Content Locking Privacy Policy



This policy describes the information collection, use, and dissemination practices of CPAlead, LLC, ("Content Locking") and applies to CPAlead's collection, use, storage and disclosure of information by CPAlead on its (a) websites, including all its divisions, subsidiaries and related companies (collectively, the "Websites"), (b) on various Third Party websites, and (c) to CPAlead's other information collection, including the purchase of customer lists from Third Parties. CPAlead is not responsible for the information collection or privacy practices of Third Party websites or applications.


Companies that collect personally identifiable information ("PII") from California residents and disclose such information to Third Parties (including affiliated entities) for marketing purposes must, in response to a request by a consumer, either (1) provide a list detailing the categories of information shared and the entities to which such information was provided, or (2) provide a mechanism by which a consumer may opt-out of having their information shared with Third Parties. We have elected the second option and you may request that your PII not b2e shared with Third Parties by sending your request, including your full name, email address and postal address to: Content Locking, LLC., 1660 S. Church St., Suite #262, Watertown, WI 53094. In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, Suite 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to [email protected].


1. Collection of Information.

1.1 Survey Information

Content Locking collects information from individuals by various methods, including, but not limited to, when an individual voluntarily completes a survey, order form, or a registration page either online or offline, or by means of online or offline surveys, order forms, or registration pages operated by Third Parties (collectively, a "Survey"). (As used herein, "online" means using the Internet, including the Websites, and related technologies, and "offline" means by methods other than online, including in person, in the postal mail, using telephones and cell phones, and other similar means.) In the Surveys, Content Locking or a Third Party (a "Third Party") may ask an individual to provide various information to Content Locking, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, social security number, employment information, personal and online interests, and such other information as may be requested from time to time (together, "Survey Information"). Content Locking may also collect information concerning an individual from another source and uses that information in combination with information provided from this web site. Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to Content Locking or Third Party, but an individual may receive incentives from Content Locking or a Third Party in exchange for providing Survey Information to Content Locking.

1.2 Site Membership or Registration

To the extent registration is required to receive email and possibly postal communications from Content Locking or a Third Party Advertiser, this Privacy Policy also applies to consumers that have agreed to receive e-mail marketing from Content Locking or a Third Party Advertiser, whether at our Website, via email, on Third Party websites or otherwise. We collect information in certain portions of our Website, where guests provide content submissions and suggestions or participate in interactive online activities (i.e., by way of responding to questions and surveys, community listings, ratings, searches and comparison searches, bidding, purchasing, chat, games, or bulletin boards, etc.). The personal profile information you submit to Content Locking or Third Party Advertisers remains your property, but by submitting that information to Content Locking or Third Party Advertisers, you grant Content Locking and/or Third Party Advertisers, the right to use that information for marketing purposes. Content Locking or Third Party Advertisers may also use such information for content improvement and feedback purposes. We may sell the personal information that you supply to us and we may join together with other businesses to bring selected retail opportunities to you. These businesses may include providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation. In addition, Content Locking reserves the right to release current or past information in the event Content Locking believes that the information is being or has been used in violation of the Rules or to commit unlawful acts, if the information is subpoenaed, if Content Locking is sold or acquired, or when Content Locking deems it necessary or appropriate. By agreeing to these terms, you hereby consent to disclosure of any record or communication to any Third Party when Content Locking in its sole discretion, determines the disclosure to be appropriate.

"Subscription" occurs when an end-user registers for Content Locking's and/or Third Party Advertisers' services, either via registration at our website, via co-registration at a marketing partner's website, or via a permission pass / opt-out / no-opt mailing Content Locking collects personally identifiable information about our subscribers, based on: information gathered at the time of registration, subscriber interaction and response to subsequent electronic mailings and website use, information provided by marketing partners, and information appended from data aggregators. Information collected may include, but is not necessarily limited to: name, email address, postal address, gender, birth date, telephone number, activity, interests, user behavior and other demographic information. This information enables us to better tailor our content to subscribers' needs and to help our clients to promote and sell their products and services.

1.3 Third Party List Information

Content Locking collects information from individuals when an individual provides information to a Third Party and Content Locking subsequently purchases, licenses, or otherwise acquires the information from the Third Party (the "Seller"). Such purchased information may include, but is not limited to, an individual's name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, industry of employment, personal and online interests, and such other information as the individual may have provided to the Seller (together, "Third Party List Information"). When acquiring Third Party List Information, Content Locking seeks assurances from the Seller that the Seller has a right to transfer the Third Party List Information to Content Locking and that the Seller has a right to provide offers from Advertisers to the individuals whose personal information is included on the Seller's list.

1.4 Other Information.

Other occasions when Content Locking obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by Content Locking or by a Third Party, (2) when an individual requests assistance through Content Locking's customer service department, (3) when an individual voluntarily subscribes to a service or newsletter; (4) when private information is provided by means of a referral by a third party to Content Locking or a Third Party Advertiser (together, "Other Information").

