Privacy Policy

This privacy policy is effective as of and was last updated on December 1st 2010

The types of information we collect and how we use it

Empire State Consulting Group ("we" or "us" or "our") respects the privacy concerns of each visitor ("you" or "your") to its website - escg.net (the "Website") - and has created this Privacy Policy to explain the type of information gathered from your visit to and use of the Website and our services, and how such information may be used. Please take a moment to review this Privacy Policy and feel free to contact us with any questions at notify@escg.net.

As a general policy, no "Personally Identifiable Information" (as defined below) is automatically collected from your visit to the Website. However, certain non-personal information, including the type of browser being used, its operating system and your IP address ("Non-Personally Identifiable Information"), may be automatically recorded by the standard operation of the Website's internet servers. This Non-Personally Identifiable Information can be used to help diagnose server problems, administer the Website and generally enhance your online experience.

"Personally Identifiable Information" includes, without limitation: (i) contact data (such as your first and last name, physical street address, city, state, zip code, phone number and email address), (ii) financial data (such as your credit card number, expiration date, and verification code), (iii) demographic data (such as your zip code and gender), and (iv) other legal data (such as your social security number and other sensitive information used to complete and generate the proper documents based upon the specific information and direction).

We will collect and use Personally Identifiable Information about you in a number of ways, including:

• responding to your request for products or services offered through the Website; and
• notifying you about products, services, and other opportunities we think will be of interest to you.

By utilizing the Website, you are consenting to the use and disclosure of your Personally Identifiable Information as described in this Privacy Policy.

If you would like to make corrections or updates to your Personally Identifiable Information, including your email address, phone number, mailing address, credit card information or password reminder phrase, you can easily make them through the edit profile section of your account.

We will also collect certain information arising out of your use of the Website, such as Cookies, or augment the data we collect with other information from other online or offline sources. We reserve the right to collect information about you and store it in connection with other online or offline information we may possess or obtain about you.

Sources of Information

The Personally Identifiable Information which we collect may come from a number of sources, including:

• Registration Information, which you provided when registering for our services or products, offered through the Website. For example, you will be required to submit personal information such as your name, and email address to verify your identity prior to establishing your account.
• Billing information, such as a credit card number, which is required to process the payment for the products or services you order from us.
• Information you provide to us in response to our communications. For example, we may request that you provide your e-mail address so that we may send you notifications, alerts, special offers and newsletters.
• Information that you provide to us through customer service communications and correspondence and general feedback.

Cookies

A cookie is a piece of data stored on the hard drive of your computer that contains information about you and that is used for record keeping purposes. Cookies enable us to track and target your interests to enhance your experience on the Website. We may set and access cookies on your computer to provide you with customized content and to assist in providing the products that you have requested. We also work with companies who provide services to maintain the Website and enable those service providers the right to use cookies on our website. Most cookies automatically delete themselves from your hard drive after each session. Like many other websites, we may automatically track information based upon your behavior on the Website, including combining information that we obtain through the use of cookies with Personally Identifiable Information, or other aggregate or anonymous data, including a unique identification we may assign you. The information may include browser type, internet service provider, referring/exit pages, platform type, date/time stamp, IP address, and number of clicks, all used to analyze trends, administer the Website, track your movement in the aggregate, and gather broad demographic information for aggregate use. Most web browsers are initially set up to accept cookies; however, you can reset your web browser to reject all cookies. If you reject the cookie, you may still use the Website, although your access to and use of some areas of the Website may be limited. In addition, if you refuse to accept cookies you agree to assume all responsibility for any resulting loss of functionality.

Web Beacons

Pages on our website also may contain "web beacons" (also known as Internet tags, pixel tags and clear GIFs). Web beacons allow third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party. We use log files to store the data that is collected through web beacons.

All of your Personally Identifiable Information and Non-Personally Identifiable Information, as well as any other information described above may be referred to collectively as the "User Information."

Sharing

We may share certain of the User Information, including Personally Identifiable Information, with affiliated and non-affiliated third parties, including without limitation in connection with the following:

• Special Offers - We sometimes disclose the information we collect to our affiliated companies for marketing purposes and to enhance our products or services to better suit your needs. When identifying methods of improving our products or services, or if we think a product or service may be of interest to you, we may extend select special offers of goods or services to you. If you would like to opt-out of receiving these offers, please refer to the "Offering You Choices - Marketing Options," section below.
• Vendors - We sometimes disclose the information we collect to companies that operate various services for us, such as marketing, distribution, advertising, or certain product functionalities, or who otherwise provide goods or services which may be of interest to you. If you provide information to us, you are expressly consenting to receiving telephone calls, emails or text messages, or direct mail, from us, or on our behalf, regarding the products and services offered on the Website; and
• As Permitted by Law - We may share your non-public Personally Identifiable Information with non-affiliated third parties as permitted by law.

Personally Identifiable Information will not be sold, leased or otherwise made available to any person or entity not authorized by or associated with us. However, please be advised that certain Personally Identifiable Information becomes a matter of public record upon the filing of certain documents with the appropriate government agency or court.

In addition to the above, we may disclose your Personally Identifiable Information in special cases when we have reason to believe that disclosing this information is necessary: (a) to identify, contact or bring legal action against someone who may be causing injury to or interfering (either intentionally or unintentionally) with: (i) our legal rights or property, (ii) another visitor or anyone else that could be harmed by such activities; or (b) by operation of law.

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 Personally Identifiable Information and any information you provide to us will likely be among the assets transferred, and you hereby consent to such transfer.

Offering You Choices - Marketing Options

You have choices when it comes to learning about our new offers, products or services, as well as those offered by our partners and affiliates. If you do not wish to receive these offers, you may opt out by emailing our Customer Care department at any time at info@subwaydata.com. Alternatively, each marketing e-mail we send to you will include instructions how to opt-out which you may utilize. Please note that you may still receive information from third parties to whom we have disclosed your information prior to the time you opted-out. You should contact each party in the event that you no longer want to receive information from such party.

Links

We are deeply committed to your right to privacy. However, please note that this Website's Privacy Policy only applies to the Website and not to any other websites that you may access from the Website, each of which may have privacy polices that are materially different from this Privacy Policy. We encourage you to be aware when you leave the Website and to read the privacy policies of each and every other website, as we are not responsible or liable for the commitments and obligations made to you in any privacy policy or the terms and conditions of any such website.

Security

We restrict access to nonpublic personal information about you or your children (if applicable) to our employees who need to have access to such information in order to provide products or services to you, as well as to authorized third parties (as stated above). We maintain physical, electronic, and procedural safeguards designed to protect your nonpublic personal information. We protect your information over the internet by using a secure web server, which allows web browser programs (Netscape, Microsoft Internet Explorer, Safari or Firefox) to interact with our web server via an encrypted session. Depending on which browser you use, you will know you are in secured area by "https" or a lock appearing in the lower right hand corner of your browser window. When you visit the Website, you may move in and out of secured areas.

Notwithstanding the forgoing, we cannot guarantee that our security measures will prevent our computers from being illegally accessed, and the data on them stolen or altered, and we assume no liability or responsibility to you or to any third party arising out of any loss, misuse, destruction, or alteration of your information.

Notification of Changes

We reserve the right to modify, alter or otherwise update this Privacy Policy from time to time, so you are encouraged to review this Privacy Policy from time to time. However, please note that each time you use the Website, the current version of this Privacy Policy will apply.

If we decide to change our Privacy Policy, we will date and post those changes on the Website so that you are always aware of what information we collect, how such information is used and under what circumstances, if any, such information is disclosed. Any and all changes to our Privacy Policy will also be reflected on this page. Unless we obtain your express consent, any revised Privacy Policy will apply only to information collected after such time as the revised Privacy Policy takes effect. If at any point we decide to use Personally Identifiable Information in a manner different from that stated at the time it was collected, we will notify you by way of email and you will then have a choice whether or not we can use such information in this different manner.

Visitor's Acceptance of These Terms

By using the Website, you hereby accept all of the terms set forth in our Privacy Policy. If you do not agree to accept all or any portion of such terms, then you are respectfully asked not to use the Website. Your continued use of the Website following the posting of such modifications, alterations or updates will signify your acceptance thereof.