Privacy Policy

Last Updated: April 6, 2008

We value your privacy, and we want to help make your experience with the Centricity Platform as satisfying and safe as possible. We have established this Privacy Policy to explain how Centricity collects Personal Information (as defined below) on the Centricity Platform, and how Centricity uses and discloses that Personal Information. "Personal Information," as used in this Privacy Policy, is information that allows a person to directly identify an individual, such as name or email address, and information that we combine directly with such identifying information. This Privacy Policy is incorporated into and is subject to the Centricity Terms of Service. Any capitalized terms not defined herein have the meaning set forth in the Centricity Terms of Service. By using the Centricity Platform, you expressly consent to the information handling practices described in this Privacy Policy.

1. HOW THE CENTRICITY PLATFORM OPERATES

Centricity provides a software platform (the "Centricity Platform") that enables registered users ("Centricity Members") to create, join or browse social networks built on the Centricity Platform. The Centricity Platform also allows Third Party Application Developers to develop Third Party Applications for use on the Centricity Platform. This Privacy Policy refers to social networks on the Centricity Platform as "Networks," and refers to Centricity Members who create Networks as "Network Creators." Centricity Members who join a Network are "Network Members" of that Network. Network Creators are also considered Network Members of the Networks they create.

In its operation of the Centricity Platform, and its provision of its services to Network Creators and Third Party Application Developers, Centricity collects, uses, and retains all information, including Personal Information and Network Member Data, that you disclose to Network Creators in your use of Networks. When you sign up to become a member of a Network, you are providing Personal Information to Centricity, as well as to that Network's Network Creator. Centricity's use and disclosure of Personal Information is described in this Privacy Policy. Additionally, if you add a Third Party Application to your Network or your profile, Centricity may provide certain Personal Information to that Third Party Application Developer. Centricity's disclosures of Personal Information to Network Creators and Third Party Application Developers are described in greater detail under the "When Centricity Discloses Personal Information" heading below.

Network Creators and Third Party Application Developers may also collect additional types of Personal Information, and may use and disclose Personal Information in accordance with their own privacy policies. For each Network you use, you should check with the Network Creator regarding its policies governing its collection, use, and disclosure of Personal Information. Additionally, for each Third Party Application that you add to your Network or your profile, you should check with the Third Party Application Developer regarding its policies governing its collection, use and disclosure of Personal Information.

2. COLLECTION OF PERSONAL INFORMATION

Personal Information You Provide

Centricity Member Data

You must register for a Centricity ID to become a Centricity Member, sign up for a Network, or to sign up as a Third Party Application Developer. When you register for a Centricity ID, you are required to provide certain Personal Information, including your name, email address, date of birth, and a password that you select. You also may create a Centricity Profile and provide other Personal Information within your Centricity Profile, such as your gender, city, state, and country, and a photo. You may choose not to display some of this information, causing it not to be displayed to other Centricity Members. Please note, however, that even if you choose not to display Personal Information in your Centricity Profile, that information will be accessible by Centricity and the Network's Network Creator. Your Centricity Profile is separate from any additional profile you may create on a Network.

When you sign up for a Network, you will be asked to sign into the Network with your Centricity ID. The Personal Information in your Centricity ID (except for your password) is provided to the Network Creator. Certain Personal Information (your name and email address) from your Centricity ID is pre-populated into your "My Profile" Page and your Centricity Profile upon sign in. Additionally, any Personal Information you choose to add to any Centricity Profile is pre-populated in your My Profile Page when you sign up for any new Networks. The Personal Information in your My Profile Page may be accessed by the Network Creator and all Centricity Members who browse the Network.

You also may have other opportunities to voluntarily provide Personal Information to Centricity. For example, if you contact us to provide feedback or request support, we collect your email address and other Personal Information that you provide. Another example is when you add a Centricity Application running on the Centricity Platform to a third party web site and you voluntarily input certain Personal Information.

Network Member Data

Network Creators may also request additional Personal Information from Centricity Members who register for their Networks. Certain Personal Information collected from Network Members will be retained in the Network Member's My Profile Page for that Network, but may be displayed in other Networks. If requests for additional information are marked "private," they will be viewable only by Centricity, the Network Creator, administrators designated by the Network Creator, or Members who you have given permission to view the private information. Network Creators may also designate Networks that they create as private, limiting Network Members to those that they approve or specifically invite. Please note, however, that while the general public cannot view private Networks, or your My Profile Page for private Networks, Centricity, Network Members, the Network Creator, and administrators designed by the Network Creator can view this information.

