Pravicy Policy

Lee& Company, INC. PRIVACY POLICY

 

Lee& Company, Inc. and its subsidiaries (“Lee& Company,” “we,” “us,” and “our”) is concerned about the privacy and security of your information. We want to make your experience with the Lee& Company® service as enjoyable and rewarding as possible, and also allow you to feel secure that your privacy interests are being respected. This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our website or Services. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage. By visiting or using the Website or Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways. Any capitalized terms used herein without definition shall have the meaning given to them in Lee& Company’s Terms of Use (which is hereby incorporated into this Privacy Policy).

 

Collection of Information

Required Information

Lee& Company collects certain information that is necessary to fully service your Lee& Company account. As a customer, you will be asked to provide Information that is needed in order to create your Lee& Company account and fulfill our service commitment to you such as your name, address, phone number, e-mail address and billing information. We treat this personal information that you provide to us as highly confidential. Lee& Company may use this Information for editorial and feedback purposes, marketing and promotional purposes, for statistical analysis and for product development. Your personal information, however, will not be sold to any company nor will it be shared with third parties, unless stated otherwise or in special circumstances.

Optional Information

Like any business interested in attracting and offering the highest quality of service to customers, Lee& Company gathers voluntary demographic information about our customers. These questions seek to gain insight on such things as how an individual became aware of our service, their gender, occupation and travel preferences and practices. In addition, customer comments and inquiries are collected and stored for each customer that submits them. This information is collected and stored with the customer’s individual Lee& Company account information.

Lee& Company occasionally conducts user surveys to better target our service offering to existing as well as new customers. We sometimes share aggregated demographic information in these surveys with various business partners that offer complimentary offerings to the Lee& Company service. This information is summarized, and information about specific individuals is not shared with any third party. Participation in our customer surveys is voluntary.

Lee& Company may offer incentive programs to customers, visitors to the Lee& Company Web site (www.waffle.at), the general public and individuals identified through direct mail lists. These offerings are promoted on the Web site, advertisements and press releases. At a minimum, required information includes name and e-mail address; in some cases, the customer must answer mandatory survey questions about other personal data or enter a program code. The information gathered in the entry form is used to verify the entrant’s identity, to send the entrant an e-mail notification that their entry has been received, and to contact winners and/or prize recipients. Because the rules and terms of each program can vary, all information about each program is clearly posted during the event. All such programs are conducted in full accordance with United States federal and state laws.

Lee& Company has and may institute referral programs or similar programs, such as the “Tell a Friend” program. Lee& Company’s “Tell a Friend” program allows customers to receive credit for each individual (a “Referral”) that, as a result of their recommendation, also becomes a customer. For a customer to receive a free month of service under this program, (1) the Referral must become a subscriber to Lee& Company Unlimited and remain a subscriber of Lee& Company Unlimited for more than 31 days; (2) the Referral cannot be an existing Lee& Company customer; and (3) the Referral cannot have been previously submitted to the “Tell a Friend” program by another person. Existing customers provide the e-mail address of the Referral, and Lee& Company may send an e-mail message to the Referral from the referring customer’s e-mail address informing them of the Lee& Company service.

When Lee& Company collects usage information (such as the numbers and frequency of visitors to the Website), we only use this data in aggregate form, and not in a manner that would identify you personally. For example, this aggregate data tells us how often users use parts of the Services, so that we can make the Services appealing to as many users as possible. We may also provide this aggregate information to our partners; our partners may use such information to understand how often and in what ways people use our Services, so that they too, can provide you with an optimal experience. We do not disclose aggregate information to a partner in a manner that would identify you personally.

Geographic Location Information

When you use Lee& Company’s services on a mobile device (such as your laptop or a smart phone), Lee& Company may collect and/or track certain geographic location information that is derived from your usage of the Lee& Company service such as usage patterns, travel patterns, Web site page views, traffic patterns and information about your geographic location. Lee& Company may use this tracking and location information for statistical purposes to improve our products and services and to manage our networks and systems more efficiently.

