Web Site Privacy Policy

Last Updated October 2012

Global Privacy Standards

True Action is a wholly owned subsidiary of GSI Commerce®, Inc. GSI is an eBay Inc. (NASDAQ: EBAY) company. GSI complies with the EU Safe Harbor framework as set forth by the Department of Commerce regarding the collection, use, and retention of data from the European Union. Further, our parent company, eBay Inc. has established a set of corporate rules for privacy, known as Binding Corporate Rules (BCRs), which are the global privacy standards for all eBay Inc. companies. These BCRs have been approved by a number of European Union privacy regulators. They are a commitment by eBay Inc. to protect your personal information and honor our privacy obligations regardless of where your personal information is collected, processed or stored. Depending on where you reside, the BCRs may also provide you some additional privacy rights through your local privacy regulator or court. The privacy practices of our corporate family are consistent with those described in this Privacy Policy and our BCRs. More information about our BCRs and our global privacy practices and principles, including information on how to contact us with any questions, is available at our eBay Privacy Center.)

Contents

Trueaction.com has created this Privacy Statement to inform you of the information collection practices for this Web site www.trueaction.com ("Web Site"), including what type of information is gathered, how the information is used, and with whom the information is shared.

By using trueaction.com, its services and tools, you expressly consent to our collection, use, disclosure and retention of your personal information as described in this Privacy Policy.

Collection

In general, you can visit this Web Site without identifying yourself or revealing any personally identifiable information. There are times, however, that you may choose to give us personally identifiable information. For example, if you would like to receive information about True Action, you will need to provide us information such as your name, address, email address, telephone and/or fax number.

Marketing

True Action will not sell, rent, or lease to others any personally identifiable information that you provide through this Web Site. Unless we have your permission, we will only share the personally identifiable information you provide through this Web Site with business partners who are acting on our behalf for the uses described in this Privacy Statement. All True Action business partners having access to your personally identifiable information are subject to this Privacy Statement with respect to the use of your personally identifiable information.

Use

We only use the personally identifiable information that you provide through this Web Site to help us improve our services to you, to provide you with the information you have requested or to respond to your questions. Any non-personally identifiable material, information, suggestions, ideas, concepts, know-how, techniques, questions, comments or other communication you transmit or post to this Web Site in any manner is and will be considered non-confidential and non-proprietary ("User Communications"). True Action, each of our affiliates and/or their designees may use any or all User Communications for any purpose whatsoever, including, without limitation, reproduction, transmission, disclosure, publication, broadcast, development, manufacturing and/or marketing in any manner whatsoever for any or all commercial or non-commercial purposes.

True Action may, but is not obligated to, monitor or review any information you provide through this Web Site. True Action shall have no obligations to use, return, review, or respond to any requests, information, questions, material, comments, submissions or other communications through this Web Site. You are prohibited from posting or transmitting to or from this Web Site any unlawful, threatening, libelous, defamatory, obscene, offensive, or pornographic material, or material that would violate any law. True Action will have no liability related to the content of any such communications, whether or not arising under the laws of copyright, libel, privacy, obscenity, or otherwise.

Disclosure

We may also share your personal information with:

Cookies

We use "cookies" (small data files placed within your computing device) on certain of our pages to help analyze our web page flow; customize our services, content and advertising; measure promotional effectiveness, and promote trust and safety.

A few important things you should know about our use of these technologies are:

Access

If you would like to access personally identifiable information that you have provided through this Web Site to correct or request deletion, please contact us as described below. We will respond to your request within 30 days.

Security

Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been made anonymous so that it does not identify a specific user.

We store and process your personal information on our computers in the U.S. where our facilities are located. We protect your information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls.

We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. We retain information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, and take other actions permitted by law.

Third Parties

Except as otherwise expressly included in this Privacy Policy, this document addresses only the use and disclosure of information we collect from you. True Action does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your personal information to others.

Changes

We reserve the right to modify this Privacy Statement at any time, so please review it frequently. If we make material changes to this Privacy Statement, we will notify you by means of a notice on our home page.

Questions

Questions regarding this Privacy Statement should be directed to True Action by e-mail to copyright@gsicommerce.com, or by regular mail to Attn: True Action Registered Agent, 935 First Avenue, King of Prussia, PA 19406.