GACO Corporation, an Arizona limited liability company which owns and operates the www.virtualheadacheclinic.com web site, respects the privacy of each user of our web site. GACO Corporation, is a licensee of the TRUSTe Privacy Program. This privacy statement discloses the privacy practices for the www.virtualheadacheclinic.com Web site.

If you have any questions or concerns regarding this statement, you should first contact rcowan@virtualheadacheclinic.com. You can also contact us via regular mail at: GACO Corp 3331 Calle del Montana, Sedona, AZ 86336.

If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact TRUSTe at http://truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with the Web site to resolve your concerns.

Notification by our Web Site

By applying for the TRUSTe trustmark, the www.virtualheadacheclinic.com web site has agreed to notify each user of the following:

1. What personal information of yours or a third party is collected from you by the www.virtualheadacheclinic.com web site.
2. The name of the organization collecting such information.
3. How the information is or may be used.
4. With whom the information may be shared.
5. What choices are available to you regarding the collection, use and distribution of such information.
6. The security procedures that are in place to protect the loss, misuse or alteration of the information which is under the control of www.virtualheadacheclinic.com.
7. How you can correct any inaccuracies in the information.

Information Collection and Use

The www.virtualheadacheclinic.com web site collects information from our users at several different points on our web site. When you use the web site, some basic, general information is collected. This general information is used internally in connection with our business to improve the web site, including our marketing and advertising efforts, and to make your use of the web site as enjoyable and efficient as possible.

When you set up an account on our web site or purchase an item from our web site, we collect personal information provided by you that may include your: (i) first and last name; (ii) billing address; (iii) shipping address; (iv) other shipping addresses; (v) email address; (vi) phone number; (vii) credit card account number; (viii) items purchased from us; and (ix) browsing, buying and selling patterns. We use this personal information in order to provide you with the goods and services that you purchase on our web site. We use your email address to provide you with information about your order and its status and we may occasionally send out emails, including newsletters, to people who have placed an order on-line, with information about other goods and services available on our web site. Your phone number is used by us only in the event that our customer service representatives need to contact you about an order you have placed.

GACO Corp owns and operates the www.virtualheadacheclinic.com web site and is the sole owner of this information collected on the web site. We will not sell, share, or rent this information to a third party in any way other than as disclosed in this privacy policy. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities and may, in our sole discretion, disclose personal information or other information to satisfy any law, regulation, subpoena, or government request. We reserve the right to release personal information or other information about users who we believe are engaged in illegal activities or are otherwise in violation of our Terms of Service, even without a subpoena, warrant or court order, if we believe, in our sole discretion, that such disclosure is necessary or appropriate to operate our web site or to protect the rights or property of www.virtualheadacheclinic.com, our affiliates, or our officers, directors, employees, agents, third-party content providers, suppliers, sponsors, or licensors. We also reserve the right to report to law enforcement agencies any activities we reasonably believe in our sole discretion to be unlawful. If we are legally compelled to disclose information about you to a third party, we will attempt to notify you by sending an email to the email address in our records unless doing so would violate the law or unless you have not provided your email address to us.

Registration

To use some features on the www.virtualheadacheclinic.com web site, a user must first complete a registration form on the web site. During registration, a user is required to give contact information, such as name and email address. This information is used to contact users about the services on our web site for which they have indicated interest. It is optional for users to provide additional, demographic information, such as age and gender, but we encourage our users to provide such information so that we can provide a more personalized experience for our users on our web site.

Orders

We request additional personal information from our users when placing an order on our web site. In completing our order form, a user must provide contact information, such as name and shipping address, and financial information, such as credit card account number and expiration date. This information is used for billing purposes and to fulfill our customer orders. If we experience difficulties processing an order, we will contact a user through this information.

Cookies

A cookie is a text file stored on the user’s hard drive containing information about the user. Web sites create cookies to record information about a user’s preferences, such as the items you add to your shopping cart, and for security purposes (see Security below). Cookies are also used to help us determine the various services you use and the support you may need, and to help us detect and solve any problems you may have while using our web site. In addition, the use of a cookie on our web site will enable users to log on without having to reenter their password on each visit and to fully participate in the website’s services Most cookies expire after a certain time period. If you wish, you may set your browser to reject all cookies and still view our web site. Cookies placed by virtualheadacheclinic.com are not tied to any personally identifiable information.

Log Files

Like most standard web sites, we use log files on our servers. These log files store information regarding IP (internet protocol) addresses, browser type, ISP (internet service provider), referring/exit pages, platform type, date/time stamp, and number of clicks. These log files are used to analyze trends, administer the web site, track user’s movements in the aggregate, and gather broad demographic information for our use. IP addresses, etc. are not linked to personal information.

Sharing of General or Demographic Information

We will share aggregated, general or demographic information we collect about our users and their use of our web site with our partners (except where noted for specific co-branded relationships below) and advertisers in a manner which does not identify any individual user. We use an outside shipping company to ship orders placed on our web site, and a credit card processing company to bill users for goods and services purchased on our web site. These companies will not retain, share, store or use any of our user’s personal information for any secondary purposes. We may partner with other parties to provide specific services which are available on our web site. When a user signs up for these services, we will share the user’s name or other contact information that is necessary for the third party to provide these services to the user. These parties are not allowed to use such personal information except for the purpose of providing these services.

Co-Branded Relationships

GACO Corporation partners with DrPacheco.com for the non-headache-related health products and services. No personal information of users from www.virtualheadacheclinic.com is shared with DrPacheco.com. DrPacheco.com does share with GACO Corporation a user's email address and whether or not the users have taken advantage of their products and services. DrPacheco.com also shares aggregate purchase information with GACO Corporation for the purpose of determining revenue share. They do not share the details of a user's personal information except in aggregate so that products and services can be improved over time.

