The Sefton Group, LLC ("SEFTON") respects your privacy and
we are committed to protecting it. We recognize your need for appropriate
protection and management of the personal information we learn about you while
you visit our Web Site and suite of Sefton Application software. This privacy
policy lets you know how we use and protect that information. The information
that we receive depends on what you do during your visit and use, and what
service(s) you request.
Purpose and Scope
about you when you visit or use our Web Site and Application software. It
describes how we use that information and how you can control it.
European Union Users
YOU EXPRESSLY CONSENT TO SEFTON GROUP'S PROCESSING OF YOUR
INFORMATION MAY BE PROCESSED BY SEFTON GROUP IN THE COUNTRY WHERE IT WAS
COLLECTED AND IN THE UNITED STATES. UNITED STATES LAWS REGARDING PROCESSING OF PERSONAL INFORMATION MAY BE
LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY.
IF YOU REPRESENT AN ORGANIZATION, YOU WILL BE RESPONSIBLE TO
ENSURE THAT EACH MEMBER OF YOUR ORGANIZATION (INCLUDING EMPLOYEES AND
CONTRACTORS) ABOUT WHOM PERSONAL INFORMATION MAY BE PROVIDED TO SEFTON GROUP
HAS GIVEN HIS OR HER EXPRESS CONSENT TO SEFTON GROUP'S PROCESSING OF SUCH
Information Sefton Group Gathers and Tracks
Customers and individuals who use the Applications are
hereafter collectively called "Users", or individually "User". Customer Content
and Users' personal and corporate information are collectively called "Customer
Information." SEFTON collects and utilizes Customer Information as follows:
Registration: Each User must register, obtain a password,
and be approved to use the Services. By registering, Users give at
least the following data: name, company name, e-mail address, mailing address
and telephone number.
Customer Information Tracking: SEFTON collects and tracks aggregate Customer
Information regarding how Users use the Applications.
Cookies: A cookie is a piece of data stored on the User's
the Users use our Applications, such as identifying a returning User when they are such
User logged in to SEFTON and giving such User a personalized service.
Contact between Users: When a User is working on a specific project
with other Users, Users can share contact data among themselves. Otherwise, Users cannot
obtain contact data of other Users or even discover who else is using the Applications.
Sharing of Customer Information: SEFTON may share aggregated demographic data
with its partners and advertisers. This
is not linked to any Customer Information that can be used to identify any
individual User or any particular supplier or client of Customer.
Correcting/Updating Customer Information: If a User's
personally identifiable data or account data changes, User may enter the
changes in the Accounts section of SEFTON's Web Site.
When you request a service or information, place an order,
submit feedback or participate in a forum or survey, we may need to ask you for
personal information such as your name, address, email address and telephone number.
We do not send you information unless you request it or we believe that the
information would benefit your business needs. If you do not want to receive
further information from us, simply contact us at the email address listed in
the Feedback; Removal from Contact List section below, and request to be
removed from the contact list. Once we
receive your request, we will use commercially reasonable efforts to remove
your name from the contact list. If you
wish to update any of your personal information, please contact us at such
email address, and we will use commercially reasonable efforts to update your
contact information accordingly. Please
be aware, however, even if we update your personal information in our contact
list, or we remove such information, it may still be stored in other databases
(including those kept for archival purposes) and may still be used to compile
aggregated or demographic information for supply to third parties in accordance
policy to not provide information that identifies you personally to a third
party without your permission, except to process or fulfill your requests, or
We may collect information about our visitors, customers,
page views, traffic patterns and related site and application information. This
information helps us evaluate and improve our Applications and is sometimes
useful for marketing and investment analysis. We may share this information with
third parties, but only in aggregate statistical form that includes no
personally identifying information.
Use of "Cookies"
Cookies are small files that many web sites place on your
standard and common practice of many web sites. For example, if you allow a
site to remember your login name or password, the site places a cookie on your
computer. We may place cookies on your computer to allow us to identify you
during future visits to our Web Site and during use of our Applications. We may
customize your visit. However, if you do not wish to receive cookies, or want
to be notified of when they are placed, your browser may permit you to do so.
