LAST UPDATED September 25, 2014
FELA, Inc. ("FELA" or "we") respects the privacy of visitors to our web site mylifecents.com (the "Web Site" or "mylifecents.com") and has developed this
user of the Web Site or our services, the information we collect, how that information may be used, with whom it may be shared, and your choices about such
Site, you should check the date set forth above to determine whether an updated version has been posted and to review any changes since your last
1. Types of Information We Collect on the Web Site
We may now, or in the future, collect three types of information from users of the Web Site: "personally identifiable information" such as your name, email
address, postal address, phone number, and, if you transact business with us, financial information such as credit card number, type and expiration date.
We also may collect "aggregate information" such as age, gender, financial habits and demographic information, frequency of visits to the Web Site, search
terms entered and pages most frequently accessed. Lastly, we may also collect “self-reported” information based on your interactions with the Web Site
which include education related information such answers to questions, quizzes, surveys, and assessments; we may collect self-reported financial
information and other personal metrics.
We use this information in an effort to improve your experience on the Web Site and to communicate with you about the Web Site and our services. We may
also use this information to make offers to you, to help us target specific services to you, and to help us develop and tailor the Web Site to your
2. Collection of Personally Identifiable Information
We only collect personally identifiable information that is voluntarily provided by users of the Web Site when users register as members on the Web Site
("Members"). For example, when you register as a Member on the Web Site, you must provide personally identifiable information such as your name, address,
telephone number, email address, and for certain services, a valid credit card number.
If you are a Member and send us correspondence, including emails or faxes, we may retain such information in the records of your account. We will also
retain customer service correspondence and other correspondence from FELA to you. We retain those records in an effort to measure and improve our customer
service and to investigate potential fraud.
3. Collection of Aggregate Information
We also collect aggregate information from all visitors to the Web Site. Aggregate information is used in a collective manner, and no single person can be
identified by that compiled information.
4. Self-Reported Information
When you interact with the Web Site or a FELA owned Web Site, we may collect and store information about you directly from you. We may also collect and
store personally identifiable information about other people that you provide to us. If you use our Web Site to send others (friends, relatives,
colleagues, etc.) information that may interest them or messages (such as invitations) through the Web Site, we may store your personally identifiable
information, and the personally identifiable information of each such recipient.
5. Collection and Use of IP Addresses and Browser Information
In addition, we automatically collect IP addresses and browser information, such as browser type, language and access times, to obtain aggregate
information on the Web Site. An IP address is a number assigned to your computer by a web server when you are on the Internet. When you are on our Web
Site, we have a server that logs your computer's IP address. We only use the information we find out from tracking IP addresses in the aggregate, such as
how many users entered a specific area of our Web Site, and not to track a specific IP address to identify an individual user. However, we reserve the
right to use such information to identify a user if safety and/or security issues arise or to comply with legal requirements.
When you visit our Web Site, we may assign your computer one or more cookies, to facilitate access to our Web Site and to personalize your online
experience. A cookie is a small text file that is stored on a user's computer for record keeping purposes. Cookies can be either session cookies or
persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Web Site. A persistent
cookie remains on your hard drive for an extended period of time. For example, when you sign in to our Web Site, we will record your user or member ID and
the name on your user or member profile in the cookie file on your computer. We also may record your password in this cookie file, if you indicated that
you would like your password saved for automatic sign-in. For security purposes, we will encrypt any usernames, passwords, and other user or member
account-related data that we store in such cookies. In the case of sites and services that do not use a user or member ID, the cookie will contain a unique
identifier. We may allow our authorized service providers to serve cookies from our Web Site to allow them to assist us in various activities, such as
doing analysis and research on the effectiveness of our Web Site, content and advertising. You may delete or decline cookies by changing your browser
settings. (Click "Help" in the toolbar of most browsers for instructions.) If you do so, some of the features and services of our Web Site may not function
We may allow third-parties, including advertising companies, and ad networks, to display advertisements on our Web Site. These companies may use tracking
technologies, such as cookies, to collect information about users who view or interact with their advertisements. Our Web Site does not automatically
provide any personally identifiable information to these third parties, but they may collect information about where you, or others who are using your
computer, saw and/or clicked on the advertisements they deliver, and possibly associate this information with your subsequent visits to the advertised
websites. They also may combine this information with personally identifiable information they collect from you. The collection and use of that information
You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash cookies operate
differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash
cookies you can visit adobe.com and make changes at the privacy settings panel. If you disable cookies, you may lose some of the features and functionality
of mylifecents.com, as LifeCents cookies are necessary to track and enhance your experience using the Service. Please note that companies delivering
7. Web Beacons
Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to
track the online movements of web users or to access cookies. Unlike cookies which are stored on the user's computer hard drive, web beacons are embedded
invisibly on the web pages (or in email) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or
communicate with cookies, to count users who have visited certain pages and to understand usage patterns. We also may receive an anonymous identification
number if you come to our Web Site from an online advertisement displayed on a third-party website.
