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Privacy Policy

By visiting the website located at https://www.spotfront.com and any other applications and features (the “Site”) and using the services (the “Services”) provided by Spotfront, Inc. (“Spotfront”), you consent to our use and processing of your information as set forth herein. This Privacy Policy covers Spotfront’s treatment of personal information that Spotfront gathers when you are on the Site or use the Services and that our business partners share with Spotfront. These privacy practices apply to Spotfront’s small business advertisers, corporate partners, and any internet users that receive online advertising through the Spotfront advertising services. This policy does not apply to third parties that Spotfront does not own or control.

Any order forms or additional agreements to which users agree governing the provision of optional Spotfront features shall take precedence over the terms of this Privacy Policy to the extent of any differences, so please read such order forms or additional agreements carefully. Spotfront is deeply committed to protecting the privacy of internet users. Accordingly, we strictly adhere to all industry guidelines, and will continue to improve our policies and procedures to ensure the safety and protection of consumer information.

i. Advertising Data Policy
This section describes our policies for internet users that receive online advertising from Spotfront on behalf of Spotfront advertisers.

Information Collected by Spotfront
In the course of delivering an ad to you, Spotfront does not collect personally identifiable information about you. Personally Identifiable Information (PII) includes data such as your name, address, phone number, social security number or email address. Spotfront does collect non-personally identifiable information about you, for the purpose of targeting ads and measuring the effectiveness of ads on behalf of Spotfront’s advertisers. This non-personally identifiable information includes data such as:

Domain Type – .com, .net, .edu, etc
Standard Data – common information found in every communication sent over the internet. Using this information, Spotfront can infer information such as browser type (e.g., Netscape or Internet Explorer); operating system (e.g,. Macintosh or Windows); browser language (e.g., Java or Unix); and internet service provider (e.g., EarthLink or Optimum)
Clickstream Data – Spotfront can infer how you use our advertisers’ sites and various pages on the internet.

Spotfront may use this non-personally identifiable information to create data segments, and these data segments are generally based on the websites that you visit. Spotfront does not collect data or create data segments that are based on what we consider to be sensitive information such as detailed financial information and sensitive medical conditions. We don’t use data segments to determine creditworthiness, for insurance underwriting or similar purposes. At Spotfront, we think it is important to provide this transparency to help you have a better idea of which segments might be collected by us, so that you can make informed decisions as an internet user.

Information From Other Sources
To improve our Services, we may receive behavioral, contextual and demographic information about you from other sources and add it to our account information. We may purchase or receive information about you from third parties and use that information to target our customers’ advertisements and otherwise improve our Services. For example, if you visit a number of websites for French restaurants, you may be flagged as being interested in having dinner at a French restaurant.

Cookies
Cookies are alphanumeric identifiers transferred to your computer’s hard drive through your Web browser to enable our systems to recognize your browser and tell us how and when pages in our Site are visited and by how many people. Like most internet sites, Spotfront uses cookies to enhance a user’s experience on the internet. Spotfront may set cookies directly on internet users that receive ads sent through Spotfront or rely on partners to set cookies on our behalf. These cookies do not collect personal information, and we do not combine information collected through cookies with other personal information to tell us who you are or what your name or e-mail address is.

Most browsers allow you to prevent the browser from accepting new cookies, to be notified when you receive a new cookie, or to disable cookies. If you disable cookies, you may not be able to take advantage of some of Spotfront’s features. To disable cookies set by Spotfront or Spotfront partners, simply contact us at help@spotfront.com and we will provide you with an opt-out.

Data Retention
Cookies set by or on behalf of Spotfront expire after three years and the expiration date updates every time you encounter our server. Spotfront and its partners retain standard web log data for ninety days after ads are served, and aggregations and reports for up to three years after ads are served.

Consumer Choice and Access
Since Spotfront does not collect PII from internet users who receive advertisements from our advertisers, we do not maintain a process for an individual internet user to review and/or request changes to his or her PII.

ii. Advertiser and Partner Policies
This section describes our policies for Spotfront advertisers and corporate partners.

