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Privacy Policy

Effective as of January 1, 2007

Wellington Companies, LLC (”we,” “us,” “our”) makes this web site www.goldpaq.com (the “Site”) available to consumers who are interested in information about obtaining cash for broken or unwanted jewelry (”Consumers”), subject to this privacy policy (the “Policy”) and the Site’s terms and conditions of use (”Terms and Conditions”).

TRUSTe Certified Privacy Seal

This Policy explains which information we collect on the Site, how we use and / or share this information, and how such information is maintained. By using this Site, you signify your acceptance of this Policy. If you do not agree to the terms of this Policy, in whole or part, you should not use this Site. See “Changes To This Policy”.

Note that this Policy applies only with respect to the information collected on the Site and not any information collected or obtained through other methods or sources.

Wellington Companies, LLC is a licensee of the TRUSTe Web Privacy Seal Program. TRUSTe is an independent, non-profit organization whose mission is to build user’s trust and confidence in the Internet by promoting the use of fair information practices. This privacy statement covers the Web site www.goldpaq.com. Because this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

If you have questions or concerns regarding this statement, you should first contact Aaron Rover at support@goldpaq.com or 1-877-465-3720. If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe.

TRUSTe will then serve as a liaison between us to resolve your concerns.

Personally Identifiable Information

Collection of PII

We collect all personally identifiable information (”PII”) that is volunteered during the registration process or in response to specific information requests explicitly presented to Consumers. To use our product you will be requested to provide the following PII: first and last name, postal address, e-mail address, and telephone number.

Use and Sharing of PII

We reserve the right to use PII:
(1) for the specific purpose that such information was to provide you with the opportunity to exchange your broken or unwanted jewelry for payment, (2) as disclosed at the time such information is provided; and / or (3) as disclosed in this Policy. However, please note that we may change this Policy at any time (See “Changes to this Policy,” below), and that therefore in the future we may request PII for additional purposes not currently included in this Policy.

As provided in the Terms and Conditions, users of the Site are required to provide their PII to us so that we may use such information to enable us to provide you with information regarding exchanging your broken or unwanted jewelry and / or other broken or unwanted gold pieces. If you do not provide the required PII, as set forth in this Policy, we will not provide you with information regarding jewelry purchase and you should not use this site.

Finally, we may disclose PII in order to: (1) comply with applicable laws; (2) respond to governmental inquiries; (3) comply with valid legal process; and (4) protect our rights or property, this Site, and / or other users of this Site.

By registering and using this Site, Members acknowledge that the processing of their PII for the purposes described above may involve the transfer of such PII from within the European Economic Area (”EEA”) to countries outside the EEA whose data protection regulation may not be as stringent as that within the European Union.

Communications From the Site
We will communicate with you via email to respond to an inquiry or if we have a question or a problem with your request. You may not opt-out of receiving these transactional emails.

Non-Personally Identifiable Information
We also collect certain non-personally identifiable information through the standard operation of our servers and the use of log files. Such information can include the non-personally identifiable information more fully described below.

IP Address
We collect your IP (Internet Protocol) address to help diagnose problems with our server, and to administer this Site. An IP address is a number that is assigned to your computer when you use the Internet. Your IP address is also used to help identify you during a particular session and to gather broad demographic data.

Clear GIFs
We use a common technology known as a “Clear GIF” or “1-by-1 Pixel” on the Site and in e-mail communications with users. A Clear GIF, or “graphic interface format” is a small graphic (in fact, truly a 1×1 pixel) that we (or our partners) place on a page of the Site. We may also occasionally place GIFs in e-mail messages that we send to users. GIFs, which do not contain any PII, provide us with important information about how users use the Site and respond to e-mail messages. With this information, we are better able to track the performance of certain promotions and understand the effectiveness of particular creative e-mail presentations. We may also allow our advertisers and promotional partners the ability to use GIFs on the Site solely to track users who link from their respective sites to this Site, but this ability to track such activity does not allow these entities access to user PII. We have no access or control of these clear gifs.

Although the information collected through the foregoing methods does not itself contain any PII, we may analyze and match such information with other information that you provide on this Site (including PII) as well as information that we may obtain elsewhere, and we may share all or some of such information with partners, prospective partners, and other affiliated or unaffiliated third parties. We may also disclose non-personally identifiable information in order to (1) comply with applicable laws, (2) respond to governmental inquiries, (3) comply with valid legal process, or (4) protect our rights or property, this Site and / or users of this Site.

Agents and Service Provides
Wellington Companies, LLC may employ other companies and individuals to perform services on its behalf and on behalf of our Site, such as (1) sending emails, (2) providing marketing assistance, and (3) database management and analysis and (4) shipping services. Such companies and individuals will have access to Member PII only to the extent necessary to perform their services, but will not be permitted to use it for any other purpose including their own marketing.

Cookies and Tracking

Utilities
A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this site. We do not link the information we store in cookies to any personally identifiable information you submit while on our site.

We use session ID cookies
We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close you browser.

If you reject cookies, you may still use our site, but your ability to use some areas of our site, such as contests or surveys, will be limited.

This privacy statement covers the use of cookies by www.goldpaq.com only and does not cover the use of cookies by any third parties.

We use a third-party tracking service named DART which uses cookies to track non-personally identifiable information about visitors to our site in the aggregate to track usage and volume statistics to better optimize our website for marketing purposes.

In the course of serving advertisements to this Site, if any, third-party advertisers or ad servers may place or recognize a unique cookie on your browser. The use of cookies by such third party advertisers or ad servers is not subject to this Policy, but is subject to their own respective privacy policies.

We have not access or control of these third party cookies.

Links from the Site
This Site provides links to many of our advertiser and partner Web sites or other Web sites. If you link to any of these third party Web sites, this Policy will not apply to your use of, and activities on, those sites. We encourage you to read the legal notices posted on these sites, including their privacy policies. We retain no responsibility or liability for your visitation to, and the data collection and use practices of, these sites.

Access
You may update or change your information by calling us at 1-877-465-3720 or emailing us at support@goldpaq.com

Note Concerning Visitors Under 18 Years of Age

Use of the Site, is neither intended for, nor directed towards children under the age of 18.

Security
While we take commercially reasonable precautions to safeguard information collected, transmitted, and store by our Site. We may be unable to prevent unauthorized access to such information by third parties or inadvertent disclosure of such information. Users acknowledge this risk when communicating with the Site. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Consent to Processing
By providing PII and other information to this Site, users fully understand and unambiguously consent to the collection and processing of such information in, and the transfer of such information to, the United States and other countries or territories, in accordance with the terms of this Policy.

Transfer in Certain Circumstances
In our sole discretion, we may transfer, sell or assign information collected on and through this Site, including without limitation, PII and other information, to one or more third parties, as a result of our sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation. You will be notified via email and / or prominent notice on our Web site for 30 days of any such change in ownership or control of your personal information. (See “Changes to this Policy”)

Customer Service
If you have any questions or concerns, please feel free to contact us at:
Wellington Companies, LLC; 16192
Coastal Highway, Lewes, DE 19958
or via email at support@goldpaq.com.

Changes to this Policy
We may, from time to time, amend this Policy, in whole or part, in our sole discretion. Any changes to this Policy will be effective immediately upon the posting of the revised policy on the Site. Depending on the nature of the change, we may announce the change (1) on the home page of the Site, or (2) provide such notice via e-mail to users. By continuing to use the Site following any changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, in whole or part, you must terminate your site usage.

Last updated: November 2, 2007

Presented by:
Wellington Companies, LLC
16192 Coastal Highway
Lewes, DE 19958

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