1.5 Cookies, Web Beacons, and Other Info Collected using Technology.

Content Locking currently uses cookie and web beacon technology to associate certain Internet-related information about an individual with information about the individual in our database. Additionally, Content Locking may use other new and evolving sources of information in the future (together, "Technology Information").


A cookie is a small amount of data stored on the hard drive of the individual's computer that allows Content Locking to identify the individual with his or her corresponding data that resides in Content Locking's database. You may read more about cookies at Individuals who use the Websites need to accept cookies in order to use all of the features and functionality of the Websites.

a.Web Beacons.

A web beacon is programming code that can be used to display an image on a web page (by using a programming function -- see for more information), but can also be used to transfer an individual's unique user identification (often in the form of a cookie) to a database and associate the individual with previously acquired information about an individual in a database. This allows Content Locking to track certain websites an individual visits online. Web beacons are used to determine products or services an individual may be interested in, and to track online behavioral habits for marketing purposes. For example, Content Locking might place, with the consent of a Third Party website, a web beacon on the Third Party's website where cosmetics are sold. When Jane, an individual listed in Content Locking's database, visits the cosmetic website, Content Locking receives notice by means of the web beacon that Jane visited the cosmetics site, and Content Locking would then update Jane's profile with the information that Jane is interested in cosmetics. Content Locking may thereafter present offers of cosmetic related products and services to Jane. In addition to using web beacons on web pages, Content Locking also uses web beacons in email messages sent to individuals listed in Content Locking's database.

a.New Technology.

The use of technology on the Internet, including cookies and web beacons, is rapidly evolving, as is Content Locking's use of new and evolving technology. As a result, Content Locking strongly encourages individuals to revisit this policy for any updates regarding its use of technology.

a.Usage Tracking.

Content Locking tracks information related to the electronic mailings and web pages viewed by users and subscribers, as well as the hyperlinks clicked by subscribers, while viewing our emails or visiting our websites.

a.Log Files.

Log files are used to track and monitor subscriber usage.

a.Optional Registration.

Content Locking may offer free voluntary registration to potential subscribers. During such registration, the subscriber is required to supply an email address and other personal information. This information is required if the subscriber wants to participate in Company services or Third Party Services.

a.Feedback and Inquiries.

You have the ability to contact Content Locking to provide us with your feedback. Content Locking uses this information to respond to you and analyze customer service issues.

1.6 Outside Information

Content Locking may receive information about individuals from Third Parties or from other sources of information outside of Content Locking including information located in public databases ("Outside Information").

1.7 Individual Information

As used herein, Individual Information means Survey Information, Third Party List Information, Other Information, Technology Information, and Outside Information, and any other information Content Locking gathers or receives about individuals.

1.8 No Information Collected from Children.

Content Locking encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children. Content Locking will never knowingly collect any personal information about children under the age of 18. MINORS UNDER THE AGE OF 18 SHOULD NOT PROVIDE ANY PERSONAL INFORMATION, INCLUDING THEIR EMAIL ADDRESS, TO Content Locking. If Content Locking obtains actual knowledge that it has collected personal information about a child under the age of 18, that information will be immediately deleted from our active database. Because it does not collect such information, Content Locking has no such information to use or to disclose to Third Parties. Content Locking has designed this policy in order to comply with the Children's Online Privacy Protection Act ("COPPA").

1.9 Credit Card Information.

Content Locking may in certain cases collect credit card numbers and related information, such as the expiration date of the card ("Credit Card Information") when an individual places an order from Content Locking. When the Credit Card Information is submitted to Content Locking, such information is encrypted and is protected with SSL encryption software. Content Locking will use the Credit Card Information for purposes of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to Third Parties only as necessary to complete the purchase transaction. Although Content Locking takes all commercially reasonable action to protect Credit Card Information, you ultimately assume the risk of any damage or loss as a result of transmitting such information to Content Locking, including but not limited to, identify theft, credit card fraud or credit card loss.

1.10 Links to External Websites.

Content Locking's emails and websites contain links to external websites. You will be taken to external websites if you click on these links. Your information may be passed from Content Locking's database to the external website, and/or external database, for your convenience (e.g. your information may be used to pre-fill a form at a destination website). Content Locking is not responsible for the privacy practices or content of any external website owner. We encourage you to review the privacy policy of any website they visit.

2. Use of Individual Information.

2.1 Discretion of Information.


The following paragraphs in Section 2 describe how Content Locking currently uses Individual Information, but Content Locking may change or broaden its use at any time. As noted below, Content Locking may update this policy from time to time. Content Locking may use Individual Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses.

2.2 Email and Unsubscribe Policy.

Content Locking uses Individual Information to provide promotional offers by email to individuals. Content Locking may maintain separate email lists for different purposes. If email recipients wish to end their email subscription from a particular list, they need to follow the instructions at the end of each email message to unsubscribe from the particular list. To unsubscribe from all Content Locking's email lists, a person must send an email to [email protected]. Content Locking's unsubscribe process impacts only the future delivery of electronic mailings disseminated by Content Locking on its own behalf. You may still receive electronic mailings sent on behalf of Third Parties and your personal information may still be shared with Third Parties for use in offline marketing and data appends, including email appends.

