Last Updated and Effective: June 20, 2016

This privacy policy (“Privacy Policy“) applies only to the data collected by the Belcom Corp, Belcom North America LLC and Endpoint Marketing Solutions LLC, an affiliate of Belcom Corp. (“Belcom”), both offline and online, including through the Brandoodles Members Club Program (“BMC”), the Belcom Rewards Website (http://hookedonbrands), the Brandoodles (Belcom) mobile applications, the Brandoodles website (, and any other websites, web pages, interactive features, applications, widgets, blogs, social networks, social network “tabs,” alternative reality worlds, and other online or wireless offerings that post a link to this Privacy Policy, whether accessed via computer, mobile device or other technology (collectively, “Properties”). The websites and properties of affiliated Belcom companies, including some that are linked to/from the Properties, may have different privacy policies; therefore, please review the privacy policy notices on those websites or properties if you visit them.

This Privacy Policy explains the data that Belcom may collect when you interact with us and our practices with respect to that data. Please read this Privacy Policy carefully. In addition, please review the Belcom (Brandoodles) Rewards Terms of Use, which govern your use of the BMC Program, the Belcom Rewards Website, the Belcom Rewards mobile applications and the Belcom Terms of Use, which govern your use of the Brandoodles website (

Collection of Data:

Data You Provide To Belcom

We may ask you to provide data that could reasonably be used to contact you or to identify you personally (such as first and last name, e-mail address, mailing address, telephone number, mobile phone number, photos of both people and objects, and videos) (“Personal Data“). In the event that you provide us with photos, such photos may include metadata which can indicate data about the photos, including but not limited to, where and when the photo was taken. If you choose not to provide this data, you may not be able to participate in the BMC Program, the Properties or a particular feature we offer. We may also ask you to provide other data about yourself, such as demographic data (such as gender, zip code, age, etc.) or payment data or certain data about your preferences and interests. If we combine demographic or other data we collect about you with Personal Data about you, we will treat the combined data as Personal Data. Please note that data submitted to the Properties via a “contact us” or other similar function may not receive a response.

The BMC Program and the Properties are open only to individuals who are 13 years of age and older. We do not knowingly seek or collect data from persons younger than 13 years of age. If we learn that we have inadvertently collected Personal Data from a person younger than 13 years of age through the Properties, we will take reasonable measures to delete such data from our records.

Data Belcom Collects Automatically

In addition to any data, including Personal Data, that you choose to submit to the Properties, whenever you visit or interact with the Properties or our content, Belcom, as well as any third party analytics providers or other service providers, may use a variety of technologies that automatically or passively collect data about how the Properties are accessed and used (“Usage Data“). Usage Data may include, without limitation, browser type, operating system, the page served, time on the Properties, and the preceding page views. Usage Data is generally non-identifying, but if Belcom associates it with you as a specific and identifiable person, we will treat it as Personal Data.

Belcom may also automatically collect your IP address or other unique identifiers (“Device Identifiers”) for the computer, mobile device, technology or other device (collectively, “Devices”) you use to access the Properties. A Device Identifier is a number that is automatically assigned to your Device when you access a property or its servers, and our computers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third-party service providers with data regarding the physical location of the Device used to access the Properties.

The technologies used on the Properties to collect Usage Data, including Device Identifiers, include:

Cookies. A cookie is a data file placed on a Device when it is used to visit the Properties or otherwise access our online content. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our Properties. If you choose to disable cookies on your Device, some features of the Properties or our content may not function properly.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”), may be included in the Properties and our e-mail messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Properties, to monitor how users navigate the Properties, to count how many e-mails that were sent were actually opened or to determine whether content sent was actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect data about your interactions with the Properties, such as the links you click on. The code is temporarily downloaded onto your Device from our server or a third party service provider, is active only while you are connected to the Properties, and is deactivated or deleted thereafter.

Please note that third parties may collect Personal Data about your online activities over time and across different websites when you visit or use our Properties or other online websites and services. For example, some third parties’ embedded content or plugins on the Properties, such as social media sharing tools, allow their operators to learn that you have visited or interacted with our Properties, and they may combine this data with other, identifiable data they have collected about your visits to other websites or online services. These third parties may handle this data, and other data they directly collect through their content and plugins, pursuant to their own privacy policies.

Data We Receive from Third Parties

Belcom may receive data about you from third parties. For example, if you choose to apply for a Belcom (Brandoodles) branded debit card we may receive data about you, from an issuing bank (proposed), which may include Personal Data as well as data regarding how you use the Belcom (Brandoodles) branded credit card. In addition, if you are on another property and you opt-in to receive data from us, that property may forward to us your e-mail address and other data about you so that we may contact you as requested. We may also supplement the data we collect about you with outside records from third parties in order to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to purchase products or services that we believe may be of interest to you. We may combine the data we receive from these third parties with data we collect. In those cases, we will apply this Privacy Policy to any Personal Data received, unless we have disclosed otherwise.

