We are sensitive to your privacy concerns, and in this statement describe our practices in regard to the personal information we collect and receive about you . We recognize your interest in understanding how personally identifiable data about you is being gathered and used, and what choices you have regarding its collection and use.

Scope and Nature of Policy

This Policy will notify you of what personal information of yours is collected when you enroll in an Encore membership club and/or use its benefits and/or access an Encore membership club website, and how the information is collected, used and stored. We will describe our efforts to maintain the security of your personal information, and other details concerning your personal information and our policies. Please note that this Policy does not apply to our use of aggregated data from which personally identifiable characteristics have been removed. We retain the right to use aggregated data in any way that we feel advances our business interests.

We do not knowingly solicit personal information from persons under the age of 13. Children under the age of 18 may use the membership services of Encore only in connection with the enrollment of a parent or guardian.

Collection and Use of Information

The primary reason we collect personal information about you is to process your enrollment in our membership services, provide requested membership services and products, confirm member identity, to enable us to better communicate with you by helping us respond to your contacts more effectively, and to contact you to provide information we believe could be of interest. In the ordinary course of our business we gather personal information about you including:

• Required enrollment information you provide such as name, address, phone number and email address and date of birth to establish your Encore club membership and verify your identity.
• Billing information you provide, such as a credit card account number and expiration date, as required to process the payment of your Encore club membership fee or for other products or services you may order from the Encore club.
• Information about your transactions with us, our affiliates or others, with whom we have business relationships, such as any purchases of products and services you have made through your Encore club membership, enabling us to better customize our services for you.
• Other information we collect, such as city of birth and mother's maiden name, may be used to verify your identity in the event you forget your Encore membership club identification or password required for access, including on-line access, to your membership services. Your email address is collected and used to send you notifications, special offers and any applicable membership club e-newsletters.

Our web server recognizes with respect to visits to our membership club web sites the IP address, information from cookies (alphanumeric identifiers we transfer to your computers hard drive through your web browser) and web pages accessed. We use this information to analyze trends, administer the site, track visitor movements, and gather broad demographic information for aggregate use. We endeavor to apply this acquired knowledge to improve the content of our web sites and enhance their value and appearance to you.

Information Sharing

We may disclose your personal information to other parties for a variety of purposes as described in this section. We break these purposes down as being administrative related or marketing related.

ADMINISTRATIVE PURPOSES

We may disclose your personal information to other companies and individuals who we appoint to undertake on our behalf, services related to the administration of your Encore club membership, including mail houses, call center providers, credit card processors, credit reporting agencies and such other third party providers of membership benefits provided to you as described in your Encore club membership package. These parties are required to use your personal information solely for the purposes of performing their tasks ( e.g. fulfilling orders, delivering packages, administering customer service, processing credit card payments, providing member benefits, etc.) on behalf of, and under our instructions and to observe the relevant portions of our Policy with respect to the information disclosed.

We may disclose your personal information as we reasonably believe is necessary to protect our business, to comply with applicable law, to protect the rights, privacy, safety or property of you or others, and to permit us to pursue available remedies or limit the damages that we may sustain. For example, if you breach a membership agreement with us by obtaining services from us under false pretences or through intentional misuse of membership benefits, your personal information may be used or disclosed to the extent necessary to remedy the misconduct. We may also legally disclose information about you to unaffiliated third parties when the law requires our cooperation, for example, in response to a subpoena or in response to a request by a law enforcement agency or governmental regulator.

We may share personal information about you amongst ourselves and disclose such data to our affiliates to enable us to perform the functions described above. In the event such information is shared amongst ourselves or disclosed to our affiliates, the party to whom we disclose and with respect to whom we share such data will be required to observe the relevant provisions of our Policy with respect to your personal information. We may also share information about you, unless legally prohibited, with the company, if any, who sponsored our membership club offering to you and who has a pre-existing relationship with you.

When we are required to treat personal information about you as sensitive, we will observe any applicable legal requirements with respect to the use and disclosure of such information. We will not disclose that information to our affiliates or business partners other than as authorized by applicable laws, and will not use that information for marketing purposes. To our knowledge we possess no sensitive personal information, such as information specifying medical or health conditions, about our customers

By accepting an offer to enroll in an Encore membership club and by providing us with personal information about yourself, you are consenting to the use and disclosure of your personal information for the purposes described herein. If you do not wish to consent to such use or disclosure, please do not accept an Encore membership club offer. We will not make any non-marketing use of personal information about you other than in connection with the uses above that are so authorized, unless we give you notice of that use and provide you with the opportunity to direct us not to make that use of your personal information or we are otherwise permitted by law or prevailing industry standards to make the use of your personal information without providing you with the opportunity to direct us not to.

MARKETING PURPOSES

We may share your personal information (other than sensitive personal information) with other companies we know and have relationships with, both affiliated and non-affiliated, who may wish to promote to you products and services they have which we and they believe may be of interest to you. Such companies may market their products and services to you pursuant to joint marketing agreements they have with us. Any information we do disclose to any other party will only be under conditions that require information safeguarding and use only as authorized. Please note that your credit card information is kept secured and will never be disclosed to any third party for marketing purposes. We may disclose your credit card information to a third party to enable them to use this information to bill a purchase transaction you have made with them only upon receiving your authorization.

