Gramm-Leach-Bliley Act

We implement and maintain an information security program with all administrative and technical safeguards designed to protect all our customer’s information to the extent that any information obtained is deemed “nonpublic personal information” about “consumers” or “customers” (collectively, “Consumer Data”).  These terms are defined in accordance with GLBA regulations.  All customers are entitled to their right to "opt out" if they don't want their information shared with certain third parties.

 Without any written agreement, it will always be positgram.com’s, managed by Doraphora LLC, first-hand priority on not to disclose or use the Consumer Data provided to us to any Third Party in any manner as prohibited by the GLBA or the regulations issued by the FTC.  In addition, we further make a covenant and agree to continually maintain appropriate measures designed to meet the objectives of the applicable guidelines establishing information security standards as adopted by any federal regulatory agencies having jurisdiction over online transactions. These measures include appropriate disposal of Consumer Data, as required, and taking appropriate actions to address incidents of unauthorized access to sensitive Consumer Data, including notification to the other Party as soon as possible of any such incident.  

 Further, without limiting the foregoing, positgram.com represents and warrants that its information security program is designed to: (i) ensure the security and confidentiality of Consumer Data; (ii) protect against any anticipated threats or hazards to the security or integrity of such data; and (iii) protect against unauthorized access to or use of such data that could result in substantial harm or inconvenience to any consumer.

 If you want to know more about GLBA, visit the FTC website: Gramm-Leach-Bliley Act | Federal Trade Commission (ftc.gov)