PRIVACY POLICY

Effective Date: September 29, 2006

Achievementor Group LLC and its affiliates, including Rich and Rowdy, LLC (collectively "Achievementor") understand and respect your concerns about privacy. At the same time, information is the cornerstone of Achievementor's ability to provide products and services to its clients. Achievementor created this Privacy Policy to provide you with notice of the types of information Achievementor may collect, how such information may be used or shared with third parties, and how such information relates to the operation of the richandrowdy.com website ("Website"). This Privacy Policy is part of and subject to the Terms and Conditions of Use (the "TCU") posted on the Website, including the provisions regarding changes or modifications to this Privacy Policy and other policies as set forth in the TCU. Please be sure to read this Privacy Policy before using this Website or submitting information to Achievementor. You are responsible for checking this page periodically for changes and updates to the Privacy Policy. Your use of the Website constitutes acceptance of this Privacy Policy and any subsequent use is subject to any posted changes to the Privacy Policy which are also deemed as accepted upon use of the Website. The effective date noted above will indicate the date that this Privacy policy was last updated.

Defining Visitors to the Website

While Achievementor contemplates that people may visit the Website for several reasons, there are several types of visitors to its Website who will access the Website for particular purposes. Achievementor considers a "Visitor" to the Website comes to this Website either intentionally or unintentionally. Those individuals who visit the Website for a particular purpose are considered Members, Subscribers, or Customers, as defined herein. As to this Privacy Policy, anyone visiting this Website will be considered a Visitor except as expressly referenced herein. "Member" shall mean who registers through the Website and who is eligible for membership privileges as defined by Achievementor. "Subscriber" shall mean an individual who subscribes to newsletters or other publications provided as a result of such subscription. "Customer" shall mean an individual who obtains goods or services offered on the Website.

What Information is Collected and Stored?

Achievementor collects and stores certain information automatically whenever a Visitor accesses this Website. The amount and type of information Achievementor collects depends upon the use of the Website. Achievementor collects the Visitorís IP address, browser information and related information. Achievementor also collects information regarding traffic patterns and site usage. This information is used to analyze and improve this Website and to provide Visitors with an improved Website experience. Achievementor may make message boards and discussion forums available to you. If you choose to voluntarily disclose certain information on any such public area of the Website, this Privacy Policy will not cover such disclosure of information. Achievementor urges you to exercise caution when disclosing information on public message boards or discussion forums.

Achievementor may ask Customers, Members and Subscribers for personal information, for example, when they register at the Website, subscribe to a newsletter or respond to a survey. Achievementor will only use individual information internally. This information enables Achievementor to contact Customers, Members and Subscribers and provide information regarding Achievementor's products and services, including new products and services that Achievementor may introduce from time to time, and to enable Customers, Members and Subscribers to obtain product literature, receive on-line newsletters, or access restricted areas of the Website.

Achievementor collects and stores information that Customers, Members and Subscribers enter through this Website or otherwise. For example, when a Customer opens an account or places an order, Achievementor collects and stores some or all of the following information: name, billing address, shipping address, email address, telephone number, credit card number and expiration date. This information is used to provide the Customer with the products and services ordered or requested, to process and ship orders, to send order and shipping confirmations and to provide Customer service. In order to process, ship and track product orders, Achievementor makes Customer name and address information available to credit card processors, common carriers and courier services. Information Achievementor collects also may be used by Achievementor to contact Customers, Members and Subscribers about products, promotions, upcoming events, special offers and new Website features. Achievementor reserves the right to request any additional information necessary to establish and maintain your account for use of the Website and for your membership activities. Achievementor may use your information to send you promotional materials via e-mail and/or facsimile about Achievementor and its business partners. Achievementor may also use your information to contact you, as necessary.

Information from Children

This Website is not intended for children under the age of 13. We will not knowingly collect information from Website Visitors in this age group. If Achievementor learns that a child under the age of 13 has submitted personally identifiable information online, in contravention of these measures, it will take all reasonable measures to delete such information from its databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others or as required by law).

How and With Whom Achievementor Shares Your Information

Achievementor will not sell, rent or license your personal information to third parties other than to its business partners as set forth herein. However, Achievementor may from time to time aggregate statistical information regarding our Visitors, traffic patterns and Website usage, or sell our research, which may contain aggregate information. In addition, Achievementor may report aggregate information to our advertisers. Such aggregate information will not individually identify any user.

