At PurseBlog, we are committed to protecting the privacy of our users and visitors. The following Privacy Policy describes the information Midley, Inc. (“Midley”, “we” or “us”) may collect when you use our PurseBlog website located at www.purseblog.com, which includes our PurseForum site located at forum.purseblog.com, our TalkShoes website located at www.talkshoes.com, or our PurseBlog mobile applications (which are referred to collectively in this Privacy Policy as “PurseBlog”) and how we may use that information to better serve visitors and members of PurseBlog. This Privacy Policy is part of, and is governed by, the terms and conditions set forth in our Terms of Service located at www.purseblog.com/terms/.

If you have questions about this Privacy Policy, please contact us.

1.Updates to this Privacy Policy. We may modify this Privacy Policy from time to time. We will notify you of material changes to this Privacy Policy by posting the amended terms on PurseBlog at least thirty (30) days before the effective date of the changes, and posting a notice on our website announcing the forthcoming changes. If you are a registered user of PurseBlog, we will notify you of material changes to this Privacy Policy by email at least thirty (30) days before the effective date of the changes. It is therefore very important that you make sure we have a current email address for you on file so that you will receive notice of any material changes. If you do not agree with the proposed changes, you should discontinue your use of PurseBlog prior to the time the new Privacy Policy takes effect. If you continue using PurseBlog after the new terms take effect, you will be bound by the modified Privacy Policy.

2. Children and Minors. Protecting the privacy of young children is important to us. For that reason, Midley does not knowingly collect any information from persons under 13 years of age, and no part of PurseBlog is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access PurseBlog at any time or in any manner. If Midley learns that information of persons under 13 years of age has been collected on PurseBlog (or in the case of California residents, information of persons under 18 years of age), then Midley reserves the right to take the appropriate steps to delete this information.

3. Information We Collect

A. Information Users Directly Provide to PurseBlog. Midley collects information when you register or request information from us. In order to become a registered user of PurseBlog, you must provide us with a user name, password and email address. As part of you user profile we may also collect additional information such as your date of birth, your geographic location, your occupation, and information about your hobbies. Providing this additional information is voluntary and you are not required to provide it in order to register to use PurseBlog.

B. Information Users Provide to PurseBlog about Other People. You may provide us with information about your friends and contacts when you use PurseBlog. For example, you may provide us with a friend or contact’s email if you want to invite that friend or contact to use or visit PurseBlog, or when you request that we send your friend or contact an email link to PurseBlog. In this circumstance, we will collect the recipient’s email address from you. However, we will only use the email address you provide for you friend or contact for the limited purpose of sending the applicable invitation, link or other communication to your friend or contact.

C. Information Automatically Collected through PurseBlog. Midley may also automatically collect information from you when you use PurseBlog. We collect this data to help us improve PurseBlog. The information we automatically collect through PurseBlog includes:

(i) In General: Your IP Address, Time of Visit, Browser Information and Operating System.

(ii) Mobile device users: In addition, when you access PurseBlog through your mobile device, we may be able to identify the location of your mobile device. You may choose not to share your location details with us by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

(iii) First party cookies: When you are logged in to PurseBlog we use cookies keep track of your application states and log in status. Cookies are small files that take up minimal space on your computer. Cookies work by assigning a number to a user that has no meaning outside of the assigning web site, in this case, PurseBlog. If you do not want information to be collected through the use of cookies, your browser allows you to deny or accept the use of cookies. There may, however, be some features on PurseBlog that require the use of cookies in order to customize the delivery of information and content to you, and you may not be able to use these features if you disable cookies.

D. Third Parties’ Use of Cookies and Web Beacons. PurseBlog may include third party advertising, links to other websites, and other content from third party businesses. These third parties may use cookies and web beacons to track the actions of users online over time and across different web sites or platforms to deliver targeted electronic advertisements to an individual user. For information about how tracking works for online advertising purposes you can visit http://www.aboutads.info/choices. In addition, some third party advertising companies may provide a mechanism to opt-out of their technology. For more information about the opt out process, you may visit the Network Advertising Initiative website, available at: http://www.networkadvertising.org/managing/opt_out.asp.

