Privacy Statement

Privacy Policy GENERAL This platform (“Company” or “we” or “us” or “our”) respects the privacy of its users (“user” or “you”). The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the platform, about the types of information that Company may gather about or collect from you in connection with your use of the Platform. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the platform, however, the current version of this Privacy Policy will apply. The platform is hosted in the United States of America and is subject to Massachusetts and U.S. federal law. If you are accessing our platform from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our platform, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the platform. BY USING OR ACCESSING THIS PLATFORM, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY. GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION Users of the Platform Generally “Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most platform operators, Company gathers from users of the platform Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the platform. Although such information is not Personally-Identifying Information, it may be possible for Company to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. Company analyzes Non-Personally-Identifying Information gathered from users of the platform to help Company better understand how the platform is being used. By identifying patterns and trends in usage, Company is able to better design the platform to improve users’ experiences, both in terms of content and ease of use. From time to time, Company may also release the Non-Personally-Identifying Information gathered from users in the aggregate, such as by publishing a report on trends in the usage of the platform. Web Cookies A “Web Cookie” is a string of information which assigns you a unique identification that a platform stores on a user’s computer, and that the user’s browser provides to the platform each time the user submits a query to the platform. We use cookies on the platform to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the platform and to facilitate purchase procedures. Company also uses Web Cookies to track the pages that users visit during each platform session, both to help Company improve users’ experiences and to help Company understand how the platform is being used. As with other Non-Personally-Identifying Information gathered from users of the platform, Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Company, its partners and others better understand how the platform is being used. COMPANY USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE PLATFORM, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE PLATFORM MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. PLATFORM USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY. Analytics We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on your past activity on the platform, including Google Analytics for Display Advertising. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings (www.google.com/settings/ads). Aggregated and Non-Personally Identifying Information We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on the platform. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the platform and the most popular features or services accessed. This information does not contain any Personally Identifying Information and may be used to develop platform content and services that we hope you and other users will find of interest and to target content and advertising. Mobile Device Additional Terms • Mobile Device. If you use a mobile device to access the platform or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address. • Geo-Location Information. Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application or our services, except that it may be possible for Company to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data. • Push Notifications. We send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings. • Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally Identifying Information you submit within the mobile application. COLLECTION, USE AND DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION Platform Registration As defined above, Personally Identifying Information is information that can be directly associated with a specific person. Company may collect a range of Personally Identifying Information from and about platform users. Much of the Personally Identifying Information collected by Company about users is information provided by users themselves when (1) registering for our service, (2) logging in with social network credentials, (3) participating in polls, contests, surveys or other features of our service, or responding to offers or advertisements, (4) communicating with us, (5) creating a public profile or (6) signing up to receive newsletters. That information may include each user’s name, address, email address and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender, age, date of birth, username, hometown and other demographic or relevant information as determined by Company from time to time. Users of the platform are under no obligation to provide Company with Personally Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain platform features. BY REGISTERING WITH OR USING THE PLATFORM, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION” SECTION. Online Postings Certain Personally Identifying Information collected from users may be disclosed as a matter of course as a result of your use of the platform. We may provide areas on the platform where you can post reviews and other information relating to your activities on the platform. Such postings are governed by our Terms of Service. In addition, such postings may appear when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE OF PERSONAL INFORMATION. Company Communications We may occasionally use your name and email address to send you notifications regarding new services offered by the platform that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails at the time of registration or through your account settings, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, even if you opt out of all voluntary email notifications. Company Disclosures Company will disclose Personally Identifying Information under the following circumstances: • By Law or to Protect Rights. When we believe disclosure is appropriate, we may disclose Personally Identifying Information in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Company, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our Terms of Service or other agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us. • Marketing Communications. Unless users opt-out from receiving Company marketing materials upon registration, Company may email users about products and services that Company believes may be of interest to them. If you wish to opt-out of receiving marketing materials from Company, you may do so by following the unsubscribe link in the email communications, by going to your account settings (if applicable) or contacting us using the contact information below. • Third-Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the platform’s functionality and supporting contests, sweepstakes, surveys and other features offered through the platform. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose. CHILDREN The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally Identifying Information through the platform represents to us that he or she is 13 years of age or older. If we learn that Personally Identifying Information has been collected from a user under 13 years of age on or through the platform, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the platform or has otherwise transferred Personally Identifying Information to the platform, please contact Company to have that child's account terminated and information deleted. Changing Personally Identifying Information; Account Termination You may at any time review or change your Personally Identifying Information by going to your account settings (if applicable) or contacting us using the contact information below. Upon your request, we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and accordance with our deactivation policy and applicable law. To make this request, either go to your account settings (if applicable) or contact us as provided below. We will retain in our files some Personally Identifying Information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our Terms of Service and to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your Personally Identifying Information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud with your account. Changes We may make changes to this privacy policy from time to time. If we change our privacy policy we will post the changes on this page. If the change in our privacy policy affects the use of your personal information we will use our best endeavours to contact you by email to seek your consent to the use. Continued use of the service will signify that you agree to any such changes Sale of business If this business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.