We at ThinkDirect Marketing Group take seriously our obligation to respect and protect the information or “data” about you that we collect, process, or share with others. This Privacy Policy governs all websites and digital and non-digital properties owned or operated by TDMG (“Website”) and applies to all registrants, entrants, visitors and other users of such Website (“Users”).

We may occasionally change the features and content found on this site. Consequently, our privacy policy may be modified to reflect any revisions to the site. We suggest you revisit our privacy policy from time to time to be sure that you are familiar with our practices.

ACCEPTANCE OF PRIVACY POLICY: We reserve the right, at our discretion to change, modify, add or remove portions of this privacy policy. If we make material changes to this policy, we will notify you here, by e-mail, or by means of a notice on our home page. This policy and all of our legal obligations under this policy are subject to the laws of Florida and the USA regardless of the location of the user. If you use or access our Website after such a change is made, you will consent to and agree to be bound by the change.

1. Why does TDMG collect personal information?
2. From whom does TDMG collect consumer data?
3. What information does TDMG gather or track?
4. What are Cookies?
5. Does TDMG disclose user information to third parties?
6. Can I opt-out of TDMG’s data collection and/or distribution?
7. What about external web sites?
8. What does TDMG do to keep their site secure?
9. Does TDMG collect information from users outside of the United States?
10. Does TDMG collect personal information from children?
11. What about TDMG’s offline information and privacy practices?
12. What are my Nevada rights?
13. What are my California rights?

1. Why does TDMG collect personal information?
We need to collect certain personal information from our customers and visitors primarily to process their sweepstakes entries and magazine orders for the products and services we offer. For example, we need your full name, full address, e-mail address, and telephone number to verify eligibility and enter you in the sweepstakes, notify you if you’ve won a prize and to send you any products and/or services you may purchase. We may also use the personal data we collect for systems administration and troubleshooting purposes, and to report aggregate information to our partners and others. To provide our users with a more personalized and relevant web service, we also collect and use personal data to identify users’ specific interests and needs. If given permission, we may notify our users of offers and information we feel may be of interest to them available from our partners. If given permission, we may also share information with our select partners who may directly contact our users regarding their own offers of interest.

Your email will only be shared with our preferred mailing partner for the purposes of sending third party promotional email communication.

Providing Customer Service may be another reason to collect personal information, in order to communicate to you via SMS / email / direct mail / phone about your entries, orders, payments, and any other question you might have.

We may share our unsubscribe list with our select partners for the sole purpose of insuring that individuals on this list do not receive electronic commercial mail messages containing ThinkDirect Marketing Group advertisements that may be sent by such partner. If you are currently receiving commercial e-mail messages from TDMG after previously providing permission and no longer wish to receive such offers you may always follow the unsubscribe procedures which will be found within the commercial e-mails received from TDMG. From time to time, we post customer testimonials on our web site which may contain personally identifiable information such as the customer’s name. We do obtain the customer’s consent prior to posting these testimonials.

2. From whom does TDMG collect consumer data?

Directly from the Consumer: The information you provide us directly when registering on our website (e.g., name and address), claiming prizes, and entering into the Sweepstakes.

Integrated data collection: when you visit our website, information such as your IP address, device ID, browser type, internet service provider, operating system, date/time stamp and through the use of “cookies” or “Pixel tags”, through similar tracking technologies.

Third party sources: we also obtain data from third party platforms, advertisers, publishers, as well as commercial data aggregators who collect data from businesses and other sources and make that data available to commercial users like TDMG for a valuable consideration, or through coops and exchanges in which third party operators pool their consumer data and make it available to others in the coop or exchange.

3. What information does TDMG gather or track?

TDMG collects data from our consumers in the following categories:

Identifying information: mainly during the initial registration process for sweepstakes entry and order
processing.
Demographic Data: We may collect information such as geographic area, gender, age, entry date, and sweepstakes winners and payout preferences.
Technical Data: We may collect site traffic data such as your IP address, Mobile Advertising ID, and data on the website that may have referred you to us.
Interest/Affinity Data: Information about your hobbies, products you’ve subscribed to and payments made.
Winner Information Data: Information may be collected for the sweepstakes you’ve entered, prized you’ve won, and payment preferences.

