TABLE OF CONTENTS
- Privacy Statement
- Consent to Share and Disclose Information, Including International Data Transfers
- Consent to Electronic Notice If There is a Security Breach
- Type of Information We May Collect
- Internet Users – Cookies, Internet Protocol (IP) Address, Aggregate Information
- Children and Data Collection
- A Note to Parents/Guardians—Additional Information About Children’s Privacy
- Our Use of Your Personal Information
- Collection and Use of Employee Personal Information
- Verifications of Employment
- Medical Information
- Collection and Use of PTI Customer Information
- Collection and Use of PTI Franchisee and Prospective Franchisee Information
- Collection and Use of PTI Development Agent Information
- Mobile Information
- Marketing Promotions and Advertising
- Forward-to-a-Friend and Refer-a-Friend
- Opt-Out of Email and Mobile Updates
- Sharing of Personal Information
- Storage, Retention and Accuracy of Personal Information
- Access, Control and Update Information About You
- Contact Information
- Links to Non-PTI Web Sites and Third Parties
- Social Media and Online Engagement
- Your California Privacy Rights
- Safe Harbor Compliance
- Members of the European Union
1. Privacy Statement
- The European Union Data Protection Directive and the U.S. Department of Commerce Safe Harbor Program Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.
- Fair information practices established by the Organization for Economic Co-operation and Development (OECD).
- The Asia Pacific Economic Cooperation forum (APEC) Privacy Framework.
Franchise Brands, LLC is the owner of Personal Training Franchise Ventures, LLC (“PTI”), and PTI Real Estate, LLC (“PTI Real Estate”) which provides services to PTI, which include, but are not limited to, legal, development, finance, retail technology, executive, human resources, public relations, marketing support, operations, franchise sales and other fitness center development services. Franchise World Headquarters, LLC, (“FWH”) is an affiliate of and service provider to Franchise Brands, LLC, PTI, and other affiliated franchise concepts, which provides its affiliates with certain services, including but not limited to franchise marketing, franchisee training, and accounting services.
3. Consent to Share and Disclose Information, Including International Data Transfers
4. Consent to Electronic Notice if there is a Security Breach
If PTI or a Recipient is required to provide notice of unauthorized access of certain security systems, you agree that PTI, or the Recipient, may do so when required or voluntarily by posting notice on the Website or sending notice to any email address PTI or the Recipient has for you, in the good faith discretion of PTI or the Recipient. You agree that notice to you will count as notice to any other individual for whom you are acting and agree to provide the notice to any such individual.
5. Type of information we may collect
Personal Information is defined as any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to a Social Security Number and/or Identification Number (hereinafter “SSN/I.N”) or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.
Personal Information shall include but is not limited to: name, home address, home zip code, home telephone number, mobile phone number, email address, Social Security Number and/or Identification Number, financial information and employment related information such as may be found on resumes, applications, background verification information, or in employment references.
PTI takes measures to maintain the confidentiality of your SSN/I.N to protect your SSN/I.N from unlawful disclosure, and to limit access to your SSN/I.N. PTI will not make your SSN/I.N available to the general public, print your SSN/I.N on any card, require you to provide your SSN/I.N to access any products or services, transmit your SSN/I.N over the Internet unless the connection is secure or your SSN/I.N has been encrypted, or requires the transmittal of your SSN/I.N to access our Website without requiring additional authentication.
Non-personal information is information that is already a matter of public record or knowledge. Business contact information is considered non-personal information and not subjected to special protection and it can be routinely shared with anyone inside or outside of the business. Business contact information shall include but is not limited to: business name, business address, business telephone number, and is not considered personal information in certain jurisdictions.
Sensitive data is information that can include but is not limited to, an individual’s gender, racial or ethnic origins, politics, religion, trade union membership, veteran status, physical or mental health, disabilities, sex life, sexual orientation, or criminal (or alleged criminal) activities, proceedings or convictions. We will never collect Sensitive Personal Information except to comply with Affirmative Action data requirements.
6. Internet Users – Cookies, Internet Protocol (IP) Address, Aggregate Information
Cookies can expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) or they can be stored for longer.
