A. Overview
B. Information We Collect
C. Our Use and Disclosure of Information
D. Information Security
E. Accessing and Changing Your Information
F. Contacting Us
A. Overview
In order to operate the New4vets.com on-line buying services and to reduce the risk of fraud, New4vets.com ("NVC" or "we") must ask you to provide information about yourself and your credit card and/or bank account. This Privacy Policy describes the information we collect and
how we use that information.
New4vets.com takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail in Part C below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on the New4vets.com.com Web site, whether the services are offered by New4vets.com, by its subsidiaries, or by various third-party vendors and/or suppliers.
If you have questions or concerns regarding this Privacy Policy, you should first contact New4vets.com using this form. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact TRUSTe. TRUSTe will then serve as a liaison with New4vets.com to resolve your concerns.
By accepting the Privacy Policy and Member Agreement in registration, you expressly consent to our use and disclosure of your personal information in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the New4vets.com Member Agreement. This Privacy Policy will take effect on March 1, 2006. This Privacy Policy was last updated on March 1, 2006. Please note that your personal information will be stored and processed on our computers in the United States. The laws on holding personal data in the United States may be less stringent than the laws of your country but New4vets.com will hold and transmit your personal information in a safe, confidential and secure environment. If you object to your personal information being transferred or used as described in this Privacy Policy, please do not register for the New4vets.com service.
Notification of Changes
This policy may be revised over time as new features are added to the New4vets.com service or as we incorporate suggestions from our customers. If we are going to use or disclose your personally identifiable information in a manner materially different from that stated at the time we collected the information, you will have a choice as to whether or not we use or disclose your information in this new manner. Any material changes will be effective only after we provide you by e-mail with at least 30 days' notice of the amended Privacy Policy (if you have closed your New4vets.com account, you will not be contacted to notify you of the amended Policy and your personal information will not be used or disclosed in this new manner). We will post the amended Privacy Policy prominently on our Web site so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the New4vets.com Web site at www.new4vets.com at any time for the most current version of our Privacy Policy. New4vets.com Shops and other pages on the New4vets.com Web site include links to third party Web sites. These sites are governed by their own privacy statements, and New4vets.com is not responsible for their operations, including but not limited to their information practices. members submitting information to or through these third party Web sites should review the privacy statement of these sites before providing them with personally identifiable information. A Special Note About Children. Children are not eligible to use our service and we ask that minors (under the age of 18) do not submit any personal information to us or use the service.
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B. Information We Collect
Required Information
To become a New4vets.com member, you must provide your e-mail address and a member password. To use our on-line catalog or buying group service, you must supply your name, title, company name, company address, company phone number, and company email address. In order to make payments through New4vets.com, you must provide credit or debit card information. We also ask you to choose a security questions to answer (such as your city of birth or your pet's name). This required information is necessary for us to process transactions, issue a new password if you forget or lose your password, protect you against credit card fraud and to contact you should the need arise in administering your account.
In order to comply with the Bank Secrecy Act, we will require your Tax Identification Number if you send or receive certain high-value transactions or high overall payment volumes through New4vets.com. If you choose to register or apply for certain optional features or products offered through New4vets.com Web sites you may be required to provide additional information to establish that you qualify for such features or products.
Transaction Information
When you use New4vets.com VetTraderTService to purchase or sell your used equipment and to send money to someone else or request money from someone else, we ask you to provide information related to each transaction, including the amount of the transaction, the type of transaction (purchase of goods, purchase of services, or simple money transfer ("quasi-cash")) and the e-mail address of the third party. We retain this information for each of your transactions through New4vets.com. We also collect the Internet address (IP address) of the computer or device you use to access your New4vets.com account, in order to help detect possible instances of unauthorized transactions. Information About You From Third Parties In order to protect all our members and customers against potential fraud, we may verify with third parties the information you provide. In the course of such verification, we may receive personally identifiable information about you from such services. In particular, if you register a credit card or debit card with New4vets.com, we will use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to New4vets.com, and that the card has not been reported as lost or stolen. If you register your online business with New4vets.com Shops or if you send or receive high overall payment volumes through New4vets.com, in some circumstances we will conduct a background check on your business by obtaining information about you and your business from a credit bureau or a business information service such as Dun & Bradstreet. If you incur a debt to New4vets.com, we will generally conduct a credit check on you by obtaining additional information about you from a credit bureau, to the extent permitted by law. New4vets.com, at its sole discretion, also reserves the right periodically to retrieve and review a business and / or consumer credit report for any account, and reserves the right to cancel your credit or debit card purchase privileges based on information obtained during this credit review process.