Personal Information Collected By Spotfront
NOTE: this section describes personal information collected from Spotfront advertisers and corporate partners only. As described in the previous section Advertising Data Policy, Spotfront never collects or uses personal information from internet users who receive advertising from Spotfront on behalf of Spotfront advertisers.

Information You Provide to Us
We receive and store any information you enter on the Site or through the Services or provide to us in any other way. You can choose not to provide us with certain information, but then you may not be able to take advantage of many of our features. The personal information you provide is used for such purposes as responding to your requests for services, customizing the content you see, communicating with you about our products, and marketing our Services and those of our partners to you.

In order for you to use all of our features, you must register with Spotfront. We require your e-mail address, username, password, business name, business website URL, and street address during the registration process. We also require information about your business, the industry your business is in, and your business’s social media accounts.

Further information may be required if you choose to purchase paid components of the Services, such as credit card and billing information. Spotfront may use third party partners for credit card processing who may require and store your credit card and billing information.

Automatic Information
We receive and store certain types of information whenever you interact with us. Spotfront automatically receives and records Traffic data on our server logs from your browser including your IP address, Spotfront cookie information, and pages you request. Spotfront uses this traffic data to analyze trends and administer the Site. Our service automatically collects usage information, such as the numbers and frequency of visitors to our Site and its components. This data is only used in the aggregate. This type of collective data enables us to figure out how often users use different parts of the Site and Services. In addition, we may provide statistical collective user information, not information about you personally, to our partners so that they understand how often people use specific components of our Site and Services.

E-mail Communications
If you create and distribute advertisements through the Site or Services, Spotfront will provide status updates regarding the performance of your advertising campaigns to you by e-mail. You consent to receiving such confirmations by e-mail. If you contact us via e-mail through the Site, we may retain a record of your contact information and any information you provide us in your message to respond to you. We may receive a confirmation when you open an e-mail from Spotfront.

We may also send e-mails with service updates, news or promotions. If you do not want to receive e-mail from us, please contact us at help@spotfront.com. If you do not want to receive legal notices from us, such as this Privacy Policy, those legal notices will still govern your use of the Site and Services.

Information From Other Sources
To improve our Services, we may receive information about you from other sources and add it to our account information. We may purchase or receive information about you from third parties and use that information to target our customers’ advertisements and otherwise improve our Services. We may also pool data about business owners in the aggregate which we receive from third parties to improve our customers’ advertising campaigns. Like the information you provide to us, we do not share this information with anyone except authorized third parties in connection with providing you with our Services and we will not use this data to identify or locate you personally.

Cookies
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your Web browser to enable our systems to recognize your browser and tell us how and when pages in our Site are visited and by how many people. Spotfront cookies do not collect personal information, and we do not combine information collected through cookies with other personal information to tell us who you are or what your name or e-mail address is. Spotfront uses cookies to enable user sessions for our application users. Spotfront partners engaged to gather metrics on Site usage to improve the Services also use cookies for our application users.

Most browsers allow you to prevent the browser from accepting new cookies, to be notified when you receive a new cookie, or to disable cookies. If you disable cookies, you may not be able to take advantage of some of Spotfront’s features. To disable cookies set by Spotfront or our partners, simply contact us at help@spotfront.com and we will provide you with an opt-out.

Data Retention
Cookies set by or on behalf of Spotfront expire after three years and the expiration date updates every time you encounter our server. Spotfront and its partners retain standard web log data.

Sharing of Information by Spotfront
We neither rent nor sell your PII to anyone. Except as provided for in any additional agreement you enter into with Spotfront, we share your personal information only as described below:

Affiliated Businesses We Do Not Control
Spotfront may provide services or sell products jointly with affiliated businesses. We will share customer information that is related to such transactions with those affiliated businesses. We require our affiliates to provide the same level of privacy protection that we do and they do not have the right to share or use personal information for any purpose other than for an authorized transaction. Spotfront shall be entitled to receive from such third party affiliated businesses a record of your interactions and transactions with them using the Services. Spotfront may share aggregated demographic information with business partners.