8. Sharing, Selling, and Trading Personally Identifiable Information Collected Online with Third Parties
We do not actively rent, sell or otherwise disclose your personally identifiable information to unrelated third parties without your consent, except as
experience. For example, we may use information collected from you in any one or more of the following ways:
§ to create your accounts and allow use of our Web Site
§ to make recommendations related to badges, goals, tasks, and other content
§ to identify and suggest connections with other mylifecents.com users
§ to enable user-to-user communications
§ to enable communications with partners, mentors, and coaches
§ to provide access to rewards, incentives, and other virtual currencies
§ to connect you to relevant programs, partners, products, and services
§ to provide technical support and respond to user inquiries
§ to prevent fraud or potentially illegal activities, and enforce our Terms of Service
§ to deliver and target advertising
§ to notify users of Service updates
§ to provide peer-to-peer comparisons and promote User achievements
§ to solicit input and feedback to improve FELA’s products and services and customize your user experience
§ to inform users about new products or promotional offers
§ to engage in commonly accepted practices, such as contacting you at the email address We have on file if you are a potential winner in a sweepstakes or
We may share personally identifiable information with third party service providers hired by FELA, such as companies who perform technical and processing
functions on our behalf. These services may include processing credit card payments, providing customer service and marketing assistance, performing
business and sales analysis, supporting our Web Site functionality, and supporting contests, sweepstakes, surveys and other features offered through our
Web Site. These third parties are not authorized to retain, share, store or use your personally identifiable information for any purpose other than
completion of the specific services for which they were hired.
One important use of your information is communication. If you have provided your e-mail address to FELA, we will use it to respond to (i) customer support
inquiries, and (ii) keep you informed of your activity and progress, including comments from mentors, coaches, partners, and administrators. We may also
send promotional e-mail messages and promotional SMS messages ("Promotional Communications") directly or in partnership with parties other than FELA. Each
Promotional Communication will generally offer recipients choices about receiving additional messages.
When you engage in promotions offered through our Web Site or our services, we may share personally identifiable information with the businesses with which
we partner to offer you those products, services, promotions, contests and/or sweepstakes. When you elect to engage in a particular merchant's offer or
program, you authorize us to provide your email address and other personally identifiable information to that merchant.
In addition, in the following circumstances we may share or transfer personally identifiable information to unrelated third parties: (a) to comply with a
legal requirement, judicial proceeding, court order, or legal process served on us; (b) to investigate a possible crime, such as fraud or identity theft;
(c) when we believe it is necessary to do so to protect the rights, property, or safety of our company or other persons; and (d) In connection with a
substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of
9. Sharing, Selling, and Trading Aggregate Information Collected Online with Third Parties
We may sell, share, trade or otherwise disclose aggregate information collected on our Web Site with third parties. As stated earlier, no single person can
be identified by such aggregate information.
We may provide areas on our Web Site where you can post information about yourself and others and communicate with others, as well as post reviews of
searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personally identifiable information on publicly-viewable web
pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive
unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to
exercise discretion and caution with respect to your personally identifiable information.
11. Third-party Websites
example, if you click on an advertisement or a search result on our Web Site, you may be taken to a website that we do not control. These third-party
websites may independently solicit and collect information, including personally identifiable information, from you and, in some instances, provide us with
information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking
on the "privacy" link typically located at the bottom of the webpage you are visiting.
12. How You Can Access Your Information
If you have an online account with us, you have the ability to review and update your personally identifiable information online by logging into your
account. You can also review and update your personally identifiable information by contacting us at support@myFELA.com. More information about how to
After you close your account, you will not be able to sign in to our Web Site or access any of your personally identifiable information. However, you can
open a new account at any time. If you close your account, we may still retain certain information associated with your account for analytical purposes and
recordkeeping integrity, as well as to prevent fraud, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our Web
Site or our users, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties as
13. Your Choices about Collection and Use of Your Personally Identifiable Information
You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Web Site because such
information may be required in order for you to register as a Member; participate in a contest, promotion, survey, or sweepstakes; ask a question; rate,
review or comment on articles and merchants, or initiate other transactions on our Web Site.
