Privacy Policy

Privacy & Security. Your privacy is very important to us, and trust extremely valuable. It is our intent to protect against the loss, misuse or alteration of any information that we have collected from you, and also respect your communication preferences at all times. This privacy statement covers the means through which we collect personal information from you, how we use it, who we share it with and in what circumstances, how you can change your marketing preferences with us and/or the suppliers whose merchandise you purchase, and how to contact us for more information.
About E4X and FiftyOne. E4X, Inc. ("E4X") develops and deploys solutions that facilitate, stimulate and encourage international ecommerce, with offices in New York City, U.S.A. and Tel Aviv, Israel. FiftyOne is a set of products and services built and managed by E4X, Inc. that allow suppliers of popular brand name retail merchandise ("Suppliers") and international consumers to connect and transact effortlessly.
Third Party Review. E4X is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent organization whose mission is to build user’s trust and confidence in the Internet by promoting the use of fair information practices. Because E4X wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.
Data Collected. The information collected from you by E4X during the FiftyOne Global Checkout is consistent with information typically collected by transactional ecommerce websites as that information is necessary to accept and process purchase instructions for merchandise, and to protect against credit card fraud per association and industry regulations and standards. More specifically the information collected includes but is not limited to: (i) your billing address, (ii) your shipping address, (iii) your email address, (iv) your IP address, (v) credit card information, (vi) your marketing preferences with E4X and (vii) your marketing preferences with the Supplier whose merchandise you are purchasing.
Data Handling, Storage and Security. We use a variety of current technologies and processes for protection of your data, and to ensure that any and all personal data is transmitted in a safe, encrypted format. Data protection takes place at a number of levels within our platform and the team that operates it. All personally identifiably information is transmitted between E4X and its partners over secure channels. Where data is exchanged in real time, we do so over SSL-encrypted channels. Where data is exchanged in batch, we encrypt the data set prior to transmission. In both cases, we use asymmetric key cryptography ensuring that the data itself is not transmitted in clear text but also only the authorized receiving party is able to decrypt the data. Data is stored securely in a database hosted at our collocation facility and disaster recovery site. Both sites employ a series of physical access control measures preventing unauthorized physical access to our systems, including biometric access control technologies. Network access to these sites also flows through a wide range of protective measures. There are many levels of intrusion protection in place ranging from perimeter firewalls which tightly control network traffic, regularly maintained software, operating system and where applicable firmware updates for systems behind the firewall. Tightly managed access rights protocols are used throughout our network to ensure only authorized users have access to very granularly controlled services. Activity is logged and logs are regularly reviewed for irregularities. Third party security specialists are routinely engaged to test intrusion protection methods by performing routine scans of platform hosts whereby they cycle through a series of up-to-date exploits to verify all system hardening controls are current.
Data Provision to Fulfillment Service Providers. You acknowledge that E4X may provide your personal information to certain E4X service providers, in connection with the fulfillment of your purchase instructions, including but not limited to delivery agents, customs brokers, international revenue authorities and fraud management parties. E4X will always attempt to limit the information we provide to be what is reasonably sufficient for those service providers to carry out their responsibilities as they relate to the fulfillment of your purchase instructions, and to subscribe you to any E4X and/or Supplier marketing messages you opt in to receive. E4X does not share, sell, rent, or trade your information with any third parties for their promotional purposes, other than Suppliers who you authorize during the E4X checkout.
Opting In with E4X. If you opt in to receive notification from E4X of new U.S. Suppliers that become enabled with the FiftyOne service from time to time, your personal information may be used by E4X and/or its contracted marketing services partners to send you emails detailing the availability of new Suppliers, merchandise and/or promotions. Your marketing preferences with E4X will be based on the selection you have made during the most recent purchase instruction.
Opting In with Suppliers. If you opt in to receive information from a Supplier regarding any offers or promotions said Supplier may make available from time to time by consenting within the E4X checkout, your name, email address, billing address, and shipping address will be shared with the Supplier within the purchase instructions provided by E4X. E4X will indicate, within those purchase instructions, that you have indicated that you wish to receive marketing messages directly from them, at the email address and/or physical address you have provided to E4X within the billing information. You further acknowledge that once your personal data has been shared with a Supplier at your instruction, the subsequent safeguarding of your personal data by the Supplier will be governed by the Supplier’s privacy policy, and any request for further information with respect to their intended use and/or to change your marketing preferences with the Supplier shall be directed at the Supplier and not E4X. If you have previously opted in to receive marketing communication from a specific Supplier via an order placed with E4X, unchecking the marketing box within any subsequent order for merchandise sold by that same Supplier will not be treated as an opt out for marketing communication in which you previously opted in. FOR GREATER CLARITY, YOU ACKNOWLEDGE THAT ONCE YOU HAVE INSTRUCTED E4X TO PROVIDE YOUR PERSONAL INFORMATION TO A SUPPLIER FOR MARKETING PURPOSES, ANY SUBSEQUENT ADMINISTRATION OF YOUR COMMUNICATION PREFERENCES SHALL BE COMMUNICATED DIRECTLY TO THAT SUPPLIER AND THE USE OF YOUR PERSONAL INFORMATION WILL BE GOVERNED BY SUPPLIER’S PRIVACY POLICY.
Communications from E4X. E4X will send order-related emails to the email address you provided within the FiftyOne Global Checkout including but not limited to, for each order you place with E4X, an (i) order acknowledgement email, (ii) order confirmation emails, and (iii) shipment confirmation email. We may additionally attempt to contact you upon order placement at either the email address you provided during the FiftyOne Global Checkout or at the billing telephone number you provided, if we were unable to programmatically verify your billing details with your financial institution and/or public record databases, and where further information was determined to be required to protect E4X, Inc. and you against unauthorized credit card use. The foregoing contacts will only be attempted or made in connection with the fulfillment of your purchase instructions. Emails that are marketing in nature will only be sent to you if you opt in to receive updates on new Suppliers that become enabled with the FiftyOne service from time to time.
Modifying your Communication Preferences. If you wish to change your marketing communication preferences with E4X at any time, or correct, update or delete personal information previously provided to E4X, please send us an email at optout@fiftyone.com with the details of your request. We will respond to your request within 30 days. If you have previously placed an order with E4X, and opted in and consented for E4X to provide your contact information directly to the Supplier whose merchandise you were providing purchase instructions for, and you wish to change your marketing choices and/or communication preferences with that Supplier, please contact them directly.
EU Safe Harbor. E4X, Inc. complies with the EU Safe Harbor framework as set forth by the Department of Commerce regarding the collection, use, and retention of data from the European Union. If you have questions or concerns regarding this statement, you should first contact Iris Shechter, Director Merchant Services, E4X, Inc. at iris@e4x.com or 212-299-3500. If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with us to resolve your concern.

