CPO Commerce, LLC ("CPO") operates the websites located at  www.cpooutlets.com and other websites on  which a copy of this privacy policy appears (cumulatively the "CPO  Sites") as a service to its customers residing in the United States of  America, its territories and possessions. CPO is the owner or  authorized user of the content displayed on the CPO Sites.
				    CPO has adopted this privacy policy to inform you of the following: 
				    
				      - How we collect information on the CPO Sites.
- The types of information we collect on the CPO Sites.
- How we use information we collect.
- The circumstances under which CPO may disclose information gathered on the CPO Sites to third parties.
- The choices available to you on the CPO Sites regarding the collection and use of your information.
- Security procedures that we have put in place to protect your Personal Information.
For the purposes of this privacy policy, "Personal Information" is  personally identifiable information about an individual person, as more  particularly described under applicable privacy laws. You should  carefully review this privacy policy before using the CPO Sites.
				    If you have questions or concerns regarding this privacy policy or  the CPO Sites, you should contact us you should contact us (see section 12).
				
				1. Policy Scope
				    This privacy policy applies  to your use of the CPO Sites and CPO's treatment of information,  including Personal Information, collected by or on behalf of CPO  through the CPO Sites. Your use of linked or associated websites, or  websites to which you may be directed, may be subject to different or  additional terms, notices and policies, and such terms, notices and  policies shall control as to those websites. For information regarding  the collection and use of information on any of those websites or other  third party sites, please refer to the terms of use and policies  provided by those websites.
				    NOTE: THIS PRIVACY POLICY DOES NOT APPLY TO INFORMATION YOU PROVIDE,  EITHER VOLUNTARILY OR INVOLUNTARILY, THROUGH RESPONSES TO SOME SURVEY  REQUESTS INITIATED AT THE CPO SITES. SOME OF THESE SURVEYS ARE  CONDUCTED BY YAHOO! INC. AND OTHER THIRD PARTIES. SUCH INFORMATION WILL  BE GOVERNED BY THE APPLICABLE PRIVACY POLICY(IES) OF YAHOO! INC. OR  OTHER THIRD PARTIES. 
				
				2.	Our Information Collection Practices
				    Automatically Collected Information. When you visit the CPO Sites to place an order, browse, read, or  download information, we may automatically collect and store the  following types of non-personally identifiable information: 
				    
				      - Information collected as server logs from information provided by your browser.
- Click-through statistics.
- Your IP address.
- The type of web browser you are using to access CPO Sites.
- The type of operating system you are using.
- The name of the domain and host from which you access the Internet.
- The date and time you access CPO Sites.
- The Internet address of the sites from which you linked directly to CPO Sites.
Personal Information Provided Voluntarily by the User. You can use portions of the CPO Sites without providing any Personal  Information. However, in order to take advantage of the full  capabilities of the CPO Sites and to obtain access to, and use of, many  of the features found on the CPO Sites, including placing orders for  products offered for sale on the CPO Sites and receiving CPO email  exclusives, you must provide certain Personal Information. You may also  provide Personal Information when you participate in various services  and offerings on the CPO Sites. Personal Information may include,  without limitation: 
				    
				      - Your name, mailing address, email address, telephone  number, fax number, billing information, and credit card number and  related information.
- Information concerning your interests, occupation, product use and preferences.
You may also be asked to respond to additional questions to help us  meet your needs. Certain functionalities on the CPO Sites, such as the  "Email This Page to a Friend" feature, may require you to provide  information regarding third parties. Similarly, if you request that an  order or gift be sent directly to an individual other than yourself,  you will also be asked to submit information about the recipient of the  order or gift. This information may include a third party's name,  address, phone number, fax number, email address, and other similar  information.
				    
				3.	Information Warranty
				    If you do provide  Personal Information through the CPO Sites, including Personal  Information regarding individuals other than yourself, you warrant that  (i) you have the authority to provide that Personal Information and to  grant CPO the right to use such Personal Information consistent with  this privacy policy, (ii) you have provided that Personal Information  voluntarily, and (iii) you consent to the use of that Personal  Information consistent with this privacy policy.
				