Network Members also have access to Centricity's Address Book feature. The Address Book feature allows Network Members to input contact information for their friends, whether or not those friends have Centricity IDs, and to send event and other invitations to them. Network Members may use the Address Book by entering contact information for their friends manually or, alternatively, retrieving contact information from supported email service providers. To retrieve contact information from a third-party service provider, the Network Member must provide login credentials for the email service providers that he or she has selected. That information is used to retrieve the contact information from the selected third-party service providers and is not retained by Centricity. If you send out invitations to join a particular Network, the contact information that you enter for the friends that you have invited, including information that is imported into, or entered manually into, the Address Book, may be accessed by Network Creators and their designated administrators.

Personal Information is also obtained when you subscribe to a Group, add a friend, or engage in activities that create consensual relationships with another Member.

Also please be aware that any information that you voluntarily choose to display on any publicly available portion of the Centricity Platform, or on any Network, becomes publicly available and may be collected and used by Network Creators, Centricity or others without restriction.

3. PASSIVE DATA COLLECTION

Like most web-based services, Centricity automatically receives and records information on our server logs from your browser when you use the Centricity Platform. Centricity may use a variety of methods, including clear GIFs (also known as "web beacons"), and "cookies" to collect this information. The information that Centricity collects with these automated methods may include, for example, your IP address, a unique device or user ID, browser type, system type, the content and pages that you access on the Centricity Platform, and the "referring URL" (i.e., the page from which you navigated to the Centricity Platform).

We also use cookies on the Centricity Platform to recognize your Centricity ID, and to store references to your Centricity ID and session validators on your hard drive. We also include clear GIFs in some of our email messages in order to learn whether the messages are delivered and opened.

We use passively-collected information to administer, operate, and improve the Centricity Platform and our other services and systems, and to provide services and content that are tailored to you, this includes providing customized advertisements and monitoring and reporting of the effectiveness of marketing campaigns. If we directly combine any information gathered through passive means with Personal Information, we treat the combined information as Personal Information under this Privacy Policy. Otherwise, we use information collected by passive means in aggregated or other non-personally identifiable forms.

Websites visited before visiting Centricity or a Network might place Personal Information within the URL of your browser during a visit to that previous website. Centricity may unintentionally collect that information as part of referring URL information that it collects.

If you wish to disable cookies, you may do so through your individual browser options. More detailed information about cookie management with specific web browsers can be found at the browsers' respective websites.

Also, please be aware that third parties, including advertising servers, advertising networks, Third Party Application Developers, and Network Creators, may set cookies or use other means of passively collecting information about your use of their services. We do not have access to, or control over, these cookies or other means of passive data collection. You should consult the respective privacy policies of these Third Party Application Developers, Network Creators, advertising servers or advertising networks for more detailed information on their practices as well as for instructions about how to opt-out of certain practices. This Privacy Policy does not apply to, and we cannot control the activities of, such other advertisers, Third Party Application Developers or websites.

4. CONTENT AND USE OF NETWORKS

When you send messages, make postings, or otherwise post or transmit any Content within a Network on the Centricity Platform, others who visit or use that Network may access any Personal Information within such Content. Within your Network Member settings for each Network, accessible at the " Settings" link, you may be able to modify your privacy settings for certain types of Content that you make available on that Network. For example, you may be able to specify that your photos and blog posts will be viewable by anyone, by your "friends" only, or only by you. We collect and maintain posts, messages, and other Content that you have posted or transmitted to a Network, as well as information about that Content and your interaction with it.

Some of this information, such as your latest activity on the Centricity Platform or a Network, and the most active members of a Network, will be made available to Network Creators, and may also be made available to other members of, and visitors to, the Centricity Platform as well as to Third Party Application Developers.

Because you may voluntarily disclose Personal Information when you post or otherwise transmit Content, please be careful with the information that you choose to disclose.

5. THIRD PARTY ADVERTISERS

Centricity allows other companies, called third-party ad servers or ad networks, such as Google AdSense, to serve advertisements within Networks on the Centricity Platform. These third-party ad servers or ad networks may use technology to send, directly to your browser, the advertisements that appear within a Network on the Centricity Platform, and when this happens they automatically receive your IP Address, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, and number of clicks and other log file information. Such third-party ad servers may also use other technologies (such as cookies, javascript, or web beacons) to measure the effectiveness of their advertisements and to personalize their advertising content.