In many browsers, you can change the browser settings to warn you before accepting
cookies or to block cookies. If you block cookies, you may not be able to use
certain site features or functions, or the Web Site may not operate in an optimal
SEFTON has used commercially reasonable efforts to design SEFTON's
Web Site, Applications and Customer's Web Site to make sure that only
authorized Users may obtain Customer Information about their projects. Users have a password that must be used each
time a User logs-in to SEFTON's Applications. Users may change their password at any time. SEFTON strongly urges Users not to share
their passwords with others. Also, SEFTON
strongly recommends that each User log-out completely after User is finished
using SEFTON's Applications. Unfortunately, no data transmission over the
Internet can be guaranteed to be secure, and every system that allows online
access is potentially vulnerable to outside attacks from unauthorized third
parties. As a result, while SEFTON
strives to protect Customer Information, SEFTON can't and doesn't guarantee or
warrant the security of any Customer Information User transmits to SEFTON, and
User does so entirely at User's own risk.
We use reasonable security procedures to protect the
information you share with us from unauthorized access or disclosure.
Privacy Protections for Children
Our Web Site and Applications are not directed at
children. Therefore, we do not wish to
receive, nor do we knowingly collect, personal information from minors.
Our Applications may link to other web sites not controlled
by SEFTON. Although we try to be careful in the selection of our strategic
service and technology partners, we are not responsible for the privacy or
security practices of any other web sites, and you acknowledge and agree that
any use of such other web sites is entirely at your own risk. You should carefully review the privacy and
security practices of the other web sites before you provide such web sites
with any of your personal information.
Links to Other Sites: Users may find links from the SEFTON
Application to independently owned, controlled and/or managed web sites whose
content SEFTON believes will be of possible interest and value to our Users.
Additionally, Users may see links from advertisers, sponsors and other partners
that may use SEFTON's logo as part of a co-branding agreement.
Once a User leaves SEFTON's servers, either directly or
indirectly, the use of any Customer Information a User provides is governed by
of these sites via a link from the site's homepage, the User should contact the
site directly for more information.
Although your privacy is very important to us, due to the
existing legal, regulatory, technical and security environment, we cannot fully
ensure, nor do we represent or warrant, that your private communications and
other personal information will not be disclosed to third parties. For example, we may be required to disclose
your personal information to the government or other third parties under
certain circumstances, or third parties may unlawfully intercept or access
transmissions or private communications.
Additionally, in the unlikely event we need to investigate
or resolve possible problems or inquiries, we can (and you authorize us to)
disclose any information about you (including personal information) to private
entities, law enforcement or other government officials as we, in our sole
discretion, believe necessary or appropriate. In all instances, we will cooperate fully when required by law to
provide information regarding visitors.
time. If SEFTON decides to change its
Users are always aware and able to determine what Customer Information SEFTON
collects, how SEFTON uses it, and under what circumstances, if any, SEFTON
discloses it. If at any point SEFTON
decides to use Customer Information in a manner different from that stated at
the time it was collected, SEFTON will notify Users by email. Each User will have an opportunity to consent
choice as to whether or not SEFTON uses Customer Information in this different
manner. Except as expressly set forth in
a notification of change as described herein, SEFTON will use Customer
Information was collected.
Feedback; Removal from Contact List
If you have a question or comment about the Sefton Group Web
Site and/or Applications, or wish to update your contact information or be
removed from our contact list, please email us at firstname.lastname@example.org.
Transfer of Information
Notwithstanding anything expressed or implied in this
transfer or disposition of some or all of the assets of The Sefton Group, LLC.,
or its affiliated entities, you agree that we can accordingly assign, sell,
license or transfer any information, including personal information, that you
have provided to us to those third parties directly involved in the transfer or
disposition of such assets.
the Sefton Group, Inc. Web Site & Application's Software End-User License
Agreement, which can be found at