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KeyCorp Executive Suites is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Statement of Privacy applies to the KeyCorp Executive Suites Web site and governs data collection and usage. By using the KeyCorp Executive Suites website, you consent to the data practices described in this statement.

COLLECTION OF YOUR PERSONAL INFORMATION

KeyCorp Executive Suites collects personally identifiable information, such as your e-mail address, name, home or work address or telephone number. KeyCorp Executive Suites also collects anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites.

There is also information about your computer hardware and software that is automatically collected by KeyCorp Executive Suites. This information can include: your IP address, browser type, domain names, access times and referring Web site addresses. This information is used by KeyCorp Executive Suites for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the KeyCorp Executive Suites Web site.

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through KeyCorp Executive Suites public message boards, this information may be collected and used by others. Note: KeyCorp Executive Suites does not read any of your private online communications.

KeyCorp Executive Suites encourages you to review the privacy statements of Web sites you choose to link to from KeyCorp Executive Suites so that you can understand how those Web sites collect, use and share your information. KeyCorp Executive Suites is not responsible for the privacy statements or other content on Web sites outside of the KeyCorp Executive Suites and KeyCorp Executive Suites family of Web sites.

USE OF YOUR PERSONAL INFORMATION

KeyCorp Executive Suites collects and uses your personal information to operate the KeyCorp Executive Suites Web site and deliver the services you have requested. KeyCorp Executive Suites also uses your personally identifiable information to inform you of other products or services available from KeyCorp Executive Suites and its affiliates. KeyCorp Executive Suites may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

KeyCorp Executive Suites does not sell, rent or lease its customer lists to third parties. KeyCorp Executive Suites may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, KeyCorp Executive Suites may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to KeyCorp Executive Suites, and they are required to maintain the confidentiality of your information.

KeyCorp Executive Suites does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

KeyCorp Executive Suites keeps track of the Web sites and pages our customers visit within KeyCorp Executive Suites, in order to determine what KeyCorp Executive Suites services are the most popular. This data is used to deliver customized content and advertising within KeyCorp Executive Suites to customers whose behavior indicates that they are interested in a particular subject area.

KeyCorp Executive Suites Web sites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on KeyCorp Executive Suites or the site; (b) protect and defend the rights or property of KeyCorp Executive Suites; and, (c) act under exigent circumstances to protect the personal safety of users of KeyCorp Executive Suites, or the public.

USE OF COOKIES

The KeyCorp Executive Suites Web site use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize KeyCorp Executive Suites pages, or register with KeyCorp Executive Suites site or services, a cookie helps KeyCorp Executive Suites to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same KeyCorp Executive Suites Web site, the information you previously provided can be retrieved, so you can easily use the KeyCorp Executive Suites features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the KeyCorp Executive Suites services or Web sites you visit.

SECURITY OF YOUR PERSONAL INFORMATION

KeyCorp Executive Suites secures your personal information from unauthorized access, use or disclosure. KeyCorp Executive Suites secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

CHANGES TO THIS STATEMENT

KeyCorp Executive Suites will occasionally update this Statement of Privacy to reflect company and customer feedback. KeyCorp Executive Suites encourages you to periodically review this Statement to be informed of how KeyCorp Executive Suites is protecting your information.

CONTACT INFORMATION

KeyCorp Executive Suites welcomes your comments regarding this Statement of Privacy. If you believe that KeyCorp Executive Suites has not adhered to this Statement, please contact KeyCorp Executive Suites at admin@keycorpexecutive.com. We will use commercially reasonable efforts to promptly determine and remedy the problem.

REGARDING EMAIL MARKETING:

Spam is absolutely prohibited by KeyCorp Executive Suites members and site users. KeyCorp Executive Suites supports ONLY permission-based email marketing practices. In this regard, KeyCorp Executive Suites has implemented some of the strictest policies in the email industry and supporting procedures that:

  • Help prevent the KeyCorp Executive Suites system from being used for the purpose of unsolicited email campaigns.
  • Encourage permission-based marketing.
  • Respond to all complaints suggesting sites have been used as a vehicle to send unsolicited email.

KeyCorp Executive Suites actively monitors import lists and outgoing emails for suspiciously large intended or actual broadcasts. Any user found Spamming is subject to being permanently barred.