Please note that if an advertiser asks Centricity to show an advertisement to a certain audience or audience segment and you respond to that advertisement, the advertiser or ad-server may conclude that you fit the description of the audience that they were trying to reach.

You should consult the respective privacy policies of these third-party ad servers or ad networks. This Privacy Policy does not apply to, and we cannot control the activities of, such other advertisers or web sites. Centricity reserves the right to add or remove third-party ad networks or ad servers in its discretion and Centricity may not at all times list such updated ad network or ad server partners in this Privacy Policy.

6. INFORMATION RECEIVED FROM THIRD-PARTY SOURCES

We may also obtain information, including Personal Information, from third-party sources. This includes certain Personal Information that may be provided to us through the installation and use of Centricity Applications on third party web sites. If we directly combine information from other third parties with Personal Information that we collect on the Centricity Platform, we will treat the combined information as "Personal Information" and handle it in accordance with this Privacy Policy.

7. HOW CENTRICITY USES PERSONAL INFORMATION

We may use Personal Information to operate, provide, improve, and maintain the Centricity Platform, and our other services and systems, and to develop new products and services; to prevent abusive and fraudulent use of the Centricity Platform and our other services and systems; to personalize and display advertisements (via our own advertising engine or server) and other content on the Centricity Platform; to send you administrative messages, and information about Networks, content, and Centricity services in which we believe you may be interested; and for other administrative and internal business purposes.

8. WHEN CENTRICITY DISCLOSES PERSONAL INFORMATION

Unaffiliated Third Parties

Centricity may share Personal Information with unaffiliated third parties for marketing purposes.

Centricity Service Providers

Centricity may provide Personal Information to third parties for their use in performing internal business functions (e.g., payment processing, maintenance, security, data analysis, or data hosting) on our behalf.

Network Creators

In the Centricity Terms of Service, Centricity requires each Network Creator to comply with applicable laws (e.g., CAN-SPAM) and not to use or disclose Personal Information in a manner that violates this Privacy Policy. For each Network that you join, Centricity provides the Network Creator and the designated administrators of that Network with your email address, name, and date of birth as stored in your Centricity ID, and pre-populates your My Profile Page on new Networks with any additional Personal Information from your Centricity Profile that you may have provided. Network Creators also have access to all Network Member Data that Centricity collects.

Centricity Affiliates

Centricity may share some of all of your Personal Information with any current or future parent company, subsidiaries, joint venture partners, or other companies that it controls or is under common control with (collectively, "affiliates"), in which case we will seek to require those affiliates to honor this Privacy Policy.

Legal Requirements

Centricity may disclose Personal Information if we have a good-faith belief that doing so is required by a subpoena or other judicial or administrative order or otherwise required by law. Additionally, Centricity may disclose Personal Information where we, in good faith, deem it appropriate or necessary to prevent violation of the Centricity Terms of Service, or our other agreements; take precautions against liability; protect the rights, property, or safety of Centricity, any individual, or the general public; maintain and protect the security and integrity of our services or infrastructure; protect ourselves and our services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third-party claims or allegations; or assist government enforcement agencies.

9. CHANGE OF OWNERSHIP

In the event of a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we reserve the right to transfer all of your Personal Information, including email addresses, to that entity. Centricity will use reasonable efforts to notify registered users of such a transfer (by a posting on our home page, or by email to a Centricity Member's email address that was provided to us, as chosen by us in our discretion).

10. SECURITY

We have implemented and and shall maintain reasonable security procedures and practices that are appropriate to the nature of the Personal Information, in order to protect the Personal Information within our control from unauthorized access, destruction, use, modification, or disclosure, and each contract we have or may in the future have with a nonaffiliated third party that we provide with any Personal Information shall require that the third party implement and maintain reasonable security procedures and practices appropriate to the nature of the Personal Information, to protect the personal information from unauthorized access, destruction, use, modification, or disclosure.

Although we make good faith efforts to maintain the security of such Personal Information, we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. Further, while we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent "hackers" or other unauthorized persons from illegally accessing or obtaining this information. We do not assume any liability to third parties whose information you include in your Address Book, or which you post or transmit in any Content on a Network. To help maintain the security of your Centricity ID, please keep your password secure (and, if you are a Network Creator, keep your master key secure).

