Circle Street, Inc.

Circle Street Privacy Policy

Last Updated: 12/1/2009

Welcome to the services of Circle Street (“Circle Street,” “we,” or “us”). This privacy policy describes our collection of information from users of our Web site at www.circlestreet.com (the “Site”), our software applications that we may offer on one or more mobile device platforms (the “Applications”), and our services made available on the Site, on third-party social networking services (the “Social Networking Services”) and on and through our Applications (collectively, the “Services”), as well as our use and disclosure of such information. By using any of our Services, you consent to the collection and use of information in accordance with this policy.

Personal Information

“Personal information,” as used in this policy, is information that specifically identifies a person, such as a person’s name, address, telephone number, or e-mail address. Personal information also includes information about a person’s activities, such as information about his or her activity on our Site or our Services, and demographic information, such as date of birth, gender, geographic area, and preferences, when any of this information is linked to personal information that identifies that person.

Personal information does not include "aggregate" or other non-personally identifiable information. Aggregate information is information that we collect about a group or category of products, services, or users that is not personally identifiable or from which individual identities are removed. We may use and disclose aggregate information, and other non-personally identifiable information, for various purposes.

Collection of Information

Passive Information Collection

When you visit our Site or use any of our Services, some information is automatically collected, such as your computer’s IP address, browser type, system type, the content and pages that you access on the Site or Service, “referring URL” (i.e., the page from which you navigated to the Site), the pages from which you navigate to and from the Site or Service, and the time you spend on the Site or the Service.

We collect this information passively using technologies such as standard server logs, cookies, and clear GIFs (also known as “Web beacons”). We use passively-collected information to administer, operate, and improve our Site, our Services, and our other services and systems, and to provide services and content that are tailored to you. If we link or associate any information gathered through passive means with personal information, we treat the combined information as personal information under this policy. Otherwise, we use information collected by passive means in non-personally identifiable form only.

Also, please be aware that third parties may set cookies on your hard drive or use other means of passively collecting information about your use of their services or content. We do not have access to, or control over, these third-party means of passive data collection.

Collection of Voluntarily Provided Information

We may offer various ways for you to provide personal information to us voluntarily on our Site or our Services. For example, we ask that you create an account with us in order to use many of our services. We also may offer the ability to create and maintain user profiles and the ability to post or share content with third parties. We also collect personal information when you request information about our services, request help or support, or otherwise communicate with us using contact forms or other methods for contacting us on our Site or our Services. We may collect personal information such as name, e-mail address, city, state, country, other demographic information, and interests and preferences in these manners.

Information from Other Sources

We may receive information about you, including personal information, from third parties, and may combine this information with other information we maintain about you. If we do so, this policy governs any combined information that we use or maintain in personally identifiable format.

Use of Personal Information

We use personal information to provide services and information that you request; to enhance, improve, operate, and maintain the Site, our Services, and our other systems and resources; to prevent fraudulent use of our Site and our Services; to tailor your user experience; to maintain a record of our dealings with you, and for other administrative purposes.

We may also use personal information you provide to contact you regarding our products, services, and offers that we believe you may find of interest. Additionally, by using some of our services, you may indicate to us that you wish to receive offers or promotions regarding third-party products and services. We allow you to opt-out from receiving marketing communications from us as described in the “Choice” section below.

Disclosure of Information

We are not in the business of selling personal information about our users to third parties. We may disclose information about our users, including personal information, to third-party service providers (e.g., data storage and processing providers), that assist us in our work. We limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their work for us.

We may also disclose information about our users, including personal information, if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.

As described below in the “Personal Information Available to Third Parties” section, personal information that you post or transmit to publicly-accessible areas of our Services, or to third-party services (each, a “Submission”) may be available to third parties.

In addition, information about our users, including personal information, may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership, in which personal information could be transferred to third parties as one of our business assets.

Personal Information Available to Third Parties

Some features of our Services may allow you to post or submit personal information that is made available to other users of the Site and our Services, and to third-party services. If you post or submit information using these features, any personal information that you include with the post or submission will be made available to other users of our our Services, as well as to any users of third-party services to which the post or submission is directed. You include personal information in any posts or submissions using such features at your sole risk. We may allow you to select privacy options that limit access to some types of personal information that you post or submit using such features, but no security measures are impenetrable or perfect. Additionally, even in the event that information posted using such features may be removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information. We cannot warrant or guarantee that any personal information that you provide on and in connection with any such features will not be accessed, viewed, or used by unauthorized persons.

Choice

If you receive marketing or promotional communications from us, you may unsubscribe at any time by following the instructions contained within the message that we send. You may also opt-out from receiving marketing or promotional communications from us by sending us an email or by writing to us at the address given at the end of this policy.

Additionally, if you do not wish to be notified by [email, postal mail, telephone, or text messages] regarding [products, services, events, programs, and offers that we believe you may find of interest] [our products and services], you may opt-out from such communications by sending us an email or by writing to us at the address given at the end of this policy. Even if you opt-out from marketing and promotional communications, you may still receive messages regarding any accounts you maintain with us, and regarding important updates to our Site or our Services.

Links

For your convenience, our Site and our Services may contain links to other Web sites, products, or services that we do not own or operate. If you choose to visit or use any third-party products or services, please be aware that this policy will not apply to your activities or any information you disclose while using third-party products or services or otherwise interacting with third parties.

Children

Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. We do not knowingly collect personal information from children under the age of 13 without obtaining parental consent.

International Visitors

Our Site is hosted in the United States and is generally intended for United States visitors. If you visit from other regions with laws governing data collection and use that may differ from U.S. law, please be aware that you are transferring personal information to the United States. The United States does not have the same data protection laws as some other regions. By providing personal information to us, you consent to the transfer of it to the United States and the use of it in accordance with this policy.

Security

We use reasonable security measures that are designed to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please note, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any personal information or other information. You transmit personal information to us at your own risk.

Updates to this Policy

We may occasionally update this policy. When we do, we will also revise the “last updated” date at the beginning of the policy. If we make a change to this policy that would result in our treating personal information collected before the effective date of the change in a manner materially less restrictive than prior to the change, we will attempt to notify you (by placing notice on our Services or contacting you via the contact information you have provided to us) prior to applying the change to personal information collected prior to the effective date of the change. Your continued use of this Site after changes to this policy will be subject to the then-current policy. We encourage you to periodically review this policy to stay informed about how we collect, use, and disclose personal information.

Contacting Us

If you have any questions, comments, or concerns about this privacy policy, please contact us using the following contact information:

Circle Street, Inc.

[info@circlestreet.com]