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BONNE BELL PRIVACY POLICY This site is operated by Bonne Bell. The Bonne Bell Company is committed to protecting your private information while you surf our websites. We want to keep all the visitors to our site happy and secure, so we urge you to read this entire Privacy Policy (and if you are under 13 your parents must read it with you) so that you will know what The Bonne Bell Company does with the private information you provide to us. CHILDREN'S PRIVACY POLICY Bonne Bell is especially sensitive to the need to protect the interests of children and has adopted this Children's Privacy Policy to supplement its Privacy Policy, which appears below. This Children's Privacy Policy describes the additional, special policies Bonne Bell applies to the collection, use or disclosure of personally identifiable information from visitors to our site(s) who are under 13 years of age. COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION FROM CHILDREN UNDER 13 When a visitor to our Site is under the age of 13, Bonne Bell does not require the disclosure of more personally identifiable information than is reasonably necessary for him or her to participate in an activity as a condition of such participation. Bonne Bell may use different types of personally identifiable information submitted to this Site by children under 13 in a variety of ways, which are described below. In each instance, we comply with the parental consent requirements of Children's Online Privacy Protection Act ("COPPA"). USE: BONNE BELL'S USE OF PERSONALLY IDENTIFIABLE INFORMATION We may collect a child's email address, first name and other personally identifiable information in connection with a contest, sweepstakes or game for the sole purpose of communicating with the child on a one-time-only basis (i.e., to contact a contest winner). This information will not be used to re-contact the child, and will be deleted from our records when the contest or game is over. Parental consent is obtained before we send the winner a prize. We may collect a child's email address and first name in order to respond more than once to a child's specific request. For example, the child may want to subscribe to an online newsletter or receive other online communications from Bonne Bell. In these instances, Bonne Bell will also obtain a parent's email address along with the child's. Before any further contact with the child, Bonne Bell will send an email to the parent (a) notifying him or her we have collected the child's email address in order to respond more than once to the child's request for a subscription, information, or other service; (b) informing the parent that he or she can refuse us permission to contact the child, and how to do so; and (c) informing the parent that if he or she does not respond to the email within one (1) week, Bonne Bell may use the child's information for the purpose for which it was submitted. Under no circumstances will the child be allowed to participate without giving a parent's email address. We may collect a child's personally identifiable information (including name, email address, mailing address and phone number) for such activities as surveys, games, requests for suggestions, content submissions, requests for products or services, or requests for additional information. In these instances we will initially collect only the child's first name and email address and the email address of the child's parent. Before using this information for any purpose, we will send the parent an email that (a) informs the parent that we wish to collect and use the child's personal information and (b) provides the parent with a link to access this Privacy Policy, which describes our information collection and use policies as required by COPPA. Bonne Bell will ask the parent to provide consent online (e.g., by return email, via a link to webpage) If parent does not consent to such use or the parent does not respond, we will not use the child's personally identifiable information for any purpose and we will delete the child's personally identifiable information. Bonne Bell will only use the child's personally identifiable information for internal purposes and will not share it with any third party. We may share anonymous, aggregated information with third parties, provided that it is not traceable to any particular user and will not identify you. We will only do so under a contract which requires the third party assisting us to keep such information confidential. We may collect a child's name and email address to the extent reasonably necessary to protect the security of this Site, to protect against liability or as required or permitted by law. Information collected for these reasons will not be used for any other purpose. During member registration process, new members are encouraged not to use their name or other identifying information, however, they are asked to enter birth date, so that we may identify members that are under age 