If we learn or are notified of a security breach, we shall notify to any person whose unencrypted Personal Information was, or is reasonably believed to have been, acquired by an unauthorized person so that the person you can take appropriate protective steps. Notice will be given in the most expedient time possible and without unreasonable delay, consistent with the legitimate needs of law enforcement or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. By using the Centricity Platform or providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Centricity Platform. If a security systems breach occurs, we may send email to you at the email address you have provided to us.

11. CHILDREN

The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under 13 years of age. Centricity does not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personal Information through the Centricity Platform represents to us that he or she is 13 years of age or older. If Centricity learns that Personal Information has been collected from a user under 13 years of age on or through the Centricity Platform, then Centricity 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 Centricity Member, please contact Centricity at privacy@centricityhq.com or at the address set forth below in the "Contacting Centricity" Section to have that child's account terminated and information deleted.

12. YOUR CHOICES

You may, at any time, update, correct, or delete certain categories of Personal Information that you have provided to Centricity by logging into the Centricity Platform and updating the Personal Information. Additionally, you may update, correct, or delete certain categories of Personal Information within your My Profile Pages on individual Networks by following the directions there.

You may also, at any time, elect to deactivate your membership within any Network on the Centricity Platform by visiting the My Settings page while logged into that Network. If you leave a Network that is governed by a separate privacy policy, the Network Creator may still maintain and use Personal Information that you have provided to that Network Creator in accordance with the Network Creator's privacy policies. Additionally, you may terminate your Centricity ID account and end your use of the Centricity Platform at any time and for no reason by contacting us at info@centricityhq.com or at the address set forth below in the "Contacting Centricity" Section.

Additionally, even if you update or remove Personal Information that you have provided to Centricity or any Network Creator, your Personal Information may be retained in backup files and archives for a reasonable period of time for legal purposes.

Centricity shall take all reasonable steps to destroy, or arrange for the destruction of a Member's records within its custody or control containing Personal Information which is no longer to be retained by Centricity by (1) shredding, (2) erasing, or (3) otherwise modifying the personal information in those records to make it unreadable or undecipherable through any means.

13. EMAIL COMMUNICATIONS AND UNSOLICITED COMMERCIAL EMAIL

We may send you administrative messages, and updates regarding your Centricity ID account, the Centricity Platform, and Centricity's services, by email. Network Creators may also send you administrative or promotional messages to the extent permitted by applicable law and the Centricity Terms of Service. When you are logged into a Network, you may indicate your preferences regarding certain administrative email messages by following the directions there. Additionally, if you receive an email invitation from a Network to join that particular Network and do not wish to receive any future messages for that Network, you can choose to opt-out of receiving future messages from that Network by following the directions on the bottom of the email message you receive. You do not need to sign up to a Network to block all future emails from the Network.

The Centricity Terms of Service prohibit Network Creators and Network Members from engaging in any activity involving the sending of email in violation of applicable law, including CAN-SPAM and other laws regulating unsolicited commercial email. Violations of these policies may result in immediate termination of service and legal action against any senders or initiators of such messages.

Centricity offers email masking and relay when Members choose to communicate with other Members on Networks to reduce third party email harvesting of email addresses for purposes of sending unsolicited commercial email ("spamming").

14. THIRD-PARTY SERVICE

The Centricity Platform, and Networks, may contain links to websites and services provided by third parties. Any Personal Information you provide on third-party sites or services is provided directly to that third party and is subject to that third party's policies governing privacy and security. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links are displayed on the Centricity Platform or on Networks. We encourage you to learn about third parties' privacy and security policies before providing them with Personal Information.

15. INTERNATIONAL USERS

The Centricity Platform is hosted in the United States. If you use the Centricity Platform from the European Union, or any other region with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal data to the United States. The United States does not have the same data protection laws as the European Union and other regions. By providing Personal Information under this Privacy Policy, you consent to the use of Personal Information in accordance with this Privacy Policy and the transfer of your Personal Information to the United States.

16. CHANGES AND UPDATES TO THIS PRIVACY POLICY

We may occasionally update this Privacy Policy. If we do, we will update the "effective date" at the top of the Privacy Policy. We encourage you to periodically review this Privacy Policy to stay informed about our collection, use, and disclosure of Personal Information on the Centricity Platform. Your continued use of the Centricity Platform constitutes your agreement to this Privacy Policy and any updates.

17. CONTACTING CENTRICITY

If you have questions about this Privacy Policy, you may contact us at privacy@centricityhq.com.

You may also write to us at:

Centricity LLC

855 N. Douglas St

El Segundo, CA 90245

Attn: Privacy Matters