Effective date: December 1, 2018

As a visitor or Member of Our Platform, the collection, use and sharing of Your Personal Data is subject to this Privacy Policy and any updates.

Five to Nine operates the Platform. This section informs You of Our policies regarding the collection, use and disclosure of personal data when You use Our Platform and the choices You have associated with that data.

We use Your data to provide and improve the Platform. By using the Platform, You agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Use, accessible from


Personal Data” means data about a living individual or entity that can be identified from those data (or from those and other information either in Our possession or likely to come into Our possession). Personal Data may include, but is not limited to:

  • Email address

  • First name and last name

  • Phone number

  • Address, State, Province, ZIP/Postal Code, City

  • Cookies and Usage Data

  • Transaction information

Usage Data
Usage Data is data collected automatically either generated by the use of the Platform or from the Platform infrastructure itself (for example, the duration of a page visit).

Cookies are small files stored on Your device (computer or mobile device).

Types of Data Collected

Personal Data  
While using Our Platform, We may ask You to provide Us with certain Personal Data. We may use Your Personal Data to contact You with information that We deem may be of interest to You. You may opt out of receiving any, or all, of these communications from Us by contacting Us.

Usage Data
We may also collect information on how the Platform is accessed and used ("Usage Data"). This Usage Data may include information such as Your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Our Platform that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on Our Platform and We hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to Your browser from a website and stored on Your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze Our Platform.

You can instruct Your browser to refuse all cookies or to indicate when a cookie is being sent. However, if You do not accept cookies, You may not be able to use some portions of Our Platform.

Examples of Cookies We use:

  • Session Cookies. We use Session Cookies to operate Our Platform

Use of Data  
Five to Nine uses the collected data for various purposes:

  • To provide and maintain Our Platform

  • To notify You about changes to Our Platform

  • To allow You to participate in interactive features of Our Platform when You choose to do so

  • To provide customer support

  • To gather analysis or valuable information so that We can improve Our Platform

  • To monitor the usage of Our Platform

  • To detect, prevent and address technical issues

  • To support Our decisions in sourcing the right service selection, relationships and tools for You and Your employees

  • To provide insight to employers, vendors and manufacturers about the aggregated data of the services provided on the Platform

  • To provide You with news, special offers and general information about other goods, services and events which we may offer that are similar to those that You have already purchased or inquired about unless You have opted not to receive such information

Transfer of Data  
Your information, including Personal Data, may be transferred to – and maintained on – computers located in the state of Virginia, U.S.A. The data protection laws may differ from those of Your jurisdiction.

If You are located outside United States and choose to provide information to Us, please note that We transfer the data, including Personal Data, to the United States and process it there.

Your use of the Platform or Your submission of such information constitute your consent to this Privacy Policy and represents Your agreement to that transfer.

Five to Nine will take all the steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your Personal Data and other personal information.

Disclosure of Data  

Business Transaction  
If Five to Nine is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Legal Requirements  
Five to Nine may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation

  • Protect and defend the rights or property of Five to Nine 

  • Prevent or investigate possible wrongdoing in connection with the Platform

  • Protect the personal safety of users of the Platform or the public

  • Protect against legal liability

Security of Data
The security of Your data is important to Us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Service Providers  
We may employ third party companies and individuals to facilitate Our Platform (“Service Providers”), provide the Platform on Our behalf, perform Platform-related services or assist Us in analyzing how Our Platform is used. 

These third parties may have access to Your Personal Data only to perform these tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

We may provide paid products and/or services within the Platform. In that case, we use third-party services for payment processing ( “Payment Processors”).

We will not store or collect Your or Your employees’ payment card details. That information is provided directly to Our Payment Processors whose use of  personal information is governed by their privacy policy. These Payment Processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Links to Other Sites  
Our Platform may contain links to other sites that are not operated by Us. If You click a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy
Our Platform does not address anyone under the age of 18 ("Children").

We do not knowingly collect Personal Data from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from children without verification of parental consent, We take steps to remove that information from Our servers.

California Privacy Rights
Users residing in certain jurisdictions, like California, have a right to access Personal Data held by Us about them and their right of access can be exercised in accordance with applicable law. California law requires certain businesses to respond to requests from California residents asking about the business’ practices related to disclosing Personal Data to third parties for the third parties’ direct marketing purposes. Alternatively, such businesses may have in place a policy not to disclose Personal Data of customers or clients to third parties for the third parties’ direct marketing purposes if the resident has exercised an option to opt-out of such information sharing. We have such a policy in place.

California residents may request further information about our approach to this law by writing to Us. When writing to Us, you must include any relevant information (like Your name, contact information, any Member number or unique site identifier associated with You) in order to assist in Your request. Please allow 30 days for a response.

Changes to This Privacy Policy  
We may update our Privacy Policy from time to time. We will notify You of any changes by emailing You the new Privacy Policy and/or posting the updated Privacy Policy within the Platform website prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us  
If you have any questions about this Privacy Policy, please contact Us:

  * By email: [email protected]