13, and prevent our under age 13 members from using features that might allow them to enter personal information without prior parental consent. For example, our Site includes Chic-chat, where members can enter their own messages. If a member under age 13 requests access to the Chic-Chat area he or she will be prompted to provide his or her parent's email information. We use this information only for the purpose of providing notice to you and requesting parental consent. If we do not receive consent from a member under age 13, that member will still be allowed to participate in Chic-Chat, but all messages will be reviewed and filtered by our staff prior to posting on the Site to prevent the posting of personal information. This will likely cause a delay in the posting of messages. Messages of members under the age of 13 for which we have received parental consent will not undergo this extra scrutiny, and will not experience the resulting delay. We also allow members to submit images to the Site, such as photographs or artwork, for display on the Site. All images are reviewed prior to posting on the Site both for appropriateness and to try and prevent identifying information from being provided by our members. If a member under age 13 requests to post an image, he or she will be prompted to provide his or her parent's email information. We use this information only for the purpose of providing notice to you and requesting parental consent. If you object to a posted image for any reason you may contact us at (http://www.lipsmackerlounge.com/photoreview.php) and request that the image be removed. LINKS/CO-BRANDED SITES Users may, through hypertext or other computer "links," gain access to other websites on the Internet which are not operated by Bonne Bell. Bonne Bell is providing these links to you only as a convenience, and the inclusion of any link does not imply endorsement by Bonne Bell of the website linked to. BONNE BELL ASSUMES NO RESPONSIBILITY FOR ANY MATERIAL OUTSIDE OF THE WEBSITES OPERATED BY BONNE BELL AND ITS AFFILIATES, INCLUDING ANY WEBSITES WHICH MAY BE ACCESSED THROUGH A LINK ON A BONNE BELL OPERATED WEBSITE. Unless otherwise indicated at a Bonne Bell operated website, Bonne Bell is not sponsored by or affiliated with the linked websites. Bonne Bell specifically disclaims responsibility for any inadvertent viewing by anyone under age eighteen (18) of any material intended for adults on a website accessed through use of a linked website. This Site may link directly to sites operated by Bonne Bell's advertisers, business partners and affiliated companies. Those sites, which are not controlled by Bonne Bell, may collect personal information from your child. Parents should therefore check the relevant site's privacy policy to understand how it collects and uses children's personal information. Bonne Bell will not share in any personal information obtained by another site from a child under the age of 13 unless that site follows the requirements of COPPA. We are not, however responsible for other websites' privacy practices or website content. Occasionally, you may receive cookies from advertisers, partners, and vendors. We do not control these cookies. REVIEWING AND MAKING CHANGES TO PERSONALLY IDENTIFIABLE INFORMATION COLLECTED FROM CHILDREN UNDER 13 Parents of children under age 13 may review or delete personal information about their children from our records and refuse to allow further collection or use of their children's information. If you would like your child's personal information deleted, please contact us through any of the following options: On-line Privacy, The Bonne Bell Company 18519 Detroit Avenue Lakewood, Ohio 44107 Attention: webmaster Tel: 1-800-321-1006 / Bob Evans Or by e-mail at: webmaster@bonnebell.com. We will delete your child's information from our database if you so request. If you would like to review the personal information in our records submitted by your child, or change any personally identifiable information previously submitted by your child, please contact us through any of the following options: On-line Privacy, The Bonne Bell Company 18519 Detroit Avenue Lakewood, Ohio 44107 Attention: webmaster Tel: 1-800-321-1006 / Bob Evans Or by e-mail at: webmaster@bonnebell.com. Effective Date: 11/25/08 GENERAL PRIVACY POLICY TERMS Bonne Bell has adopted a set of Privacy Principles applicable to all its websites. Bonne Bell has implemented those Principles in this Privacy Policy, which describes how we collect, use and share personally identifiable information ("PII") we obtain from and about individuals located in the U.S., both online and off-line. From time to time Bonne Bell may revise this Privacy Policy to reflect industry initiatives or changes in the law, our PII collection and use practices, the features of our websites or technology. If we make revisions that change the way we collect or use your PII, those changes will be posted in this Privacy Policy and the effective date will be noted at the