Effective Date: November 12, 2014.
This Website User Privacy Policy (“WPP”) applies to ESE Holdings, LLC. (“ESE”) and those persons (hereinafter referred to as “You” or “Yourself”) who use of this website (www.esenetworks.com) and any variations or successors to this website (the “ESE Site”) solely in connection with Your use of the ESE Site.  This WPP only covers electronic data that ESE collects through the ESE Site and does not apply to (i) any other data collection or processing, including, without limitation, data collection practices by any non-ESE owned web pages to which the ESE Site may link, or (ii) any data that ESE and/or ESE’s agents, partners and/or affiliates collect offline or in connection with web sites, products, and/or services that do not display a direct link to this WPP.  By accessing and/or utilizing the ESE Site, You are accepting the current version of this WPP as posted at www.esenetworks.com  at that time.


A. WHAT INFORMATION ESE COLLECTS FROM YOU


This clause describes two types of information about You that ESE may collect in connection with your use of the ESE Site:  1. “Personal Information.  “Personal Information refers to information containing the specifics of who You are and how you can be contacted or located  (e.g. name, mailing address, telephone number, and e-mail address). ESE may collect Personal Information when You use the ESE Site including, without limitation, filling out surveys, corresponding with ESE, and otherwise volunteering information about Yourself.  2. “Non-Personal Information.” Non-Personal Information refers to information that, by itself, does not identify You as a specific individual (e.g. demographic information, website visitation records).  ESE may collect Non-Personal Information through any of the methods discussed above as well as automatically through Your use of certain technologies described in this WPP.


B. HOW ESE COLLECTS YOUR INFORMATION


This clause describes methods pursuant to which ESE may collect Personal Information and Non-Personal Information from You.  1. Contact Through the ESE Site.  ESE may require certain Personal Information and Non-Personal Information in order to contact You (“Contact Details”) following Your submission of a request to ESE, for example in connection with the ESE Site’s Contact Us web page.  Failure to provide all Contact Details required by ESE may prevent ESE from responding to your request.  2.  Information Collected Through Technology.  While You are able to visit the ESE Site without providing Contact Details, ESE or its third party service providers may still collect Non-Personal Information about Your use of the ESE Site (including, without limitation, Your internet browser, operating system, IP address, connection speed, and/or the domain name of Your internet service provider). Such information may be gathered by the following methods: (a) IP Address. ESE may automatically collect Your IP address when you visit the ESE Site. An IP address is a number that is automatically assigned to Your computer, laptop or other device (“Device”) whenever You begin utilizing an internet service provider (“IP Address”). Each time You access the ESE Site and each time You request one of ESE’s web pages, ESE’s servers may receive and log Your IP Address. (b) Cookies and Web Beacons. Cookies, including local shared objects, are small pieces of information that are stored by Your internet browser on Your Device’s hard drive which work by assigning to Your Device a unique number that has no meaning outside of the ESE Site (“Cookies”).  Cookies do not generally contain any Personal Information.  Most internet browsers automatically accept Cookies, but You may be able to configure Your internet browser to prevent this. Not accepting Cookies may make certain features of the ESE Site unavailable to You.  Web beacons are small pieces of data that are embedded in web pages and e-mails. ESE may use the foregoing methods in HTML e-mails that ESE sends to You to determine whether You have opened such e-mails and/or clicked on links in such e-mails (“Web Beacons”).  The information from use of these technical methods may be collected in a form that is Personal Information. ESE may also use information from Cookies and Web Beacons to learn about Your visits to the ESE Site and/or analyze such information to help us understand traffic to the ESE Site and to improve the ESE Site.   Such information may, for example, include: the date and time You visit the ESE Site, the areas or pages of the ESE Site that You visit, the amount of time You spend viewing the ESE Site, the number of times You return to the ESE Site, other click-stream data, and/or other automatically collected data.  Do Not Track Disclosure. Your web browser and/or other tracking opt out services that You use may (or may be configured to) send signals to the ESE Site requesting that the ESE Site does not collect Personal Information and/or Non-Personal Information from You (“Do Not Track Signals”).  Please be advised that ESE and ESE’s third party providers do not honor Do Not Track Signals and will continue to collect Personal Information and Non-Personal Information in accordance with this WPP.  If the foregoing is of concern to You, ESE suggests that You refrain from visiting the ESE Site.