Agents
We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products and services. Examples include billing, processing payments, providing marketing assistance, and providing customer service. Our agents subscribe to the same level of privacy protection as we do. Unless we tell you differently, Spotfront’s agents do not have any right to use the personal information we share with them beyond what is necessary to assist us.

Financial and billing information collected through the Site and Services is used solely to bill for the Services. Spotfront may transmit this information to independent contractors who are bound to us by written confidentiality agreements. This billing information is not used by Spotfront for marketing or promotional purposes. Spotfront uses a third-party intermediary to manage credit card processing who may store, retain, and use the information provided solely for the purpose of credit card processing.

Promotional Offers
We may send offers to certain users on behalf of other businesses or provide our merchants with the opportunity to notify users directly of promotions by text messages or e-mail. If you do not wish to receive these offers, please e-mail us at help@spotfront.com.

Information You Post
When you post information on the Site or through the Services, your username and certain profile information are visible to other users. When you transmit advertisements through the Services, recipients receive any personal information included in those advertisements. You are solely responsible for the consequences of posting that information. Spotfront assumes no liability for the consequences of your disclosure of information about your business, yourself or any other subject matter on the Site and through the Services. Spotfront or other parties may use information posted by you, along with your profile information, in any medium now existing or developed in the future. Spotfront will use commercially reasonable efforts to attempt to notify you before using information posted by you along with your profile in other media.

Business Transfers
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if Spotfront, or substantially all of its assets, were acquired, user information would be one of the assets that is reviewed and transferred. You acknowledge that such transfers may occur, and that any acquirer of Spotfront may continue to use your personal information as set forth in this policy.

Protection of Spotfront and Others
We may release personal information when we in our sole discretion believe in good faith that release is necessary or appropriate to comply with the law, enforce or apply our conditions of use and other agreements, or protect the rights, property, or safety of Spotfront, our employees, our users, or others.

With Your Consent
Except as set forth above, you will be notified when your personal information may be shared with third parties.

iii. Additional Policies

Information Security
Your Spotfront account information is protected by a password for your privacy and security. We use industry-standard Secure Socket Layer (SSL) software to protect the security of your personal information during transmission, which encrypts all of the information you input. Only employees or agents who need personal information to perform a specific job are granted access to it. All of our employees are kept up to date on our privacy and security practices. While Spotfront uses commercially reasonable means to secure your information, we do not guarantee that your personal information will not be improperly accessed, disclosed, or destroyed by breach of any of our safeguards.

Accessing Information
You are able to access, add to and update certain information about you. When you update information, however, we often maintain a copy of the unrevised information in our records. You may deactivate your Spotfront account by contacting help@spotfront.com. Some information may remain in our records after deletion of your account.

Conditions of Use
Your use of the Site and Services and any possible dispute over privacy are subject to this Privacy Policy and our Terms and Conditions, including limitations on damages, arbitration of disputes, and application of New York state law.

International Visitors
For users outside the United States, please note that any data or personally identifiable information you enter into the Services or Site will be transferred out of your country and into the United States. You consent to such transfer through your use of the Services and Site. You also warrant that you have the right to transfer such information outside your country and into the United States.

Use of Spotfront by Children
Spotfront is not intended for children. If you are under 18, you may use the Site and Services only with the supervision of your parent or guardian.

Third Party Sites
The Site and Services may permit you to link to other websites on the Internet, and other websites may contain links to the Site or Services. These other websites are not under Spotfront’s control and Spotfront is not responsible for the privacy or security practices or the content of such websites.

Changes to this Privacy Policy
Spotfront may amend this Privacy Policy. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes to our privacy policy, we will notify you by posting an announcement on our Site.

Questions or Concerns
If you have any questions or concerns regarding privacy at Spotfront, please send us a detailed message to help@spotfront.com or to Spotfront, Inc. at 175 Varick Street, New York, NY 10014. Your privacy is important to us and we will make every effort to resolve your concerns.

Last Updated: June 2012