Privacy Statement

The Consumer Opinion Center (“COC”) respects your concerns about privacy. This Privacy Statement describes the types of personal information we collect on consumeropinioncenter.com (the “Site”), how we use the information and with whom we may share it. We also describe the measures we take to safeguard the information and how to contact us about our privacy practices.

Information We Collect

When you visit our Site, you may choose to provide us with personal information, such as:

* Contact information (such as name, address, telephone number and email address)

* Demographic information (such as gender, marital status, date of birth, race/ethnicity, employment status, name of employer, education level, income level, car ownership, food allergies, menthol allergies and tobacco usage)

* Login credentials (such as username and password)

* Other personal information you choose to submit on the Site

In addition, when you visit the Site, we may obtain certain information by automated means, such as cookies and web beacons. The information collected in this manner may include IP addresses, dates and times of visits, duration of visits, specific pages visited, referring site, operating system type, browser type, domain and other system settings.

“Cookies” are text files that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our website.

We may use third-party web analytics services on our Site, such as those of Google Analytics. This service provider uses technologies, such as cookies and web beacons, to help us analyze how users use the Site and which links they clicked on to arrive at the Site. The information collected by the cookies and web beacons (including your IP address) will be disclosed to this service provider, who uses the information to evaluate your use of the Site. To learn about opting out of Google Analytics, you may visit http://tools.google.com/dlpage/gaoptout.

How We Use the Information We Obtain

We may use the information you provide to:

* Create and manage your online profile and participant account

* Send you notifications or other communications, and administer your participation in, special events, programs, surveys, contests, sweepstakes, and other offers or promotions

* Verify your identity, age and eligibility for studies

* Schedule study appointments

* Issue you participation incentive payments and tax reporting documentation

* Provide tax reporting documentation to the Internal Revenue Service

* Manage our participant information databases

* Operate, evaluate and improve our business

* Comply with applicable legal requirements, industry standards and our own policies and terms

We also may use the information in other ways for which we provide specific notice at the time of collection.

We may use information collected through automated means for purposes such as (i) customizing our users’ visits to the Site, (ii) delivering content tailored to our users’ interests and the manner in which our users browse our Site and (iii) managing our Site and other aspects of our business.

Information We Share

We do not sell or otherwise share personal information about you, except as described in this Privacy Statement. We may share personal information we collect on the Site with third parties who perform services on our behalf based on our instructions. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

We may disclose information about you (i) if we are required to do so by law, regulation or legal process (such as a court order or subpoena); (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual fraudulent or illegal activity.

We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including, without limitation, in the event of a reorganization, dissolution or liquidation).

Your Choices

We offer you certain choices about how we communicate with you and what information we obtain from you. To update your information, ask us to remove you from our mailing lists, or submit a request, please contact us as indicated in the “How to Contact Us” section of this Privacy Statement.

How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect the personal information you provide on our Site against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Links to Other Websites

Our Site may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with us. Linked websites, including those operated by COC or Altria Group, may have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that we do not control, any use of those websites, or the privacy practices of those websites.

Updates to Our Privacy Statement

This Privacy Statement may be updated periodically and without prior notice to you to reflect changes in our personal information practices or relevant laws. We will post a notice on the Site to notify you of any significant changes to our Privacy Statement and indicate at the top of the Privacy Statement when it was most recently updated.

How to Contact Us

If you have any questions or comments about this Privacy Statement, please contact us by email at info@consumeropinioncenter.com or by phone at 1-800-9267-COC (1-800-926-7262).

You also may write to us at:

Consumer Opinion Center
PO Box 2368
Richmond, VA 23218

Effective Date October 2014