Additional Verification
If we cannot verify the information that you provide, we may ask you to send us additional information by fax (such as your drivers' license, credit card statement, and/or a recent utility bill or other information linking you to the applicable address), or to answer additional questions online to help verify your information.
Web Site Traffic Information
Because of the way that World Wide Web communication standards work, when you arrive at or leave the New4vets.com Web site, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Web site you visit while you are on the New4vets.com site, the type of browser you use and the times you access our Web site. We use this information only to try to understand our customers' preferences better and to manage the load on our servers, so as to improve our service and your experience with New4vets.com. We do not track the Web sites that you visit before or after you leave the New4vets.com site.
Our Use of "Cookies"
"Cookies" are small files of data that reside on your computer and allow us to recognize you as a New4vets.com customer if you return to the New4vets.com site using the same computer and browser. We send a "session cookie" to your computer if and when you log in to your New4vets.com account by entering your e-mail address and password. These cookies allow us to recognize you if you visit multiple pages in our site during the same session, so that you don't need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect. We also use longer-lasting cookies to display your e-mail address on our sign-in form, so that you don't have to retype the e-mail address each time when you log in to your New4vets.com account. In addition, we use cookies to process our referral program, described in Section C below. Our cookie files are encoded so that your e-mail address and other information can only be interpreted by New4vets.com. We may, however, share cookie information regarding whether or not a certain member is already registered with New4vets.com with certain merchants with whom we have an official co-marketing relationship.
Customer Service Correspondence
If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from New4vets.com to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of
our Member Agreement. We may, over time, delete these records if permitted by law.
Questionnaires, Surveys and Profile Data
From time to time, we offer optional questionnaires and surveys to our members for such
purposes as collecting demographic information or assessing members' interests and needs.
The use of the information collected will be explained in detail in the survey itself. If we
collect personally identifiable information from our members in these questionnaires and
surveys, the members will be given notice of how the information will be used prior to their
participation in the survey or questionnaire.
Non-member Recipients and Requests
When a member either sends a payment to, or requests a payment from, an individual
who is not a registered member of New4vets.com, we will retain the information that the
member submits to us, including, for example, the other party's email address and/or
name, for the benefit of the member who is attempting to contact the non-member, so
that the member can see a complete record of his or her transactions, including
uncompleted transactions. Although this information is stored indefinitely, we will not
market to the non-member in any way at any time. Additionally, these non-members
have the same rights to access and correct information about themselves (assuming that
their email addresses were correct enough to reach them) as anyone else who uses
New4vets.com.
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C. Our Use and Disclosure of Information
Internal Uses
We collect, store and process your personal information on servers located in the United
States. We use the information we collect about you in order 1) to provide our services
and process your transactions, 2) to provide customer service, 3) to determine your
eligibility to receive offers for special features or products, such as the New4vets.com
Net Work Buying Group (NWBG) and 4) to improve our products and services. At your option
(as indicated in your New4vets.com Profile settings), we use the information you provide to
access specific third party services on your behalf and perform the actions that you
request us to perform, such as invoicing winning bidders on behalf of product/service sellers.
We give access to individually identifiable information about our members only to those
employees who require it to fulfill customer service requests.
Disclosure to Other New4vets.com Customers
If you are a registered New4vets.com member, your name, e-mail address, date of sign-up, and
whether you have verified access to our Network Buying Group are displayed to other New4vets.com
customers whom you have paid or who are attempting to pay you through New4vets.com. If you
are a Business account holder, we will also display to other New4vets.com customers the Web
site address (URL) and customer service contact information that you provide us.
However, your credit card number, bank account and other financial information will
NEVER be revealed to anyone whom you have paid or who has paid you through New4vets.com,
except with your express permission or if we are required to do so pursuant to a subpoena or other legal process.
If you are buying goods or services through New4vets.com, we will request that the mailing address that New4vets.com has confirmed for you match the billing address in the credit card system. You do not have to provide this information. If you do not provide the information, however, we may choose not to accept your New4vets.com payment and not to complete the transaction.
