Privacy Policy

LCO Software, Inc. (“LCO”) operates the website www.napleschristmascheer.com (the “Site”) and manages the data collected, organizes its maintenance and the placing of its content.

LCO is strongly committed to issues of privacy and this policy sets out LCO’ approach to the collection, storage, usage and transfer or disclosure of collected information.

Data Collection

LCO only collects personal information or data that is voluntarily supplied by a user of the website. By way of examples, users of the website may wish to provide personal information for the purposes of:

•Registering to use certain portions of the website;
•Applying to participate in a program;
•Making contact with the company

Information supplied by users for such purposes may include e-mail addresses, names, dates of birth, contact addresses, household member details and any other additional information that users may choose to supply. These data collection forms do not use cookies.

Security

The security and protection of personal information supplied by a user to this website is of the highest importance and concern to LCO. LCO has in place all generally accepted standards of technology and operational security in order to protect personal information submitted to this website from loss, misuse, alteration or destruction and to ensure compliance with the requirements of the Data Protection Act 1998.

Notwithstanding the arrangements set out above, a user of this website submits personal information to the website at the user’s own risk.

Use of Data

LCO commits to the user that it will only use the personal information supplied by the user for the purposes for which such information was provided or for its own statistical analysis. The website does not collect personal information for sale or dissemination to third parties or host mailings on behalf of third parties. Where required by the reason for which the personal information was initially supplied by the user, the personal information will be shared with other companies under the protections required by the Data Protection Act 1998 and with the explicit consent of the user.

In particular, users supplying personal information for the Salvation Army Christmas Cheer Program, should note that in doing so they are consenting to the exchange of such personal information between LCO and the Salvation Army with all legally required data protection requirements being in place.

Data Controller

LCO Software, Inc. (a registered Florida corporation) is the data controller of any personal data collected through this website and will process such information in accordance with the provisions of the Data Protection Act 1998. Any enquiries relating to data protection issues should be sent to our legal team at legal@LCOinc.com.

Disclosure of Personal Information to Third Parties

LCO will not share any personal information collected on the website with Third Parties unless required by law, required to enable the fulfilment of the purpose for which the personal information was originally supplied or as otherwise set out in this Policy. In submitting personal information to this website the user is giving explicit consent for such usage.

LCO may transfer all or part of its business in the circumstances of a merger or sale of part or all of its business. In such circumstances personal information supplied by a user of this website may be transferred but this will be only in circumstances where the acquiring company has agreed to the same standards and terms of privacy as are set out in this policy.

LCO complies with the US-EU Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from EU member countries. LCO has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement.

Use of cookies on the Site

The use of cookies is now commonplace on many websites. Cookies enable LCO to identify your device. We use cookies that are strictly necessary to enable you to move around the site or to provide certain basic features. We use cookies to enhance the functionality of the website by storing your preferences, for example. We also use cookies to help us to improve the performance of our website to provide you with a better user experience. LCO also uses cookies through our use of Google Analytics on the Site, to track user interaction with the Site. We do this so we can identify which content is of greatest interest to users, in order to allow us to deliver more meaningful content in the future. Tracking usage of the Site through Google Analytics entails placing small digital files on your device (for example, computer or mobile phone). These include small files known as “cookies”. They cannot be used to identify you personally. This information includes the number of visitors to the Site, how visitors have reached the Site from and the pages that they visited within the Site.

Google Analytics

Google Analytics collects first party cookies, as described above. The information collected using these cookies is sent to Google and is used to evaluate how the Site is being used. This enables LCO to compile statistical reports on how the Site is being used in order to help us deliver more meaningful content for visitors to the Site.

LCO does not collect (nor allow any third party to collect using the Site) personally identifiable information of visitors to the Site. We will not associate any data gathered with any personally identifying information. We will not link or seek to link any cookie information with any IP address or with the identity of a computer user. In short, our use of Google Analytics does not identify who you are, but it does track your movements on the Site.

A full list of cookies used by Google Analytics and explanations on how these work are available on Google’s website

https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

http://www.google.com/analytics/learn/privacy.html

http://www.google.com/intl/None/policies/privacy/

Legal Requirements

The law requires us to obtain the consent of our users to download cookies on to their machines, and we want our users to find information and services quickly. You can access this information through the privacy policy page which is linked to in the footer of every web page.

How to disable cookies

You can stop cookies being downloaded on to your computer by selecting the appropriate settings on your browser. However please note that if you do this you may not be able to use the full functionality of the Site.

There is more information about cookies, including how to delete them on the website aboutcookies.org. You may also opt out of being tracked by Google Analytics.

privacy@napleschristmascheer.com