Session cookies – allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes such as remembering what a user has put in their shopping basket as they browse around a site. They could also be used for security or to facilitate use of webmail. These session cookies expire after a browser session and would not be stored long term.
Persistent cookies – are stored on a users’ device in between browser sessions which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site or to target advertising
First and third party cookies – Whether a cookie is ‘first’ or ‘third’ party refers to the website or domain placing the cookie. First party cookies in basic terms are cookies set by a website visited by the user – the website displayed in the URL window. Third party cookies are cookies that are set by a domain other than the one being visited by the user. If a user visits a website and a separate company sets a cookie through that website this would be a third party cookie.
For more information about cookies, including how to see what cookies have been set and how to manage, block and delete them, visit www.allaboutcookies.org. The website www.allaboutcookies.org gives you detailed step by step guidance on how to control and delete cookies depending on your browser type. You can adjust your browser settings to your preferred level of protection. In the table below we have, where possible, included links to privacy controls for third-party websites that deliver cookies via our website within advertisements or widgets.
To opt out of being tracked by Google Analytics across all websites visit: tools.google.com/dlpage/gaoptout.
Web Beacon – Also called a web bug or a pixel tag or a clear GIF. We use pixels tags or transparent GIF files, to help manage our online advertising and promotions. These tags collect anonymous (not personally identifiable) information about which advertisements and promotions bring users to our website. With both cookie and tag technology, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address.
Used in combination with cookies, a web beacon is an often-transparent graphic image, usually no larger than 1 pixel x 1 pixel, which is placed on a web site or in an e-mail that is used to monitor the behavior of the user visiting the Web site or sending the e-mail. When the HTML code for the web beacon points to a site to retrieve the image, at the same time it can pass along information such as the IP address of the computer that retrieved the image, the time the Web beacon was viewed and for how long, the type of browser that retrieved the image and previously set cookie values.
Web beacons are typically used by a third-party to monitor the activity of a site. A web beacon can be detected by viewing the source code of a web page and looking for any IMG tags that load from a different server than the rest of the site. Turning off the browser’s cookies will prevent Web beacons from tracking the user’s activity. The web beacon will still account for an anonymous visit, but the user’s unique information will not be recorded.
Internet Protocol (IP) Address – an Internet Protocol (IP) Address is associated with your computer’s connection to the internet. PTI may use your IP address to help diagnose problems with PTI’s server, to administer the Website and to maintain contact with you as you navigate through the Website. Your computer’s IP address also may be used to provide you with information based upon your navigation through the Website. PTI does not link IP addresses to any Personal Information.
Aggregate Information – is used to measure the visitors’ interest in, and use of, various areas of the Website and the various programs that PTI administers, PTI will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, PTI may undertake statistical and other summary analyses of the visitors’ behaviors and characteristics. Although PTI may share this aggregate information with third parties, none of this information will allow anyone to identify you, or to determine anything else personal about you.
7. Children and Data Collection
PTI adheres to the federal privacy protection standards as stated in the Children’s Online Privacy Protection Act (“COPPA”). We care about the safety of children. We will not knowingly allow anyone under 13 to provide us any personally identifying information. Children under 13 years of age are required to obtain the express permission of a parent or guardian before submitting any Personal Information about themselves (such as their names, e-mail address, and phone number) over the Internet. If a child has provided us with personally-identifiable information without the consent of a parent or guardian, the parent or guardian of that child should contact the Privacy Officer immediately at firstname.lastname@example.org. We will use reasonable efforts to promptly delete the child’s information from our servers.
8. A Note to Parents/Guardians—Additional Information About Children’s Privacy
At PTI, children’s privacy is important to us. Therefore, we take additional measures to help children protect their privacy while online including not asking them to disclose more personally identifiable information than is necessary for them to participate in an activity and encouraging them to use non-personally identifiable screen names rather than their real names.
PTI is dedicated to protecting your privacy and handling any personal information we obtain from you with care and respect. This Children’s Privacy Statement is designed to answer your questions regarding our privacy policies and principles with respect to children under the age of 13. PTI recognizes the need to provide additional privacy protections when children visit our website at www.personaltraininginstitute.com.
