I. Collection and Use of Information

A. Information We Collect

i. Personal Information vs. Usage Information

1. “Personal Information” means information associated with or used to identify or contact a specific person. Personal Information includes: (1) contact data (such as e-mail address, telephone number and employer); (2) demographic data (such as gender, date of birth and zip code); and (3) certain Usage Data (defined below), such as IP address; and (4) describe any other categories of information the user provides or the digital service operator collects, such as user generated content or purchases].

2. “Usage Information” or “Usage Data” is information about an individual’s online activity that, by itself, does not identify the individual, such as browser type, operating system and webpages visited. Generally, we do not consider Usage Data as Personal Information because Usage Data by itself usually does not identify an individual. Personal Information and Usage Data may be linked together. Different types of Usage Information also may be linked together, and once linked, may identify an individual person. Also, some Usage Data may be Personal Information under applicable law.

a. Categories of Usage Data:

1. Technical information;

   • Information about user searches/looking at while using the service;

   • Information about communications the user made using the Services;

   • Metadata.

ii. Sensitive Personal Information

Certain Personal Information, such as information about personal health or finances, is characterized as sensitive and subject to stricter regulation than other personal information. Before providing it to us, we urge you to carefully consider whether to disclose your sensitive Personal Information to us. If you do provide Sensitive Personal Information to us, you consent to use and disclosure for the purposes and in the manner described in this Privacy Policy.

iii. Location Data

“Location Data” is a category of Personal Information collected about the location of a mobile device or computer, including:

1. The location of the mobile device or computer used to access the Services derived from GPS or Wi-Fi use;

   • The IP address of the mobile device or computer or internet service used to access the Services;

   • Other information made available by a user or others that indicates the current or prior location of the user, such as [information that you or others post indicating your location] [geotag information in photographs].

iv. Combining Information from Third Party Sources

We may combine the information we collect from you with information from other sources and use the combined information as described in this Privacy Policy.

v. E-Mail and E-Mail Addresses

If you send an e-mail to us or provide your e-mail address to us, we will collect your e-mail address and the full content of your e-mail, including attached files, and other information you provide. We may use this e-mail address to contact you. You may indicate your preference to stop receiving further promotional communications as further detailed below.

B. How Information is Collected

i. General

We collect information that you provide to us and from your use of the Services. The information that we collect and how we process it depends on how you use and access the Services. Some information is collected automatically through use of cookies and similar data collection tools.

ii. We collect Information from you when you:

1. Use the Services: we collect Personal Information and Usage Data from you when you create an account to use one of the Services, contact us for help or information or otherwise voluntarily provide your Personal Information.

2. Connect with Social Media through the Services: The Services may offer you the ability to use Facebook Connect or other social media services (collectively, ‘Social Media’) in conjunction with certain Services. When you access the Services through your Facebook or other Social Media account, the Services may, depending on your privacy settings, have access to information that you have provided to the Social Media platform. We may use this information for the purposes described in this Privacy Policy.

3. From our Business Partners and Service Providers: Third Parties that assist us with our business operations also collect information (including Personal Information and Usage Data) about you through the Services and share it with us. For example, our vendors collect and share information with us to help us detect and prevent fraud.

4. Usage Data: we also automatically collect Usage Data when you interact with the Services.

iii. Information Collected Via Technology

1. As you use our Website, certain information may also be passively collected and stored on our or our service providers' server logs, including your Internet protocol address, browser type, and operating system. We also use Cookies and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and the solutions and information for which you searched and viewed, or on which of the advertisements displayed on our site you clicked. This type of information is collected to make our Website and solutions more useful to you and to tailor the experience with our Website to meet your special interests and needs.

2. An "Internet protocol address" or "IP Address" is a number that is automatically assigned to your computer when you use the Internet. In some cases your IP Address stays the same from browser session to browser session; but if you use a consumer internet access provider, your IP Address probably varies from session to session. For example, we, or our service providers, may track your IP Address when you access our Website to assist with ad targeting. "Cookies" are small pieces of information that a website sends to your computer's hard drive while you are viewing a website.

3. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience with our Website. Persistent Cookies can be removed by following your Internet browser help file directions. In order to use our Services offered through our Website, your web browser must accept Cookies. If you choose to disable Cookies, some aspects of our Website may not work properly, and you will not be able to receive our Services.

