| Privacy Statement |
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We at ICT-ESL are committed
to good privacy practices regarding your personal information. Your inquiry to our
web site seeking information, a returning user, job seeker, or visitor is important,
and we hope that our concerns regarding your privacy, as described in this policy
(the "Privacy Policy" or "Policy"), demonstrate our commitment to making your experience
with ICT-ESL an enjoyable and satisfying one. Although ICT-ESL respects the privacy
of all those who visit our Web sites and use our online services, we do collect
information from our visitors, including ESL users and customers. This Privacy Policy
governs your interaction with the ICT-ESL web site and your registration for and
use of ICT-ESL's online services (collectively, the "Services"). Except as set forth
within this Privacy Policy and our Terms of Use and other published guidelines,
we do not release personally identifiable information about our members and visitors
without their permission. Note that, by using the Services, you signify your agreement
to this Privacy Policy. If you do not agree to this Policy, please do not use the
Services. Your continued use of the Services subsequent to changes to this Policy
will mean that you accept the changes; therefore, please bookmark this page and
review it periodically. If you have any questions regarding this Privacy Policy,
or any other privacy issues in connection with the Services, please e-mail us at
privacy@ICT-ESL.com.
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A. The information we gather.
ICT-ESL gathers two types of information about users: |
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1. Non-personally identifiable information (information
that does not identify a specific individual): When visitors use the Services, we
collect and aggregate information indicating, among other things, which pages were
visited, the order in which they were visited, and which links were "clicked." Collecting
such information involves the collection and logging of IP addresses, operating
system, and browser software used by each user of the Services. Although such information
is not personally identifiable, we can determine from the IP address a visitor's
Internet Service Provider and the geographic location of his or her point of connectivity.
The non-personally identifiable information we collect helps us identify the most
popular areas of our web site and determine the effectiveness of our promotional
activities. In addition, we may disclose some of this information to advertisers
to inform them of the number of people who have seen and/or clicked through their
advertisements. We collect non-personally identifiable information in part through
the use of "cookies" - that is, small text files placed on your computer's hard
drive - that help us determine the type of content and pages to which you link,
the length of time you spend at any particular area of the Services, and the Services
you choose to use. Cookies also tell us which advertisements you have seen on our
Services, allowing us to continue to provide many of these Services at little or
no cost to you. Essentially, cookies are your identification cards for the ICT-ESL
computers or servers that placed them there. Cookies are only read by the server
that placed them, and are unable to execute any code or virus; they will not permit
a Web site operator to learn any personally identifiable information (see below)
about you unless you have previously provided that information to the Web site operator
or you have set the preferences in your browser to provide this information. Cookies
allow ICT-ESL to serve you better and more efficiently, and to personalize your
experience with the Services - for example, by allowing us to save your password
so that you do not have to reenter it each time you use the Services. Nevertheless,
you should be able to control how and whether cookies will be accepted by your web
browser. For more information on how to do so, please refer to the documentation
accompanying your browser. Please note that our advertisers and their designees,
as well as other third parties, may collect information about you through cookies
or other technologies when they serve advertisements through the Services or when
you visit their Web site(s). Additionally, the Services contain links to other third
party Web sites, including co-branded or other affiliated sites which may or may
not be owned or operated by or in conjunction with ICT-ESL. You acknowledge that
we do not monitor or control the information collection or privacy practices of
any third parties, and are not responsible for their practices or the content of
their web sites, including their use of any information (such as IP number, browser
type, or operating system) collected when visitors or Members "click through" links
to their sites or view advertisements served by them. Even though certain information
collected by such third parties might not identify you personally, we strongly encourage
you to become familiar with their privacy practices, and to contact such third parties
if you have any questions about their respective privacy policies.