Because we work directly with manufacturers and/or other wholesale distributors with which we have various purchase agreements, and in order to complete your transactions efficiently and in a timely manner, we may have your item drop-shipped by the manufacturer, wholesaler or distributor. If an item is drop-shipped you will NOT incur any additional expenses, (i.e. shipping and delivery charges). At no time will you be invoiced by anyone other than new4vets.com. If you receive an invoice from other than new4vets.com please contact us at contact@new4vets.com immediately. You agree to permit New4vets.com to share information with the drop-ship manufacturer, wholesaler, distributor on the validity of the personally identifiable information you provided in your New4vets.com account.
New4vets.com does not store the personally identifiable information provided by these merchants
to validate the existence of your account.
New4vets.com will also disclose to other New4vets.com VetTraderT customers the number
of VetTrader transactions you have received from Verified New4vets.com customers (as defined in the Member Agreement on the www.new4vets.com website), or other aggregate measures that provide an
indication of your reputation with other New4vets.com customers.
Disclosure to Third Parties Other Than New4vets.com Customers
New4vets.com will not sell or rent any of your personally identifiable information to third parties.
New4vets.com will not share any of your personally identifiable information with third parties
except in the limited circumstances described below, or with your express permission
(and with other New4vets.com customers as described above). These third parties are limited by
law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.
- We share information with companies that help us process the transactions you request and protect our customers' transactions from fraud, such as sharing your credit card number with a service that screens for lost and stolen card numbers. See "Information About You From Third Parties" in Section B above. Additionally, if you go into a negative balance and owe us money, we may share information with processing companies including collection agencies.
- We may disclose the information we collect, as described in Section B above, to companies that perform marketing services on our behalf. We may also disclose the information we collect (but not your bank account or credit card information) to other financial institutions with whom we have joint marketing agreements, in order to determine whether you are pre-approved for the products that New4vets.com is jointly marketing with the third party (such as a possible New4vets.com Visa credit card). These companies are subject to confidentiality agreements with us and other legal restrictions that prohibit using the information except to market the specified New4vets.com-related products or services, unless you have affirmatively agreed or given your prior permission for other uses. If you do not want New4vets.com to share any of your information with our joint marketing partners, please log in to your account to set your Notification preferences in the Profile page of the My Account tab to indicate that you do not want to receive Partner/Third-Party Promotions or the New4vets.com Periodical Monthly Newsletter and Product Updates. Use the following URL to see your Notification preferences: https://www.new4vets.com.com/PREFS-NOTI.
- We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our Member Agreement. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity's contact information (but not bank account or credit card information) to victims who request it.
- We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.
- When a member signs up for a co-branded version of New4vets.com (e.g. New4vets.com Evite) through links to New4vets.com from our co-branded partner's website, New4vets.com will share with the co-branded partner that member's name, e-mail address and physical address in order to provide enhanced integration between New4vets.com's services and the services of our co-branded partner. If you do not want your information shared with New4vets.com's co-branded partner, you should sign up with New4vets.com directly and not through a link from our partner's website.
- We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
- We share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our members live in California. However, this aggregated information is not tied to personally identifiable information.
- As with any other business, it is possible that New4vets.com in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by New4vets.com, including customer account information, but would continue to be bound by this Privacy Policy unless and until it is amended as described in Section A above.
- We share your information with our parent, subsidiaries and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.
Our Contacts with New4vets.com Customers
We communicate with members on a regular basis via e-mail to provide requested services, and we also communicate by phone to resolve customer complaints or investigate suspicious transactions. We use your e-mail address to confirm your opening of a New4vets.com account, to send you notice of payments that you send or receive through New4vets.com (including referral payments described below), to send information about important changes to our products and services, and to send notices and other disclosures required by law. We also use your e-mail address to send you other types of communications including the New4vets.com newsletter, VetTrader announcements, new product updates, customer surveys and notice of special third-party promotions. You can choose whether to receive some, all or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your account on the New4vets.com Web site and changing your preferences in the Profile page of the My Account tab. You can also change your choices at any time through the same procedure.
In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.
Internet Address Information
We use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.