We do not have access to or control over web beacons or cookies that third party websites may use. We are not responsible for the privacy practices or the content of these third party websites. You are encouraged to review the privacy policies of the different websites you visit.

E. Do Not Track Settings. Your browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. However, those technologies are not yet standardized and as a consequence we will not disable tracking technology that may be active on PurseBlog in response to any “do not track” requests that we receive from your browser.

F. Social Media Services. We may provide social media features through PurseBlog that allow you to share information with your social networks and to interact with PurseBlog on social media sites. If you post any comments, reviews, photos or other information on any PurseBlog social media pages, we may display those comments, reviews, photos or information on PurseBlog. In addition, your use of these features may result in the collection or sharing of information about you by these sites, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites.

G. Public Forums. You should be aware that if you voluntarily disclose information in comment areas or on a bulletin board within PurseBlog, that information might be collected and disseminated by third parties, and, although unauthorized, result in, among other things, unsolicited inquiries, messages, and offers from third parties. In addition, if you are a registered user of PurseBlog and you are logged in to PurseBlog, depending on the settings you have selected, other users of PurseBlog, and the public generally, may be able to see your date of birth and profile picture, and any posts or comments you make will be associated with your PurseBlog User Name. Please understand that any information that is disclosed in these areas becomes public information and Midley therefore cannot control any subsequent uses by PurseBlog users or other third parties. Please exercise caution when deciding to disclose your information in a comment area or on a bulletin board.

4. How We Use Your Information

A. Operating and Improving PurseBlog. Among our primary goals in collecting information is to provide you with a customized experience when visiting PurseBlog and to make PurseBlog more valuable to you. We use information we collect through PurseBlog to closely monitor which areas of PurseBlog are used most and to determine which areas we need to focus on improving. This information is used exclusively by PurseBlog in aggregate form so that we may continue to improve the value of the services and information on PurseBlog for our members as a whole. We also use your Internet Protocol (IP) address to help diagnose problems with our servers, and to administer PurseBlog. Your IP address is used to help identify you, and to gather broad demographic data.

B. Contacting Users of PurseBlog. We may also use the information we collect from users of PurseBlog to contact and communicate with you and to respond to your communications and requests. If you provide your email address to us, we may email you about products and services that we believe may be of interest to you, including our newsletter by email if you have opted in to receive our newsletter. If you wish to stop receiving our newsletter, please follow the instructions contained in each email you receive from us which will allow you to opt-out of receiving our newsletter. In addition, if you do not wish to receive any marketing communications from us, you can do so by contacting us or by changing the appropriate option on your user account.

5. How We Share Your Information

A. No Transfers for Third Party Marketing Without Your Opt-In Request to be Included. Midley does not sell or rent user information it collects through PurseBlog to any third parties for their own marketing purposes. In the event Midley wants to sell or rent your information to third parties for their own marketing purposes in the future, we will notify you and you will have an opportunity to affirmatively opt-in to receiving these third party marketing communications.

B. Transfers to Third Parties. Midley does share your information with third parties in the following circumstances:

(i) Employees, Third-Party Processors and Third-Party Service Providers. We will disclose your information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers (“Service Providers”) who provide certain services to us or on our behalf, such as operating and supporting PurseBlog, analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the information needed to perform these limited functions on our behalf.

(ii) Complying with the law, Responding to Court Orders or Subpoenas, Enforcing our Terms of Service, or Protecting Our Rights or the Rights of Other Users. To the extent permitted by law, we will disclose your information to government authorities or third parties: (a) if required to do so by law, or in response to a subpoena or court order; (b) if we believe that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; (c) if we believe that you have abused PurseBlog by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws; or (d) to enforce our Terms of Service, comply with applicable laws or when we deem necessary to protect PurseBlog. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law or their privacy policies.

(iii) In Connection with Business Transfers or Bankruptcy. In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected from users of PurseBlog to third parties. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Privacy Policy. Any information you submit or that is collected after a transfer, however, may be subject to a new privacy policy adopted by the successor entity.