Spam is unsolicited commercial email, junk mail or bulk mail that has not been requested by the recipient. In addition to wasting valuable resources and time, it is intrusive, irrelevant and often offensive, Typically, spam emails do not contain an option to unsubscribe from the mailing list. Spam is the opposite of permission-based emails ---- those that are anticipated, personal, relevant and often associated with a "pre-existing business or personal relationship."

PREVENTING UNSOLICITED EMAILS

User specifically agrees not to send unsolicited bulk email, for commercial or non-commercial purposes (unsolicited bulk email is defined as email sent to more than 10 individuals without their permission). The agreement also includes such provisions as:

User agrees not to post, upload or otherwise transmit:

  • any content related to inappropriate subject matters;
  • any content to "rented" or "purchased" lists;
  • any content that is unlawful, harmful, threatening, abusive, harassing, tortious, defamatory, vulgar, obscene, libelous, invasive of another's privacy, hateful, or racially, ethnically or otherwise objectionable;
  • any content that you do not have a right to post and transmit under any law or contractual/fiduciary relationships;
  • any content, such that such posting, uploading, or transmission constitutes the infringement of any patent, trademark, trade secret, copyright or other proprietary rights of any party;
  • any materials that contain software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment;
  • any materials which imposes an unreasonable large load on our infrastructure;
  • any content that is harmful to minors;
  • content that intentionally or unintentionally violates any applicable local, state, national or international law, including, but not limited to, regulations promulgated by the U.S. Securities Exchange Commission, any rules of national or other securities exchange, including without limitation, the New York Stock Exchange, the American Stock Exchange or the NASDAQ, and any regulations having the force of law;
  • content that is misleading or impersonates any person or entity or falsely states or otherwise misrepresents your affiliation with a person or entity;
  • content with manipulated, or forged identifiers;
  • content promoting harm or providing instructional information about illegal activities;

With regard to email campaigns, all users must also accept that an unsubscribe option will be automatically appended to every email sent to more than 100 people. This is mandatory. In the event that a user violates any one of our usage rules, or for any other reason deemed appropriate by KeyCorp Executive Suites or affiliated partner sites, KeyCorp Executive Suites reserves the right to suspend or terminate, without notice, their membership.

PERMISSION-BASED MARKETING

KeyCorp Executive Suites offers free tools to encourage system Users to create and manage "opt-in" (and double opt-in) lists of contacts. By building and using an "opt-in" (and double opt-in) lists, system Users can be certain that they are sending emails to recipients that have expressly given their permission to do so.

RECOMMENDED ACTION --- UNSOLICITED EMAIL COMPLAINTS

If a complaint is received by KeyCorp Executive Suites regarding alleged unsolicited emails being sent from our system tools, an immediate investigation is undertaken.

Warning -- The system User is notified that an unsolicited email complaint has been lodged against them and a demand is issued to "show proof" that the complainant opted in to the User's list. The User is reminded of the terms they accepted in the End User License Agreement (including possible legal ramifications if the user has is guilty of spamming). In addition, the complainant's email address is automatically tagged as "unsubscribed" if the complainant did unsubscribe--so no further emails are sent to the complainant. The User is also required to manually remove the complainant's email address from their contact list if the complainant did not unsubscribe.

Termination---If KeyCorp Executive Suites or affiliated partner sites have ANY reason to believe the User, despite the warnings, is or will continue to send unsolicited bulk email to more than 10 individuals without their permission, or any complainant who has previously unsubscribed, the User's KeyCorp Executive Suites account privileges are subject to immediate termination.

THINK YOU'VE BEEN SPAMMED?

  • Immediately unsubscribe using the "unsubscribe" link at the bottom of the email.
  • Forward the unsolicited email to admin@keycorpexecutive.com and provide any other information that you believe may help us in our investigation.

KeyCorp Executive Suites takes permission marketing very seriously. Thank you for reviewing our Anti-Spam Policy.

Many spam complaints are registered with anti-spam agencies. We fully support the efforts of agencies working to responsibly curtail the sending of unsolicited commercial email. However, if an individual opted-in to receive an email and then falsely and/or maliciously files a spam complaint against KeyCorp Executive Suites or affiliated partner sites, we will cooperate fully with appropriate agencies to ban the user from further use of anti-spam software and community.

This policy was last updated: January 1, 2009. We reserve the right to modify this policy at any time.



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