The Children’s Online Privacy Protection Act (“COPPA”) requires that we inform parents and legal guardians about how we collect, use, and disclose personal information from children under 13 years of age; and that we obtain the consent of parents and guardians in order for children under 13 years of age to use certain features of our website. Also, when we use the term “parent”, we mean to include legal guardians.
Children can participate in many of our features without providing personally identifiable information. However, to enable their participation in certain of our interactive features, we may ask children to provide us with personally identifiable information. The types of information we may request include first name as well as the child’s and parent’s email addresses. We use a child’s email address to respond to a specific request to participate in an activity (e.g., participate in a contest or sweepstakes, respond to their question, enable them to subscribe to a newsletter). We use parents’ e-mail addresses to obtain their consent or notify them of their child’s online activities and enable the parent to unsubscribe the child from a newsletter or other similar activity.
At any time parents can refuse to permit us to collect further personal information from their child and can request that any personal information we have collected be deleted from our records.
We will provide parents notice by e-mail of any material changes in the way we intend to collect, use, and/or share their child’s personal information. Please note that, at all times, parents should update their personal information to provide us a current email address.
If you would like to review any personally identifiable information that we have collected online from your child, have this information deleted, and/or request that there be no further collection or use of your child’s information, or if you have questions about these information practices, you may contact our Privacy Officer. The Privacy Officer can be reached by telephone at: 1-800-797-2308; by Facsimile at: (203) 783-7952; by email at: email@example.com; or by mail at Personal Training Franchise Ventures, LLC, In care of: 325 Bic Drive, Milford, CT, 06461.
9. Our Use of Your Information
10. Collection and Use of Employee Personal Information
PTI also collects Personal Information from its employees and applicants (human resource data) in connection with administration of its Human Resources programs and functions. These programs and functions include, but are not limited to: job applications and hiring programs, compensation and benefit programs, performance appraisals, training, access to PTI facilities and computer networks, employee profiles, internal intranet employee directories, Human Resource recordkeeping, Affirmative Action data, and other employment related purposes.
It is the policy of PTI to keep all past and present employee information private from disclosure to third parties. There are certain business related exceptions and they are:
- To comply with county, state or federal agency requests;
- Inquiries from third parties with a signed authorization from the employee to release the information, except in situations where limited verbal verifications are acceptable (see below);
- Third parties with which PTI has contractual agreements to assist in administration of company sponsored benefits.
11. Verifications of Employment
Prospective employers, financial institutions, and residential property managers routinely contact PTI requesting information on a former or current employee’s work history and salary. All such requests of this type shall be referred to and completed on a confidential basis by the Human Resources Department or Payroll Department.
For written verification of employment requests, information will be provided on the form only when it is accompanied by an employee’s signed authorization to release information. The form will be returned directly to the requesting party and filed as part of the Human Resources or Payroll Department’s confidential records.
12. Medical Information
PTI is compliant with federal HIPAA regulations and only utilizes information related to the company sponsored healthcare plan on a “need to know” basis for administration of the healthcare plan.
13. Collection and Use of PTI Customer Information
PTI will not collect customer Personal Information, unless the customer contacts PTI directly. In order to adequately address a customer’s concern, their Personal Information may be shared with our affiliate Franchise Brands, LLC and other affiliates, the Development Agents and franchisees. PTI’s Development Agents assist with franchise sales, site location, training, and provide operational assistance to franchisees. Failure to provide necessary information may prevent PTI from fully addressing any customer concerns.
14. Collection and Use of PTI Franchisee and Prospective Franchisee Information
If you choose to, you may submit via www.personaltraininginstitute.com an electronic application seeking consideration as a prospective PTI franchisee. By submitting an electronic application, you agree that we may disclose your personal information to our affiliates within PTI, their Development Agents, other PTI affiliates, and third party service providers as part of their consideration to your inquiry and to help them conduct their franchise marketing efforts. Information on your online form will become part of any application for a franchise that you might later submit. We require our affiliates within PTI and Development Agents to respect PTI’s privacy practices and not use your personal information for purposes other than to carry out our instructions.
