Privacy Policy

Last modified: March 1, 2010

We recognize that privacy is important. So we will do our best to protect your private information.

Information we collect (but NOT any information our users collect with our products or services, e.g. Private Accouts registered with a user’s Hotspot, phone numbers required to be authenticated) and how we use it

  • Information you provide – When you sign up for an account or other service or promotion that requires registration, we ask you for personal information (such as your name, email address, phone number, postal address, account, etc)
    in order to provide you with a better experience and to improve the quality of our services.
  • User communications – When you send email or other communications to us, we may retain those communications in order to process your inquiries,
    respond to your requests and improve our services.
  • Sometimes, when you visit our web site, we send one or more cookies – a small file containing a string of characters –
    to your computer that uniquely identifies your browser.
    We use cookies to improve the quality of our service by storing user preferences and tracking user trends, such as user’s language.
    Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent.
    However, some features and services in our web sites may not function properly if your cookies are disabled.

In addition to the above, we process personal information for the purposes including:

  • Providing our services to users, including the display of customized content and advertising.
  • Auditing, research and analysis in order to maintain, protect and improve our services.
  • Developing new services.

Choices for personal information

When you sign up for a particular service that requires registration, we ask you to provide personal information.
If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.

If we propose to use personal information for any purposes other than those described in this Privacy Policy and/or in the specific service privacy notices,
we will offer you an effective way to opt out of the use of personal information for those other purposes.

You can decline to submit personal information to any of our services, in which case we may not be able to provide those services to you.

Information sharing

We only share personal information with other companies or individuals outside of us in the following limited circumstances:

  • We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
  • We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf.
    We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
  • We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to
    (a) satisfy any applicable law, regulation, legal process or enforceable governmental request,
    (b) enforce applicable Terms of Service, including investigation of potential violations thereof,
    (c) detect, prevent, or otherwise address fraud, security or technical issues, or
    (d) protect against imminent harm to the rights, property or safety of us, its users or the public as required or permitted by law.

If we become involved in a merger, acquisition, or any form of sale of some or all of its assets,
we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

We may share with third parties certain pieces of aggregated, non-personal information,
such as the number of users who searched for a particular term,
for example, or how many users clicked on a particular advertisement. Such information does not identify you individually.

Information security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data.

These include internal reviews of our data collection, storage and processing practices and security measures,
as well as physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to our employees,
contractors and agents who need to know that information in order to operate, develop or improve our services.
These individuals are bound by confidentiality obligations and may be subject to discipline,
including termination and criminal prosecution, if they fail to meet these obligations.

Data integrity

We process personal information only for the purposes for which it was collected and in accordance with this Privacy Policy
or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect,
store and process the personal information needed to provide or improve our services.
We take reasonable steps to ensure that the personal information we process is accurate, complete, and current,
but we depend on our users to update or correct their personal information whenever necessary.

Accessing and updating personal information

When you use our services, we make good faith efforts to provide you with access to your personal information and either to correct this data
if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes.
We ask individual users to identify themselves and the information requested to be accessed,
corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic,
require disproportionate technical effort, jeopardize the privacy of others,
or would be extremely impractical (for instance, requests concerning information residing on backup tapes),
or for which access is not otherwise required.
In any case where we provide information access and correction, we perform this service free of charge,
except if doing so would require a disproportionate effort. Some of our services have different procedures to access,
correct or delete users’ personal information. We provide the details for these procedures in the specific privacy notices or FAQs for these services.

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time.
We will not reduce your rights under this Privacy Policy without your explicit consent, and we expect most such changes will be minor.
Regardless, we will post any Privacy Policy changes on this page and,
if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).

Comments are closed.