In order to provide you with co-branded services, and to improve our features, Achievementor will sometimes share your information with our business partners. Achievementor reserves the right to disclose any information if such action is necessary (a) to conform to the requirements of the law or to comply with legal process or subpoena served on Achievementor, (b) to protect and defend the legal rights or property of Achievementor, the Website, or its users, or (c) in an emergency, to protect the health and safety of its users or the general public. Achievementor further reserves the right to release any information concerning any user if that user participates (or is reasonably suspected of participating) in any illegal activity, even without a subpoena, warrant, or other court order. Achievementor will cooperate with law enforcement agencies in identifying those who may be using our servers or services for illegal activities. Achievementor also reserves the right to report any suspected illegal activity to law enforcement for investigation or prosecution.

It is possible that Achievementor, its affiliates, its joint ventures, or any combination of such, could merge with or be acquired by another business entity. Should such a combination occur, you should expect that Achievementor would share some or all of your information in order to continue to provide the service. If permissible, notice of any such event (to the extent it occurs) may be posted on the Website.

How Achievementor Uses Cookies

As part of offering and providing customizable and personalized services, Achievementor uses cookies to store and sometimes track information about you. A cookie is a small amount of data that is transferred to your computer's hard drive. All portions of the Website that prompt you to log in or that are customizable require that you accept cookies. Cookies will not be used by Achievementor to retrieve any information about you, or from your computer, that you have not voluntarily given to Achievementor. Cookies may also be placed on your computer when you link from the Website to other websites or when you click banner ads provided on our Website. Cookies placed on your computer by third parties by or through the Website are not the responsibility of Achievementor and are not subject to the TCU. Please contact the third party placing these cookies to find out what information is collected and how it is used. You can usually edit your browser not to accept cookies, but the features of our Website may not function properly if you do not accept cookies.

Steps Taken to Protect Your Personal Information

For all our transactions, Achievementor employs reasonable and current Internet security methods and technologies. Where appropriate, Achievementor or its agents use passwords, encryption techniques and firewalls to protect information. Achievementor strives to protect you. Achievementor encourages its participating service providers to adopt and honor their own privacy policies. It is your responsibility to contact such website operator or advertiser directly to determine their privacy policy. For all our efforts to safeguard your privacy, no system can be guaranteed. Achievementor cannot ensure or warrant the security of any information that you transmit to us, or that Achievementor transmits to you, or guarantee that it will be free from unauthorized access by third parties. Once Achievementor receives your information, Achievementor will use reasonable efforts to ensure its security on our systems. Also, this Website is not intended for use by persons under the age of thirteen. Individuals who are under the age of thirteen are expressly prohibited from submitting any personally identifiable information about themselves to the Website.

Accessing, Updating or Deleting Your Information

As part of your use of the Website, you are responsible for maintaining and updating, as applicable, your membership information with current, accurate and complete information. You may view, update and/or edit your membership information you have provided to Achievementor by using the "Contact Us" form on the Website.

You may occasionally receive information about your Achievementor membership and the Achievementor products or services and the products and services of our partners. Achievementor believes that these updates are interesting and informative. In every update that Achievementor sends, Achievementor may include an option to "opt-out" of receiving future updates. Achievementor reserves the right to limit any access to our Website to those who will accept our information and to those who will provide the requested information on applications and other forms. In the event you "opt-out" while your membership is in effect, you understand that removal of information may impede your participation as a member and/or result in termination of your membership. Achievementor shall not be liable for problems arising from the removal of such information.

Opt-out Policy

Contact information received from forms, surveys, and other sources is used to send information and promotional material about Achievementor to you. In addition, that information may be shared with our business partners who may want to contact you. The default assumption is that you have "opted-in" and consented to use of your information in this manner and in accordance with our standard policies and procedures. If you no longer wish to receive updates, faxes or e-mails from Achievementor, please send your request to us at info@achievementorgroup.com or call us at 312.XXX.XXXX.

California Privacy Rights

As of January 1, 2005, California Civil Code Section 1798.83, California residents have the right to request in writing from businesses with whom they have an established business relationship, (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the Customer, Subscriber or Member, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties' direct marketing purposes, and (2) the names and addresses of all such third parties. To request the above information please send an email message to info@achievementorgroup.com with "Request for California Privacy Information" on the subject line and in the body of your message. The requested information will be provided in response to the e-mail address from which Acheivementor received the message.

A response to such written requests will be provided within 30 days following receipt at the e-mail or mailing address stated above. If a request is received at a different e-mail or mailing address, Achievementor will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that Acheivementor is only required to respond to each Customer, subscriber or Member once per calendar year.
Contacting the Website

If you have any questions about this Privacy Policy, the practices of this Website, or your dealings with this Website, or if you think that anyone has violated this Privacy Policy, please contact Achievementor Group at:

Webmaster
Achievementor Group LLC
1106 West Madison
Chicago, IL 60607
info@achievementorgroup.com
Phone: 800-401-0607

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