By applying to become a PTI franchisee, a prospective franchisee consents to the collection, use, and disclosure of Personal Information in accordance with the following terms and conditions. We collect and use Personal Information in order to assist a prospective franchisee in applying to become a PTI fitness centers franchisee and to assist our affiliates within PTI in selecting franchisee candidates.
Personal Information collected from prospective franchisees include, but is not limited to: name, address, telephone number, facsimile number, email address, date of birth, citizenship, educational background, criminal background, bank account information for Electronic Funds Transfer, financial statement, litigation history, and taxpayer identification number. Failure to provide requested Personal Information may negatively impact a prospective franchisee’s ability to become a franchisee. Once a prospective PTI fitness centers franchisee becomes a franchisee, they may then reference themselves by their Franchise Agreement Number. In order to better service franchisees, a franchisee’s Personal Information may be shared between PTI and its affiliates within PTI, and Franchise Brands, LLC, pursuant to the service contracts between them.
A franchisee and/or prospective franchisee’s information may be shared with Development Agent in their area. A Development Agent is an independent contractor of PTI. The Development Agents assist with franchise sales, site location, service franchisee leasing needs, provide operational assistance and related administrative functions, training to the franchisee. Development Agents also make recommendations as to whether a prospective franchisee in their territory should be granted a franchise. The Development Agent may use this information to: address a franchisee’s concerns in a customer complaint, respond to a franchisee’s inquiries for franchise sales, franchisee Personal Information may be shared during restaurant transfers, and any other inquiry which may require a response.
Finally, upon becoming a PTI franchisee you consent to PTI disclosing former or past franchisee contact information including Personal Information in its Disclosure Document for one (1) year after leaving the system, as required by law, unless you advise otherwise. Contact our Privacy Officer in writing, either by email or regular mail received, of your desire to not have your details or contact information disclosed, corrected or changed when you sell or transfer your PTI fitness center, or exit the Personal Training InstituteTM fitness centers System (whether by termination or otherwise). To contact the Privacy Officer, please see the section provided below entitled “Contact Information”.
15. Collection and Use of PTI Development Agent Information
By applying via www.personaltraininginstitute.com to become a Personal Training InstituteTM fitness centers Development Agent, a Development Agent applicant consents to the collection, use, and disclosure of Personal Information in accordance with the following terms and conditions. We collect and use Personal Information in order to assist you in applying and evaluating you to become a Personal Training InstituteTM fitness centers Development Agent. Personal Information is collected to assist our affiliates within PTI in selecting Development Agent candidates and for the purpose of operating a development territory.
Personal Information collected includes, but is not limited to: name, home address, home telephone number, facsimile number, email address, date of birth, bank account information for Electronic Funds Transfer, financial statement, resume, taxpayer identification number and background checks. Failure to provide necessary information may negatively impact your ability to become a Development Agent.
Once a Development Agent candidate becomes a Development Agent, they may then reference themselves by their Development Agent Number. As a Development Agent for PTI, certain business information with respect to restaurants within your territory may be shared in the aggregate amongst your DA community. Such business information may include, but is not limited to, 3 year DA Performance Report, Emerging Market Developing Activity Report, Developed Market Report, and the Weekly Same Store AUV and Units Report.
16. Mobile Information
Mobile Information We Collect
- Personally identifiable information (e.g. Name, email address) we collect consists only of what you share with us. For example, certain products may ask for this type of information so that we may contact you by phone or email at your request. You choose what, how, and when you want to share.
- If you use any location-enabled products, you may be sending us location information. PTI does not store or use this information other than to provide the service you requested. For example, a mobile product may use GPS data to find a nearby restaurant you requested. Location-enabled features are opt-in and you have control over your participation and can turn these services off at any time.
- Some mobile applications will utilize Google Analytics (or similar tool) to help us better serve our customers through improved products, services, and revisions to the mobile applications. This collected information will not identify you to PTI. It may, however, let us know anonymously, which services and features you are using the most within the application, as well as device type and hardware features, country and language of download.