 

Cookies, Web Beacons and Media Access Controller Tracking

To keep track of traffic on their servers, Web sites often store a small data file on your hard disk when you visit them. This file is commonly referred to as a “cookie.” A cookie file can contain user specific information, such as User ID, or it can be used to maintain a connection with you during your visit (so that you can visit pages of a site without retyping the same information over and over). Lee& Company uses cookies to track customer traffic patterns, to maintain a connection during your visit with us, to track your preferences, and to diagnose problems on our server and administer our site. Cookies enable you to enter all parts of the Lee& Company Web site, and are used to save your User ID on the login page (we encrypt the User ID for added security). In addition, cookie files help us assist you with questions about site navigation, functionality or performance. Partners also may use their own “cookies.” IF YOU DO NOT WISH TO HAVE WEB COOKIES PLACED ON YOUR COMPUTER, YOU SHOULD SET YOUR BROWSER TO REFUSE WEB COOKIES, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THIS SITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. IF YOU REFUSE WEB COOKIES, YOU ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

We do not control the use of our partners’ cookies and expressly disclaim responsibility for information collected through them.

Web sites may contain an electronic file called a “web beacon” that allows a website to track users who have visited that page or to access certain cookies. Lee& Company may use web beacons in the following ways:

  • Lee& Company may use web beacons within our Web sites in order to track customers signing up at one of our hotspot locations.
  • Lee& Company may use web beacons within our Web sites in order to fulfill sponsored access campaigns or other promotions.
  • Lee& Company may use web beacons to measure where customers leave the signup process in order to improve customer experience.
  • Lee& Company may use web beacons to track customers that come through our Web sites from advertisements or search engines.
  • Lee& Company may use web beacons to serve ads to customers after they leave our Web sites.

  • Lee& Company also records the MAC (Media Access Controller) address from the network card in or used with your computer or other device to enable Lee& Company to accurately perform our billing functions.

     

    Use and Disclosure of Information

    Except as described in this Section, Lee& Company will not divulge any of your personal information, contact, financial, bill history, or geographic location — to any other organization unless (1) you give Lee& Company explicit and specific, prior permission (for example, if you opt-in to a sponsorship offer from one of our partners), (2) the disclosure is required by law or by legal process authorized by a court of competent jurisdiction, (3) Lee& Company suspects fraud by a customer involving Lee& Company, in which case Lee& Company may investigate and report any evidence, including personal information, to law enforcement officials and to the courts in the course of seeking remedies at law and equity, and/or (4) you make an inquiry, request or complaint that requires follow-up and we share your information with others to satisfy your inquiry.

    Subject to the terms of this privacy policy, we may disclose information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers who process information on our behalf, participate with us in the provision or operation of our site or provide you with services.

    Lee& Company may choose to buy or sell assets or companies, or merge with or into other companies. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if Lee& Company (or its assets) are acquired, or if Lee& Company goes out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.

    We may email you about products and services that we believe may be of interest to you.  If you wish to opt-out of receiving marketing materials from us, please follow the instructions at the bottom of each email for opting out. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes.

    In instances where Lee& Company and a partner jointly promote the Lee& Company service, Lee& Company may provide that partner certain information, such as name and e-mail address, for the sole purpose of allowing Lee& Company and the partner to evaluate the promotion.

    Lee& Company may contact customers or Web site visitors regarding account status and changes to this privacy policy and any other policies or agreements relevant to Web site visitors. Lee& Company may use your information to disclose summary information to strategic and business partners. This is obtained by combining data from many individuals with the name and other identifiers removed. Lee& Company also may create aggregate reports on user demographics and traffic patterns. This information may be used to negotiate with service providers who complement the Lee& Company service or assist us in our efforts to expand our customer base.

    Lee& Company opposes the e-mailing of any junk mail, and does not sell customer information to e-mail lists or telemarketers. If any of our partner sites engage in such practices, for any reason, Lee& Company will immediately investigate, and if appropriate, discontinue services with such parties. If you receive junk e-mail that mentions Lee& Company or its services, please send details to us at mkt@waffle.at and we will investigate promptly.

    We allow advertisers and/or merchant partners (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers and you agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact you are located in San Francisco to show you ads or offers for San Francisco businesses, but we will not tell such businesses who you are.

    Advertisers may serve ads that appear on our sites or services, which may contain a feature allowing you to input your email address. If you choose to input your email address in connection with these ads, you understand that we will transmit your email address to the applicable third party advertiser; this Privacy Policy does not apply to such advertisers’ collection and use practices, so please review their privacy policies before providing your email address in this manner.

