carefully review the Terms of Use.

8. PRIVACY OF CHILDREN. We make it a practice not to knowingly obtain and/or retain information about individuals under the age of eighteen (18). Indeed, no part of TannersWay Services is directed to anyone under the age of eighteen (18).

9. ADDITIONAL INFORMATION

9.1 When you post content on and/or through the TannersWay Services, you have the ability to post content which may include personally identifiable information or PII about yourself. You are responsible for the information you (a) post online; (b) post through use of the TannersWay Services; or, (c) share with another Web site that you link to from our Web site. You do so at your own risk. TannersWay warns you to be careful in posting information accessible to the public.

9.2 If you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties or other unwanted and possibly harmful contact. TannersWay warns you to be careful in posting information accessible to the public.

10. CUSTOMER OBLIGATIONS. By using the TannersWay Services, you agree to use any information about any other TannersWay Customer, particularly PII, obtained through TannersWay Services in a manner consistent with the Terms of Use, this Privacy and Security Policy, and the privacy protections provided for in such policies.

11. CHANGES TO PRIVACY AND SECURITY POLICY

11.1 TannersWay reserves the right to amend, change, modify, or revise this Privacy and Security Policy, our Terms of Use, and other policies and agreements at any time and in any manner.

11.2 TannersWay shall provide notice of such changes by posting any such revised agreements and policies in their applicable location on the TannersWay owned Web sites.

11.3 With respect to this Privacy and Security Policy and all of our agreements, policies, and terms, you should visit TannersWay.com from time to time to review the then-current terms. At any time, the current-posted policies govern and shall be binding.

For Additional Information or Questions, Contact Our Privacy Officer

If you have additional questions or concerns regarding how TannersWay is managing or using your personal information, please send your concerns in writing to support@TannersWay.com.