Last Updated: 8-9-2010

Inside Wall Street (“IWS”) has developed this Privacy Policy to share with you our information collection practices and the options you have when visiting www.guesstheindex.com (hereinafter referred to as “the Website” or “the Site”). This Privacy Policy is an online Privacy Policy and applies only to information collected from you through this Website.   This Privacy Policy does not apply to information that you furnish to us offline or in any other manner except through this Website.

Please note that other Websites affiliated with Inside Wall Street may be governed by separate policies. When visiting any of our other sites, please refer to its Privacy Policy.

By using this Site, you are agreeing to accept the practices described in this Privacy Policy.

IWS occasionally may update this Privacy Policy. When we do, we will revise the "updated" date at the top of the Privacy Policy.  In the event that we make material changes to this Privacy Policy, we will notify you at our option either by placing a prominent notice on the home page of our Website or by sending you a notification directly. We encourage you to review this Privacy Policy periodically to stay fully informed about how we are protecting your personal information.  Be advised that your continued use of this Website constitutes your agreement to this Privacy Policy and any updates.

As referenced throughout this Privacy Policy, the term “Personally Identifiable Information” means any piece of information that potentially can be used to uniquely identify, contact, or locate a single person and that IWS collects from you.  Personally Identifiable Information may include, without limitation:  user name, password, first name, last name, address, e-mail address, phone number, birth date, etc.

Any Personally Identifiable Information collected by IWS will be safeguarded to protect against unauthorized access.  Procedures are in place to secure any personal information provided to IWS.  IWS stores your personal information in an encrypted computer database on dedicated servers that allow only limited access.  IWS employs commercially reasonable efforts to protect this information from loss, misuse, and other unauthorized disclosure, alteration or destruction.

Who is Collecting Your Information

IWS and its affiliates are the sole owners of the information collected; except as otherwise provided in this Privacy Policy, we will not sell, share, rent or loan this information to any third party. However, we may use and share aggregated information that does not personally identify you with third parties in order to improve the Site for our Website users.

IWS may share information provided through the Website with third parties under contract with IWS to assist in providing certain services or other features offered to our Website users.  In the event that IWS utilizes a third party to provide such services, our contract with the third party will include obligations upon the third party to keep all information obtained during such contract confidential and secure.

In addition, if you opt-in to our marketing database, or if you request to receive newsletters, e-mail alerts, or other promotional materials, you thereby agree that IWS may sell, rent, lease, share or exchange your Personally Identifiable Information with any third party.

What is Collected, and How Do We Use It

Although you may browse the public pages of our Website without registering or providing any Personally Identifiable Information, certain pages of our Website can be accessed only by registered users, including the “Guess the Index” Game.  Other sections of our Site may provide forms on which you may choose to supply personalized information that will allow you to make purchases online or receive individualized services or features that we cannot offer anonymous users.  You can always choose not to provide information; however, if you do choose not to provide such information, you will not be able to play the “Guess the Index” game and you may not be able to take advantage of certain other Website features.

In order to access pages requiring registration, you will be required to create a User Account by completing the registration form and creating a User ID and password.   If you create a User Account, IWS collects certain Personally Identifiable Information when you register, including your user name, password, first name, last name, address, e-mail address, and birth date.

If you register for any paid services or make any purchases via our Website, IWS will also collect a credit card number.  It is optional for you to decide whether to provide additional information beyond these items.

Except as necessary to facilitate or fulfill any aspect of any services, products or features that you purchase or request or register for via the Website, or as otherwise set forth in this Privacy Policy, we will not intentionally sell, rent, lease, share or exchange your Personally Identifiable Information with any third party.

 

As noted above and below, if you opt-in to our marketing database, or if you request to receive newsletters, e-mail alerts, or other promotional materials, you thereby agree that IWS may sell, rent, lease, share or exchange your Personally Identifiable Information with any third party.

The following are categories of pages on the Website where we may collect Personally Identifiable Information about you.  As set forth below, please note that if you request to receive any newsletters, promotions or any sort of content that is promotional in nature, you thereby agree that IWS may sell, rent, lease, share or exchange your Personally Identifiable Information with any third party.

Alerts, Newsletters, and Other Subscriptions

Our Website may offer features that allow you to receive electronic alerts or notices about updates to our Website, promotional announcements, new products, games and other information or to subscribe to newsletters or other subscriptions.  When you sign up for such electronic alerts or notices or subscribe to newsletters or other subscriptions, we will collect certain Personally Identifiable Information, which may include without limitation your name, e-mail address and other basic contact information.   By signing up for such electronic alerts or notices or subscribing to such newsletters or other subscriptions, you agree that IWS may sell, rent, lease, share or exchange your Personally Identifiable Information with any third party.

 

Online Orders

If you order products through our Website, we will collect Personally Identifiable Information, which may include without limitation, name, address, phone number, e-mail address, and shipping and other contact information for the recipient of the item (if different than yours), your name and account number (if applicable) as well as payment information, such as credit card number, billing address, expiration date and other billing information.