You should also note that unsubscribing from Content Locking's electronic mailings will not automatically unsubscribe the subscriber's information from any Third Party associates and licensees of the data. Since Third Party associates and licensee partners maintain separate databases from Content Locking, and you will need to unsubscribe from each source individually, if desired. This allows you the freedom to pick and choose which subscriptions to maintain and which to discontinue.

2.3 Content of Email Messages.

In certain commercial email messages sent by Content Locking, an Advertiser's name will appear in the "From:" line but hitting the "Reply" button will cause a reply email to be sent to Content Locking. The "Subject:" line of Content Locking email messages will usually contain a line provided from the Advertiser to Content Locking.

2.4 Solicited Email.

Content Locking only sends email to individuals who have agreed on the Websites to receive email from Content Locking or to individuals who have agreed on Third Party websites to receive email from Third Parties. As such Content Locking does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable to Content Locking's email messages.

2.5 Targeted Advertising.

Content Locking uses Individual Information to target advertising to an individual. When an individual is using the Internet, Content Locking uses Technology Information (see also Section 2.7 below) to associate an individual with that person's Individual Information, and Content Locking attempts to show advertising for products and services in which the person has expressed an interest in the Surveys, indicated an interest by means of Technology Information, and otherwise. Content Locking may, at its discretion, target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers.

2.6 Direct Mail and Telemarketing.

Content Locking uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones.

2.7 Use of Technology Information.

Content Locking uses Technology Information (1) to match a person's Survey Information and Third Party List Information to other categories of Individual Information to make and improve profiles of individuals, (2) to track a person's online browsing habits on the Internet, (3) to determine which areas of Content Locking's websites are most frequently visited. This information helps Content Locking to better understand the online habits of individuals so that Content Locking can target advertising and promotions to them.

2.8 Profiles of Individuals.

Content Locking uses Individual Information to make a profile of an individual. A profile can be created by combining Survey Information and Third Party List Information with other sources of Individual Information such as behavioral and other information obtained from public databases. Content Locking may also publish personal information in the form of a testimonial if such information is sent to Content Locking by you.

2.9 Storage of Individual Information.

Content Locking stores the Individual Information in a database on our computers. Our computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under Content Locking's control. Not withstanding such measures, Content Locking cannot guarantee that its security measures will prevent our computers from being illegally accessed, and the Individual Information on them stolen or altered.

3. Dissemination of Individual Information.

3.1 Sale or Transfer to Third Parties.


3.2 Order Fulfillment.

Content Locking will transfer Individual Information to Third Parties when necessary to provide a product or service that a person orders from such Third Party while using Content Locking websites or when responding to offers provided by Content Locking.

3.3 Legal Process.

Content Locking may disclose Individual Information to respond to subpoenas, court orders, and other legal processes.

3.4 Summary Data.

Content Locking may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.

3.5 Access.

Individuals have access to their Individual Information collected to provide an opportunity for an individual to correct, amend, or delete such information. Access can be obtained by contacting [email protected]. Content Locking may also grant advertising clients and email services providers' access to an individual's email address to verify the origin of the Individual Information collected.

4. Privacy Practices of Third Parties.

4.1 Advertiser cookies and web beacons.

Advertising agencies, advertising networks, and other companies (together, "Advertisers") who place advertisements on the Websites and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. Content Locking does not control Advertisers' use of such technology and Content Locking has no responsibility for the use of such technology to gather information about individuals.

4.2 Links.

The Websites and email messages sometimes contain hypertext links to the websites of Third Parties. Content Locking is not responsible for the privacy practices or the content of such other websites. Linked websites may contain links to websites maintained by Third Parties. Such links are provided for your convenience and reference only. Content Locking does not operate or control in any respect any information, software, products or services available on such Third Party websites. The inclusion of a link to a web site does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.

4.3 Affiliated Companies.

Content Locking may disclose, transfer, and sell Individual Information to entities affiliated with Content Locking in Content Locking's discretion.

5. Unsubscribe Procedures.

If you wish to discontinue receiving email messages from Content Locking, you have several options:

a.Unsubscribe from one email list.

To unsubscribe from a particular list, either (1) send an email to [email protected] or (2) follow the instructions in each promotional email message sent by Content Locking.

a.Unsubscribe from all of Content Locking's email lists.

We reserve the right to add Individual Information to multiple lists maintained by Content Locking. To globally unsubscribe from all of Content Locking's lists, send an email to [email protected].

For more information about protecting your privacy, you may wish to visit: If you have questions about this policy, please contact us at [email protected].

Content Locking may receive information about individuals from Third Parties or from other sources of information outside of Content Locking including information located in public databases ("Outside Information").