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ONLINE PRIVACY POLICY

LAST UPDATED September 25, 2014

FELA, Inc. ("FELA" or "we") respects the privacy of visitors to our web site mylifecents.com (the "Web Site" or "mylifecents.com") and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. This Privacy Policy is intended to describe for you, as an individual who is a user of the Web Site or our services, the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures. We encourage you to read this Privacy Policy carefully when using our Web Site or services or transacting business with us.

By using our Web Site, you are accepting the practices described in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Web Site. Each time you use the Web Site, the current version of the Privacy Policy will apply. Accordingly, when you use the Web Site, you should check the date set forth above to determine whether an updated version has been posted and to review any changes since your last visit.

If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

1. Types of Information We Collect on the Web Site

We may now, or in the future, collect three types of information from users of the Web Site: "personally identifiable information" such as your name, email address, postal address, phone number, and, if you transact business with us, financial information such as credit card number, type and expiration date. We also may collect "aggregate information" such as age, gender, financial habits and demographic information, frequency of visits to the Web Site, search terms entered and pages most frequently accessed. Lastly, we may also collect “self-reported” information based on your interactions with the Web Site which include education related information such answers to questions, quizzes, surveys, and assessments; we may collect self-reported financial information and other personal metrics.

We use this information in an effort to improve your experience on the Web Site and to communicate with you about the Web Site and our services. We may also use this information to make offers to you, to help us target specific services to you, and to help us develop and tailor the Web Site to your interests.

2. Collection of Personally Identifiable Information

We only collect personally identifiable information that is voluntarily provided by users of the Web Site when users register as members on the Web Site ("Members"). For example, when you register as a Member on the Web Site, you must provide personally identifiable information such as your name, address, telephone number, email address, and for certain services, a valid credit card number.

If you are a Member and send us correspondence, including emails or faxes, we may retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from FELA to you. We retain those records in an effort to measure and improve our customer service and to investigate potential fraud.

3. Collection of Aggregate Information

We also collect aggregate information from all visitors to the Web Site. Aggregate information is used in a collective manner, and no single person can be identified by that compiled information.

4. Self-Reported Information

When you interact with the Web Site or a FELA owned Web Site, we may collect and store information about you directly from you. We may also collect and store personally identifiable information about other people that you provide to us. If you use our Web Site to send others (friends, relatives, colleagues, etc.) information that may interest them or messages (such as invitations) through the Web Site, we may store your personally identifiable information, and the personally identifiable information of each such recipient.

5. Collection and Use of IP Addresses and Browser Information

In addition, we automatically collect IP addresses and browser information, such as browser type, language and access times, to obtain aggregate information on the Web Site. An IP address is a number assigned to your computer by a web server when you are on the Internet. When you are on our Web Site, we have a server that logs your computer's IP address. We only use the information we find out from tracking IP addresses in the aggregate, such as how many users entered a specific area of our Web Site, and not to track a specific IP address to identify an individual user. However, we reserve the right to use such information to identify a user if safety and/or security issues arise or to comply with legal requirements.

6. Cookies

When you visit our Web Site, we may assign your computer one or more cookies, to facilitate access to our Web Site and to personalize your online experience. A cookie is a small text file that is stored on a user's computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Web Site. A persistent cookie remains on your hard drive for an extended period of time. For example, when you sign in to our Web Site, we will record your user or member ID and the name on your user or member profile in the cookie file on your computer. We also may record your password in this cookie file, if you indicated that you would like your password saved for automatic sign-in. For security purposes, we will encrypt any usernames, passwords, and other user or member account-related data that we store in such cookies. In the case of sites and services that do not use a user or member ID, the cookie will contain a unique identifier. We may allow our authorized service providers to serve cookies from our Web Site to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our Web Site, content and advertising. You may delete or decline cookies by changing your browser settings. (Click "Help" in the toolbar of most browsers for instructions.) If you do so, some of the features and services of our Web Site may not function properly.

We may allow third-parties, including advertising companies, and ad networks, to display advertisements on our Web Site. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. Our Web Site does not automatically provide any personally identifiable information to these third parties, but they may collect information about where you, or others who are using your computer, saw and/or clicked on the advertisements they deliver, and possibly associate this information with your subsequent visits to the advertised websites. They also may combine this information with personally identifiable information they collect from you. The collection and use of that information is subject to the third-party's privacy policy.

