PRIVACY POLICY                     Back
Last Modified June 1, 2011 

Finlay Investments LLC and FinlayInvestments.com (“We,” Us,” the “Website(s)”) are only responsible for the presentation of 3rd party offers. We are not responsible for the administration of any sales, trial, membership, incentive, contest and/or product testing program. The owners of trademarked names and merchandise used in our promotions may not sponsor and may not have not endorsed the 3rd party actually making the offer. All trademarks are the property of their respective owners with all rights reserved.

We promote offers for 3rd parties. To become a member and participate in their promotions, you must be at least 18 years old and a legal resident of the United States with a valid email and mailing address. Some promotions are additionally restricted by the state in which you reside. If you do not meet these requirements, we ask that you do not complete the registration process. Furthermore, if you do not wish to receive marketing offers and promotions via email, direct mail, SMS text and/or telephone (see below under “Opt-In Notice”), we ask that you carefully consider whether to complete the registration process. 


How We Collect And Use Information:
This Policy describes how we store and use the information you give us. Our registration form may request that you provide certain contact and profile information (like your name, e-mail address, postal address, and phone number). This information is required in order for us to communicate with you about future promotions that we feel you may be interested in participating. 

Additionally, we may receive information about you from outside sources and add it to your membership information. We do this to improve personalization of the Services (for example, providing advertising or special offers that we think will interest you).

We also collect information such as the identification of the server your computer is logged onto and whether you responded to e-mail messages delivered to you on our behalf. We also may compare our member list to lists received from other companies, in an effort to avoid sending identical messages to our members. 

Cookies: A cookie is a small text file stored on a user’s computer for record-keeping purposes. We may use cookies to, among other things, save your password so you don't have to re-enter it each time you visit the website. Many web browsers are automatically set to accept cookies. You may change your browser settings to either reject cookies or notify you when a cookie is about to be placed on your computer. Please note, however, that rejecting cookies while visiting the website may result in certain parts of the website not operating correctly or as efficiently as if they were allowed. For example, you may need to enter your username and password each time you visit member's only areas. 
We also provide links to external advertisers and marketing partner companies; these sites may choose to use cookies to better promote their products and services. These advertisers and marketing partner companies have their own privacy procedures and policies that are not controlled by us.  We encourage our users to be aware of the individual privacy policies of every Web site that the user contacts. 
Clear Gif's (Web Beacons/Web Bugs): We may also use clear gif's (also known as web beacons or web bugs) to help us determine what content on our site is most effective. Clear gif's are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. We do not tie the information gathered by clear gif's to users’ personally identifiable information.

E-mail Links: In some instances we may include certain links in our e-mails that will allow us to monitor whether you access specific content or advertisements contained in that e-mail. When you click on one of these links, we will record that click and certain activities on the Web page associated with that link. We may use this information for various purposes, such as to conduct internal research on our users' demographics, interests, and behavior in and to our e-mail advertisements and content, and to better understand and serve you. 
We use all of this information in the following ways:
1. to provide you with personalized marketing information via electronic delivery, telephone and/or direct mail; 
2. to send you targeted advertising via electronic delivery, telephone, SMS text, and/or direct mail; 
3. to contact you for feedback and surveys via electronic delivery, telephone and/or direct mail; 
4. to send you general and administrative information about your membership via electronic delivery, telephone and/or direct mail; 
5. to provide your contact information to our marketing partners to allow them to send you special offers via electronic delivery, telephone and/or direct mail. This most often occurs when you request that we do so such as when completing an online survey; and
6. to deliver products to you for the purpose of incentive redemptions, contest fulfillment or product review and testing.

We may also employ other companies and individuals to perform certain functions on our behalf. Examples include sending direct and electronic mail, removing duplicate information from customer lists, analyzing data, and providing marketing analysis. These agents have access to members’ personal information as needed to perform their functions for us but we do not permit them to use it for other purposes.
Users who opt-in to the offerings from the sponsoring companies are also electing to receive additional information from these companies. The companies may request additional demographic and/or personally identifiable information for their use in subsequent marketing and promotion activities.  We are not responsible for the privacy practices or the content of such third party sites. If you have a question about the privacy policy of those other sites, please contact them directly. 
Right to Sell/License Data: We may sell and/or license the personal information that you provide to us to third party businesses. These businesses may include providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation, email marketing, SMS text marketing and telemarketing. 

OPT-IN NOTICE: By Participating, You Expressly "Opt In" To Receive Information And Grant Us Permission To Share Your Information:
Telemarketing:  By accepting the terms and conditions of this website, providing your telephone number to participate, and selecting “Yes” to any question on the website promoting products or services, you are agreeing to potentially receive telemarketing calls by us or on behalf of our marketing partners or affiliated entities. Notwithstanding that your telephone number may be listed at the Federal Trade Commission’s Do-Not-Call List, you give us, our partners or affiliated entities the right to contact you via telephone. 
 
By accepting the terms and conditions of this website, providing your telephone number to participate, you are expressly consenting to receive prerecorded telephone messages from us or a representative of the 3rd party sponsoring the offer. Your consent will be effective regardless of whether the number you have provided: (a) is a home, business, or cell phone line; and/or (b) is or will be registered on any state or federal Do-Not-Call (DNC) list, and shall remain in effect until you revoke your consent and cancel your subscription.   
 
To unsubscribe:  You may cancel your subscription and revoke your consent to receive telephone calls at any time by utilizing the opt-out procedure included in any message you receive.
 