beginning of the Policy. Therefore, you should review it periodically so that you are up to date on our most current policies and practices. If Bonne Bell materially changes its practices regarding collection or use of your PII, your PII will continue to be governed by the Policy under which it was collected unless you have been provided notice of and have not objected to the change. COLLECTION: COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION ("PII") BY BONNE BELL Bonne Bell collects personally identifiable information ("PII" -- that is, information such as your full name, email address, mailing address or telephone number) in order to create or enhance our relationship with you. When we collect PII from you it is because you are voluntarily submitting the information to us in order to participate in activities like sweepstakes, contests, games, surveys, forums, subscription registrations, in connection with content or suggestions you submit to us, chats, bulletin boards, or because you want us to furnish you with products, services or information. We may also obtain PII from reputable third parties. In addition, when we connect information that we obtain from third parties with PII that we have collected under this Privacy Policy, we will treat the acquired information like the information that we collected ourselves, and except as permitted by this Privacy Policy, the information will not be shared with third parties. WEBSITE SPECIFIC INFORMATION COLLECTION * LipsmackerLounge.com Membership Users of the LipsmackerLounge.com Website may anonymously join LipsmackerLounge.com by creating a screen name and password. Screen names should not be user's actual names. User names and passwords are confidential and must not be divulged by users to anyone. Although LipsmackerLounge.com includes opportunities to earn points, get homework help, view exclusive content not featured on our Smackers site, and send comments to Smackers, we do not ordinarily collect any PII of our users in connection with LipsmackerLounge.com. We do, however, give our users the opportunity to send a postcard to a friend inviting them to LipsmackerLounge.com. Names and e-mail addresses collected in connection with such requests are used for no other purpose and are permanently deleted from our records promptly after the postcard has been sent. We also give our users the opportunity to send feedback and ideas to us. Although LipsmackerLounge.com includes opportunities to earn points and get homework help, no personally identifiable submissions from children under the age of 13 are posted on the Website without prior written consent of parents or guardians. Except as described in this Privacy Policy, any data collected in connection with LipsmackerLounge.com remains anonymous and The Bonne Bell Company will keep such data separate from contact information collected exclusively to fulfill a user's request for updates. (See "Lipsmacker Lounge Updates," below, for more information.) * Lipsmacker Lounge Updates Users of the Website may request to receive regular updates from LipsmackerLounge.com. The only information we require from a child is their e-mail address. If the requester indicates that he or she is under the age of 13, we ask for the e-mail address of a parent. We automatically contact the parent by e-mail to let them know about the child's request to receive regular updates from Lipsmacker Lounge. In that e-mail message, we provide parents with instructions to refuse to permit further contact with the child and to require the deletion of the information we have collected from the child and, in each update, we provide a way to unsubscribe and a link to this Privacy Policy. The contact information we collect is used only to send these updates to the child and for no other purpose. The Bonne Bell Company will not combine contact information collected exclusively to fulfill a user's request for updates with any other information collected on the Website, including LipsmackerLounge.com user names and account data. If we use the services of a third party to help us deliver or process the delivery of these updates to the child, we will only do so under a contract which requires the third party assisting us to keep such information confidential. (Please see "LipsmackerLounge.com Membership," and "Parent's Rights to their Children's Collected Information," above, for more information.) * Smackers Advisory Panel Certain LipsmackerLounge.com members may be selected as Smackers Advisory Board members. With the advance written consent of parents or guardians, Advisory Board members will be asked to provide input on projects such as new product concepts, product testing, product preferences, opinion surveys, teen lifestyle questions and other Smackers research as well as her name, age and other information via e-mail, the Smackers Advisory Board Website or otherwise (the "Advisory Panel Submissions"). Personally identifiable Advisory Panel Submissions may be combined with information