4. We may also enable advertisers and ad servers to promote third-party products and/or services by placing advertisements on our Website. These advertisers and ad servers may use Cookies and/or Web Beacons in order to monitor information related to served advertisements. Clicking on such advertisements will direct you to the website of a third-party and the advertiser. This Privacy Policy does not cover the privacy practices of any advertisers or ad servers.

a. Cookies

i. The Website uses cookie technology to improve the quality of your experience. A cookie is a small file that contains information sent by a website that is saved on your hard disk by your computer’s browser. Cookies store information that a website may need in order to personalize your experience and gather website statistical data. Any time you visit our Website to browse or to read or download information, we collect and store the name of the domain and host from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browser software you use and your operating system; the date and time you access the Website; and the Internet address of the website from which you linked directly to the Website. We use this information to measure the number of visitors to areas of the Website, and to help us make the Website more useful and interesting to our visitors. We use information from cookies in the aggregate to analyze for trends and statistics, we do not track individuals, only instances of entry onto the Website.

ii. Some consumers may not know that cookies are being placed on their computers when they visit websites. If you want to know when this happens, or to prevent it from happening, you can set your browser to advise you when a website attempts to place a cookie on your computer.

C. How Information is Used

i. We use the Personal Information that we collect to operate, improve and personalize the Services, to provide customer service, customize our advertising and marketing to detect, prevent and mitigate fraudulent or illegal activities. You agree that we may use your Personal Information as follows:

1. Operate, improve and personalize the Services

1. Provide use of and access to the Services;

   • Customize, measure and improve the Services;

   • Provide content that we think users will like;

   • Provide services requested by you;

   • As described when we collect the information.

2. Provide customer support

1. Provide customer support for the Services or for the products offered by/through the Services.

   • Contact users, either via email or telephone, text (SMS) messages (if applicable) as authorized by the recipient user to resolve disputes, collect fees and troubleshoot problems with the Services and for other purposes authorized by law and consistent with this Privacy Policy. Message and data rates may apply.

   • Check and verify Personal Information with third parties as necessary.

   • Customize our advertising and marketing communication.

   • Customize, measure, and improve our content and advertising based on users' ad customization preferences.

   • Contact users, either via email, telephone, text (SMS) messages (if applicable based on your consent), postal mail or otherwise as authorized by you to inform you about the Services special offers, etc. Message and data rates may apply.

3. Detect, prevent, and mitigate fraudulent or illegal activities

1. Prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities.

   • Enforce our Terms of Use or other applicable policies.

D. Sharing/Disclosure of Information

i. Except as otherwise stated in this Privacy Policy, we do not generally sell, trade, rent, or share the Personal Information that we collect with third parties, unless you ask or authorize us to do so. In general, Personal Information you submit to us is used by us to provide you better access, improve your experience, and to better tailor the features, performance, and support we provide to you, and to offer you additional information, opportunities, promotions and functionality from us, our partners or our advertisers at your request. Additionally, we do share your content preferences and other information with the social network from which you have connected to, along with those companies and persons you have asked us to share your information with. We may share and disclose information as described at the time information is collected or as follows:

1. To Perform Services. We may disclose Personal Information to third parties in order to perform services requested or functions initiated by users. In addition, we may disclose Personal Information in order to identify a user in connection with communications sent through the Services. We also may offer users the opportunity to share information with friends and other users through the Services.

2. With Third Party Service Providers Performing Services on Our Behalf. We share information, including Personal Information, with our service providers to perform the functions for which we engage them (such as hosting and data analyses). We may share information as needed to operate other related services.

3. For Legal Purposes. We also may share information that we collect from users, as needed, to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose Personal Information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share Personal Information as required to pursue available remedies or limit damages we may sustain.

4. Corporate Changes. We may transfer information, including your Personal Information, in connection with a merger, sale, acquisition or other change of ownership or control by or of us or any affiliated company (in each case whether in whole or in part).

ii. We may disclose your Personal Information if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect and defend our rights or property, you, or third parties. You hereby consent to us sharing your Personal Information under the circumstances described herein.

E. How Information is Retained and Secured

i. Retention and Disposal

1. We retain information as long as we deem necessary and relevant for our operations. In addition, we retain personal information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use, [collect any fees owed] and other actions permitted by law.

ii. Security

1. We are committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. Even though we have taken significant steps to protect your Personal Information, no company, including us, can fully eliminate security risks associated with Personal Information.

II. Linked Services

The Website may contain links to other sites. These links are an accommodation to the respective third-party site owners and for your convenience. Sites linked to and from the Website are not necessarily under our control, and we shall have no responsibility or liability whatsoever for the content or privacy practice of any linked sites, or any link or linking program at any time. You should read and understand our policies with respect to such third-party links, as stated in the Terms and Conditions of Use of the Website.