Consumer Privacy Policy

1. 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.
2. About FiftyOne. FiftyOne, Inc. ("FiftyOne" - f/k/a E4X, Inc.) 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 FiftyOne, Inc. that allow suppliers of popular brand name retail merchandise ("Suppliers") and international consumers to connect and transact effortlessly.
3. Third Party Review. FiftyOne has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information.  TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions.
4. Data Collected. The information collected from you by FiftyOne during the FiftyOne Global Checkout is consistent with information typically collected by transactional ecommerce Web sites such that said 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 e-mail address, (iv) your IP address, (v) credit card information, (vi) your marketing preferences with FiftyOne and (vii) your marketing preferences with the Supplier whose merchandise you are purchasing. If you choose to send us a question or request more information regarding our products and services we will ask for information such as name, e-mail address, and phone number.
5. 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 identifiable information is transmitted between FiftyOne 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.
6. Data Provision to Fulfillment Service Providers. You acknowledge that FiftyOne may provide your personal information to certain FiftyOne 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. FiftyOne 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 FiftyOne and/or Supplier marketing messages you opt in to receive. FiftyOne 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 FiftyOne checkout.
7. Opting In with FiftyOne. If you opt in to receive notification from FiftyOne of new U.S. Suppliers that become enabled with the FiftyOne service from time to time, your personal information may be used by FiftyOne and/or its contracted marketing services partners to send you e-mails detailing the availability of new Suppliers, merchandise and/or promotions. Your marketing preferences with FiftyOne will be based on the selection you have made during the most recent purchase instruction.
8. 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 FiftyOne checkout, your name, e-mail address, billing address, and shipping address will be shared with the Supplier within the purchase instructions provided by FiftyOne. FiftyOne will indicate, within those purchase instructions, that you have indicated that you wish to receive marketing messages directly from them, at the e-mail address and/or physical address you have provided to FiftyOne 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 FiftyOne. If you have previously opted in to receive marketing communication from a specific Supplier via an order placed with FiftyOne, 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 FiftyOne 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.
9. Communications from FiftyOne. FiftyOne will send order-related e-mails to the e-mail address you provided within the FiftyOne Global Checkout including but not limited to, for each order you place with FiftyOne, an (i) order acknowledgement e-mail, (ii) order confirmation e-mails, and (iii) shipment confirmation e-mail. We may additionally attempt to contact you upon order placement at either the e-mail 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 FiftyOne, 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. E-mails 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.
10. Modifying your Communication Preferences. If you wish to change your marketing communication preferences with FiftyOne at any time, or correct, update or delete personal information previously provided to FiftyOne, please send us an e-mail at optout@fiftyone.com with the details of your request or, as relates to marketing communications, you may follow the unsubscribe instructions contained in the marketing communications you receive. We will respond to your request within 30 days. If you have previously placed an order with FiftyOne, and opted in and consented for FiftyOne 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.
    We will retain your information for at least as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
11. EU Safe Harbor. FiftyOne, Inc. complies with the EU -- & Swiss Safe Harbor framework as set forth by the Department of Commerce regarding the collection, use, and retention of data from the European Union and Switzerland. If you have questions or concerns regarding this statement, you should first contact Ari Staiman, Chief Privacy Officer & General Counsel, FiftyOne, Inc. at ari.staiman@fiftyone.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://watchdog.truste.com/pvr.php?page=complaint. TRUSTe will then serve as a liaison with us to resolve your concern. Information regarding the E.U. Safe Harbor Framework can be found at:  http://export.gov/safeharbor.
12. Dispute Resolution with FiftyOne. FiftyOne, Inc. participates in the U.S.-EU and U.S-Swiss 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://watchdog.truste.com/pvr.php?page=complaint fax at (415) 520-3420, or mail at Watchdog Complaints, TRUSTe, 55 Second Street, Suite 2, 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://watchdog.truste.com/pvr.php?page=complain 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.
13. Dispute Resolution with Suppliers. If you previously placed an order through the FiftyOne checkout for merchandise supplied by one of FiftyOne’s Suppliers, and you opted in and consented for FiftyOne 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.
14. 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, Inc. In the event FiftyOne goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred.
15. Analytics. By placing an order with FiftyOne or visiting our site, you acknowledge that FiftyOne 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 FiftyOne 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.
16. 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 e-mail, or by means of a notice on our home page.

Corporate Address
FiftyOne, Inc.
8 W. 40th Street, 5th Floor
New York, NY 10018
U.S.A.

Effective Date of this policy is October 16, 2008

Last Updated October 31, 2011