 

Surveys and Other Voluntary Demographic Information

In addition to the above information, certain forms on various pages throughout our Site also ask users to voluntarily provide a limited amount of demographic information.  In addition, IWS or its affiliates may conduct online surveys that ask you for demographic data, such as your zip code, age or income level. IWS or IWS’ agents may also contact you by e-mail, using your e-mail address collected when you filled out one of the forms on our Website, with the option to participate in consumer research studies. Providing such demographic information and participating in such surveys or other consumer research are always voluntary. IWS aggregates the responses we receive before using the information to improve the products and services we offer. We do not link your individual responses to your personal information at any time.  IWS uses this information only for internal marketing research to help us better serve our users and customers.

 

Contests, Sweepstakes & Games

From time to time, IWS offers sweepstakes, contests or other games.  If you participate in such promotions, IWS may ask for some personal information, such as names, phone numbers, e-mail addresses, or other contact information, so that we can contact potential contest or sweepstakes winners.  We will clearly post the rules and terms of each contest or sweepstakes.  Please note that, from time to time, IWS may retain third party vendors to administer such sweepstakes, games or contests and in such circumstances, those third parties will be required to collect your personal information in order to administer and fulfill the promotion, as well as to contact potential winners.  Please review the Official Rules for such promotions carefully, as the personal information collected during these promotions may be subject to the privacy policies of these third party vendors as well as this Privacy Policy.  In that event, the Official Rules will refer you to the privacy policy of the third party vendors.  Please review those privacy policies as well, because IWS does not have control over the treatment of personal information by such third party vendors.  In addition, if you opt-in to our marketing database when you register for a contest, game or sweepstakes, you thereby agree that IWS may sell, rent, lease, share or exchange your Personally Identifiable Information with any third party.

 

Marketing, Promotional or Other Transactional Communications

If you have opted in to receive marketing, promotional or other informational communications from or on behalf of IWS, we may use your e-mail address from time to time to contact you to announce new features, products, investment ideas or services that may be available on our Website or to send news and information regarding IWS or our products or services and IWS may sell, rent, lease, share or exchange your Personally Identifiable Information with any third party. You can opt out of receiving these promotional communications at any time by following the instructions in the e-mail.  However, your opt-out will only affect our use of the information following your opt-out.  If you information has already been shared with third parties at that time, IWS will not have any further control over the use of such information by those third parties.

 

NOTE: IWS only intends to sell, rent, lease, share or exchange your Personally Identifiable Information with third parties that may offer our users products, services, investment ideas or information.

 

We may also use your e-mail address to contact you to verify and/or update any information related to services, features or transactions that you have requested via our Website.  Although you may opt out of the promotional e-mails as noted above, you should be aware that, that as long as you use our products and services or otherwise maintain a business relationship with us, however, you may not opt out of receiving communications from us relating specifically to those products and services or that business relationship.

 

“Contact Us” Pages

You may also provide Personally Identifiable Information to us when you voluntarily communicate with us, such as by requesting information via e-mail, utilizing the “Contact Us” features on the Website, or otherwise contacting us electronically.  We may retain such Personally Identifiable Information for use and disclosure consistent with this Privacy Policy.

 

Change in Ownership or Business Transfers

As we continue to develop our business, we might sell or buy assets. In such transactions, customer information generally is one of the transferred business assets. Also, in the event that IWS or substantially all of its assets are acquired, customer information, including Personally Identifiable Information, will of course be one of the transferred assets to the extent permissible under law.

 

Other Information

We collect additional information about how you use and access our Website to analyze trends, administer our Website, track user’s navigation on the Site and gather broad demographic information for aggregate use, which enables us to improve the Site by making it more accessible and easier to navigate. For example, we may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your PC), your computer’s name, the type and version of your web browser, referrer addresses and other generally-accepted log information. IP addresses are not linked to Personally Identifiable Information.  We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Website is being used.

 

Cookies

By use of this Website, you consent to our use of cookies. A "cookie" is a piece of data stored on your hard drive containing information about you. Usage of a cookie is in no way linked to any Personally Identifiable Information while on our Website. Cookies do not contain any registration information that would personally identify you, as all such data is kept behind our firewall. Nor do cookies allow us to track your usage of other Websites or the Internet in general.  In addition, when registered users visit our Website and log-in using their passwords, our Website uses "non-persistent cookies."  A non-persistent cookie is a form of technology that a server gives to your browser when you access our Website or a section of the Website.  The use of non-persistent cookies allows you to navigate our Website without being required to enter your password more than once during your visit to our Website.  Also, this cookie is deleted once you leave our Website.  Most web browsers are set to accept cookies by default, though you can manually disable the cookies feature of your browser. You should review the online documentation relating to your browser or consult with the provider of your browser for instructions on how to disable cookies. Please note that if you disable cookies on your computer, some parts of the Website may not function properly or offer you the same degree of personalization.

 

Referrers

A “referrer” is the information passed along by a web browser that references the web URL you linked from and is automatically collected by our Web server.  We may collect and use this information to understand the Websites referring traffic to our Website and to present appropriate content to our potential users.  We may tabulate referrer information on an aggregate basis to identify trends and traffic patterns.