4. What are Cookies?

“Cookies” are small pieces of information that are stored by your web browser software on your computer’s hard drive or temporarily in your computer’s memory. The use of cookies is now an industry standard, and users will find them on most major web sites, TDMG may place and store Internet cookies on a user’s hard drive. Cookies can save any of the types of information noted above. Cookies enable us to recognize you and personalize your viewing experience on TDMG websites. For example, we use cookies to recognize user access privileges, track site usage and traffic patterns, add advertisements for goods or services that we think may interest you, and estimate our audience size. We also use cookies to store user names and information that are supplied at registration.

Although most web browsers are initially set up to accept cookies, if you prefer, you can decline the placement of a cookie on your hard drive by using the appropriate feature(s) of your web browser software (if available) to delete the cookie. Please note, however, that certain areas on the site will not function properly if your web browser does not accept cookies. As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.

5. Does TDMG disclose user information to third parties?

Except as otherwise noted in this policy, TDMG only discloses user information in aggregate form to partners. For example, we might tell a partner how many users visited TDMG websites over a period of time, but we will never tell them who it was, unless that user has given us permission to do so.

TDMG believes that consumers should be able to control the use of their data. We will not share personally identifiable information with partners if you follow the simple unsubscribe procedure. If an opt-out is not submitted, we will notify users of exciting offers of interest from TDMG and our partners. We may also share your name, land address, e-mail address and telephone number with our partners so that they can send you offers directly for products and services that may be of interest to you. The personal information our users provide to us may be combined with other personally identifiable information (such as demographic information and past purchase information) available from our records and other sources. We use a third party to verify your address, in order to process your order prior to shipping. This allows us and our partners, with permission, to present our users with offers and information geared towards their interests.

We require each permission based e-mail our partner sends to include a description of a simple opt-out process that will enable you to stop receiving promotional e-mail from them in the future. Nevertheless, TDMG is not and cannot be responsible for the activities or privacy policies of these third parties. We may share our unsubscribe list with our select partners for the sole purpose of insuring that individuals on this list do not receive electronic commercial mail messages containing TDMG advertisements that may be sent by such partner.

We do not rent, license, or sell personal data to third parties unless permission is granted. In the event of a merger, acquisition, or change of control of TDMG, customer data would be considered a business asset and would be transferred. We will disclose information we maintain when required to do so by law, for example, in response to a court order or a subpoena. We may also disclose personal information as required by law or to protect the safety and security of our users.

Marketing Partners who wish to target and/or retarget our Users with relevant advertisements or products, and magazine publishers or direct-to-consumer merchants who wish to communicate directly with our customers and users through name rental or exchange.

We use other third parties such as credit card processors and e-mail service providers to provide order fulfillment and e-mail delivery services on our site. When you register on our site, we will share your personally identifiable information as necessary for these third parties to provide these services.

These third parties are prohibited from using your personally identifiable information for any other purpose including their own marketing purposes.

6. Can I opt-out of TDMG’s data collection and/or distribution?

Receiving email messages from TDMG, our affiliates and partners is optional. As noted earlier, the collection, use, and distribution of personal data helps us create a more personalized, relevant, and intelligent web service for our users. While some basic data is necessary to provide certain services, such as entry into the sweepstakes and fulfillment of products and services ordered through TDMG, there are some cases where the submission of information is optional.

We will not contact you with e-mail offers or share personally identifiable information with our partners if you follow the simple opt-out procedure. If you are already receiving TDMG emails and no longer wish to receive such communications, simply follow the “unsubscribe” instructions that appear in every TDMG e-mail.

If you have provided personal information directly to our third-party partners and are receiving email communications directly from them, TDMG cannot, in most instances, unsubscribe users. If you wish to unsubscribe from one of our partner’s e-mail programs, please follow their unsubscribe procedures which will be found within their e-mails or in their privacy policy.

7. What about external web sites?

To the extent hyperlinks or banner advertisements incorporating hyperlinks are utilized on this Site to access third party sites, users should be aware that these third-party web sites are not controlled by TDMG and, therefore, are not subject to this privacy policy. We recommend that users check the privacy policies of these individual sites to see how their personal information will be utilized.

Please note that our Web sites utilize framing techniques to make it appear that the user is still on the site when the user is actually on a third-party Web site. For example, if you are on a page that has the look and feel of TDMG, but the URL listed in your browser is a different URL than TDMG, then know that the information is being collected by this third party and their privacy policy governs the collection and use of this information.

