The FreeGiftCardsNow.com program (the “Program”) and the FreeGiftCardsNow.com Web site (the "Web Site") is an independent program and Web site owned and operated by Q Interactive, Inc. (“Q Interactive,” “we”, “us” and “our”).  Protecting your privacy is a top priority for us for consumers who participate in the Program. We understand that some of the information that you might provide on our Web Site is personal and private. By submitting your personal information, you are entrusting us to handle information that you regard as private, solely for the purposes and in the manner set forth in this Privacy Statement and for no other purpose. In exchange for your trust, you expect us to handle your personal and private information in a professional manner that will be in keeping with your trust. Our Privacy Statement explains what information we obtain in the Program and on this Web Site, and how we use the information disclosed to us to link you to our business affiliates who have expressed a willingness to provide you with the products and services associated with the Program and this Web Site.  This Privacy Statement covers all of the information handling practices for the Program.  This Privacy Statement is effective upon acceptance in registration for new registering users, and is otherwise effective on February 28, 2006 for all users.  The previous Privacy Statement was effective for all users on January 3, 2006.

What information is required for the Program, and why?

Enrollment Information. To set up your membership with the Program, you may need to provide certain personally identifiable information including some combination of data such as your name, mailing address, e-mail address, phone number, gender, and date of birth.  The password for your membership will be automatically generated by us and sent to you via e-mail.  Please keep this e-mail is a safe, secure place where only you may access it.  The password for your membership will be unique to you.  We may append additional data we obtain from third parties to your enrollment information for analysis and marketing purposes. This information will also allow us to provide better, more relevant offers to you.

Transaction Information.  We collect, from other third parties, details of your transactions on the Web Site such as the date and type of your actions in order to keep track of your activity in the Program.  None of this transaction information will be released to any third party in a personally identifiable way, only in aggregate or anonymous form.

Please note, while we do not store financial information (i.e., credit card numbers or other information such as social security numbers and drivers licenses on this Site ("Financial Information").  We do retain such information on our servers for a period of 45 days solely for back-up information purposes and to facilitate the processing and completing of purchase transactions with our business affiliates. In such cases, Financial Information will be disclosed to our business affiliates only as necessary to complete a transaction. Thereafter, Financial Information will automatically be deleted from our servers after 45 days, or the approximate time when your contemplated transactions are completed.

How will my information be used?

Management of Your Account. When you become a member of the Program, we use your enrollment information and transaction data to manage your account.  We will not rent, sell or share any personal information we gather through the Program to third parties except as indicated below or to provide information regarding the products or services you have ordered.  There are other circumstances where your information may be shared with other parties for non-marketing purposes.  The following describes the other ways that your information may be disclosed in the normal course of business to provide our services.

Use of Information with Other Companies Owned by or Under Common Control with Us.  We may use your information for other products and services owned by or under common control with us in order to provide services to our members.

Use of Information with Our Participating Merchants.  We may share certain data with our participating merchants in aggregate form, but the Program is designed to attempt to ensure you are not identified personally to participating merchants unless you make the choice to share your personal information directly with them.  We will not disclose any of the personal information you supply to us to our participating merchants without your prior express consent. The only information that may be shared between us and one of our participating merchants is information that pertains to orders. Order information, including order numbers and amounts, may be available to us, the merchant, or third party affiliate program management companies for accurate discount tracking purposes. This information will not be released by us to other parties unless required by law or to protect us and our members from losses.  We do not record any personal information passed from our members to our participating merchants, including credit card information or merchant passwords.

Service Providers.  We provide information to trusted companies who work on behalf of or with us under confidentiality agreements.  These companies may use your personal information to help us communicate with you about offers of interest to you or for other services necessary to operate the Program. However, these service providers do not have an independent right to use, share or sell this information.

Use of Third Parties for Fulfillment Purposes. We may use certain third parties to provide marketing and administrative services, such as analyzing data, delivering special offers to you on our behalf or on behalf of our partner companies or to administer our Program, such as mailing gift cards to you.  In order to obtain these services, we may need to share certain personally identifiable information about you. However, these third parties will be bound by legal agreements to not use or disclose the information we provide them for any purpose other than to perform the requested service.
On occasion, contests, sweepstakes or surveys on our Web Site may be co-sponsored by us and another company, or may be sponsored by companies other than us. Some or all of the data collected through these contests, sweepstakes or surveys may be shared with the sponsor(s) or companies indicated on the entry form. If such data will be shared, then there will be a notice prior to the time of data collection or transfer.