collected from your child as a LipsmackerLounge.com member, however such information will be used only for The Bonne Bell Company's marketing purposes in connection with the sale or advertising of Bonne Bell's products. Except as set forth under this Privacy Policy, any information shared with third parties will be done on an anonymous, aggregated basis and only under a contract which requires the third party assisting us to keep such information confidential. * colorandflavorshop.com Our Website offers users the chance to purchase Bonne Bell and Smackers products though colorandflavorshop.com. colorandflavorshop.com will collect personal information in order to complete purchase transactions. Data collected will be kept separate from contact information collected exclusively to fulfill a user's request for LipsmackerLounge.com updates as well as LipsmackerLounge.com user names and account data. All information provided is maintained by The Bonne Bell Company and is subject to The Bonne Bell Company's privacy policy. If you are not comfortable with our policies, do not make a purchase through colorandflavorshop.com. COLLECTION BY AUTOMATED SYSTEMS We may collect and log certain non-personally identifying information which a user's browser makes available whenever a user visits the Website. This information may include a user's Internet Protocol ("IP") address (a unique number assigned to every computer on the Internet), home server domain name, computer type, browser type, browser language, as well as the date and time of a user's visit. This information does not include a user's Personal Information. We use this information to administer, operate, develop, and improve the Website. We may also track and store information in the aggregate as it relates to user's movement within the Website such as the pages from which the user was referred, entry and exit points for the Website, search terms, pages a user visits, page views/impressions, access times, domain names and browser types. None of this information is linked to a user's PII. Cookies are small bits of information that Bonne Bell's Internet sites place on the hard drive of your computer. Cookies remember information about your activities on our site(s) and enable Bonne Bell to make your visits to our site(s) more enjoyable. For example, cookies can store your password for easy logon to a site you have previously visited or can save your preferences for a personalized home page. Third party advertisements displayed on Bonne Bell's sites may also contain cookies set by Internet advertising companies or advertisers. Bonne Bell does not control these cookies and visitors to our web site(s) sent by Internet Advertisers or other companies, should check the privacy policy of the advertiser to see whether and how it uses cookies. Bonne Bell may use cookies and similar tools to relate your use of our web site(s) to PII obtained from you or a reputable third party. For example, if you've asked us to send you information about our upcoming products or promotions, cookie and/or click stream data about your activities on Bonne Bell's websites may allow us to limit the materials we send you to items we think you will find interesting, based on your prior online activities and preferences. However, if Bonne Bell wishes to combine your personal and cookie or click stream information in this manner, we will obtain your express affirmative consent. You can program your computer to warn you each time a cookie is being sent or to refuse cookies completely. However, without cookies you won't have access to certain features on Bonne Bell's websites such as registration for sweepstakes. We may also use web beacons on our Website. A web beacon, also known as a "web bug," is a small, graphic image on a Web page, in a Web-based document or in an e-mail message that is designed to allow us to monitor visitors to the Website, the IP address of the computer to which the Web beacon is sent, the URL of the page from which the Web beacon comes, and the time it was viewed. None of this information is linked to a user's PII. NOTICE: BONNE BELL WILL PROVIDE YOU WITH NOTICE ABOUT ITS PII COLLECTION PRACTICES When you voluntarily provide PII to Bonne Bell, we will make sure you are informed about who is collecting the information, how and why the information is being collected and the types of uses Bonne Bell will make of the information. At the time you provide PII, Bonne Bell will notify you of your options regarding our use of your PII, including whether we will share it with outside companies (See "Choice" below). This Policy describes the types of other companies that may want to send you information about their products and services and therefore want to share your personal information, provided you have given Bonne Bell permission to do so (See "Use" below). Sometimes we collect personally identifiable information from consumers in manual format or off-line, such as a post card or subscription form. Providing detailed