Social Media Applications

Functionality on the Properties may permit interactions between such Properties and third party properties, such as Facebook and Twitter. Such functionality enables you to “like” a product or online content, “share” content to other properties, otherwise link the Properties with another property, and also, to log into the Properties from such third party websites in some instances. If you choose to “like” or “share” content or to otherwise post data from or via the Properties to a third party property that information will become public and the third party property will have access to information about you and your use of the Properties.

You may also choose to participate in a third party application or feature (such as one of our Facebook applications or a similar application or feature on a third party property, logging in through Facebook Connect, or otherwise linking the Properties with another property) through which you allow us to collect (or the third party to share) data about you, including Personal Data. When you choose to participate, you may be opting to link your activity on our Properties with that third party property, which may then collect data about your visits to our Properties and may publish that activity as you request to your “profile” or similar feature with that third party (such as if you choose to share content you find on one of our Properties with your “connections” on the third party’s property). The data we collect is subject to this Privacy Policy. However, the data collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us or with other third parties, the types of information shared, and your choices with regard to what is visible to others on that third party’s property. The third party may allow you to remove an application or feature, in which case we will no longer collect data about you through the application or feature, but we may retain the data previously collected. In addition, we may receive data about you if other users of a third party property give us access to their profiles and you are one of their “connections” or data about you is otherwise accessible through your “connections’” web page, profile page, or similar page on a social networking site or other third party property.

How Belcom Uses The Data It Collects and Your Choices

Belcom will use the data it collects, including your Personal Data, (i) to process and allow your registration and participation in the Brandoodles Members Club Program (BMC), and other features we offer, including, at times, to verify that the e-mail address you provide is active and valid, (ii) to tailor the content, advertisements, and offers you see and to determine which products we offer might interest you, and (iii) to provide you with data about your account and products, services, promotions, or offerings that may be of interest to you. We may also use the data we collect to improve the Properties and our products and services; for internal business purposes; to contact you with regard to your use of the Properties, your account, and, in our discretion, changes to any of our policies; for purposes disclosed at the time you provide your Personal Data; or otherwise with your consent.

You may be able to indicate your contact preferences at the time you register to join the BMC. You may also update your preferences by visiting the “Preferences” section of the “My Account” tab of the or, or the “Email Notification Preferences” section of the “My Account” tab of the Website. In addition, you may opt out of receiving marketing emails by following the opt-out instructions provided to you in those e-mails. If you sign up to receive SMS or MMS messages that may be offered by Belcom, you may unsubscribe from any SMS or MMS messages received by replying “STOP”. Please note that even if you opt out and/or unsubscribe, we reserve the right to send you certain communications relating to your account or use of the Properties and these transactional account messages may be unaffected by your choice to opt-out from marketing communications. In accordance with our routine record keeping, we may delete certain records that contain Personal Data you have submitted through the Properties or otherwise. We are under no obligation to store such Personal Data indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Data. In addition, you should be aware that it is not always possible to completely remove or delete all of your data from our databases without some residual data because of backups and other reasons.

When and with Whom Belcom May Share Data Collected

California residents, please see the section below regarding your California privacy rights.

We may share non-Personal Data, such as aggregate user statistics, demographic information, and Usage Data with third parties for a variety of purposes, including tailoring Belcom (Brandoodles) promotions, advertising and communications we present to you.

We may also share your data, including your Personal Information, as disclosed at the time you provide your information, as set forth in this Privacy Policy and in the following circumstances:

When You Consent to Have Your Personal Data Shared or Otherwise Request That We Share Your Data. We or affiliated or related Belcom companies may offer you the opportunity to receive information and/or marketing offers from third parties or to otherwise consent to the sharing of your information with a third party. If you agree to have your Personal Information shared (either by opting in or choosing not to opt-out), your Personal Information will be disclosed to the third party and the Personal Information you disclose will be subject to the privacy policy and business practices of that third party. If you consent to receiving communications from third parties, you will need to communicate with them directly if you later decide that you no longer wish to receive their communications.

You also may request, sometimes through your use of an interactive feature or third party application, that we share information about you with a third party and we will typically do so under those circumstances.

Third Parties Providing Services On Our Behalf. We may from time to time employ third parties to perform functions on our behalf; examples include hosting or operating the Properties; sending e-mail, mobile message communications, and other communications; providing customer support; executing IVR programs; and performing data analysis. We may share Personal Information with third parties in order for them to provide content, complete a requested transaction or otherwise perform services for Belcom. We and our affiliated or related Belcom companies may also share your Personal Information with third party advertising partners and with co-promotion partners.

