PURE GOLD
WEB SITE PRIVACY POLICY

Pure Gold is concerned about your privacy.  We want you to understand what Personally Identifiable Information we collect about you, and how we use your Personally Identifiable Information. To demonstrate our commitment to your privacy, we participate in the TRUSTe Privacy Program.

TRUSTe is an independent, non-profit organization whose mission is to build users’ trust and confidence in the Internet by promoting the use of fair information practices. As a licensee in the TRUSTe Privacy Program, we are notifying you of our privacy practices in this Privacy Policy.

What is “Personally Identifiable Information”?
 “Personally Identifiable Information” (“PII”) refers to any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains.  This includes information that is used in a way that is personally identifiable, including linking it with identifiable information from other sources, or from which other personally identifiable information can easily be derived, including, but not limited to, name, address, phone number, fax number, email address, demographic information such as age, income, and zip code, financial profiles, social security number, and credit card information.  To the extent unique information (which by itself is not Personally Identifiable Information) such as a personal profile, unique identifier, biometric information, and IP address is associated with Personally Identifiable Information, then such unique information is also considered Personally Identifiable Information.  Personally Identifiable Information does not include information that is collected anonymously (i.e., without identification of the individual user) or demographic information not connected to an identified individual.

What PII does Pure Gold collect and how?
When you register on our Pure Gold Web Site, we will ask you for certain PII such as, for example, your address, telephone number, and e-mail address. If you send Pure Gold correspondence, via email, fax, or regular mail, or if other users or third parties such as businesses send us correspondence about your activities in connection with your use of the Web Site, Pure Gold may retain that information.  If any third parties provide information to us about you, we will treat that information in accordance with this Privacy Policy.

Pure Gold may use cookies, or functionally equivalent technology, to collect certain information about you based upon your behavior while visiting the Pure Gold Web Site.  This information may include the Uniform Resource Locator (URL) that you just came from (whether this URL is on the site or not), which URL you next go to (whether this URL is on the site or not), what browser you are using, and your IP address.  Cookies can also help us provide information about services that are targeted to your particular interests. Cookies are stored on your local machine, not on the site. You are always free to decline cookies if your browser has this functionality. Pure Gold will not link information collected by cookies to any PII.

Who collects this information?
Pure Gold collects this information through the services of third party web site host Elias-Savion Interactive, Inc. who operates, manages and maintains the Pure Gold Web Site. Elias-Savion Interactive, Inc. acts solely as an agent of Pure Gold in the collection of such information and is required to comply with this Privacy Policy.  Pure Gold does not sell, rent or share PII except in accordance with this Privacy Policy.

How does Pure Gold use PII?
We use the information you provide through the registration process to: provide you with the information and services you request; communicate with you on matters relating to the Web Site; assist you with bookings through our eBooking Agent feature and via direct contact by our representatives; manage your account with Pure Gold if you have one; and, provide you with information about related services and/or products from our business associates.

Information that is automatically collected regarding your activities while visiting our Web Site as well as demographic information derived from your registration and others may be aggregated and shared with associates and third parties, but only in aggregated form that does not contain any PII.

Any information, comments, or other written material in any form, electronic or otherwise related to Pure Gold and/or a Pure Gold performance that you submit via Fan Feedback or otherwise to Pure Gold (“Feedback”), may be used by Pure Gold for any purpose, including posting on our Fan Buzz area for viewing by other visitors to our Web Site.

In addition, Pure Gold uses information maintained about you, and other information obtained from your current and past activities to resolve disputes, troubleshoot problems and, if necessary, to enforce our rights.  At times, Pure Gold may review the information of multiple users to identify problems or to resolve disputes.

What choices are available regarding the collection, use and disclosure of PII?
You may at any time choose to disclose or not disclose the PII we request; however, if you choose not to disclose the requested information, we may not be able to provide you with some or all of the information or services you request.

If you do not wish to receive certain communications from Pure Gold such as marketing communications, you may opt out by declining the service offered or informing us that you no longer wish to receive such communications.  We will use reasonable efforts to comply with your request unless such communications are necessary for the administration of your account, required by law, or necessary to protect our rights.