notice in those situations often proves impractical, so consumers will instead be provided with a short notice that describes how to obtain the full text of this Policy and other relevant information from us. Bonne Bell's web sites may be linked to Internet sites operated by other companies. Some of these third party sites may be co-branded with a Bonne Bell logo, even though they are not operated or maintained by Bonne Bell. Bonne Bell's web sites may also carry advertisements from other companies. Bonne Bell is not responsible for the privacy practices of web sites operated by third parties that are linked to our sites(s) or for the privacy practices of third party or national Internet advertising companies. Once you've left a Bonne Bell site via such a link or by clicking on an advertisement, you should check the applicable privacy policy of the third party or advertiser site to determine how they will handle any PII they collect from you. Bonne Bell's web sites may also be linked to sites operated by companies affiliated with Bonne Bell. Although affiliated entities adhere to the Group's Privacy Principles, visitors to those affiliated sites should still refer to their separate privacy policies and practices, which may differ in some respects from this Policy. CHOICE: BONNE BELL WILL PROVIDE YOU WITH CHOICES ABOUT THE USE OF YOUR PII Bonne Bell will not use the PII you provide to us for purposes different from the purpose for which it was submitted or share your PII with third parties that are not affiliated with Bonne Bell, unless we obtain your permission. USE: BONNE BELL'S USE OF PII Bonne Bell will use the PII you provide in a manner that is consistent with this Policy. If Bonne Bell obtains PII from a third party, such as a business partner, our use of that information is governed by this policy. Bonne Bell may share your PII with companies that are affiliated with us. Provided you have given us consent, Bonne Bell may also share your PII with advertisers and business partners that are not affiliated with Bonne Bell, but would like to send you information about their products and services. However, you will always have the opportunity to instruct us not to share your information with third parties when PII is collected. Bonne Bell employees, agents and contractors must have a legitimate business reason to obtain access to your PII. Bonne Bell may share your PII with outside contractors or agents who help us manage our information activities (i.e., sweepstakes administration, order fulfillment, statistical analyses) but they may only use your PII to provide Bonne Bell with a specific service and not for any other purpose. There may be instances when Bonne Bell may disclose PII without providing you with a choice in order to protect the legal rights of Bonne Bell, other companies affiliated with Bonne Bell or their employees, agents and contractors; to protect the safety and security of visitors to our web sites; to protect against fraud or for risk management purposes; or to comply with the law or legal process. In addition, if Bonne Bell sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, Bonne Bell may transfer your PII to a third party as part of that transaction. SECURITY: BONNE BELL PROTECTS THE SECURITY OF PII Bonne Bell uses reasonable administrative, technical, personnel and physical measures to safeguard PII in its possession against loss, theft and unauthorized use, disclosure or modification. In addition, Bonne Bell uses reasonable methods to make sure that PII is accurate, up-to-date and appropriately complete. ACCESS: HOW TO ACCESS, CORRECT OR DELETE YOUR PII Visitors to Bonne Bell websites may review the PII we maintain about them in our records whenever possible. If you would like to review, correct, or delete this information, please contact Bonne Bell through any of the following options: Via post, telephone and email: On-line Privacy, The Bonne Bell Company 18519 Detroit Avenue Lakewood, Ohio 44107 Attention: webmaster Tel: 1-800-321-1006 / Bob Evans Or by e-mail at: webmaster@bonnebell.com. REMEDIES AND COMPLIANCE: HOW TO CONTACT BONNE BELL ABOUT PRIVACY CONCERNS Bonne Bell welcomes any suggestions on how to make Bonne Bell a better and safer place. If you would like to communicate with us about our Privacy Policy or have privacy issues or complaints regarding this policy, please contact us through any of the following options: On-line Privacy, The Bonne Bell Company 18519 Detroit Avenue Lakewood, Ohio 44107 Attention: webmaster Tel: 1-800-321-1006 / Bob Evans Or by e-mail at: webmaster@bonnebell.com. ACCEPTANCE OF PRIVACY POLICY This Privacy Policy outlines the information usage practices of Bonne Bell. By accessing, browsing or using this Website or by submitting your personal information to Bonne Bell, you signify your agreement to the terms and conditions of this policy. If you do not agree to this policy, please do not submit your personal information to us.
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