You will be given the opportunity, in any commercial e-mail that we send to you, to opt out of receiving such messages in the future. It may take up to 10
days for us to process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as service
announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that changing
information in your account, or otherwise opting out of receipt of promotional email communications will only affect future activities or communications
from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have
to change your preferences directly with that third party.
If you are a resident of California, in addition to the rights set forth above, you have the right to request information from us regarding the manner in
which we share certain categories of personally identifiable information with third parties for their direct marketing purposes. California law gives you
the right to send us a request to receive the following information:
- the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year
- the names and addresses of the third parties that received that information; and
- if the nature of the third party's business cannot be determined from their name, examples of the products or services marketed.
We may provide this information in a standardized format that is not specific to you. The designated email address for submitting these requests to
14. How We Protect Your Personally Identifiable Information
We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personally identifiable information
from unauthorized access and disclosure. For example, only authorized employees are permitted to access personally identifiable information, and they may
do so only for permitted business functions. In addition, we use encryption in the transmission of your sensitive personally identifiable information
between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personally identifiable information.
However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect,
that your personally identifiable information, searches, or other communications will always remain secure. Users should also take care with how they
handle and disclose their personally identifiable information and should avoid sending personally identifiable information through insecure email. Please
refer to the Federal Trade Commission's website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to
protect yourself against identity theft.
IN NO EVENT WILL FELA OR OUR OFFICERS, DIRECTORS, EMPLOYEES, AFFILIATES, AGENTS, LICENSORS, SUPPLIERS OR ANY PARTY INVOLVED IN CREATING, PRODUCING OR
DELIVERING The Web SITE ("RELEASED PARTIES") BE LIABLE IN ANY MANNER WHATSOEVER FOR ANY DAMAGES OF ANY KIND, INCLUDING BUT NOT LIMITED TO DIRECT, INDIRECT,
INCIDENTAL, CONSEQUENTIAL, SPECIAL OR PUNITIVE DAMAGES ARISING OUT OF: (a) The Web SITE, YOUR ACCESS, USE OR INABILITY TO USE The Web Site; (b) ANY FAILURE
OR PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DEFECT, DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS OR LINE OR SYSTEM FAILURE (INCLUDING LOSS
PROFITS, LOSS OF BUSINESS OR DATA, BUSINESS INTERRUPTION, AND DAMAGES THAT RESULT FROM INACCURACY OF THE INFORMATION OR INCONVENIENCE, DELAY, OR LOSS OF
THE USE OF THE web SITE); (c) PERSONAL INJURY OR PROPERTY DAMAGE, OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO AND USE OF THE Web SITE, (d) ANY
UNAUTHORIZED ACCESS TO OR USE OF OUR SECURE SERVERS AND/OR ANY AND ALL PERSONALLY IDENTIFIABLE INFORMATION STORED THEREIN, (e) ANY BUGS, VIRUSES, TROJAN
HORSES, OR THE LIKE, WHICH MAY BE TRANSMITTED TO OR THROUGH THE Web SITE BY ANY THIRD PARTY. THE FOREGOING LIMITATIONS APPLY WHETHER THE ALLEGED LIABILITY
IS BASED ON CONTRACT, TORT, NEGLIGENCE STRICT LIABILITY OR ANY OTHER BASIS, EVEN IF THE RELEASED PARTIES OR ANY OTHER PARTY HAS BEEN ADVISED OF THE
POSSIBILITY OF SUCH DAMAGES.
15. Children's Privacy
Our Web Site is a general audience site, and we do not knowingly collect personally identifiable information from children under the age of 13. However, we
are concerned about the safety of children when they use the Internet, and understand that children may not understand all of the provisions of our Privacy
Policy or make informed decisions about the choices that are made available to adult users of the Web Site. If we become aware that a user is under the age
of 13 and has registered without prior verifiable parental consent, we will remove his or her personally identifiable information from our files.
16. Visiting Our Web Site from Outside the United States
from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers
are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive
as those in your country. By visiting our Web Site or using our services, you understand that your information may be transferred to our facilities and
17. No Rights of Third Parties
of the Web Site.
identifiable information, we will notify you by sending an e-mail to the e-mail address you most recently provided us in your account, profile or
registration (unless we do not have such an email address), and/or by prominently posting notice of the changes on our Web Site. We recommend that you
19. How to Contact Us
of personally identifiable information to third parties for their direct marketing purposes, please contact us by e-mail or postal mail to the attention of
the "FELA Privacy Officer" as follows:
400 Massachusetts Ave, NW #614
Washington, DC 20001