E4X, Inc. will fulfill your request to update, change or delete your personal information within 30 days.
Dispute Resolution with E4X. E4X, Inc. participates in the EU Safe Harbor Privacy Framework as set forth by the United States Department of Commerce. As part of our participation in the Safe Harbor, we have agreed to TRUSTe dispute resolution for disputes relating to our compliance with the Safe Harbor Privacy Framework. If you have any complaints regarding our compliance with the Safe Harbor you should first contact us (as provided above). If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet at http://www.truste.org/consumers/watchdog_complaint.php, fax at 415-520-3420, or mail at Watchdog Complaints, TRUSTe, 685 Market Street, Suite 270, San Francisco, CA, USA 94105. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, see http://www.truste.org/consumers/watchdog_complaint.php or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English. For human resources data we have agreed to cooperate with Data Protection Authorities.
Dispute Resolution with Suppliers. If you previously placed an order through the E4X checkout for merchandise supplied by one of E4X’s Suppliers, and you opted in and consented for E4X to provide your contact information directly to that Supplier so that you could receive information directly regarding any offers or promotions they may make available from time to time, any questions, comments or complaints about the data practices of the Supplier whose merchandise you purchased (including without limitation compliance with data privacy principles of notice, choice, onward transfer, access, security, data integrity, or enforcement) should be addressed to the Supplier.
Legal Disclaimer. We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on or to FiftyOne or E4X, Inc.
Use of Cookies. E4X uses cookies as part of our platform. The cookies our platform sets do not contain any personally identifiable information. Cookies are associated with computing sessions on our systems to ensure continuity for users as they move from one screen to another using our application. Our system does not employ the concept of buyer accounts, meaning buyers are not asked to login when they use our services. Each interaction with our platform creates a separate instance for a buyer and we do not link these instances by way of an account or cookies set.
Analytics. By placing an order with E4X, you acknowledge that E4X reserves the right to analyze transactional data, anonymously and in aggregate, for the purpose of identifying trends, statistics and measurements that could contribute to the enhancement of E4X services. By way of example and not limitation, such aggregate use could include identifying market sensitivities, and relative market interest in specific product categories. For greater clarity, any transactional data analyzed will expressly exclude any personally-identifiable information and will be aggregated.
Changes to this Privacy Statement. If we decide to change our privacy policy, we will post those changes to this privacy statement at http://www.fiftyone.com/privacy and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page.

Corporate Address
E4X, Inc.
55 W. 39th Street, 18th Floor
New York, NY, U.S.A. 10018

Effective Date of this policy is October 16, 2008

Last Updated August 6, 2009