NOTE: We are unable to honor any unsubscribe requests regarding e-mail sent by other 3rd party companies sponsoring the offers.  If you are receiving offers via e-mail, please follow the unsubscribe instructions included therein.  

SMS, Wireless and Other Mobile Offerings: By accepting the terms and conditions of this Site and providing your cell phone number, you are expressly consenting to receive SMS, wireless or other mobile offerings to your cell phone from us and other organizations. You understand that your wireless carrier's standard charges and rates apply to these messages. For SMS text messages, you may remove your information by replying "STOP", "END", or "QUIT" to the SMS text message you have received and we will remove your personal information within 10 days of receiving such request. 
 

Email: By accepting the terms and conditions of this Site and requesting further information you are consenting to receive email from us and the 3rd party sponsoring the offer.

Disclosures: We may disclose information about you and your use of our Web Site and Services if we believe such disclosure is reasonably necessary: (i) to comply with the law or legal process; (ii) to protect or defend the rights or property of us or others; (iii) to enforce the Website Terms and Conditions or this Privacy Policy; and (iv) to respond to claims that the content(s) of a communication violates the rights of another. In addition we may share or transfer information about you and that you provide to us, to one or more third party entities pursuant to a sale, merger, assignment, joint venture or other transfer or disposition of a portion, or all of, the assets or stock of our company or its affiliated entities, or as otherwise provided herein. We may also disclose information to allow third party business partners and affiliates deliver marketing offers to you.

Security: The Web Site has security measures in place intended to protect the loss, misuse and alteration of the information under our control. Our hardware infrastructure is housed in a controlled access facility that restricts access to authorized individuals with positive identification. Our network access to the infrastructure is protected by a firewall protection system. Member information is backed up on a periodic basis to protect against accidental loss. However, we cannot guarantee that communications between you and us will not be intercepted by others and that information stored on our servers will be free from unauthorized access. While we have taken reasonable precautions to protect this information, you should always use discretion in what information you send to us and not expect that such information will be absolutely free from intrusion. 
Updates: We may revise this Policy at any time in the future to (i) improve or modify the Service, (ii) reflect future developments in data information gathering, storing and release practices, (iii) comply with applicable laws, and (iv) reflect changes in business structure. Accordingly, you should review these terms and policy from time to time to check for updates. Your continued use of the Website shall evidence your acceptance of any changes.

DISCLAIMER OF WARRANTIES: THE SITE, THE GIVEAWAY, THE PROGRAMS, PRIZES, GIFTS, AND ANY PRODUCTS AND/OR SERVICES THAT YOU MAY RECEIVE FROM US OR ONE OF OUR THIRD PARTY PARTNERS ARE PROVIDED TO YOU ON AN “AS IS” AND “AS AVAILABLE” BASIS AND ALL WARRANTIES, EXPRESS AND IMPLIED, ARE DISCLAIMED TO THE FULLEST EXTENT PERMISSIBLE PUSUANT TO APPLICABLE LAW (INCLUDING, BUT NOT LIMITED TO, THE DISCLAIMER OF ANY WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT OF INTELLECTUAL PROPERTY AND/OR FITNESS FOR A PARTICULAR PURPOSE). IN PARTICULAR, BUT NOT AS A LIMITATION THEREOF, COMPANY MAKES NO WARRANTY THAT: (A THE SITE, THE GIVEAWAY, THE PROGRAMS, PRIZES, GIFTS, AND ANY PRODUCTS AND/OR SERVICES THAT YOU MAY RECEIVE FROM US OR ONE OF OUR THIRD PARTY PARTNERS WILL MEET YOUR REQUIREMENTS; (B) THE SITE, THE GIVEAWAY, THE PROGRAMS, PRIZES, GIFTS, AND ANY PRODUCTS AND/OR SERVICES THAT YOU MAY RECEIVE FROM US OR ONE OF OUR THIRD PARTY PARTNERS WILL BE UNINTERRUPTED, TIMELY, SECURE OR ERROR-FREE; (C) THE APPLICABLE PRIZE OR GIFT WILL MEET WITH YOUR REQUIREMENTS AND/OR THAT ANY THIRD PARTY PARTNER WILL PERFORM ITS ASSOCIATED OBLIGATIONS IN A TIMELY OR SATISFACTORY MANNER; (D) YOU WILL QUALIFY FOR A GIFT BY COMPLETING ANY OF COMPANY’S THIRD PARTY PARTNERS’ PROGRAM TERMS; OR (E) THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE SITE, THE GIVEAWAY, THE PROGRAMS, PRIZES, GIFTS, AND ANY PRODUCTS AND/OR SERVICES THAT YOU MAY RECEIVE FROM US OR ONE OF OUR THIRD PARTY PARTNERS WILL BE ACCURATE OR RELIABLE. THE SITE, THE GIVEAWAY, THE PROGRAMS, PRIZES, GIFTS, AND ANY PRODUCTS AND/OR SERVICES THAT YOU MAY RECEIVE FROM US OR ONE OF OUR THIRD PARTY PARTNERS, MAY CONTAIN BUGS, ERRORS, PROBLEMS OR OTHER LIMITATIONS. WE WILL NOT BE LIABLE FOR THE AVAILABILITY OF THE UNDERLYING INTERNET CONNECTION ASSOCIATED WITH THE SITE. NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM COMPANY, ANY OF ITS THIRD PARTY PARTNERS OR OTHERWISE THROUGH OR FROM THE SITE, SHALL CREATE ANY WARRANTY NOT EXPRESSLY STATED IN THIS AGREEMENT.