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2. Personally identifiable
information: In certain areas of the Services - such as those in which you Announce
Availability, complete a profile, create a new account, or enter ICT-ESL-sponsored
contests or promotions - we may request that you provide us with certain personally
identifiable information, such as your e-mail address, name, zip code, profession,
or work experience. We will, in such situations, seek to identify which informational
items are required and which are optional. The Services are not available to children
under 13 years of age. We do not knowingly collect personally identifiable information
from children under 13 years of age. Please note that ICT-ESL cannot control the
acts of users of the Services. All members and visitors should be aware that, when
they disclose personally identifiable information to a third party advertiser, the
information may be collected and used by others to send that person unsolicited
email from other parties outside ICT-ESL. In the event that you encounter any ICT-ESL
user who is improperly collecting or using information about you or other users,
please contact
privacy@ICT-ESL.com. |
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B. How we use (and do not use)
the information we gather. Please take some time to familiarize yourself with the
different ways we use the information we gather. Keep in mind that, while ICT-ESL
encourages all third parties involved - including but not limited to its advertisers
- to adhere to our policies regarding the privacy of our members and visitors and
to otherwise handle personal information in a responsible manner, we cannot and
do not assume any responsibility for any actions or omissions of third parties,
including the manner in which they use information received either from ICT-ESL
or independently. Nevertheless, in the event you encounter any third party associated
with, or who claims association with ICT-ESL, who you feel is improperly collecting
or using information about you, please contact privacy@ICT-ESL.com . We will be
happy to forward your message to the third party or contact the third party on your
behalf.
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1. How we use (and do not use) Personally & non-personally
identifiable information: We use non-personally identifiable information in aggregate
form to build higher quality, more useful Services by performing statistical analyses
of the collective characteristics and behavior of our visitors and members, and
by measuring demographics and interests regarding specific areas of the Services.
We may provide statistical information based on this data to advertisers and other
current and potential business partners. We may also use the aggregate data to inform
these third parties as to the number of people who have seen and clicked through
links to their sites. Please note that ICT-ESL reserves the right to disclose information
submitted by or concerning any visitor or member as we reasonably feel is necessary
to protect our systems or business. Specifically, but without limitation, we reserve
the right to disclose such information when a visitor or member is in violation
of our Terms of Use or other published guidelines, or partakes (or is reasonably
suspected of partaking) in any harmful, infringing or illegal activity, even without
a subpoena, warrant, or other court order, and to disclose such information in response
to court and governmental orders, civil subpoenas, discovery requests, and as otherwise
required by law, as well as in response to allegations of infringement. We cooperate
with law enforcement agencies in identifying those who may be using our servers
or services for illegal activities. We also reserve the right to report any suspected
illegal activity to law enforcement for investigation or prosecution, or to suspend
or terminate your membership in connection with any suspected illegal or infringing
activity. Finally, ICT-ESL reserves the right to assign, sell, license, or otherwise
transfer to a third party your personally identifiable information in connection
with an assignment, sale, joint venture, or other transfer or disposition of any
portion or all of ICT-ESL's or its affiliated entities' assets or stock. Subject
to the foregoing, ICT-ESL uses your personally identifying information in several
ways:
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• to customize various aspects
of the Services to your preferences;
• to determine which advertisements or sponsor messages will appear
on your screen; |
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• to send to you ICT-ESL solicitations, product announcements,
and the like that we feel may be of interest to you (you may "opt out" of receiving
these materials, as provided below);
• to send to you certain e-mail messages that are critical to your use of the Services,
such as system status updates or order confirmations (because these messages contain
important information, you may not be able to "opt out" of receiving such messages);
• to "pre-populate" forms that are displayed for the purpose of collecting individual
data by ICT-ESL and/or its sponsors (in no case will pre-populating a form automatically
transfer any data to an advertiser or other third party - only if you voluntarily
request that such data be transferred will any such transfer take place, e.g., by
clicking the "Submit" button); and
• as may be necessary to support the operation of the Services, such as for billing,
account maintenance, and record-keeping purposes. In addition to the circumstances
described above, ICT-ESL may disclose your personally-identifiable information to
third parties as follows:
• If you "opt in" to receive promotional materials (see below), information you
have made available to ICT-ESL may be made available to third parties who provide
goods or services that we believe may be of interest to you.
• If you provide us with your credit card information, we will not release that
information to third parties unless necessary to complete a transaction between
you and such a third party. Credit card transactions are handled by a third-party
financial institution, which receives the credit card number and other personal
identifying information only to verify the credit card numbers and process transactions.
• All information made available to ICT-ESL may be made available to our contractors
and consultants, and professional advisors (such as attorneys or accountants), but
only to the extent necessary for them to perform services on our behalf, and only
under a duty of confidentiality. |
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