8. What does TDMG do to keep their site secure?

We have implemented a number of security features throughout TDMG sites that are intended to prevent the unauthorized release of or access to the user information we collect online. For example, database information is firewall protected. Also, only authorized TDMG personnel have access to any stored personal information we collect from our users. Moreover, password and credit card information you submit to TDMG is always encrypted during transmission. Users should be aware that e-mail is not encrypted and is not considered a secure means of transmitting credit card numbers.

While we strive to create a secure and reliable site for our users, the confidentiality of any communication or material transmitted over the Internet cannot be 100% guaranteed. Users should keep in mind that any information submitted through an Internet transaction is potentially accessible to the public, and consequently, can be collected and used by others without their consent. TDMG is not responsible or liable for illegal interception of personal data via any Internet transaction. When we collect and transmit sensitive data such as your credit card number, we encrypt it using secure socket layer technology (SSL).

9. Does TDMG collect information from users outside of the United States?

TDMG sites are not directed to visitors residing outside of the United States. However, as indicated in the Official Rules on the site, some sweepstakes promoted on TDMG sites are open to residents of the 50 United States, the District of Columbia, Puerto Rico (excluding other U.S. territories and possessions), and Canada (except for the province of Quebec). Residents from these countries can participate in these sweepstakes by registering online. We regret that as a result of system limitations at this time non-U.S. residents may not order products or services through TDMG.

10. Does TDMG collect personal information from children?

The TDMG sites are not targeted nor directed to children under the age of eighteen. TDMG does not intend to collect personally identifiable information from individuals in this age group. If TDMG receives actual notice that a child under the age of eighteen has provided personal information to TDMG, we will use reasonable efforts to remove such information from its files.

11. What about TDMG’s offline information and privacy practices?

ThinkDirect Marketing Group collects certain personal information from our direct mail customers and entrants primarily to process sweepstakes entries and fulfill orders for the products and services we offer. For example, we need your full name, full address and telephone number to enter you in the sweepstakes, notify you if you’ve won a prize or to send you any magazine subscription or product or service you may purchase. We may also use the personal data we collect for systems administration and troubleshooting purposes, and to report aggregate information to our partners and other third parties. From time to time we may share or exchange marketing information about the consumers who respond to our offers with other companies so they may contact you about products and services that may interest you.

If you do not want your name passed on to other companies for the purpose of receiving marketing offers, please contact us at 1-800-690-3623 and we will be pleased to respect your wishes. Please make sure to provide your full name, address, city, state and zip code information.

12. What are my Nevada rights?

Under Nevada law, consumers that reside in Nevada have the right to make a verifiable request prohibiting us from selling “covered information” that we have collected or will collect to a third party (“Verifiable Opt-Out Request”). “Covered Information” may include your first name and last name; a home or other physical address; and email address; a social security number; an identifier that allows for a person to be contacted either physically or online; or any other information concerning a person collected from the person through the Site and maintained in combination with an identifier that makes the information personally identifiable. We may not be required to follow a consumer’s Nevada Opt-Out Request under specific circumstances.

If you are a Nevada consumer and would like to make a Verifiable Opt-Out Request, please email us cs@nmemags.com. We intend to respond to Verifiable Opt-Out Requests within 60 days. If we need more time to respond to a Verifiable Opt-Out Request, we will notify you of such an extension.

13. What are my California Privacy rights?

This Privacy Notice for California Residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. PLEASE READ CAREFULLY THIS NOTICE, AND ALL OTHER NOTICES DESCRIBED ABOVE, WHICH IS PART OF THE WEBSITE PRIVACY POLICY, BEFORE YOU PROVIDE PERSONAL INFORMATION TO US VIA THE WEBSITE. ACCESSING, DOWNLOADING OR OTHERWISE USING THE WEBSITE INDICATES THAT YOU ACCEPT AND AGREE TO BE BOUND BY THIS CCPA PRIVACY NOTICE, PRIVACY POLICY IN FULL. IF YOU DO NOT ACCEPT THIS CCPA PRIVACY NOTICE, DO NOT ACCESS, DOWNLOAD OR OTHERWISE USE THE WEBSITE. You acknowledge (a) that you have read and understood this Privacy Policy; and (b) this Privacy Policy shall have the same force and effect as a signed agreement.