     

    Correcting and Updating Your Information

    As a Lee& Company customer, you are in full control of the information that we maintain to service you. You can change your information at any time and as often as necessary via our self-care application which can be accessed at:  http://www.waffle.at. You can also request that the data be changed or deleted (requests for deletion of certain information may require closing the account) by calling the following numbers:

    From Korea: 82-10-2010-8324

    Information about a customer may be withheld or exempted from deletion if this is required by law, is part of a fraud investigation or is required for accounting and audit purposes.

     

    Opt-out Policy

    If you have provided us with a means of contacting you, we may use such means to communicate with you. For example, we may send you promotional offers on behalf of other businesses, or communicate with you about your use of the Services.

    Lee& Company automatically opts customers in to providing Lee& Company with information, as well as a separate opportunity to opt-in to certain location-tracking services, or receiving communications from us and our partners.

    Alternatively, customers can opt not to provide certain information when enrolling for the Lee& Company service or when participating in some programs and surveys, although choosing not to provide certain information may hinder our ability to complete your registration process.

    Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes.

     

    Commitment to the Privacy of Your Family

    We do not knowingly collect information from children under the age of 13. If we determine that we have collected personally identifiable information on children, we will promptly delete it from our system. We recommend that children who are 13-17 years old receive permission from a parent before gaining access to the Lee& Company service or sending information to Lee& Company or anyone else online. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any personal information to us or on the Services. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at mkt@waffle.at.

     

    Security Measures

    Your account information is protected by a unique User Identification and password that is issued to you. Your User Identification and password should be kept confidential because it is the key to accessing the information held by Lee& Company about you. If your computer or other device is accessible to or by others, please log out of the Lee& Company site before you leave it. Security is also provided through your web browser, which supports 40, 56 or a 128-bit version of encryption with the SSL (Secure Sockets Layer) security protocol.

    Lee& Company has instituted internal safeguards to reduce the likelihood of accidental disclosures and unintended access of your information (although it is impossible to eliminate this possibility completely). In general, all employees, contractors and other companies engaged by Lee& Company are contractually required, through signed, internal non-disclosure agreements, to keep your Personal Information confidential and not to use it in any way other than what is necessary to perform their work for Lee& Company. Violations of these policies can result in termination in the case of employees, the severing of contractual obligations in the case of contractors and other companies, and in civil and criminal penalties if warranted and applicable by law.

    While Lee& Company uses reasonable measures to protect the security of your information, no security measures are foolproof, and Lee& Company does not guarantee that your information will remain confidential.

    The Services may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site’s privacy policy.

     

    Security of Third Party Networks;

    Because of the global nature of our services, there are some places where you cannot access the Lee& Company Wi-Fi Network. In these places, you may (1) manually search for available third party networks and, if required to do so, assent to Terms of Service or other click-through agreements; or (2) connect to other people’s Wi-Fi networks automatically by using the Lee& Company Wi-Finder tool if you opt-in to use this feature. Please see our FAQs for more information about these options:   mkt@waffle.at

    Third parties are under no obligation to comply with this privacy policy with respect to information that you provide directly to those third parties or that those third parties collect for themselves. We do not control the third-party sites that may be accessible through this Site or Lee& Company’s services. Thus, this privacy policy does not apply to information provided to third-party sites or gathered by the third parties that operate them. Before visiting a third-party site, whether by means of Lee& Company Wi-Finder, manually searching for an available third party network or otherwise, and before providing any information to any third party, you should inform yourself of the privacy policies and practices (if any) of the third party, and should take those steps necessary to your discretion, to protect your privacy.

     

    Privacy Policy Changes

    Because of changes in technology and the growth and development of our business, or for other business reasons, we may need to modify this privacy policy from time to time. We will alert you by email if this privacy policy is revised (if you have given us your email address), and we will post a copy of the new policy with its effective date on this Site. It is therefore important that you register with us and notify us if you change your email address. If you do not provide us with a current email address, you should regularly review this policy to ensure that you are informed of any changes.

     

    Additional Information

    This privacy policy is effective as of May 17, 2013. Lee& Company reserves the right to change this policy at any time. By using the Lee& Company service, you are acknowledging and accepting all terms and conditions outlined in this Lee& Company, Inc. privacy policy.

    If you have any questions regarding this policy statement, please e-mail us at mkt@waffle.at.

    This privacy and security pledge is part of our contract with you. Thank you for choosing Lee& Company, Inc.