ONLINE AND EMAIL MARKETING PRIVACY POLICY

Last Updated: June 1, 2015
This Online and Email-Marketing Privacy Statement ("Privacy Statement") applies exclusively to: (i) Marco Polo New World, Inc.’s website located at http://www.marcopolonewworld.com/ and any other Marco Polo service that links to this Privacy Statement (each, a "Site"); and (ii) Marco Polo email-marketing communications. By using any of our Sites, you consent to the collection, use, and disclosure of your data by Marco Polo New World, Inc. and our affiliates ("Marco Polo," "we," or "us") as described in this Privacy Statement. This Privacy Statement (together with any terms of use for the applicable Site) explains how we collect and use the Personal Information of visitors to our Sites and recipients of our email marketing communications.

Gathering and Use of Personal Information: "Personal Information" is information that identifies you individually, such as name, email address, mailing address, and telephone number. We use Personal Information to respond to your inquiries and fulfill your requests, provide products and services you have requested, provide you with information about our products and services, improve our products and services, and better serve your needs. We may also combine information that we have about you with information we have obtained from business partners and other sources.

Disclosure of Personal Information: We may disclose Personal Information to our affiliates for the purposes described in this Privacy Statement. We also may disclose Personal Information to third-party service providers who provide services including, but not limited to, website hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, email delivery services, credit card processing, auditing services and other services to enable them to provide services. We may use or disclose Personal Information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates or others; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. We also may disclose Personal Information to others as part of any reorganization, merger, sale, joint venture, assignment, transfer, or disposition of all or any portion of our business, assets or stock (including in connection with bankruptcy or other proceedings).

Our Sites may include bulletin board services, chat areas, news groups, forums, communities, web logs (i.e., blogs), and other message or communication facilities designed to enable you to communicate with us and with others. Please note that any information you post or disclose through these services may become public information, and may be available to users of the Sites. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Sites.

Gathering and Use of Other Information: We may also collect other information through our Sites or email marketing communications ("Other Information"), including:



If Other Information does not personally identify you, we may use and disclose it for any purpose. If Other Information is correlated with Personal Information, or if we combine any Other Information with Personal Information, we will treat the combined information as Personal Information as long as it is combined.

Jurisdictional Issues: The Site is controlled and operated from the United States and is not intended to subject Marco Polo to the laws or jurisdiction of any state, country or territory other than the United States. We may transfer information to any country where we have operations or service providers.

Email Marketing Communications: We may occasionally send you information, news and materials regarding Marco Polo and its products and services that might be of interest to you.

If you prefer not to receive marketing emails from us in the future, you can request to be removed from our e-mail marketing lists at any time by 'unsubscribing' in accordance with the instructions on these emails to you. Please note that if you do opt out of receiving marketing-related emails from us, we may still send service announcements and other administrative messages to you, and that you cannot opt out of receiving these service and administrative messages.

Third Party Sites: The Site may contain "links" to other Web sites. This Privacy Statement does not address, and Marco Polo is not responsible for, the privacy or other practices of any third parties, including any third party operating any site to which this Site contains a link. The inclusion of a link on the Site does not imply endorsement of the linked site by Marco Polo. We recommend that you check the specific privacy policy of any site before providing any personal information.

Security: We seek to use reasonable administrative, technical and physical safeguards to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately by contacting us in accordance with the "Contact Us" section below.

Changes to this Privacy Statement: We may update this Privacy Statement from time to time. Please check the "Last Updated" legend at the top of this page to see when this Privacy Statement was last revised. Any changes to this Privacy Statement will become effective when we post the revised Privacy Statement on the Site. Your use of the Site following these changes means that you accept the revised Privacy Statement.