You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit adobe.com and make changes at the privacy settings panel. If you disable cookies, you may lose some of the features and functionality of mylifecents.com, as LifeCents cookies are necessary to track and enhance your experience using the Service. Please note that companies delivering advertisements with our content or on our websites may also use cookies or other technologies, and those practices are subject to their own policies.

7. Web Beacons

Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies which are stored on the user's computer hard drive, web beacons are embedded invisibly on the web pages (or in email) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns. We also may receive an anonymous identification number if you come to our Web Site from an online advertisement displayed on a third-party website.

8. Sharing, Selling, and Trading Personally Identifiable Information Collected Online with Third Parties

We do not actively rent, sell or otherwise disclose your personally identifiable information to unrelated third parties without your consent, except as stated in this Privacy Policy. In general, we collect, store and use your information to provide you with a safe, smooth, efficient, and customized experience. For example, we may use information collected from you in any one or more of the following ways:

§ to create your accounts and allow use of our Web Site

§ to make recommendations related to badges, goals, tasks, and other content

§ to identify and suggest connections with other mylifecents.com users

§ to enable user-to-user communications

§ to enable communications with partners, mentors, and coaches

§ to provide access to rewards, incentives, and other virtual currencies

§ to connect you to relevant programs, partners, products, and services

§ to provide technical support and respond to user inquiries

§ to prevent fraud or potentially illegal activities, and enforce our Terms of Service

§ to deliver and target advertising

§ to notify users of Service updates

§ to provide peer-to-peer comparisons and promote User achievements

§ to solicit input and feedback to improve FELA’s products and services and customize your user experience

§ to inform users about new products or promotional offers

§ to engage in commonly accepted practices, such as contacting you at the email address We have on file if you are a potential winner in a sweepstakes or contest

We may share personally identifiable information with third party service providers hired by FELA, such as companies who perform technical and processing functions on our behalf. These services may include processing credit card payments, providing customer service and marketing assistance, performing business and sales analysis, supporting our Web Site functionality, and supporting contests, sweepstakes, surveys and other features offered through our Web Site. These third parties are not authorized to retain, share, store or use your personally identifiable information for any purpose other than completion of the specific services for which they were hired.

One important use of your information is communication. If you have provided your e-mail address to FELA, we will use it to respond to (i) customer support inquiries, and (ii) keep you informed of your activity and progress, including comments from mentors, coaches, partners, and administrators. We may also send promotional e-mail messages and promotional SMS messages ("Promotional Communications") directly or in partnership with parties other than FELA. Each Promotional Communication will generally offer recipients choices about receiving additional messages.

When you engage in promotions offered through our Web Site or our services, we may share personally identifiable information with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes. When you elect to engage in a particular merchant's offer or program, you authorize us to provide your email address and other personally identifiable information to that merchant.

In addition, in the following circumstances we may share or transfer personally identifiable information to unrelated third parties: (a) to comply with a legal requirement, judicial proceeding, court order, or legal process served on us; (b) to investigate a possible crime, such as fraud or identity theft; (c) when we believe it is necessary to do so to protect the rights, property, or safety of our company or other persons; and (d) In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

9. Sharing, Selling, and Trading Aggregate Information Collected Online with Third Parties

We may sell, share, trade or otherwise disclose aggregate information collected on our Web Site with third parties. As stated earlier, no single person can be identified by such aggregate information.

10. Submissions/Forums/Groups/Comments

We may provide areas on our Web Site where you can post information about yourself and others and communicate with others, as well as post reviews of products, establishments, and the like, or upload content (e.g. pictures, videos, audio files, etc.). Such postings are governed by our Terms of Use. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personally identifiable information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personally identifiable information.

11. Third-party Websites

There are a number of places on our Web Site where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement or a search result on our Web Site, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personally identifiable information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the "privacy" link typically located at the bottom of the webpage you are visiting.

12. How You Can Access Your Information

If you have an online account with us, you have the ability to review and update your personally identifiable information online by logging into your account. You can also review and update your personally identifiable information by contacting us at support@myFELA.com. More information about how to contact us is provided at the end of this Privacy Policy.

After you close your account, you will not be able to sign in to our Web Site or access any of your personally identifiable information. However, you can open a new account at any time. If you close your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our Web Site or our users, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties' policies.

13. Your Choices about Collection and Use of Your Personally Identifiable Information

You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Web Site because such information may be required in order for you to register as a Member; participate in a contest, promotion, survey, or sweepstakes; ask a question; rate, review or comment on articles and merchants, or initiate other transactions on our Web Site.

