Last updated October 23rd, 2013
2. Types of Information Collected and Uses of Collected Information
We collect two types of information about our Website Users: Personally Identifiable Information and Non-Personally Identifiable Information.
Personally Identifiable Information. Personally Identifiable Information is information that identifies a specific End User. When you engage in certain activities on the Website, such as creating an account, ordering a product or service from us or our partners, submitting content and/or posting content in discussion forums, entering a contest or sweepstakes sponsored by us or our partners, filling out a survey, posting a review, sending us or our partners feedback, requesting information about our services, submitting an affiliate agreement, applying for a job, posting a video or signing up for special offers from third parties through the Website (collectively, “Identification Activities”), we may ask you to provide certain information about yourself. It is optional for you to engage in an Identification Activity. If you elect to engage in an Identification Activity, however, we may ask you to provide us with certain personal information about yourself, such as your first and last name, mailing address (including zip code, if applicable), email address, telephone number and date of birth. When you order products or services, we may also ask you to provide us with your credit card number, expiration date and authentication codes or related information. Depending on the activity, some of the information we ask you to provide is identified as mandatory and some is identified as voluntary. If you do not provide the mandatory information for a particular activity that requires it, you will not be permitted to engage in that activity.
We use Non-Personally Identifiable Information to troubleshoot, administer the Website, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with our authorized Third Party Service Providers and Advertisers to measure the overall effectiveness of our online advertising, content, and programming.
3. Release of Personally Identifiable Information
We will not share your Personally Identifiable Information with other parties except as provided below:
We may share your information with Putto Merchants. From time to time, we provide offers from particular merchants (referred to as "Putto Merchants") who, as part of the offer, request information on Putto customers who purchased the offer. In those cases, we share some of your Personally Identifiable Information with Putto Merchants. Sharing this Information will allow a Putto Merchant to market directly to you should they choose to do so. However, we will only share Personally Identifiable Information with a Putto Merchant if you engage in an Identification Activity, and then only to the Putto Merchant involved in that Identification Activity. Please note that we will only provide a Putto Merchant your information with an opt-in notice to you, in which you will have a chance to choose that Putto not give the Putto Merchant your personal information. We specifically disclaim any responsibility or liability for the actions of such Putto Merchant. While we inform them that they are only permitted to communicate with you for the purposes of the specific promotion with Putto, we do not have any responsibility for the actions of the Putto Merchant, and the actions of the Putto Merchant are not in our control.
We may share your information with Authorized Third Party Service Providers. We provide some of our services and products through third parties. These “Third Party Service Providers” perform functions on our behalf, like sending out and distributing our administrative and promotional emails. We may share your Personally Identifiable Information with such Service Providers to fulfill orders, deliver packages, send postal or email, administer contests or sweepstakes, remove repetitive information on customer lists, analyze data, provide marketing assistance, provide search results and links, process credit card payments, operate the Website, troubleshoot, and provide customer service. We may also collect personal information from individuals and companies ("Affiliates") with whom we have business relationships and may have to also share their information with Service Providers to accomplish our administrative tasks. For example, when you order a service, we release your credit card information to the card-issuing bank to confirm payment for the service and, if applicable, release your address to the delivery service to deliver the service. Likewise, we may release an Affiliate’s information to our bank to send out a payment. We encourage Putto Merchants and Third Party Service Providers to adopt and post privacy policies. However, the use of your Personally Identifiable Information by such parties is governed by the privacy policies of such parties and is not subject to our control.
4. Release of Non-Personally Identifiable Information
We may disclose or share Non-Personally Identifiable Information with Partners, Affiliates and Advertisers. For example, we may share aggregated demographic information (which does not include any Personally Identifiable Information) with “Third Party Advertisers” or “Third Party Advertising Companies” and other parties as provided below:
We use Third Party Advertising Companies to serve ads when you visit our Website. These companies may use Non-Personally Identifiable Information about your visits to this and other websites in order to provide, through the use of network tags, advertisements about goods and services that may be of interest to you.