Belcom. We may share your Personal Information within and among entities affiliated with or related to us, that are in the Belcom family, and with other companies that use the Belcom (Brandoodles) brand, some of which are outside the scope of this Privacy Policy, for any purpose, including but not limited to, (i) providing you with or contacting you about, content, products, services or other offerings, such as games, videos, music, software and software applications, and in order to contact you about auditions for television shows; (ii) business development; (iii) community administration or development; (iv) to support various business processes; (v) for security; (vi) for research and development; and (vii) to enable us to link your accounts and usage information between and amongst certain Belcom Properties. We may also share your Personal Information as indicated above so that other affiliated or related Belcom companies may use your information in connection with any of the purposes described above in the Section entitled “How Belcom Uses the Information it Collects.” If required by law, we will obtain your consent for such sharing. Affiliated companies using the Belcom (Brandoodles) brand but that do not use this Privacy Policy, will handle your information in accordance with their own privacy policies, the terms of which may be different than this Privacy Policy.

Business Transfers. Belcom or any of its assets, including the Properties and the Brandoodles Members Club (BMC) Program database and the Brandoodles database, may be sold, or other transactions may occur in which your Personal Information is one of the key business assets for the transaction. In such a case, your Personal Information may be one of the business assets we transfer. Hence, Belcom and affiliated and related Belcom companies reserve the right to disclose and transfer user information, including Personal Information in connection with a corporate merger, consolidation, restructuring, reorganization, the sale of certain stock and/or assets, or other corporate change including, without limitation, during the course of any due diligence process.

Legal Protections and Law Enforcement. We may transfer and disclose information, including your Personal Data, Usage Data and Device Identifier (including IP address), to third parties: to comply with a legal obligation; to prevent fraud; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce Belcom Terms of Use or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Properties or the public. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies, in our discretion. Such disclosures may be carried out without notice to you.

Sweepstakes, Contests and Promotions. We, our affiliated or related Belcom companies, and our third party partners may offer sweepstakes, contests, and other promotions (each, a “Promotion”) that may require registration. If you choose to enter a Promotion, your Personal Data may be disclosed to third parties in connection with the administration of such Promotion, such as in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list. By entering a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.

Brandoodles Members Club. In order to participate in the Brandoodles Members Club, you must provide registration information, which in some instances includes providing us with a picture and/or video. If you choose to provide such information, you are agreeing that Belcom may disclose such information to affiliated and related Belcom companies as discussed above, and to such companies as well as third parties in connection with the advertisement, marketing and promotion of Brandoodles and related programs.

Co-Promotion Partners: The Properties may offer opportunities to enter a contest or sweepstakes or other feature that we offer jointly with a third party. As a result of your participation in such feature, your information may be shared by us or our affiliated or related Belcom companies with the third party that is jointly offering the feature, which will be disclosed at the time your information is collected.

Information You Disclose Publicly on Our Properties. Our Properties may offer message boards, chat rooms, alternative reality games, multi-player games and other public areas (collectively, “Open Forums“) where you can engage in social networking, interact with others, as well as have the opportunity to submit photographs, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Data (collectively, “User Submissions“). To participate in certain Public Forums, you may be asked to select a username, screen name or member name and password. Please do not use your real name or the real name of another person when selecting a username (or screen name or member name).


Note that anything you post to an Open Forum is public — others will have access to your User Submissions and may use that information or share it with third parties. Information you choose to post or make available in the Open Forums may be viewed, collected and used by others. If you choose to voluntarily disclose User Submissions, the protections of this Privacy Policy will not cover such disclosure of information. Think carefully before you post and use caution before disclosing any Personal Information.

User Submissions may be published online or offline in any media or format (currently existing or hereafter developed). We may also publish your name, voice, likeness and other Personal Information with your User Submissions, and Belcom may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities.

Notice to California Residents

Your California Privacy Rights: Pursuant to California Civil Code Section 1798.83, some affiliated or related Belcom companies only share Personal Information with third parties for those third parties’ direct marketing purposes if you specifically opt-in or are offered the opportunity to opt-out and elect not to opt-out from such sharing at the time you provide Personal Information or at the time you choose to participate in a feature. If you do not opt-in or if you opt-out at the applicable time, those affiliated or related Belcom companies do not share your information with those identified third parties for those third parties’ own direct marketing purposes. If you are a California resident, and Belcom or the affiliated or related Belcom company with whom you are dealing does not have a policy of providing choices regarding certain kinds of sharing, as described above, you have the right to receive from Belcom or the relevant affiliated or related Belcom company: (a) information identifying any third party(ies) to whom Belcom or the relevant related or affiliated Belcom company may have disclosed, within the preceding calendar year, your Personal Information for that third party’s own direct marketing purposes; and (b) a description of the categories of Personal Information disclosed. If you are a California resident, to obtain information free of charge regarding our compliance with this law, please write to us at Belcom Corp., 180 N. Stetson Street, Suite 3500, Chicago, IL 60601 USA or submit your request via email at

