KELSOSPORTSHANDICAPPING.COM PRIVACY STATEMENT

Information Collection and Use
Kelso Sturgeon is the sole owner of the information collected on this site.  We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement.  Kelso Sturgeon collects information from our users at several different points on our website.

Registration
In order to use this website, a user must first complete the registration form.  During registration a user is required to give their contact information (such as name and email address).  This information is used to contact the user about the services on our site for which they have expressed interest.  It is optional for the user to provide demographic information (such as income level and gender), and unique identifiers (such as social security number), but encouraged so we can provide a more personalized experience on our site.

Order
We request information from the user on our order form.  Here a user must provide contact information (like name and shipping address) and financial information (like 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, this contact information is used to get in touch with the user.

Cookies
A cookie is a piece of data stored on the user’s hard drive containing information about the user.  Usage of a cookie is in no way linked to any personally identifiable information while on our site.  Once the user closes their browser, the cookie simply terminates.  For instance, by setting a cookie on our site, the user would not have to log in a password more than once, thereby saving time while on our site.  If a user rejects 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.  For example, the user will not be able to participate in any of our Sweepstakes, Contests or monthly Drawings that take place. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site.

Some of our business partners use cookies on our site (for example, advertisers).  However, we have neither access to nor control over these cookies.

Log Files
We use IP addresses to analyze trends, administer the site, track user’s movement, and gather broad demographic information for aggregate use.  IP addresses are not linked to personally identifiable information.

Sharing
We collect aggregated demographic information on our site. This is not linked to any personal information that can identify any individual person. This information may be shared with our business partners and advertisers.

Third Parties
We use an outside shipping company to ship orders, and a 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.

We partner with another party to provide specific services. When the user signs up for these services, we will share names, or other contact information that is necessary for the third party to provide these services.

These parties are not allowed to use personally identifiable information except for the purpose of providing these services.

Links
This web site contains links to other sites. Please be aware that we [Kelso Sturgeon] are not responsible for the privacy practices of such other sites.  We encourage our users to be aware when they leave our site 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 this website.

Surveys & Contests
From time-to-time our site requests information from users via surveys or contests.  Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information.  Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age level).  Contact information will be used to notify the winners and award prizes.  Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.

Security
This website takes every precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected both online and off-line.

When our registration/order form asks users to enter sensitive information (such as credit card number and/or social security 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 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 you are just ‘surfing’.

While we use SSL encryption to protect sensitive information online, we also do everything in our power 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 clerk or a customer service representative) are granted access to personally identifiable information.  Our employees must use password-protected screen-savers when they leave their desk.  When they return, they must re-enter their password to re-gain access to your information.  Furthermore, ALL employees are kept up-to-date on our security and privacy practices.  Every quarter, as well as any time new policies are added, our employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure our customers’ information is protected.  Finally, the servers that we store personally identifiable information on are kept in a secure environment, behind a locked cage. 

If you have any questions about the security at our website, you can send an email to webmaster@kelsosportshandicapping.com.

Special Offers
We send all new members a welcoming email to verify password and username. Established members will occasionally receive information on products, services, special deals, and a newsletter. Out of respect for the privacy of our users we present the option to not receive these types of communications. Please see our choice and opt-out below.

Site and Service Updates
We also send the user site and service announcement updates. Members are not able to un-subscribe from service announcements, which contain important information about the service. We communicate with the user to provide requested services and in regards to issues relating to their account via email or phone.

Correction/Updating Personal Information:
If a user’s personally identifiable information changes (such as your zip code), or if a user no longer desires our service, we will endeavor to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the member information page or by emailing our Customer Support.

Choice/Opt-out
Our users are given the opportunity to ‘opt-out’ of having their information used for purposes not directly related to our site at the point where we ask for the information. For example, our order form has an ‘opt-out’ mechanism so users who buy a product from us, but don’t want any marketing material, can keep their email address off of our lists.

Users who no longer wish to receive our newsletter or promotional materials from our partners may opt-out of receiving these communications by replying to unsubscribe in the subject line in the email or email us at customerservice@kelsosportshandicapping.com 

Users of our site are always notified when their information is being collected by any outside parties. We do this so our users can make an informed choice as to whether they should proceed with services that require an outside party, or not.

Notification of Changes
Any modifications to our privacy practices will be reflected first within this area of our Web site. If there is a material change in our privacy practices, we will indicate on our sites that our privacy practices have changed and provide a link to the new privacy statement. If we are going to be using the information collected from users in a manner materially different from that stated at the time of collection we will send affected users written notice by email of the change.

Kelso Sturgeon Refund Policy

1. This is the refund policy for products and services purchased through all divisions or venues.
2. Where applicable, all staff will advise customers upon request, prior to the completion of their initial sale, of the following policy and will provide a written copy upon request.
3. We, as a merchant, provide both products (goods) and services (information) to our customers.
4. If a service is being provided with information procured from outside source we inform our subscribers where that information is coming from, prior to completion of the sale, so they are, therefore, aware of exactly what type of information they will be receiving… Should these types of services be available online, the specific sources of the information will be detailed in the service description.
5. If merchandise or products are ordered through a Direct Mail advertisement or via the Internet the guarantee, if any, is included in the mailing, promotion or service description. Our advertising will also include the terms and conditions for refunds on any books, publications and/or systems purchased.
6. For orders or services purchased as a ”Phone-In Service” wherein selections are provided to a client who telephones the company for their information, or “Internet Service” wherein selections are provided online through one of our web sites, there will be no refunds after that service commences. More specifically, once the customer has received any selections, no refund can be issued. Our services are the absolute best we can make them. As the service subscribed to includes sports handicapping information, just as with the Stock Market, our customers must recognize that the information cannot be guaranteed, and that past performance is not a promise of future results. What is guaranteed is that each and every customer will receive the service that was purchased in full.
7. If a guarantee for services is offered as part of an individual promotion, the specific terms of that guarantee will be included in the promotion. Whether the guarantee will be for additional service or for a pro-rated refund shall be specified. Unless otherwise stated in writing, cash refunds shall not be issued without the prior written approval of the Vice President of Sales and Marketing.
8. If, at the time of their order, a subscriber requests a pro-rated refund type guarantee, it will be negotiated with the sales representative, and the terms will be included in the customer's sales record. We will provide these pro-rated refund type guarantees in writing only at the customer's request. Pro-rated refund type guarantees will not be allowed on all services.
9. To reiterate, customers will be advised of these policies, upon request, at the time of their original order. They may be directed to the web site to view the specifics of the policy or a written copy of the policy will be provided upon request.
10. Digital Content (eBooks) - An eBook reader is the software you use to read a .PDF eBook. You can download the Adobe reader for free from the Adobe web site.
    Digital content purchased from KelsoSportsHandicapping.com is not returnable and non-refundable. If you're having trouble opening or reading your purchase, please e-mail us for technical assistance.

REVISED from original dated 12/95 on 04/02
on 03/03 and again on 12/04
Senior Marketing Vice President