We also use Third Party Service Providers to track and analyze Non-Personally Identifiable usage and volume statistical information from our Users to administer our Website and constantly improve its quality. We may also publish this information for promotional purposes or as a representative audience for Advertisers. Please note that this is not Personally Identifiable Information, only general summaries of the activities of our Users. Such data is collected on our behalf, and is owned and used by us.
5. Updating and Correcting Information
We believe that you should have the ability to access and edit the Personally Identifiable Information you provide us. You may change any of your Personally Identifiable Information by sending us an email at email@example.com
or writing to us at Unit 609, 6/F, CCT Telecom Building, 11 Wo Shing Street, Fotan, New Territories, Hong Kong. Please indicate your name, address and email address, and what information you would like to update when you contact us.
We encourage you to promptly update your Personally Identifiable Information if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on the Website. In addition, it may be impossible for us to completely delete all of your information because we periodically backup information.
6. User Choices on Collection and Use of Information
As discussed above, you can always choose not to provide information, although it may be required to engage in a certain activity on the Website.
As a condition of purchase of our products and services, we will send you Administrative and Promotional emails. We will send you information regarding your account activity and purchases as well as updates about our products and promotional offers. You cannot opt-out of Administrative Emails. "Administrative Emails" relate to a User’s activity on the Website, and include emails regarding a particular User’s account, requests or inquiries, and purchases of products and services. In contrast to Administrative Emails, however, you do have a choice with respect to Promotional Emails. "Promotional Emails" advertise our products and services, including exclusive sales and other offers, and/or the products and services of our Advertisers and Affiliates. If you do not want to receive Promotional Emails from us, you may elect to opt-out of receiving Promotional Emails at any time after registering by e-mailing us at firstname.lastname@example.org
, by writing to us at the address contained herein. When contacting us, please indicate your name, address, email address, and what Promotional Emails you do not want to receive.
7. Security of Information
We take security seriously and take numerous precautions to protect the security of Personally Identifiable Information. You can access your Personally Identifiable Information on our Website through a password and your email address. This password is encrypted. We recommend that you do not share your password with anyone. In addition, your Personally Identifiable Information resides on a secure server that only selected personnel and contractors have access to. We encrypt certain sensitive information using Secure Socket Layer (SSL) technology to ensure that your Personally Identifiable Information is safe as it is transmitted to us.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we employ commercially reasonable security measures to protect data and seek to partner with companies which do the same, we cannot guarantee the security of any information transmitted to or from the Website, and are not responsible for the actions of any third parties that may receive any such information.
8. Data Tracking
Other Tracking Devices. We may use other industry standard technologies like pixel tags and web beacons to track your use of our Website pages and promotions, or we may allow our Third Party Service Providers to use these devices on our behalf. Pixel tags and web beacons are tiny graphic images placed on certain pages on our Website, or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, pixel tags and web beacons generate a Non-Personally Identifiable notice of that action. Pixel tags allow us to measure and improve our understanding of visitor traffic and behavior on our Website, as well as give us a way to measure our promotions and performance. We may also utilize pixel tags and web beacons provided by our Affiliates and/or Marketing Partners for the same purposes.
9. Privacy Policies of Third Party Websites
10. Miscellaneous Privacy Issues
Children. Minors under the age of 18 may not use the Website. We do not collect or maintain information from anyone known to be under the age of 18, and no part of the Website is designed to attract anyone under the age of 18. Putto does not sell products for purchase by children. In certain instances, we sell children's products for purchase by adults. If you are under 18, you may use Putto only with the involvement of a parent or guardian.
Public Areas. We may provide areas on our Website where you can publicly post information about yourself, can communicate with others, or can review products and submit media content. This information may be accessible by other consumers and companies and may appear on other websites or web searches, and therefore this information could be read, collected, and used by others. For example, if you post your email address along with a public product quality review, you may receive unsolicited messages. We have no control over who reads your postings or what other users may do with the information you voluntarily post, so please use caution when posting any personal information.
11. Contacting Us
Whether you’re a new or loyal customer, marketer, publisher, media member or job seeker we’d like to stay connected and want to hear from you!
Unit 609, 6/F, CCT Telecom Building,
11 Wo Shing Street, Fotan,
New Territories, Hong Kong