How TRUSTe Protects Your Privacy

As an Internet user, you have a right to expect online privacy and the responsibility to exercise choice over how your personal information is collected, used, and shared by Web sites. The TRUSTe program was designed expressly to ensure that your privacy is protected through open disclosure and to empower you to make informed choices.

A cornerstone of our program is the TRUSTe "trustmark," an online branded seal displayed by member Web sites. The trustmark is awarded only to sites that adhere to established privacy principles and agree to comply with ongoing TRUSTe oversight and consumer resolution procedures. Privacy principles embody fair information practices approved by the U.S. Department of Commerce, Federal Trade Commission, and prominent industry-represented organizations and associations. The principles include:

• Adoption and implementation of a privacy policy that takes into account consumer anxiety over sharing personal information online.
• Notice and disclosure of information collection and use practices.
• Choice and consent, giving users the opportunity to exercise control over their information.
• Data security and quality and access measures to help protect the security and accuracy of personally identifiable information.

So, What Does TRUSTe's Trustmark Mean to You?

All Web sites that display our trustmark must disclose their personal information collection and privacy practices in a straightforward privacy statement, generally a link from the home page. More than one trustmark may be displayed if personal information privacy practices vary within the site.

When you see our TRUSTe seal, you can be assured that the Web site will disclose:

• What personal information is being gathered about you
• How the information will be used
• Who the information will be shared with, if anyone
• Choices available to you regarding how collected information is used
• Safeguards in place to protect your information from loss, misuse, or alteration
• How you can update or correct inaccuracies in your information

How does the TRUSTe Children's Program protect your child's privacy?

TRUSTe recognizes that when it comes to privacy, children under the age of 13 have special needs. Often, young children can not comprehend the implications of giving out personally identifiable information. Therefore, a Web site displaying the Children's Seal is committed to obtaining prior verifiable parental consent when and if information will be collected, as well as giving parental notice of how that information will be used.

Parents and children who visit sites that post the Children's Seal will also know that TRUSTe is providing ongoing review to ensure the site is not violating its privacy statement, and that a formal complaint and resolution process exists if consumers perceive that the site may not be in compliance with the TRUSTe program.

Specifically, all sites directed at children under the age of 13 wishing to be licensed by TRUSTe must adhere to the provisions of the standard TRUSTe program in addition to the following:

Children's Privacy Seal Requirements.

If a Web Site is directed at children under 13, the site will NOT:

• Collect online contact information from a child under 13 without prior verifiable parental consent or direct parental notification of the nature and intended use of this information, which shall include an opportunity for the parent to prevent use of the information and participation in the activity. Where prior parental consent is not obtained, online contact information shall only be used to directly respond to the child's request and shall not be used to re-contact the child for other purposes.
• Collect personally identifiable offline contact information from children under 13 without prior verifiable parental consent.
• Distribute to third parties any Personally Identifiable Information collected from a child under 13 without prior verifiable parental consent.
• Give the ability to children under 13 to publicly post or otherwise distribute personally identifiable contact information without prior verifiable parental consent, and will make best efforts to prohibit a child from posting any contact information.
• Entice a child under 13 by the prospect of a special game, prize or other activity, to divulge more information than is needed to participate in such activity.

TRUSTe Oversight and Resolution

All Web sites that display our trustmark also agree to comply with TRUSTe oversight and complaint resolution procedures. We monitor licensees for compliance with program principles and posted privacy practices through a variety of measures:

• Initial and periodic reviews of the site by TRUSTe
• "Seeding," whereby we submit personal user information online to verify that a site is following its stated privacy policies
• Compliance reviews by a CPA firm
• Feedback and complaints from the online community
• Click-to-verify seal to deter piracy of the trustmark

All licensees must post the click-to-verify seal on their privacy statements. Clicking on the seal takes you to our secure server and verifies that the site is indeed a legal licensee of TRUSTe.

Your vigilance is needed as well. In fact, we encourage you to contact TRUSTe directly to report violations of posted privacy policies, misuse of our trustmark, or specific privacy concerns pertaining to a member Web site. Please see our Watchdog for instructions.

To resolve complaints raised by you or by us, licensees agree to cooperate with all TRUSTe reviews and inquiries. If we cannot reach a satisfactory resolution to an inquiry or complaint regarding a TRUSTe licensee, an escalating investigation is conducted. Depending on the severity of the violation, this process could result in a Web site compliance review by a CPA firm, revocation of the trustmark, termination from the TRUSTe program, breach of contract proceedings, or referral to the appropriate federal authority

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