Options To Limit Use Of Information

If you wish not to have your personal information shared for marketing purposes with non-affiliated companies, please contact us by e-mail or write to us at Director, Privacy Services, Encore Marketing International, Inc., 4501 Forbes Boulevard, Lanham, MD 20706-4326 and your wishes will be respected. Please note that your personal information will not be made available for marketing purposes to any other company in any instance in which the organization, if any, sponsoring our offering to you has required this by agreement.

Please note that where you have directed us not to disclose personal information about you to companies that are not our affiliates for marketing purposes, we may still contact you about our own product or service offerings and enhancements and those of our affiliated entities, unless and until you inform us not to. You may indicate so, for example, by choosing the unsubscribe option made available to you in connection with any e-mail that may be sent to you, or indicate your intention to so opt-out by writing to us at Director, Privacy Services, Encore Marketing International, Inc, 4501 Forbes Boulevard, Lanham, MD 20706-4326.

As mentioned previously, we collect anonymous information concerning Encore membership club web site users through the use of "cookies"(small files that web sites place on users' computers to identify the user and enhance the web site experience). None of this information is received at an individual level. Visitors may set their browsers to provide notice before they receive a cookie, giving the opportunity to decide whether to accept the cookie. Visitors can also set their browsers to turn off cookies. If visitors do so, however, some areas of our membership club web sites may not function properly.

By accepting an offer to enroll in an Encore membership club and by providing us with personal information about yourself, you are consenting to the use and disclosure of your personal information for the purposes described herein, subject to the choices, if any, you have made as described in the Options section above. California Residents: Encore club members who are California residents may request and receive from us no more than once per calendar year a list of categories of their personal information disclosed to third parties for third party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of those third parties, by submitting a specific request for this information to Director, Privacy Services, Encore Marketing International, Inc., 4501 Forbes Boulevard, Lanham, MD 20706-4326.

Accessing and Deleting Your Personal Information

We respect your privacy and use the personal information we have about you conscientiously and with full disclosure. We keep secure and confidential all customer data and protect it from unauthorized access. We urge you to learn about how we keep secure the information you provide use by reading our security statement. If at any time you wish to access your information in order to update, modify or delete it or you wish to obtain a copy of your personal information on file, please contact us at the address listed below. As soon as reasonably possible upon receipt of your request, we will take the action so requested. If you request that we delete your information, we may make that information unavailable for use rather than fully deleting it from our system. Please note that we may not be able to provide you with certain products and/or services once you are removed from our contact lists.

Information Regarding Former Customers

We disclose personal information about former customers only in accordance with our Policy. Over time, information about former customers is likely to be used less and less and may ultimately be removed from our records.

Transferability of Information

In the event we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal information will likely be among the assets transferred. Any successor company will be required to observe the relevant portions of this Policy with respect to your personal information (including any choices you have made under our Policy to limit the use of your information).

Linked Internet Sites

We may provide from an Encore membership club web site links to external sites, such as membership club benefit providers. We believe these sites share a similar commitment to consumer privacy and urge you to review their privacy policy when visiting their sites. We cannot, however, be responsible for their privacy practices.

Changes to Our Privacy Policy

We may change this Policy at any time in the future by posting revisions to our web site. By your continued Encore club membership and/or use of this web site, you consent to our Policy including as revised. If we change our Policy in a way that is less protective of your privacy, then the change will not apply to our use of any of your personal information that was collected by us before the change was made, unless we provide you with the opportunity to direct us not to make the new use contemplated.

Compliance With Applicable Law

Where our collection and use of your personal information is governed by federal and state laws of the United States, we will comply with such laws and will limit disclosures concerning your personal information accordingly.

Privacy Policy Compliance

We hope our Privacy Policy answers your questions about our collection and use of personal information about you. Should you have any questions about the Policy or our observance of it, please write to Director, Privacy Services, Encore Marketing International, Inc., 4501 Forbes Boulevard, Lanham, MD 20706-4326.

Security

We take every precaution and have implemented a variety of safeguards to protect your personal information.

Our databases are protected by physical, technical and procedural measures that restrict information access to authorized persons in accordance with this Policy. Our information systems are maintained behind a software firewall. We restrict access to our data center and server rooms to authorized personnel. Only employees who need the information to perform a specific required task are granted access to personal information. Our employees are trained on our privacy and security procedures, and are subject to disciplinary action, up to and including termination, for any violations.

To ensure the security of your personal information you have shared with us, we want you to have the confidence of knowing that we utilize state-of-the-art technology to safeguard your information. We have incorporated within the parts of our websites where personal financial information is requested and entered industry standard secure server software (Secure Socket Layers or "SSL") allowing this information you provide online to be kept secure via the latest encryption and authentication techniques used in the industry. We do this so that you can safely and with confidence disclose to us your credit card number, name and credit card expiration date in an SSL secure environment (via a secure encrypted link between the computer you are using and our servers). Your browser will also inform you by way of a Site Security Certificate of the presence of this secure area.