Direct Marketing Partners.  From time to time, we may provide your postal information and other relevant data to trusted direct marketing partners who may mail direct marketing material on behalf of us and also use this postal information and other data to market to you on their own behalf. In our contact with these direct marketing partners, we have restricted them from sharing or selling this information with any other third party. We do not provide your e-mail address to these direct marketing partners.

Notification About Products and Services. We offer you the opportunity to have access to goods and services that are made available to you on our Web Site, through the postal mail and, unless you opt out of receiving them, through e-mail.  We may use information about you to provide you offers tailored to your interests. Sometimes, we send offers via e-mail to selected groups of members on behalf of our participating merchants. If you do not want to receive offers via e-mail from participating merchants, you may opt out of receiving them as detailed in the E-mail section below.

Use of Information from Third Parties. We may obtain information about you from our partner companies and other third parties in order to provide you with opportunities tailored to your interests. We may also use information obtained from our partner companies and other third parties in conjunction with member account and enrollment information for analytical and audit purposes.

Legal Requests/Questionable Activities.  We will release or disclose your personal information, including to local, state, or federal law enforcement officials, when we believe in good faith that the law requires it, or when required to do so by order of a court or authorized administrative agency.

Who sees my personal information?

Only a very limited number of our employees have access to your personal information.  Primarily, this information is accessed to provide customer service to you.

We may use contractors or vendors to help us to provide some of the services for the Program.  If we need to disclose personal information for them to provide services, it is with the requirement that the information is kept confidential and is used only for those services.

How We Protect Your Privacy

We use a secure, encrypted connection (called an SSL connection) on all pages where you transmit personal data to us. Whenever you access any of your account pages or change any of your user information, it is done over an SSL connection.  Additionally, we have implemented procedural measures to safeguard your information.  For example, only a very limited number of our employees have access to your personal information.

Despite these security measures, we cannot guarantee that a third party might not unlawfully intercept or access transmissions or private communications, or that users might not abuse or misuse your personal information that they may illegally collect from the Web Site. Therefore, although we believe that our practices exceed industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.

How can I access and update my Program data?

You may access and update information stored in your account profile by visiting our Web Site and sending a request via e-mail to: customersupport@freeconsumeroffers.com .  Please keep your contact, account, and preference information up-to-date.  It is your responsibility to update and maintain accurate contact information in your account.  E-mail and street addresses that are entered into a member's personal profile page are the addresses that will be used for all contact including the mailing of gift cards.  Doing so ensures that you will receive your gift card(s) in a timely fashion.  Neither us nor any of our service providers are responsible for any mailings, including the mailings of gift cards, that are sent to incorrect addresses, if the address in question was the address listed in that member's account at the time of issuance.

What about links to other sites and participating merchants' use of information?

Through the Web Site, we may provide links to third-party web sites, such as those of our Clients. Each of these web sites have separate privacy and data-collection practices, which may differ from this Web Site, and we are not responsible for the actions or practices of these third parties, nor for the content on these web sites. We encourage you to review the privacy policies of these web sites before providing your personally identifiable information.

Digital Identifiers

Cookies.  We use "cookies" to personalize the Program to your interests, to ensure that only you can access your account, to facilitate the automatic log-in process and for web beacons (as described below in the "Web Beacons" section). A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.  You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of www.coolsavings.com or the other web sites you visit.

We also review "log-file" data to monitor site performance and analyze traffic patterns and usage of our Web Site. Each time you visit the Web Site, our server automatically recognizes the following:

• Host origin of the request (your IP address or that of your ISP if using proxy servers)
• Referrer URL (the page you came from)
• Requested document (the page you're looking at)
• Your cookie
• Date and time of your visit

This information, sometimes called log-file or clickstream data, is used to monitor Web Site performance and ensure that the Program’s services function properly.  It may also be appended to your personal profile so that we may further tailor the Program to your interests.

