Privacy Policy

This Privacy Policy will address the following points:

What information, if any, is collected as a result of your

Whether Cookies are placed on your hard drive

Whether information is shared

Information Security

Data Integrity

Accessing and updating personal information

Policy Changes

Contact Information


Information Collection

As is true of most websites, we gather information
automatically and store it in log files. This information includes internet
protocol (IP) addresses, browser type, internet service provider (ISP),
referring/exit pages, operating system, date/time stamp, and click-stream data.
We use this information, which does not identify individual visitors, to
analyze trends, to administer the website, to track visitors’ movements around
the site and to gather information about the geographic location of our
visitors as a whole.

Additionally, when a Customer sets up an account with Smart
Miles, Inc., we collect Personally Identifiable Information (“PII”)
about them. This information may include name, contact information, account
password, and for certain services, credit card or other payment account
information, which we maintain in encrypted form on secure servers.



A “cookie” is a small file containing a string of
characters that is sent to your computer when you visit a website. When you
visit the website again, the cookie allows that site to recognize your browser.
Cookies may store user preferences and other information. You can reset your
browser to refuse all cookies or to indicate when a cookie is being sent.
However, some website features or services may not function properly without

Smart Miles, Inc. uses cookies to enhance your online
experience and to learn about how you use our services in order to improve the
quality of our services. Our servers automatically record information when you
visit our website, including the URL, IP address, browser type and language,
and the date and time of your request.


Sharing of Information

Other than for the limited circumstances below, none of the
information detailed above is disseminated, shared, sold, or provided to a
third party. We may share PII and other data with other companies or entities
in the following limited circumstances:

Where we have a good faith belief that access, use,
preservation or disclosure of PII is reasonably necessary to (a) satisfy any
applicable law, regulation, legal process or enforceable governmental request,
(b) enforce applicable legal agreements between us, including investigation of
potential violations thereof, (c) detect, prevent, or otherwise address fraud,
security or technical issues, or (d) protect against imminent harm to the
rights, property or safety of Smart Miles, Inc., its users or the public as
required or permitted by law.

If Smart Miles, Inc. becomes involved in a merger,
acquisition, or any form of sale of some or all of its assets (note: we will
provide notice before PII is transferred and becomes subject to a different
Privacy Policy).

Information Security

We take appropriate security measures to protect against
unauthorized access to or unauthorized alteration, disclosure or destruction of
data. These include internal reviews of our data collection, storage and
processing practices and security measures, as well as physical security
measures to guard against unauthorized access to systems where we store
personal data. We restrict access to PII to Smart Miles, Inc. employees,
contractors and agents who need to know that information in order to operate,
develop or improve our services. These individuals are bound by confidentiality
obligations and may be subject to discipline, including termination and
criminal prosecution, if they fail to meet these obligations.


Data Integrity

Smart Miles, Inc. processes PII only for the purposes for
which it was collected and in accordance with this Policy or any applicable
service-specific privacy notice. We review our data collection, storage and
processing practices to ensure that we only collect, store and process the
personal information needed to provide or improve our services. We take
reasonable steps to ensure that the personal information we process is
accurate, complete, and current, but we depend on our users to update or
correct their personal information whenever necessary.


Accessing and Updating Personal Information

When you use Smart Miles, Inc. services, we make good faith
efforts to provide you with access to your PII and either to correct this data,
if it is inaccurate, or to delete such data at your request, if it is not
otherwise required to be retained by law or for legitimate business purposes.
We ask individual users to identify themselves and the information requested to
be accessed, corrected or removed before processing such requests, and we may
decline to process requests that are unreasonably repetitive or systematic,
require disproportionate technical effort, jeopardize the privacy of others, or
would be extremely impractical (for instance, requests concerning information
residing on backup tapes), or for which access is not otherwise required. In
any case, where we provide information access and correction, we perform this
service free of charge, except if doing so would require a disproportionate


Policy Changes

We reserve the right to modify this Privacy Policy at any
time. If we decide to change our Privacy Policy, we will post those changes in
a conspicuous manner to this Privacy Policy, and other places we deem
appropriate, so that you are aware of what information we collect, how we use
it, and under what circumstances, if any, we disclose it.


Contact Information

If you have any questions or suggestions regarding our
Privacy Policy, please contact us at: