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June 12, 2009

Breggin.com Newsletter Privacy Policy

www.breggin.com Privacy Policy

www.breggin.com is dedicated to establishing a trusting relationship with its users, based on respect for personal identity and information, by promoting the use of fair information practices. This privacy statement covers all Web properties owned and maintained by www.breggin.com, including but not limited to http://www.myfax.com, http://www.my1voice.com, www.campaigner.com and http://www.breggin.com.com. Because www.breggin.com wants to demonstrate its commitment to our users’ privacy, we are disclosing:

  • What personally identifiable information www.breggin.com collects.
  • How www.breggin.com uses the information.
  • With whom www.breggin.com may share user information.
  • Your choices about collection, use and distribution of the information.
  • The safeguarding procedures that are in place to protect the loss, misuse or alteration of information under www.breggin.com control.
  • How users can correct any inaccuracies in the information.

If users have questions or concerns regarding this statement, they should contact www.breggin.com Customer Support by email at [email protected].

A) Information Collection

www.breggin.com is the sole owner of the information collected on its web properties, including http://www.myfax.com, http://www.my1voice.com, www.campaigner.com and http://www.breggin.com.com. www.breggin.com collects information from its users at several different points on our Web sites.

1) Registration

In order to use www.breggin.com services at any level, and to access certain information or areas of the website (including various downloads, “Test Drives”, webinars, etc.), a user must first complete the registration form. During registration a user is required to give contact information (such as name, telephone number or an email address). We use this information to contact the user about services on our sites. It is optional customer to provide demographic information (such as income level and gender), but encouraged so we can provide a more personalized experience on our sites.

2) Order

When a user purchases a paying service, we request information from the user on our order form. A user must provide contact information (such as name, email, and billing address) and financial information (such as credit card number, expiration date). This information is used for billing purposes and to fill customer’s orders. If we have trouble processing an order, the information is used to contact the user.

3) Profile

We store information that we collect through cookies and log files to create a profile of our users. A profile is stored information that we keep on individual users that details their viewing preferences. Consequently, collected information is tied to the user’s personally identifiable information to provide offers and improve the content of the site for the user. This profile is used to tailor a user’s visit to our Web sites, and to direct pertinent marketing promotions to them. We do not share personally identifiable elements of your profile with other third parties. Your profile is shared in aggregate form only.

4) Cookies

A cookie is a piece of data stored on the user’s computer tied to information about the user. Usage of a cookie is in no way linked to any personally identifiable information while on our site. We use both session ID cookies and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the user’s hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions.

By setting a cookie on our site, users would not have to log in a password more than once, thereby saving time while on our site. If users reject the cookie, they may still use our site. The only drawback to this is that the user will be limited in some areas of our site. Persistent cookies enable us to track and target the interests of our users to enhance the experience on our site. See the “Profile” section, above.

5) Log Files

Like most Web sites, our servers use log files to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information.

6) Clear Gifs

Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. Clear gifs are not tied to users’ personally identifiable information.

We also use clear gifs in our HTML-based emails to let us know which emails the recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, please see the Opt-out section.

7) Children’s Privacy

We do not knowingly collect personal information from children under the age of 13. If we learn that we have personal information on a child under the age of 13, we will delete that information from our systems. www.breggin.com encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:

Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc. Know the sites your kids are visiting and which sites are appropriate. Look for Web site privacy policies. Know how your child’s information is treated.

Check out the FTC’s site for more tips on protecting children’s privacy online.

B) Information Use and Sharing of Information

www.breggin.com acts as a passive conduit for the distribution and receipt of its user’s fax, voice and e-mail communications and therefore will not monitor, edit, or disclose the contents of a user’s private communications unless www.breggin.com in good faith believes that such action is necessary to: (1) conform to the edicts of the law or comply with legal process served on www.breggin.com; (2) protect and defend the rights or property of www.breggin.com; or (3) act under exigent circumstances to protect the personal safety of its users or the public. Users should also be aware (and hereby agree) that certain technical processing of and access to fax, voice and email messages and their content may be required to: (a) route the messages; (b) conform to connecting networks’ technical requirements; (c) prevent or minimize disruptions to www.breggin.com’ services; or (d) conform to other similar requirements.

Subject to the legal exceptions listed in the Privacy Policy, www.breggin.com will not disclose to third parties the fax numbers, phone numbers or email addresses uploaded to our Web sites by our users for the purpose of using www.breggin.com products or services.

1) Communications from the Site

a) Special Offers, Free Trials and Updates
We send all new customers welcoming emails and may communicate with them to introduce and explain their new services. Visitors to our website that are not customers but provide www.breggin.com with contact information may receive emails from www.breggin.com that contain information about our services, special offers and other promotions. Established users will occasionally receive emails containing information about us, updates on new service features, service usage tips, information about third party services or other www.breggin.com services that are likely to be of interest to our users, and customers satisfaction questions. Visitors and www.breggin.com users may opt-out of such notices. Please see the Choice and Opt-out sections. We may contact former customers to gather feedback on the services.

b) Invoices and Account Statements
We send all customers regular emails summarizing usage and credit card charges. These emails are a part of the www.breggin.com service, and users cannot opt-out of receiving them, though they can deactivate their account. Information identifying the credit card is not included in these communications.

c) Service Announcements
On rare occasions it is necessary to send out a strictly service related announcement. For instance, if our service is temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.

d) Customer Service
We communicate with users on a regular basis to provide requested services and regarding issues relating to their accounts. We reply via email or phone, in accordance with the users wishes.

e) Surveys
Periodically, our site requests information from users via surveys. Participation in these surveys is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address), and demographic information (such as zip code). Survey information will be used for purposes of monitoring or improving the use and satisfaction of www.breggin.com’s services. Users’ personally identifiable information is not shared with third parties unless we give prior notice and a choice to opt-out. Though we may use an intermediary to conduct these surveys, they may not use customers’ personally identifiable information for any secondary purposes.

f) Referral Programs
Periodically, www.breggin.com offers referral services, asking a user to inform a friend about our service. We collect the name and email address of the friend, and will automatically send an email invitation to the friend. www.breggin.com stores this information for the sole purpose of sending this email and tracking success of the programs.