Your Use of Information and Our Services
In order to facilitate the transactions between New4vets.com members, our VetTrader service allows you limited access to other members' contact or shipping information. As a VetTrader seller you may have access to the Member ID, email address and other contact or shipping information of the purchaser, and as a purchaser you may have access to the Member ID, email address and other contact information of the seller. By entering into our Member Agreement, you agree that, with respect to other members' personally identifiable information that you obtain through the site or through an New4vets.com related communication or New4vets.com-facilitated transaction, you will only use this information for: (a) New4vets.com-related communications that are not unsolicited commercial messages, (b) using services offered through New4vets.com (e.g. insurance, shipping and fraud complaints), and (c) any other purpose that such member expressly agrees to after adequate disclosure of the purpose(s). In all cases, you must provide members with the opportunity to remove themselves from your database and review any information you have collected about them. In addition, under no circumstances, except as defined in this Section, can you disclose personally identifiable information about another New4vets.com member to any third party without our consent and the consent of such other member after adequate disclosure. Note that law enforcement personnel and other rights holders are given different rights with respect to information they access.
New4vets.com does not tolerate spam. Therefore, without limiting the foregoing, you may not add a New4vets.com member to your mail list (email or physical mail) without their express consent after adequate disclosure, even if said member has previously made a purchase from you. We strictly enforce our Anti-Spam Policy! To report New4vets.com-related spam to New4vets.com, please contact us at
spamnotice@new4vets.com.
Merchant Referral Program
When you sign up for a New4vets.com account, you become eligible to participate in our
Member Referral Extras (MRE) program. We provide you with a link on the Member Referral
Extras page which identifies you as the referrer. If a new member referral uses that link to sign up for a Member Purchase Account or Member Buying Group Account, and completes the bonus requirements, you are eligible for a referral bonus extra. If you use a referral link to sign up, your business name (if you have a Business account) or first and last name (if you have a Premier account) may be listed in the referrer's New4vets.com account, along with the amount of bonus you have generated for the referrer, which is calculated as a percentage of your transaction volume, as described in the Merchant Referral Bonus Policy. Please use our referral program responsibly. We strictly enforce our Anti-Spam Policy! Read details on the Referral Bonus.
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D.
Information Security
Information Security
New4vets.com is committed to handling your customer information with high standards of information security. Your credit card and bank account information are stored only in encrypted form on computers that are not connected to the Internet. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We test our security systems regularly and also contract with outside companies to audit our security systems and processes. For more information on New4vets.com's security practices, please visit the New4vets.com Security Center.
The security of your New4vets.com account also relies on your protection of your New4vets.com password. You may not share your New4vets.com password with anyone. New4vets.com will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the New4vets.com website, which will always have a URL beginning with http://www.new4vets.com/.
Any e-mail or other communication requesting your password, asking you to provide sensitive account information via email, or linking to a website with a URL that does not begin with https://www.new4vets.com.com/ should be treated as unauthorized and suspicious and should be reported to New4vets.com immediately using this form. If you do share your New4vets.com password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account at www.new4vets.com.com/us/ and changing your Profile settings, and also contact us right away as described in Section F below.
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E.
Accessing and Changing Your Information
You can review the personal information you provided us and make any desired changes
to such information, or to the settings for your New4vets.com account, at any time by logging in to your account on the New4vets.com Web site and changing your preferences in the Profile page of the "My Account" tab. You can also close your account through the New4vets.com Web site. If you close your New4vets.com account, we will mark your account in our database as
"Closed," but will keep your account information in our database. This is necessary in
order to deter fraud, by ensuring that persons who try to commit fraud will not be able
to avoid detection simply by closing their account and opening a new account. However,
if you close your account, your personally identifiable information will not be used by us
for any further purposes, nor sold or shared with third parties, except as necessary to
prevent fraud and assist law enforcement, or as required by law (for example, to send
former Money Market Fund investors a report of dividends paid during the calendar year
for tax reporting purposes).
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F.
Contacting Us
If you have any questions about this privacy statement, New4vets.com's information practices,
or your dealings with New4vets.com, you can contact us using this form, call toll-free 1-888-475-3064 Monday through Friday between the hours of 9am and 5pm PST, or write us at New4vets.com, 8891 W. Flamingo, Suite 103, Las Vegas, NV 89147.
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