PRIVACY POLICY

Effective June 2015

This Privacy Policy (“Privacy Policy”) of Coverdell & Company, Inc. (“We” “Us” “Our”) explains how We use Personal Identifiable Information (“Personal Information”) Users submit and how it is thereafter stored in the company’s database. In Our efforts to bring the customer (“Member” “You”) of the membership or other program (“The Program”) the Program in which You enrolled or requested information, We reserve the right to make limited use of basic personal information which You have agreed to provide to Us in connection with signing up and/or enrolling in the Program. You consent to receive periodic communications from Us and/or Our business affiliates regarding Your membership or inquiry, the Program and its benefits as well as consent to be contacted by Us or any third parties regarding other products or services that may be of interest.

What information is collected?

Generally, We gather Personal Information that You expressly provide when You sign up to receive information and/or enroll in the Program. This information includes, for example, Your name, mailing address, e-mail address, and phone number or some other unique personal identifier that We can use to confirm sales and billing information (e.g. city of birth or mother's maiden name). Occasionally, We may request other information from You that may be used by Our Membership Services department to confirm enrollment, update Your account or confirm Your order and so that We can improve Our program and offerings. If You use one of Our websites, We may collect data regarding Your traffic and use of the site. When You visit Our websites, cookies are placed on Your hard disk which allows a computer to remember who You are and make Your return visits to the website more convenient. We recommend that You leave cookies turned onto take full advantage of some of Our site features though they are not required.

Who is collecting the information?

The Program is owned, marketed and/or distributed by Coverdell & Company, Inc. The information collected is owned by Us and/or Our marketing partners depending on who offered You the Program. Note that this Privacy Policy outlines only Coverdell’s policy.

How do We use the information collected?

We use the Personal Information You provide to Us to service Your Program membership and store in Our database to contact You about future Programs or other offers. For example, We request Your mailing address so We know where to send the Program Material and any other information You may request. We also may send You additional membership information such as updates about Our Program or other programs that may be of interest to You. We use Your credit card information to bill You for the membership fee. We may use Your email address to notify You of Program updates and to further provide You with additional product information and opportunities of membership or offers. The Personal Information that is collected may also be shared with other groups within the Coverdell organization, and with Coverdell’s affiliates and/or marketing partners depending on who offered You membership in the program. If Your Program involves the use of one of Our websites, the technical and statistical information that is automatically collected from Your computer whenever You visit Our website is used to help Us improve the site and the member experience. From time to time We may disclose general statistical information about Our website and its visitors such as the number of visitors, the number and type of products purchased, etc.

Do you share personal information with third parties?

We may share Personal Information with third parties whom We employ to perform functions on Our behalf. For example, We use a third party to verify and process Your credit card information in order to charge You for Your Membership fee. All third parties are contractually obligated to use Personal Information only for the purpose for which it is given. We are not responsible for the information practices of third parties. The collection, use and disclosure of information by third parties are subject to their respective privacy policies, which may differ from Our policy.

From time to time, We may also share Personal Information with Our affiliates and/or marketing partners or unaffiliated third parties who offer products and services We think will be of interest to You.

Furthermore, limited customer information may potentially be transferred as a business asset of Coverdell & Company, Inc. As We continue to develop Our business, We may buy or sell assets. In such transactions, customer information generally is one of the transferred business assets. Also, in the event that Our company or substantially all of its assets are acquired, customer information will of course be one of the transferred assets. In the event that customer information is transferred as described in this paragraph, members may be notified and have the ability to opt-out of having their personal information transferred to any new entity.

How do I change/modify my information?

You can change, modify or update Your member information simply by calling the customer service number on Your membership card.

How do you secure member information?

Data Security is a critical issue for Coverdell. Credit card data is always protected during transmission between Our websites and administrative environment through the use of SSL technology. Once received at Our administrative center, data is encrypted, and access to data is protected through multiple controls and security practices in accordance with PCI standards. Coverdell is a PCI certified organization.

Internal access to member information is protected and can only be accessed by password. We also contract with industry experts to institute and review web and other security on a periodic basis.

How do you update your Privacy Policy?

We will notify You in advance if there is a material change in Our privacy practices. Additionally, We will post any changes to this Privacy Policy to Our websites if Your Program involves the use of a website.

How do I contact the Program or opt out?

If You have any questions about the practices of this Program,Your dealings with any of Our websites, or to opt out of information sharing and be placed on Our Do Not Contact List, You can contact Us at 1-800-308-0374.

By using any of Our websites, if applicable, You consent to the collection and use of information as it is disclosed in this Privacy Policy statement. If You do not agree We ask that You contact Us to opt out of information sharing and do not use Our site. Thank You.

Effective June 2015