- Use of 3rd party services such as social sharing sites (e.g., Facebook and Twitter) is governed by the privacy practices of those services. PTI does not capture or store your login information or other personally identifiable information for these services, however session info or cookies may be stored.
Mobile How We Use Collected Information
- We use the information to personalize your experience with the application and to improve your overall experience including the development of new products, services, and features. We also use the information to provide customer support, and when applicable, register and administer your account. Additionally, we may use the information you provide to contact you about updates to our service.
- Information you provide may be used to fulfill the service(s) or carry out the transaction(s) you have requested or authorized.
Mobile Information sharing
- PTI does not share any collected information with 3rd parties with the following exceptions:
- PTI may provide some personal data to third-party partners that are providing services essential to your mobile user experience.
- All requests are sent through your mobile carrier’s network and your carrier may have access to it. Consult your carrier’s privacy policies for additional information.
- Certain mobile products and services and manufacturers allow you to interact and share your information with others. For example, you may want to Tweet or post to your Facebook page content from a PTI mobile application. Consult your mobile device manufacturer, or mobile product or application developer’s privacy policies for additional information.
17. Marketing Promotions and Advertising
You may use a referral feature (either on a web page, in an e-mail, from a banner ad or other communication) to inform a friend about a PTI web page or promotion. PTI may use any e-mail address provided when using this referral feature to send both an initial e-mail and a subsequent e-mail to recipients about the particular promotion, product, or service in which you indicated your “friend” may have an interest.
19. Opt-Out of Email and Mobile Updates
You may have the opportunity to elect to receive email and mobile communications from PTI. PTI will only email you or send you mobile alerts if you elect to receive them. If you elect to receive email and mobile communications, PTI will send you occasional updates about new additions to the Website as well as special offers and promotions of which you can take advantage. If at any time you decide you would rather not receive these types of communications from PTI, you can opt-out by clicking the unsubscribe link at the bottom of any PTI email, update the contact preferences for your account, for mobile marketing, you may opt-out by following the instructions provided in the text messages you receive, or contact the Privacy Officer at firstname.lastname@example.org.
20. Sharing of Personal Information
As described above, PTI, its affiliates within PTI, third party service providers, and Development Agents may share and exchange Personal Information in order to process franchisee applications, administer the Personal Training InstituteTM fitness centers franchise system, and protect the integrity of the PTI franchise system and trademarks. Personal Information may be provided to a courier or freight forwarder to fulfill an order, which may have been requested from us.
We endeavor to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification.
Currently, our website utilizes a variety of different security measures designed to protect Personal Information of users both inside and outside PTI, including the use of encryption mechanisms (e.g., Secure Socket Layers or SSLs), password protection, and other security measures to help prevent unauthorized access to your personally identifiable information. This helps maintain the confidentiality, privacy, and integrity of your transactions, and helps to protect your confidential information – such as credit card numbers, online forms, and financial data from loss, misuse, interception and hacking.
Identity theft and the practice currently known as “phishing” are of great concern to PTI. Accordingly, safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, Social Security Number or National Identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
23. Storage, Retention and Accuracy of Personal Information
PTI and its affiliates the Franchise Brands, LLC, insures that Personal Information is safeguarded against loss, access, use, modification, disclosure or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information.
PTI will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purpose(s) remains valid after termination of our relationship with you.
We take all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.
24. Access, Control and Update Information About You
We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records. Therefore, whenever you believe that your Personal Information needs to be updated, you can email us at email@example.com to update your contact information. You may choose at any time to remove your name, telephone numbers, and postal and email addresses from the lists we use to send notices or updates and elect not to receive correspondence from us by sending us an email at firstname.lastname@example.org.
To protect your privacy, we will take reasonable steps to help verify your identity before granting access or making changes.
25. Contact Information
You may contact the Privacy Officer to access, correct or delete your Personal Information. If necessary, the Privacy Officer will contact another employee to assist in completing your requested task.