Information We Collect

We collect the following categories of personal information as described in the “How and what information does TDMG gather or track?” section #2 above:

• Identifiers, such as name, email address, mailing address, cookie and device identifiers, and IP address
• Demographic information, such as your gender and age
• Internet or other electronic network activity information, such as log data and information about the devices and computers you use to access TDMG websites
• Electronic, visual, or similar information, such as photos that you may provide voluntarily
• Other information you provide, such as responses to surveys or messages to customer service
• Inferences drawn from any of the above, including about the content or ads that may be of interest to you

We collect this personal information from you, your devices, third parties, and from the following categories of sources:

• Directly from you
• Indirectly from you. For example, through information we collect from our clients in the course of providing services to them
• Directly and indirectly from activity on our website
• From third-parties that interact with us in connection with the services we perform

How We Use Personal Information

We use these categories of personal information as described in the “Why does TDMG collect personal information?” section above. In addition, we use personal information in the following ways:

• To fulfill your requests for products, services, or information
• To process your payments and ship your products
• To provide technical and other support, including to understand and resolve technical issues with the website
• To verify eligibility and enter you in the sweepstakes, contests or promotions
• To notify you if you’ve won a prize
• For testing, research, analysis and product development

Sharing Personal Information

We disclose these categories of personal information for the business purposes described in the “Does TDMG disclose user information to third parties? ” section above. In addition, we disclose information for business purposes to the following entities:

• Service providers
• Our affiliates
• Other individuals, services, and partners at your request
• Contests and promotions partners
• Marketers
• Social media networks
• Entities for legal purposes
• Entities for sales or transfer of business or assets

Your Rights under the CCPA

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Access to Specific Information, Data Portability and Deletion Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. As a California Consumer, you also have the right to make a verifiable request that We delete any personal information about you which we have collected or maintained.

The CCPA allows you to request us to:

Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information, the business or commercial purpose for collecting your personal information, and the categories of third parties with whom we share/disclose personal information
Provide access to and/or a copy of certain personal information we hold about you
Delete certain personal information we have about you
Provide you with information about the financial incentives that we offer to you, if any
Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you.

Verification: We will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, e-mail address, and physical address.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please submit your request as outlined on the following page:

CCPA – California Residents

If you prefer, you may submit a verifiable consumer request to us by one of the following methods:

• Calling us at 1-800-690-3623
• By email at cs@nmemags.com with the subject line: “CCPA Request”
• By writing us at: ThinkDirect Marketing Group PO Box 9084 Clearwater, Florida 33758

Notice of Right to Opt-Out of Sale of Personal Information

California residents may opt out of the “sale” of their personal information. Under the CCPA, “sale” is broadly defined to mean the sharing of personal information with third parties, in exchange for valuable consideration, who are not acting as our service providers or who are otherwise not restricted from using data only on our behalf or pursuant to an applicable CCPA exception.

In some circumstances, we may share certain of your information with third parties to provide you with offers, promotions, and opportunities that may be of interest to you, which may be considered a “sale” under the CCPA.

Under the CCPA, “sale” may also include allowing third parties to “collect” certain information, such as IP address, and/or browsing behavior, through cookies and similar technologies, to deliver targeted advertising on the Services or other services. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you.

If you would like to opt out of our use of your information for such purposes that are considered a “sale” under California law, you may do so as outlined on the following page: Do Not Sell My Personal Information. Please note that we do not knowingly sell the personal information of minors under 18 years of age without legally-required affirmative authorization.

Right to Non-Discrimination for the Exercise of Your Privacy Rights

We cannot discriminate against you because you exercised your rights under the CCPA. You have a right not to receive discriminatory treatment from ThinkDirect Marketing Group for the exercise of your privacy rights conferred by the CCPA.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will update the Policy last updated date as noted on the bottom of this page

Contact Information

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California or Nevada law, please do not hesitate to contact us at:

• Postal Address: ThinkDirect Marketing Group PO Box 9084 Clearwater, Florida 33758
• You can reach us by telephone at 1-800-690-3623.
• Or you can reach us by email: cs@nmemags.com

Policy last updated: February 28, 2020