C. HOW ESE USES YOUR INFORMATION


This clause describes how ESE may use information collected from You.  1. System Administration.  ESE may use Personal and Non-Personal Information in furtherance of provisioning the ESE Site (including without limitation administering, protecting, and improving the ESE Site).  2. Personalization. ESE may use Cookies, Web Beacons and/or IP Addresses to track your navigation and/or other use of the ESE Site (including without limitation any video player contained therein) for marketing or other purposes in ESE’s sole discretion.  3. Promotional E-mails. ESE may use Your Personal Information to send You e-mails containing promotions or events relating to ESE or from ESE’s business and/or marketing partners or sponsors.  You may opt-out of receiving such promotional e-mails by sending an e-mail to info@esenetworks.com and/or following the instructions contained in ESE’s email response (if any).  Once ESE has processed Your opt-out request, ESE will not send You promotional e-mails unless You opt back in to receiving such communications. 4. Contact Information.  If You contact ESE by telephone, e-mail, letter or via the ESE Site’s Contact Us page or such similar web page accessible through the ESE Site, ESE may keep a record of Your contact information and correspondence.  If You report a problem with ESE, ESE may collect this information in a file specific to You.  5. Combining Data.  To the extent permitted by applicable law, ESE may combine the various types of data that ESE collects with other data that we collect from You.


D. HOW TO ACCESS AND CHANGE YOUR PERSONAL INFORMATION


Upon Your request, (i) ESE will permit You to update or correct Personal Information previously submitted, but only to the extent such activities will not compromise privacy or security interests, and (ii) ESE will, to the extent commercially reasonable within ESE’s existing system and internal policies, delete Personal Information from ESE’s database where such information is stored; however, You understand and agree that it may be impossible to entirely delete entries without some residual information being retained due to the manner in which data backups are maintained. You agree to submit all requests to update, correct and/or delete Personal Information solely to info@esenetworks.com.


E. WHERE ESE STORE AND PROCESS DATA


ESE and/or its agents, partners and/or affiliates store data collected in connection with the ESE Site on servers located around the world in various locations including, without limitation, parts of the United States of America, Asia and the European Economic Area.


F. DISCLOSURE OF INFORMATION TO THIRD PARTIES


ESE does not sell, trade or rent Personal Information collected through the ESE Site to any third party and does not disclose Your Personal Information except as follows: ESE may (1) disclose Personal Information upon receipt of a court order, subpoena, to cooperate with a law enforcement investigation or to enforce this WPP; (2) share or transfer Personal Information in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of ESE’s business; and (3) share or transfer Your Personal Information to ESE’s agents, partners, and affiliates.  In addition, ESE reserves the right to fully use and disclose any Personal Information that ESE collects via the ESE Site that is not in personally identifiable form.


G. SAFEGUARDING YOUR PERSONAL INFORMATION


This clause describes methods that ESE utilizes in connection with information provided by You in connection with use of the ESE Site as well as responsibilities that You have to protect Your information.  1. Security Measures.  Transmissions over the internet are never completely secure or error-free.  However, ESE in its sole discretion undertakes certain security measures aimed at to protecting against unauthorized access, alteration, disclosure or destruction of Personal Information.  2. Third Party Links. The ESE Site may contain links to third parties who may collect Personal Information and Non-Personal Information directly from You. Additionally, ESE may use third parties to provide components or portions of the ESE Site. In either case, such third parties may have separate privacy policies and data collection practices, independent of ESE, and in all cases ESE: (a) has no responsibility or liability for any such third party policies or actions; (b) is not responsible for the privacy practices or the content of such third parties or their websites; and (c) does not make any warranties or representations about the website, products or services offered by such third parties or the security of any information that You provide to them.  It is Your responsibility to determine whether You will utilize and/or access any such third party links that may appear on the ESE Site.


H. CHANGES TO THE WPP


ESE continually strives to implement new technologies and processes in connection with the ESE Site. As a result, changes to this WPP may be made by ESE from time to time. ESE recommends that You revisit this WPP on occasion to learn of any changes. 


I. CONTACT ESE


If You have any questions about this WPP, please contact ESE Holdings, LLC by sending a letter or e-mail to: ESE, Inc. Attn: Privacy 1523 Old Valdosta Road, Ray City, GA 31645 or info@esenetworks.com.