The Virtualheadacheclinic.com provides links to several sites, including site(s) that identify headaches specialists or physicians with an interest in headache by region. Virtualheadacheclinic.com is not responsible for the content available via these links and does not make any representations regarding their content or accuracy. Your use of these links is at your own risk and is subject to the terms and conditions of found on those sites.

GACO Corporation may partner from time to time with sites to sell books, CD's and tapes. GACO Corporation does not pass any personal information to these entities and no personal information is shared by them back to GACO Corp. They may share aggregate purchase information with GACO Corp for the purpose of determining revenue share.

Links

The web site contains links to other web sites. We want you to be aware that when you click on such links, including banner advertising, which take you to a third-party web site, you will be subject to such third-party’s privacy policies. Please be aware that we are not responsible for the privacy practices of such other web sites and we expressly disclaim any and all liability for the actions of third-parties, including, without limitation, actions relating to the use and/or disclosure of personal information by such third-parties. We encourage our users to be aware of when they leave our web site and enter a third-party web site and to read the privacy statements of each and every web site that collects their personal information. This privacy policy applies solely to information collected by our web site.

Newsletters

If a user wishes to subscribe Migralogue or other periodic newsletters, we will ask for contact information, such as name and email address.

Send to a Friend

If a user elects to use our referral service to inform a friend about a part of our web site, a form asks for the friend's name and email address. The form will automatically send the information to the friend via email. We do not store this information and the form is only used to send this one-time referral email.

Electronic Communication with virtualheadacheclinic.com

It is possible to email directly to various persons at virtualheadacheclinic.com. However, for certain communications at designated membership levels, you will be asked to sign in with your member login information. We do not use this information in any way other than to recognize you for postings nor do we disclose this information to any third parties.

With regard to the "Ask Dr. Cowan" feature, your name may be used if your question has been selected for use in the "Q & A" section of the website or Migralogue. If you do not wish your name used, our Editors can, at their discretion, omit this information from the posted Q&A if you elect to remain anonymous and so request in the body of your submitted question.

Do remember that whatever you post to the "Ask Dr. Cowan" feature, it is considered public knowledge, unless explicitly stated otherwise. You should always use caution when posting. Avoid posting your home address or phone number on a public board or chat. Although one must be a registered user to post messages the message boards are public and may be read by non-registered users.

GACO Corporation reserves the right to re-publish your postings from message boards or chat rooms in any format.

Surveys & Contests

From time-to-time, our web site requests information from our users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user has a choice whether or not to provide us with such information. Information requested may include contact information, such as name and shipping address, and demographic information, such as zip code, age level. Contact information will be used to notify the winners and award prizes. Survey information will be used to monitor or improve the use and efficiency of this web site.

Security

The security of your personal information is important to us. When you enter sensitive information (such as credit card number and/or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL).

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

If you have any questions about the security of our web site, you can send an email to webmaster@virtualheadacheclinic.com

Communications from our Web Site

We send all new members a welcoming email to verify their password and username. Established members will occasionally receive information on products, services, special deals, and the e-bulletins. Each user has the option to not receive these types of communications (see Choice/Opt-Out below).

Occasionally, it is necessary to send out service-related announcements. For instance, if our service is temporarily suspended for maintenance, we might send you an email informing you of such service interruption. Generally, users may not opt-out of receiving these service-related communications. In addition, we communicate with our users on a regular basis to provide requested services and regarding issues relating to their account via email.

Correction/Updating Personal Information

If a user's personal information changes or if a user no longer desires our service, we will enable our users to correct, update or remove from our web site the personal data they provided to us. Such changes can be made either through the member information page on our web site or by emailing our Webmaster at Webmaster@virtualheadacheclinic.com.

Choice/Opt-out

Our users are given the opportunity when registering with our web site to opt-out of having their information used for purposes not directly related to the provision of goods or services through our web site. Our membership form has an opt-out mechanism so users purchasing a membership from us may elect to not have their email address added to our marketing and promotional address lists.

Users who no longer wish to receive our e-bulletins or other marketing and promotional materials from us or our partners may opt-out of receiving these communications by replying to any such promotional email indicating your desire to no longer receive such emails or by emailing our Webmaster at Webmaster@virtualheadacheclinic.com.

Users of our web site will be notified if, in connection with the use of a particular service on our web site, their information will be collected by any outside third-party. At such time, the user can determine whether they wish to proceed with a service that will involve an outside party having access to their information. \

Collecting Information From Children Younger than 13

The www.virtualheadacheclinic.com web site does not knowingly collect or use any personal information from children under the age of 13 without obtaining verifiable parental consent.

Notification of Changes in Use of Information

Our privacy policy is subject to change. In the event of any change, we will provide notice of such change on our web site. If we want to use your personal information in a manner different from that stated to you at the time you provided such information to us, we will notify you of such change via email in addition to posting notification of such change on our web site. At such time, you can determine whether you wish to allow us to use your information in this different manner. If you have opted out of all communication with our web site or have deleted or deactivated your account with us, then you will not be contacted and your personal information will not be used.

If you have any questions about this privacy policy or believe that the www.virtualheadacheclinic.com web site is not abiding by our privacy policy, please contact our Webmaster by e-mail at Webmaster@virtualheadacheclinic.com. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact TRUSTe through the "TRUSTe WatchDog Dispute Resolution Process" at http://truste.org/consumers/watchdog_complaint.php. TRUSTe will serve as a liaison with the www.virtualheadacheclinic.com web site to resolve your concerns.

This privacy policy was last updated May 21, 2005.