(iv) Aggregate Information. We may share information relating to users of PurseBlog with affiliated or unaffiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.

(v) DMCA Infringement Notifications. We may share your information with third parties if you submit a Digital Millennium Copyright Act (“DMCA”) Infringement Notification as described in our DMCA Policy.

6. Security. The information we collect through PurseBlog is stored within our database, and we use standard, industry-wide practices such as encryption and firewalls for protecting your information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the Internet. We recommend that you not disclose your PurseBlog password to anyone and that you do not post or store any information or content on PurseBlog that you want to keep confidential.

7. Revisions and Amendments. We will notify you of changes to this Privacy Policy by posting the amended terms on PurseBlog at least thirty (30) days before the effective date of the changes. If you are a registered user of PurseBlog, we will also notify you of material changes to the Privacy Policy by email at least thirty (30) days before the effective date of the changes. It is therefore very important that you make sure we have a current email address for you on file so that you will receive notice of any material changes. In addition, you will be required to affirmatively accept the new Privacy Policy the first time you visit PurseBlog and log in to your user account after the new Privacy Policy takes effect. If you do not agree to the new terms, you may terminate your account within the applicable thirty (30) day period by contacting us, and you will not be bound by the amended terms. Otherwise, the new terms will take effect after thirty (30) days.

8. Accessing, Changing and Managing Your Information. If you are a registered user of PurseBlog, you may make changes to the user information you have provided in connection with your account by logging in to your account and changing the applicable information, or by contacting us. If you choose to terminate your account, you may also request that we delete your information by contacting us. Following receipt of a request from you, we will take reasonable steps to update, correct or delete your information.

9. Use of Information Outside of Your Country of Residence. PurseBlog is directed to users located in the United States. If you are located outside of the United States and you choose to use PurseBlog or provide your information to us, your information may be transferred to, processed and maintained on servers or databases located in the United States. Your agreement to this Privacy Policy followed by your submission of information through PurseBlog represents your consent and agreement to these practices. If you do not want your information transferred to or processed or maintained in the United States, you should not use PurseBlog.

10. Special Notice to California Residents.

A. General Notice to All California Residents. Under California Civil Code sections 1798.83-1798.84, also known as the “Shine the Light Law,” any users of the Site who are California residents are entitled to request and receive once a year, free of charge, a notice from us describing what categories of personal customer information (if any) we shared with third parties, including our corporate affiliates, for their direct marketing purposes during the preceding calendar year. If applicable, the notice will identify the categories of information that we shared, and the names and addresses of the third parties and affiliates with which we shared your information. If you are a California resident and would like to request a copy of this notice, please submit a written request to the following address: PurseBlog.com, 216 Madison Ave, 9th Floor, New York, NY 10016 or by email. In your request, please specify that you want a “California Privacy Rights Notice.” Please allow at least thirty (30) days for a response.

B. Notice to California Residents Under the Age of 18. In addition, if you are a California resident under the age of 18 and are a registered user, you may request us to remove content or information posted by you on our websites, online services, or mobile applications by (a) submitting a request in writing to PurseBlog.com, 216 Madison Ave, 9th Floor, New York, NY 10016 and (b) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed. Please also note that California law recognizes that the removal of such content or information does not ensure complete or comprehensive removal of the content or information posted by you on our websites, online services, or mobile applications (for example, if other users copied such content and posted it elsewhere). Moreover, please note that California law provides that we are not required to erase or otherwise eliminate content or information if (a) state or federal laws require us or a third party to maintain the content or information; (b) the content or information was posted, stored, reposted, or republished by another user; (c) the content or information is anonymized so that you cannot be individually identified; (d) you do not follow the instructions provided in this paragraph on how to request and obtain the removal of such content or information; and (e) you have received compensation or other consideration for providing the content. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain such content or information as authorized by law or pursuant to a court order.

11. Contact Information. If you have questions about this Privacy Policy or further privacy concerns please do not hesitate to ask us by contacting us.

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