(Requests that come to Belcom by other means may result in a delayed response.) You must put the statement “Your California Privacy Rights” in the subject field of your e-mail or letter. You must include your name, street address, city, state, and zip code. We are not responsible for requests that are not labeled or sent properly, or do not have complete information. Please note that we are only required to respond to one request per customer each calendar year. Belcom will respond to these requests within thirty (30) days.

California Online Privacy Protection Act Notice: Some web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. How browsers communicate the Do Not Track signal is not yet uniform. For this reason, our Properties do not currently interpret, respond to or alter their practices when they receive Do Not Track signals or other mechanisms that provide consumers with the ability to exercise choice regarding the collection of personally identifiable information about an individual user’s online activities over time and across third-party web sites or online services. To find out more about “Do Not Track,” you may wish to visit

Security; Retention and Monitoring

Unless otherwise required by law, we are not responsible for monitoring or recording any activity on the Properties, including communications, although we reserve the right to do so.

To help protect you and others, we monitor use of the Properties, and we use the Personal Information and other information we collect, in order to: identify fraudulent activities and transactions; prevent abuse of and investigate and/or seek prosecution for any potential threats to or misuse of the Properties; ensure compliance with the applicable terms of service and this Privacy Policy; investigate violations of or enforce these agreements; and otherwise to protect the rights and property of us, our partners, and customers. Monitoring may result in the collection, recording, and analysis of online activity or communications through the Properties. If you do not consent to these conditions, you must discontinue your use of the Properties.

We seek to maintain reasonable security measures designed to help protect your information against unauthorized or accidental disclosure, access, misuse, loss, or alteration. There is no such thing as perfect security. Although we strive to protect your information, we cannot ensure or warrant the security of such information.

We may retain information about you as long as it is necessary for us to fulfill the purposes outlined in this Privacy Policy. In addition, we may retain your information for an additional period as is permitted or required to, among other things, comply with our legal obligations, resolve disputes, and enforce agreements. Where and when required by applicable law, we shall delete your information. Even if we delete your information from active databases, the information may remain on backup or storage media.

Consent to Processing

The Properties are operated in the United States. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Properties, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

Third Party Content, Links to Other Properties and Services, and Belcom Content on Other Websites

Certain content on the Properties may be hosted and served by third parties, which may include third party widgets (such as those that allow you to “like” or “share” content with third party websites and interactive services). In addition, when you are on the Properties you may be directed to other websites that are operated and controlled by third parties that are beyond our control. This includes links from advertisers, sponsors and partners that may use our logo(s) as part of a co-branding agreement. In addition, Belcom content and widgets may be included on web pages and websites that are not associated with us and over which we have no control. These other websites may send their own cookies to your Device, and they may independently collect data or solicit Personal Information. Belcom is not responsible for the privacy practices of any third party.

Ad Serving and Traffic Measurement Services We May Use

Belcom licenses technology to serve advertisements on its Properties and within its videos and other content as that content is served across the Internet. In addition, Belcom may use third party network advertisers to serve advertisements on the Properties and third party analytics service providers to evaluate and provide us with information about the use of the Properties and viewing of our content. We do not share Personal Information with these third parties, but ad network providers, the advertisers, the sponsors, and/or analytics service providers may set and access their own cookies, web beacons and embedded scripts on your Device from our Properties which may collect Personal Information or other information about your use over time of the Properties and other third party websites or applications and they may otherwise collect or have access to information about you, including Usage Data.

With regard to advertisements, we and our network advertisers may target advertisements for products and services in which you might be interested based on your visits to both the Properties and other websites. Cookies and web beacons, including those set by third party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, or conduct research regarding the usefulness of certain advertisements to you.

We may share Usage Data about visitors to the Properties with third party advertising companies for the same purposes. We may use a variety of companies to serve advertisements.

Policy Governs Use: Changes to Privacy Policy

Belcom reserves the right to change this Privacy Policy at any time, without prior notice to you, and any changes will become effective immediately upon posting, so please review this Privacy Policy periodically. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Properties prior to the change becoming effective.


If you have any questions or comments about our practices regarding Personal Information or about this Privacy Policy, please write to us at Belcom Corp., 180 N. Stetson St., Suite 3500, Chicago, IL 60601 USA or submit your request via