Who does Pure Gold share private information with?
Pure Gold may disclose your PII to our affiliates and agents, as well as some third party suppliers and service providers to directly or indirectly provide you with services or information, and we may need to share your PII with them in order to permit them to provide such services or information. We require all such third parties to whom we disclose your PII to adhere to the restrictions in this Privacy Policy and to use your PII only to provide you with the information and/or services you request.

Pure Gold may disclose PII to certain intermediaries (third party services providers who do not store, retain or use your PII) solely to the extent necessary to provide the information and services you request through Pure Gold. 

Pure Gold will disclose PII if required to do so by law, regulation, subpoena or other court order.  In the event of a restructuring, sale of assets, merger, divestiture or other change of control or financial status affecting Pure Gold that could involve disclosure of PII as an incidental result of a transfer of assets by operation of law or otherwise, Pure Gold will notify you prior to any disclosure of your PII and provide you with an opportunity to request that your PII be deleted from all Pure Gold records, or, to the extent such deletion is impractical, maintain your PII in a secured environment and not disclose your PII to any third party.  Pure Gold will use all reasonable efforts to comply with such requests.

Pure Gold publishes Feedback on the Web Site and may disclose Feedback to third parties in other formats and through other media.

Pure Gold will not use or disclose your PII in any way except as specified in this Privacy Policy with your prior written or active e-mail consent.

How does Pure Gold or its providers protect the security of PII?
The Pure Gold Web Site employs a number of current technology security measures to protect the security of PII. Some of these measures currently include: Secure Sockets Layer protocol for all registration transactions; VeriSign certification; physical server and site security including biometric-only access, motion sensors and full site surveillance 24 x 7.  All Pure Gold and Elias/Savion Interactive Inc. personnel are informed of and required to abide by the requirements of this Privacy Policy, and access is limited to those individuals who require access in order to provide services in connection with the Pure Gold Web Site.

How can I correct any inaccuracies in my PII?
You may at any time request access to the PII we have collected about you, and may request corrections or updates to that information.  Pure Gold will make reasonable efforts to respond promptly to all such requests, but reserves the right to limit such requests to two per year per individual.  You may e-mail your requests to mark.silvey@elias-savion.com.   

In addition, you may at any time request Pure Gold to delete/deactivate your PII by sending a request to the above e-mail address. Please allow at least thirty (30) days for us to fully implement such requests. In the event that we are unable to physically delete all PII, we will deactivate such information, e.g., we will maintain it in a secure area, but will not use, transfer, sell or disclose the PII to any third party.

Additional Information:
This Privacy Policy only applies to information collected by Pure Gold.  Any information you provide to, or that is collected by, third-party sites may be subject to the privacy policies of those sites, if any.  We encourage you to read such privacy policies of any third-party sites you visit.  It is the sole responsibility of such third parties to adhere to any applicable restrictions on the disclosure of your PII, and Pure Gold and affiliates shall not be liable for wrongful use or disclosure of your PII by any third party.

You should also be aware that if you submit information to “chat rooms,” “forums” or “message boards” such information becomes public information, meaning that you lose any privacy rights you might have in that information.  Such disclosures may also increase your chances of receiving unwanted communications. 

Pure Gold reserves the right to change this Privacy Policy at any time by posting a new Privacy Policy on the Pure Gold Web Site. However, if we change our Privacy Policy to permit a new use or disclosure of PII, we will not so use or disclose your PII collected prior to posting of the new policy unless we first notify you via e-mail of the new policy and provide you with an opportunity to opt out of the new use or disclosure provisions.

You may at any time print, download, or request a printed copy of this Privacy Policy.  If you believe that this policy has been violated, please contact: Pure Gold, P.O. Box 5141 Pittsburgh, PA 15206-0141.

Our response to such inquiries may be limited to information under our direct control. If you do not receive any acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact TRUSTe at http://www.truste.org. TRUSTe will then serve as a liaison with Pure Gold to resolve your concerns.