Web Beacons.  The Web Site’s pages and/or HTML e-mails may contain electronic images (called  “web beacons”, “single-pixel GIFs”, or “action tags”) that allow us to count users who have visited a certain web page or opened an e-mail, conduct research on partner and Client web sites for auditing purposes, or to access your Program’s“cookie” to identify you when on third party web sites.  Using web beacons allows us to personalize your experience by tailoring advertisements, updates, and other offers to your particular interests, and measuring the marketing effectiveness of our e-mail communications.

E-mail.  With your consent, we will send you e-mail offers available to Program participants.  You may opt-out of receiving e-mail from the Program either during the registration process or at a later date. To opt-out of receiving e-mail after registration, at any time you may click on the unsubscribe link available at the bottom of any commercial e-mail you receive and follow the instructions on-screen or click on this link and follow the instructions on-screen. Please note that it may take up to 72 hours for us to process an opt-out request and that any e-mail communications within the queue prior to your decision to opt-out will still be sent to you.  On occasion, we may contact you with specific administrative notices that are required by law, regulation, or as needed to service your account (i.e. Program change notifications or if we update our Privacy Statement). While you can elect to stop receiving commercial e-mail that we may send from our participating merchants through the Program, you cannot unsubscribe from these administrative messages while enrolled in the Program.

Third Party Ad Servers.  We reserve the right to serve advertisements within our Web pages either ourselves or by allowing other companies, called third-party ad servers or ad networks, to do so.  In addition, some of our advertisers may use the services of third-party ad networks. Some of these third-party ad networks may place a persistent cookie on your computer. Doing this allows the third-party ad network to recognize your computer each time they send you an online advertisement. In this way, third-party ad networks may compile information about where you, or others who are using your computer, saw their advertisements and determine which ads are clicked on. This information allows a third-party ad network to deliver targeted advertisements that they believe will be of most interest to you. We do not have access to or control of the cookies that may be placed by the third-party ad servers or third-party ad networks. Those third-party ad networks that use persistent cookies may offer you a way to opt-out of ad targeting. You may find more information at the Web site of either the individual third-party ad network or the Network Advertising Initiative.

Delete / Deactivate from the Program

You may deactivate from participating in the Program at any time and/or delete your personal information from our database so as not to receive future communications from us by sending an e-mail to customersupport@freeconsumeroffers.com.

Note: It may take up to 72 hours for us to process your request and any e-mail communications within the queue prior to your decision to deactivate will still be sent to you.

Note:  In order to be deleted from our Direct Marketing Partner’s databases and to stop receiving direct mail marketing from them, you must delete your Program account and cease participation in the Program.  It generally takes less than 30 days to remove your information from a Direct Marketing Partner’s list, but in certain instances it may take up to 60 days.

We reserve the right to deactivate you at our sole discretion if we believe that you have used the Program or anything associated with it in a way that is fraudulent or damaging to us, our participating merchants, partners or third party processors.

Children/Minors

The Web Site will automatically block enrollment of any person once they indicate they are under the age of 18.  If we later learn that a user is under the age of 18, we will terminate the account and delete the user's information. Inherent in the Program is the responsibility of parents and/or guardians to ensure that their children's privacy is protected.  We will not be liable for any content viewed by person under the age of 18 in violation of the terms of this Privacy Statement.

Sale/Merger

We will transfer information about you if we are acquired by or merged with another company. We will notify you in accordance with the procedures contained in the Privacy Statement Updates and Web Site Maintenance section of this Privacy Statement if your information will become subject to a different privacy policy.

Limitations on Privacy

Due to the existing regulatory environment, we cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Statement. By way of example (without limiting the foregoing), third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your personal information that they collect from the Web Site. Therefore, although we exceed industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.

Privacy Statement Updates

We reserve the right, at any time and without notice, to add to, update, change, modify or revise this Privacy Statement simply by posting such change, update or modification. Any such addition, update, change, modification or revision will be effective immediately upon posting. If we materially changes how we use your personal information, we will notify you via e-mail.  Please note that if our information practices change at some time in the future, we will use only data collected from the time of the new Privacy Statement amendment forward for those new purposes.

How do I inquire about this Privacy Statement?

If you have any questions about this Privacy Statement, our information-handling practices, or other aspects of privacy, please contact us by e-mail at: customersupport@freeconsumeroffers.com or via postal mail at: Freegiftcardsnow.com Program at Q Interactive, Inc., One North Dearborn Street, 12th Floor, Chicago, Illinois 60602.

Last Updated: February 12, 2007