You will be given the opportunity, in any commercial e-mail that we send to you, to opt out of receiving such messages in the future. It may take up to 10 days for us to process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that changing information in your account, or otherwise opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.

If you are a resident of California, in addition to the rights set forth above, you have the right to request information from us regarding the manner in which we share certain categories of personally identifiable information with third parties for their direct marketing purposes. California law gives you the right to send us a request to receive the following information:

  • the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year
  • the names and addresses of the third parties that received that information; and
  • if the nature of the third party's business cannot be determined from their name, examples of the products or services marketed.

We may provide this information in a standardized format that is not specific to you. The designated email address for submitting these requests to support@myFELA.com.

14. How We Protect Your Personally Identifiable Information

We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personally identifiable information from unauthorized access and disclosure. For example, only authorized employees are permitted to access personally identifiable information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your sensitive personally identifiable information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personally identifiable information. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personally identifiable information, searches, or other communications will always remain secure. Users should also take care with how they handle and disclose their personally identifiable information and should avoid sending personally identifiable information through insecure email. Please refer to the Federal Trade Commission's website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.

IN NO EVENT WILL FELA OR OUR OFFICERS, DIRECTORS, EMPLOYEES, AFFILIATES, AGENTS, LICENSORS, SUPPLIERS OR ANY PARTY INVOLVED IN CREATING, PRODUCING OR DELIVERING The Web SITE ("RELEASED PARTIES") BE LIABLE IN ANY MANNER WHATSOEVER FOR ANY DAMAGES OF ANY KIND, INCLUDING BUT NOT LIMITED TO DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL OR PUNITIVE DAMAGES ARISING OUT OF: (a) The Web SITE, YOUR ACCESS, USE OR INABILITY TO USE The Web Site; (b) ANY FAILURE OR PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DEFECT, DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS OR LINE OR SYSTEM FAILURE (INCLUDING LOSS PROFITS, LOSS OF BUSINESS OR DATA, BUSINESS INTERRUPTION, AND DAMAGES THAT RESULT FROM INACCURACY OF THE INFORMATION OR INCONVENIENCE, DELAY, OR LOSS OF THE USE OF THE web SITE); (c) PERSONAL INJURY OR PROPERTY DAMAGE, OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO AND USE OF THE Web SITE, (d) ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SECURE SERVERS AND/OR ANY AND ALL PERSONALLY IDENTIFIABLE INFORMATION STORED THEREIN, (e) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE, WHICH MAY BE TRANSMITTED TO OR THROUGH THE Web SITE BY ANY THIRD PARTY. THE FOREGOING LIMITATIONS APPLY WHETHER THE ALLEGED LIABILITY IS BASED ON CONTRACT, TORT, NEGLIGENCE STRICT LIABILITY OR ANY OTHER BASIS, EVEN IF THE RELEASED PARTIES OR ANY OTHER PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

15. Children's Privacy

Our Web Site is a general audience site, and we do not knowingly collect personally identifiable information from children under the age of 13. However, we are concerned about the safety of children when they use the Internet, and understand that children may not understand all of the provisions of our Privacy Policy or make informed decisions about the choices that are made available to adult users of the Web Site. If we become aware that a user is under the age of 13 and has registered without prior verifiable parental consent, we will remove his or her personally identifiable information from our files.

16. Visiting Our Web Site from Outside the United States

This Privacy Policy is intended to cover collection of information on our Web Site from residents of the United States. If you are visiting our Web Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By visiting our Web Site or using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

17. No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personally identifiable information relating to users of the Web Site.

18. Changes to this Privacy Policy

We will occasionally update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will revise the "last updated" date at the top of this Privacy Policy. If we make any material changes in the way we collect, use, and/or share your personally identifiable information, we will notify you by sending an e-mail to the e-mail address you most recently provided us in your account, profile or registration (unless we do not have such an email address), and/or by prominently posting notice of the changes on our Web Site. We recommend that you check our Web Site from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

19. How to Contact Us

If you have any questions about this Privacy Policy or our information-handling practices, or if you would like to request information about our disclosure of personally identifiable information to third parties for their direct marketing purposes, please contact us by e-mail or postal mail to the attention of the "FELA Privacy Officer" as follows:

Email: info@myFELA.com

Postal:

FELA

400 Massachusetts Ave, NW #614

Washington, DC 20001