2) Sharing

a) Legal Disclaimer
Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our Web site. For example, www.breggin.com may disclose personal information to law enforcement, other government officials, or third parties in response to criminal or civil subpoenas. Sometimes, these requests come from our third party Internet, telecommunications and service providers all over the world who supply the network required for us to deliver our services. In order to maintain the integrity of our network, we often cooperate with requests from these third party providers and/or requests from law enforcement or other governmental officials directed to these providers.

b) Aggregate Information (non-personally identifiable)
We may share aggregated demographic information with our partners. This is not linked to any personally identifiable information.

c) Third Party Intermediaries
We use an outside credit card processing company to bill users for goods and services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes

d) Business Transitions
In the event www.breggin.com goes through a business transition, such as a merger, or acquisition by another company, or selling a portion of its assets, users’ personal information will, in most instances, be part of the assets transferred. Users will be notified prior to a change of ownership or control of their personal information. If as a result of the business transition, the users’ personally identifiable information will be used in a manner different from that stated at the time of collection they will be given a choice not to have their information used in this different manner, as described in the notification of changes section, below.

e) Spam and Junk Faxes
www.breggin.com does NOT share your fax number or email address externally. While we cannot be responsible for external communications received through www.breggin.com services, if we are given notice that a www.breggin.com Service is being used for spam or junk faxes, then we will deactivate that client. If you feel that you have received a junk fax, you may report a junk fax using the tools in MYFAXCENTRAL.

C) Choice/Opt-out

www.breggin.com users and visitors who do not wish to receive our promotional communications may opt-out from receiving these communications by clicking the opt-out link included at the bottom of every promotional message.

www.breggin.com users may not opt-out of receiving invoices and usage information, service announcements, and customer service communications, although they can deactivate their account.

D) Links

www.breggin.com Web sites contain links to other sites. Please be aware that www.breggin.com is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our sites and to read the privacy statements of each and every Web site that collects personally identifiable information. This privacy statement applies solely to information collected by www.breggin.com’ Web sites. www.breggin.com has advertising and affiliate relationships with dozens of third party sites that drive interested parties to our sites. Information that is collected on these sites does not fall within the auspices of this policy. www.breggin.com has Co-Brand relationships with some websites. A site is a Co-Brand of www.breggin.com if it offers www.breggin.com technology or services to its users under a different brand. The Co-Branded sites will have their own privacy policies specific to each site, and the user should read them carefully before registration.

E) Safeguards and Data Retention

1) User Information

www.breggin.com takes every precaution to protect its user’s information. When users submit sensitive information via www.breggin.com’ Web sites, their information is protected both online and off-line.

When our registration/order forms ask users to enter sensitive information (such as credit card number), that information is encrypted and is protected with the best encryption software in the industry – SSL. While on a secure page, such as our paid order form, the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just ‘surfing’.

While we use SSL encryption to protect sensitive information online, we also employ security measures to protect user-information off-line. All of our users’ information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerks or a customer service representative) are granted access to personally identifiable information. Finally, the servers that store personally identifiable information are in a secure environment.

2) Message Content Handling

We will store your personal Transmissions on our servers for a limited time and will endeavor to purge old transmissions from its servers when the expiration period has run out (up to 365 days).We use industry-standard efforts to safeguard the confidentiality of your transmissions (as well as your personally identifiable information), such as firewalls and SSL technology. These are the same technologies that most websites use to safeguard credit card information and other personal information. However, that said, “perfect security” does not exist over telephone lines and the Internet and www.breggin.com accordingly accepts only limited liability for security breaches.

3) Data Retention

The time period for which we keep information varies according to what the information is used for. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed.

F) Supplementation of Information

In order for www.breggin.com to properly fulfill its obligations to users and understand our customer demographics it is necessary for us to supplement the information we receive with information from 3rd party sources. www.breggin.com verifies the billing address on all credit card transactions and may obtain credit reports for some corporate customers. The information obtained from these third party sources is maintained in a manner consistent with www.breggin.com’ Privacy Policy.

G) Correcting/Updating/Deleting/Deactivating Personal Information

If a user’s personally identifiable information changes (such as zip code, phone, email or postal address), or if a user no longer desires our service, we provide a way to correct, update or delete/deactivate users’ personally identifiable information by contacting www.breggin.com Customer Service.

H) Notification of Changes

If we decide to change our privacy policy, we will post those changes in this privacy statement, and other places we deem appropriate, so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected.

If, however, we are going to use users’ personally identifiable information in a manner different from that stated at the time of collection we will notify users via email. Users will have a choice as to whether or not we use their information in this different manner. However, if users have opted out of all communication with the site, or deleted/deactivated their account, then they will not be contacted, nor will their personal information be used in this new manner. In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our Web site notifying users of the change. In some cases where we post a notice we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices.

Contact Information

If you have any questions or suggestions regarding our privacy policy, please email [email protected] or contact


Mailing Address:
Peter R. Breggin M.D.
206A Dryden Rd PMB 112
Ithaca, NY 14850
607-272-5328