				4.	Use and Disclosure of Information
				    Use of Automatically Collected Information. Information collected automatically through the CPO Sites provides us  with information regarding your use of the CPO Sites, including which  pages are the most popular with CPO Sites users. That information also  allows us to determine if the CPO Sites are working properly and to  make changes to the CPO Sites to allow the user to have a better  experience on the CPO Sites. We do not use that information to identify  a particular user.
				    We may aggregate and use certain non-personally identifiable  information for research or marketing purposes and may share, sell and  rent or trade that information and statistical information derived  therefrom with our marketing partners, advertisers, or other third  parties.
				    Use of Non-personally Identifiable Information Provided Voluntarily by the User. By remaining opted-in to our email list, you are acknowledging that we  may sell, rent, share, trade or otherwise provide or transfer your  non-personally identifiable information such as demographic and  occupational information to third parties. Such third parties may use  such information for whatever purposes they wish or may transfer such  information to other third parties.
				    Business Uses of Information. CPO uses Personal  Information you provide to us for internal business purposes, such as  (i) for verification at login as a registered user, if applicable; (ii)  for marketing purposes; (iii) to contact you regarding the products or  services that you have ordered or requested and to provide the same;  (iv) for fulfillment of promotions, including but not limited to  sweepstakes, contests or subscriptions that you have entered; (v) to  process and ship orders; (vi) to send order and shipping confirmations;  (vii) to provide customer service, respond to your requests and  inquiries and enhance product and service offerings; (viii) to keep  records regarding orders, returns and exchanges; (ix) to protect both  you and us against error and fraud; (x) to send information, product  and service alerts and exclusive offers; (xi) to record usage of the  CPO Sites; (xii) to adjust the CPO Sites to your personal preferences;  and (xiii) to customize advertising and CPO marketing information  regarding our products and services. We may also exchange information,  including Personal Information, with other companies and organizations  for credit fraud protection and risk reduction.
				    Service Providers and Vendors. We may also share your  Personal Information with certain third parties that perform services  for CPO. Those third parties may host the CPO Sites, operate certain  features on the CPO Sites, print or send mailings, provide marketing  materials for the CPO Sites, authorize and process your payments,  provide customer service, analyze data and assist in fulfilling your  orders, send emails on CPO's behalf, or otherwise assist CPO with the  operation of the CPO Sites. Those third parties are not authorized to  use or disclose your Personal Information for any purpose other than to  perform the services designated by CPO.
				    Cooperative Database Services. We may participate in cooperative database services.  These services help us to direct print mailings and other marketing initiatives to appropriate purchasers and website visitors.  Names and mailing addresses may be shared between participating parties in the cooperative database services, but no credit card information or email addresses are provided to the cooperative.
				    Business Transfers. Automatically collected  information and your Personal Information may be transferred as an  asset in connection with a merger or sale involving all or part of CPO  or as part of a corporate reorganization, stock sale or other change of  control.
				    Required Disclosures. CPO may also provide your  Personal Information to a third party if CPO in good faith believes  that access, use, preservation or disclosure is reasonably necessary to  satisfy any applicable law, regulation, legal process or enforceable  government request. For example, CPO may be required to disclose your  Personal Information to respond to a subpoena, court order or other  legal process.
				
				5.	Consent to Processing and Transfers of Information
				    CPO  may transfer information that you send to us, including, without  limitation, Personal Information, to recipients in countries that do  not provide the same level of legal data protection as the country from  which you access the CPO Sites. By using the CPO Sites, you consent to  those transfers and to the processing by CPO of that information.
				
				6.	Notice for Parents
				    The CPO Sites are  considered to be general audience Sites and are not to be used by  children. CPO does not sell products that are intended for children and  does not intend to collect Personal Information from individuals under  the age of eighteen (18). If you are the parent or guardian of a child  who has provided personal information to us, please inform us as  provided under Section 12 below, and we will delete that Personal  Information.
				
