PRIVACY POLICY

This document discloses the privacy practices for SailorPenGuild.com, a Website (the "Site" or "Website") owned and operated by ITOYA of America, LTD (Itoya Studio) ("Privacy Policy"). As part of the normal operation of SailorPenGuild.com's services, we collect and, in some cases, disclose information about you. This Privacy Policy describes the information we collect about you and what may happen to that information. By accepting the User Agreement, you expressly consent to our use and disclosure of your personally identifiable information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the SailorPenGuild.com's User Agreement.

1.     Minors. IF YOU ARE 13 YEARS OR YOUNGER, PLEASE DO NOT USE SAILORPENGUILD.COM OR ANY OF ITS SERVICES FOR ANY PURPOSE AT ANY TIME.

2.     Information We Collect.

(a)        Your Registration Information. To fully use our services, you will need to register using our online registration form, where you will be required to provide us with your contact information and certain other personal information, namely, email address.

(b)       Your Usage of Our Site. We automatically track certain information about you based upon your use of our Site. We use this information to conduct internal research on our users' demographics, interests, and behavior to better understand and serve our users. This information is compiled and analyzed on an aggregate anonymized basis. This information may include the URL that you just came from, which URL you next go to, what browser you are using, and your IP address.

(c)        Cookies. In addition, we use "cookies" on certain pages of our Site. Cookies are small files that can be used to track a user's steps or automatically generate a user's password. Some features of our Website may only be available through the use of a cookie. Among other things, cookies allow you to enter your password less frequently during a session. Cookies can also help us provide information which is targeted to your interests. Cookies are stored on your hard drive, not on our Site. Most cookies are automatically deleted at the end of a session. You may decline our cookies if your browser permits, although your use of the Site may then be restricted (as noted above).

(d)       Should you choose to post ant material or content on the Site, participate in any chat rooms, or discussion forums, etc., such information and/or communications that you choose to disclose will be widely available to other persons, both on and outside of the Site, including all persons who have access to such chat rooms and forums. Some forums or chat rooms may have additional terms of use and applicable rules that must be agreed to in order to participle thereon.

(e)        Your Correspondence. If you send us emails, letters, or other personal correspondence, or if other users or third parties send us correspondence about your activities or postings on the Website, we may collect such information into a file specific to you.

(f)         Your Credit Account. If you establish a credit account with us, we collect some additional information, including billing address, credit card number, and credit card expiration date and tracking information from checks or money orders.

3.     Our Use of Your Information.

(a)        Promotional Use. We use personal information about you to enhance our marketing and promotional efforts, and to improve our content and services. We may also use your information to deliver to you advertisements, new services and promotions, and other information to you that is targeted to your interests. You can avoid receiving some of this information by changing your options on your account status page. You will have the ability to not receive such advertisements, promotions, notices, and information by confirming opt-out status in account settings.

(b)       Administrative Notices, etc. We use your email address, your mailing address, and phone number to contact you regarding administrative notices, new product offerings, and communications relevant to your use of the Site. If you do not wish to receive these communications, you may have the ability to opt-out on your account status page.

(c)        Billing and Support. If you open a credit account, we use your address and billing information to bill you and provide associated support.

(d)       Dispute Resolution. We use information in the file we maintain about you, and other information we obtain from your current and past activities on the Site, to resolve disputes, troubleshoot problems, and enforce our User Agreement.

4.     Our Disclosure to Third Parties. We use practices that are consistent with standards in the industry to protect your privacy. We cannot, however, promise that your personally identifiable information or private communications will remain private. For example, third parties may unlawfully intercept or access transmissions or private communications. We do not sell or rent any personally identifiable information about you to any third party. The following describes some of the ways that your personally identifiable information may be disclosed. For a more detailed list of ways we disclose information about you, please see Terms of Use site.

(a)        Disclosures Required by Law. We reserve the right at all times to disclose any information about you as necessary to satisfy any applicable law, regulation, legal process, or governmental request. We reserve the right to fully cooperate with any law enforcement authorities or court orders requesting or directing us to disclose the identity of anyone posting any content, or publishing or otherwise making available any materials on the Site. BY ACCEPTING THIS AGREEMENT, YOU WAIVE ALL RIGHTS AND AGREE TO HOLD US HARMLESS FROM ANY CLAIMS RESULTING FROM ANY ACTION TAKEN BY US DURING OR AS A RESULT OF ANY INVESTIGATIONS AND/OR FROM ANY ACTIONS TAKEN AS A CONSEQUENCE OF ANY INVESTIGATION BY EITHER US OR LAW ENFORCEMENT AUTHORITIES.

(b)       Advertisers. We disclose aggregate information about our users to advertisers and for other marketing and promotional purposes. However, we do not disclose any personally identifying information to any of these entities.

(c)        SailorPenGuild.com Site. Throughout the Site, you are identified by your User ID. Unless you select a unique User ID, our system automatically sets your User ID as your email address. In this situation, where you are identified on the Site by your User ID, you disclose your email address to other users and third parties. As a result, other users and third parties might send you unsolicited email and be able to personally identify all of your activities on the Site. Although our pages are coded with robot exclusion headers, others may attempt to automatically collect your email address from our Site. Even if your User ID is not your email address, your User ID can be used to identify you and your activities throughout the Site. Other people can see your bids, items that you have won in the past, your feedback rating and associated comments, your postings on the Site, and so on. We also provide others a number of ways to allow other users to find more out about you and your site activities, such as our feature that allows users to quickly see all of the auctions you are offering at the time.

(d)       Third-Party Suppliers. We may use third-party suppliers to assist us in providing the services available on our website. Whenever a third-party supplier desires to collect information about you, you will be notified of the involvement of the third-party supplier, and you will never be required to disclose any information to the third-party supplier. We impose contractual restrictions on the use by our third-party suppliers of information concerning you, and we do not permit our third-party suppliers to sell your information to other third parties.

5.     Use Limited to Site-Related Communications. Because of the nature of the services offered on SailorPenGuild.com, SailorPenGuild.com allows you to access other users' contact information. You may use such information only for SailorPenGuild.com-related communications. SailorPenGuild.com-related communication expressly excludes unsolicited commercial messages. In all cases, you must give users an opportunity to remove themselves from your database and a chance to review what information you have collected about them. In addition, under no circumstances can you disclose personally identifiable information about another user to any third party without our consent and the consent of such other user after adequate disclosure. Note that law enforcement personnel, VeRO program participants, and other rights holders are given different rights with respect to information they access.

(a)        No Spam. SailorPenGuild.com and our users do not tolerate spam. Therefore, without limiting the foregoing, you are not licensed to add a SailorPenGuild.com user to your mail list (email or physical mail) without their express consent after adequate disclosure.

6.     Disclosures You Make to Third Parties. SailorPenGuild.com does not control the privacy policies of third parties. When you disclose information to third parties on SailorPenGuild.com (or any other website) about yourself, you are subject to the privacy customs and policies of that third party.