If you have any questions or complaints, please contact the Privacy Officer. The Privacy Officer can be reached by telephone at: 1-800-797-2308; by Facsimile at: (203) 783-7952; by email at: email@example.com; or by mail at Personal Training Franchise Ventures, LLC, In care of: 325 Bic Drive, Milford, CT, 06461. We will address your concern and attempt to resolve any problem.
26. Links to Non-PTI Web Sites and Third Parties
27. Social Media and Online Engagement
PTI uses a variety of new technologies and social media options to communicate and interact with consumers. These sites and applications include popular social networking and media sites, open source software communities and more. To better engage the public in ongoing dialog, PTI uses several third-party platforms including, but not limited to, Facebook, Twitter, and YouTube. Third-Party Websites and Applications (TPWA) are Web-based technologies that are not exclusively operated or controlled by PTI. When interacting with the PTI presence on those websites, you may reveal certain personal information to PTI or to third parties. Except when used by PTI employee’s for the purpose of responding to a specific message or request, PTI will not use, share, or retain your personal information.
At this time, PTI has three Social Media Accounts, http://www.facebook.com/pages/Personal-Training- Institute/46309916358, http://twitter.com/trainwithpti/, and http://www.youtube.com/trainwithPTI.
28. Your California Privacy Rights
Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to that customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. To request the above information, please email the Privacy Officer at firstname.lastname@example.org or write to us at:
PTI Privacy Officer
In care of:
325 Bic Drive
Milford, CT 06461
Attention: California Disclosure Information
We will respond to such written requests within 30 days following receipt at the mailing address above. We reserve the right not to respond to requests submitted other than to the address specified above or otherwise exempted by law. Please note that we are required only to respond to each customer once per calendar year.
29. Safe Harbor Compliance
Franchise Brands, LLC, the owner of Personal Training Franchise Ventures, LLC (“PTI”), and PTI Real Estate, LLC (“PTI Real Estate”), is in compliance with the U.S. Department of Commerce Safe Harbor requirements regarding the transfer of personal information from the European Economic Area (“EEA”) or Switzerland to the United States. Franchise Brands, LLC has been Self-Certified under the Safe Harbor privacy framework as set forth by the U.S. Department of Commerce, European Commission and Switzerland regarding the collection, storage, use, transfer and other processing of personal data transferred from the European Economic Area or Switzerland to the U.S., in accordance with the EU Directive on Personal Data Protection. The principles of Safe Harbor compliance are:
- Notice – Individuals must be informed that their data is being collected and about how it will be used; Choice – Individuals must have the ability to opt out of the collection and forward transfer of the data to third parties;
- Onward Transfer – Transfers of data to third parties may only occur to other organizations that follow adequate data protection principles;
- Security – Reasonable efforts must be made to prevent loss of collected information;
- Data Integrity – Data must be relevant and reliable for the purpose for which it was collected;
- Access – Individuals must be able to access information held about them, and correct or delete it if it is inaccurate;
- Enforcement – There must be effective means of enforcing these rules.
Further information regarding the Safe Harbor principles and certification process can be found at www.export.gov/safeharbor.
In addition, the U.S. Department of Commerce maintains a list of all compliant organizations, which can be accessed at http://web.ita.doc.gov/safeharbor/shlist.nsf/webPages/safe+harbor+list.
30. Members of the European Union
If you are a resident of the European Economic Area (“EEA”) or Switzerland and have any concerns or complaints, please first address these issues to the Privacy Officer. PTI is located in the United States, as are the servers that make our websites available. All matters relating to privacy issues and websites are governed by the laws of the United States and the State of Connecticut. If the Privacy Officer does not satisfactorily address a complaint within thirty (30) days, any dispute, controversy or claim shall be settled by an arbitration administered by an arbitration agency, such as the American Arbitration Association (“AAA”). All arbitrations will be conducted in English. Judgment rendered by the arbitrator may be entered in any court having jurisdiction. The costs of the arbitration will be borne equally by the parties. Connecticut, U.S.A. shall be the site of all hearings, and such hearings shall be before a single arbitrator. You may also submit complaints to the Federal Trade Commission at http://www.ftc.gov/ftc/complaint.htm or via telephone at (202)382-4537.
LAST UPDATED: PTI 06/01/12