				7.	Use of Cookies
				    Cookies are pieces of  information that a website transfers to an individual's hard drive to  identify previous visitors to the Sites. Cookies are text files that  can be rejected or deleted by you at any time. You may disable cookies  using your Internet browser settings. However, by deleting or rejecting  cookies, you may inhibit the user experience on the CPO Sites and other  sites. For example, in order to complete online transactions, cookies  must be accepted.
				    CPO uses cookies to store information about your visit to the CPO  Sites in order to enhance your visit to the CPO Sites. For example,  storing that information will allow us to, on occasion, customize  account pages for you. We also use cookies and tracking technologies  to: 
				    
				      - Track user visits.
- Track your shopping cart and purchases.
- Determine what set-ups are most frequently rendered.
- Save your password so you do not have to provide it each time you visit CPO Sites.
In  addition, we currently contract with several online partners to help  manage and optimize the CPO Sites. We use the services of a marketing  company to help us measure the effectiveness of our advertising and how  visitors use our sites. To do this, we use Web beacons and cookies  provided by our marketing company on the CPO Sites. The type of  information we collect includes which pages are visited, which products  are put into the shopping cart, which orders enter the checkout  process, which checkouts are executed with payment, etc. By  supplementing our records, this information helps us learn things like  what pages are most attractive to our visitors, which of our products  most interest our customers, and what kinds of offers our customers  like to see. Although our marketing company manages the information  coming from our sites on our behalf, we control how that data may and  may not be used. If you do not want to help us learn how to improve our  sites, products, offers and marketing strategy, you can "opt-out" of  our ability to analyze such data by contacting us (see Section 12).
				
				8.	Security
				    CPO and authorized third parties  employ reasonable measures, including administrative, technical, and  physical measures, to protect your Personal Information from  unauthorized access, loss, alteration, use or disclosure. For example,  any Personal Information you enter when you place an order for a  product, including, without limitation, your credit card and other  Personal Information, is encrypted before transmission to CPO Sites  servers by using Secure Sockets Layer 128-bit encryption, if supported  by your browser. In addition, we use reasonable measures to limit the  disclosure of your Personal Information consistent with this privacy  policy. However, your Personal Information can never be 100% secure:  information may be transmitted over networks without appropriate  security measures and may be accessed, deleted, altered, used or  disclosed by unauthorized persons. You can help us to protect your  Personal Information by (i) not sharing your password or other account  information with others, (ii) using a secure web browser, and (iii)  changing your password frequently.
				
				9.	Managing Your Information
				    CPO reserves the  right to retain any Personal Information reasonably necessary to  appropriately document its business activities and for archival and  record retention purposes. We will store your Personal Information for  as long as reasonably necessary for the purposes described in this  privacy policy. You may find out more details regarding this privacy  policy by contacting us (see Section 12).
				    You may "opt-out" of receiving future email or other communications  from us by clicking the "unsubscribe" link at the bottom of any email  that you receive from us, or by contacting us (see Section 12). Please  note that removal of your Personal Information from our database or  "opting-out" will not stop (i) marketing or advertising content that is  ready to be mailed or is queued for transmission to you prior to the  time when we can implement your request, or (ii) the use of your  Personal Information by third parties with whom CPO may have already  shared your information.
				
				10.	Updates and Changes to Policies
				    CPO may  change this privacy policy from time to time by posting updated  versions of the privacy policy here. As we may make changes to this  privacy policy at any time without notifying you, we suggest that you  review this privacy policy each time you access or use the CPO Sites.  Please note that our rights to use your Personal Information will be  based on the privacy policy in effect at the time the information is  collected.
				
				11.	Contact CPO
				    If you have questions  regarding the CPO Sites, the privacy policy or your privacy on the CPO  Sites, you can send a request with any further questions to our  Customer Service Department by email to privacy@cpooutlets.com or by mail to:
					CPO Outlets
				      P.O. Box 50768
				      Pasadena, CA 91115
				    California Privacy Rights
				    Under California  Law, California residents have the right to request that CPO not share  his or her personal information with third parties for those third  parties' direct marketing use. To make such a request, email us at privacy@cpooutlets.com or by  mail to:
					CPO Outlets
				      P.O. Box 50768
				      Pasadena, CA 91115
				    Effective December 31, 2007