IWS may share aggregated demographic information with our partners. This is not linked to any personal information that identifies any individual person. IWS may use your profile information to create personalized content, offers, and services, but this information will only be used by IWS and its affiliates.

Other Disclosure

IWS and its affiliates may disclose any or all of your Personally Identifiable Information if we are required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the law or comply with legal process served on us (for example, under a subpoena, court order or other regulatory requirement or to maintain or protect the security of the Website); (b) protect and/or defend our rights or property or other legal interests or of any Website user; or (c) act in urgent circumstances to protect the safety of the public or other users of the Website.  This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.  If we receive legal process calling for the disclosure of any of your Personally Identifiable Information, we will attempt to notify you via the e-mail address you supplied during registration within a reasonable amount of time before we respond to the request, unless such notification is not permitted.

 

Use of Third Parties or Agents by IWS

As noted earlier, IWS may employ third parties or other companies to perform functions on our behalf, such as processing and fulfilling online orders or requests, such as online purchases or other transactions via the Website, processing credit card payments, shipping or delivering packages, providing customer service, sending print and electronic mail, removing repetitive information from customer and e-mail lists, maintaining and analyzing information collected and/or stored via the Website, hosting sites from this Website, measuring the effectiveness of promotions and e-mails, performing analyses of users’ activities on the Website, serving images via our Website, and fulfilling other functions necessary to our business.

 

IWS also may use third party vendors or other companies to assist in providing certain services, products and communications to you, such as delivering newsletters, magazines, alerts and other communications to those Website users who have opted in to receive them.  In the event that we utilize third party vendors or companies to provide any of the services described above or similar services, we may need to share your Personally Identifiable Information with them to enable those companies to perform their obligations.  However, we will provide these companies only with that information necessary to perform their functions on our behalf, and we will not authorize them to use your Personally Identifiable Information for any other purpose.  In such event, these companies are required to agree, in writing, that they will abide by the privacy statement and privacy standards implemented herein, including the relevant confidentiality and security provisions.

 

Children under 13

IWS does not target children under the age of 13 and does not offer or knowingly sell any of its products or services to children.  IWS does not knowingly collect any personal information about children under the age of 13.

Security

IWS uses secure connections during the transmission of log in, registration and membership information. This means that information collected through those pages dealing with sign in, registration and membership information, is encrypted before it is sent over the Internet between your computer and IWS computers. The technology used is called Secure Socket Layer (SSL). Through the use of this technology, your information collected through those pages dealing with sign in, registration and membership information is encrypted on your computer, sent through the Internet as jumbled code and decoded on either IWS’ secure server or the systems of the third party contracted to provide the service in question. You can verify that the connection is secure because you will see a key or a padlock at the bottom of your browser. Another identifier of a secure connection is the URL (or Website address); the address will change from http://www.guesstheindex.com to https://www.guesstheindex.com when a secure connection is in place.

However, while we employ data encryption technology, you should be aware that there is an inherent risk in transmitting any data electronically. This risk is inherent in all Internet dealings. Consequently, we cannot guarantee that any Personally Identifiable Information transmitted will be prevented from being viewed or used by any particular person and therefore, you agree to hold us harmless from and against any injury, financial or otherwise, that results from such unauthorized viewing or use.  Moreover, e-mails sent to us over the Internet are susceptible to detection, decryption, eavesdropping or tampering. Thus, you agree to hold us harmless from and against any harm, financial or otherwise, that results from such detection, decryption, eavesdropping or tampering of e-mails.

 

In addition, you must take steps to maintain the security of your private information by keeping your password and other personal information confidential.  It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer.

 

Updating Your Information

IWS will always permit you to decline -- or “opt-out of” -- certain mailings and other materials we may offer.  You may opt out of further communications at any time by following the instructions in the e-mail that you receive.  In addition, if you request, we will remove your name and other Personally Identifiable Information from our active databases.  Please understand, however, that it may be impossible to remove this information completely, due to backups and records of deletions.  If you do not want to receive e-mail from us or to add or update certain personal information, you may contact us at This e-mail address is being protected from spambots. You need JavaScript enabled to view it As an alternative, you may write to us with your request, at the mailing address as follows: Inside Wall Street, 195 Wekiva Springs Road, Suite 310, Longwood, Florida 32779, attention: Nathaniel Rossique.  You will be removed from our databases generally within ten (10) business days of our receipt of your request. You may also request to review any Personally Identifiable Information that we maintain about you, by sending a written request to the same address, subject to our verification of your identity.

Links

Our Site may contain links to other sites. Please be aware that IWS is not responsible for the privacy policies of other sites. We encourage our Website users to be aware when they leave our Website and to read the privacy statements of each and every Website that collects Personally Identifiable Information. This Privacy Policy applies solely to the information collected by our Website.

Questions about Our Privacy Policy

If you choose to visit our Website, your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages and application of the law of the state of Florida.  Please let us know if you have any questions about our Privacy Policy. Simply send us an e-mail to This e-mail address is being protected from spambots. You need JavaScript enabled to view it