
Howsimple (the “Company”) is committed to complying with all laws intended to protect your right of privacy. This Privacy Policy describes (i) the type of information about you that we collect; and (ii) the Company's practices with respect to gathering and disseminating information about you. This Privacy Policy was established within the context of our website, the services offered through it, and the potential for gathering personal information within electronic media. Our Privacy Policy applies whenever you and the Company interact and there is a possibility that during such interaction, we may acquire certain information about you. The Company’s policy is to respect and protect the privacy of its users. This Privacy Policy describes how we collect information from you and how we use it. The Company may, but is not obligated to, update this Privacy Policy from time to time. You should review this Privacy Policy periodically to familiarize yourself with the most current version. 1. How And When Does the Company Collect Non-Public Personal Information? In the course of you using our website, or any of the services offered through it, we may collect and maintain certain nonpublic personal information that will help us to efficiently perform various tasks or transactions. We do not collect personal information (such as names, addresses, phone numbers, email addresses or credit card numbers) about you except when you specifically provide your information on a voluntary basis. Your personal information may be collected as you: • Become a registered user of our services; • Subscribe for products or services that we may periodically make available; • Participate in a special promotion or contest. Subject to the provisions in Section 2 below (Special Policy for Teens) If you are age 13 or older, the information provided at the time of registration may be used for marketing and promotional purposes by the Company, our affiliates, partners or other companies that have been prescreened by us. You may opt-out of the following services at any time: (1) sharing your information in our member directory, (2) receiving communications from the Company about new features or services, and (3) receiving communications about offers from third-party companies that offer a product or service that we think would be of value to you. If you object to such use for any reason, you may stop that use by modifying your member information online. Information provided when purchasing other services or products offered by or through the Company may be used for marketing and promotional purposes and is subject to the opt-out process described on, or linked to, each order form provided to you in connection with your purchase of any such products or services. 2. Special Policy for Teens (Users 13 to 17 years of Age). Teens (users 13 to 17 years of age) are required to provide the e-mail address of a parent or legal guardian at the time of registration. As part of the registration process, a notification message is sent to the user’s parent or legal guardian, which identifies all information provided at registration and allows the parent or legal guardian to be aware of, and participate in the user’s online experience. 3. Special Policies for Kids (Users under 13 Years of Age). The Company strongly encourages parents and legal guardians to be aware of their children’s online activity and to spend time online with them. Direct participation with your children in online activities is an effective method for assisting them to develop safe and responsible practices when engaging in online activities. No information should be submitted to, or posted on the Company’s site by any user under 13 years of age, without the prior written consent of their parent or legal guardian. Unless otherwise disclosed during collection, the Company does not provide any non-public, personally identifying information, regardless of its source; to any third party for any purpose whatsoever from our users under the age of 13. All registrants receive an e-mail confirming their registration. In addition, when a user under 13 registers, he/she is required to provide the e-mail address of his or her parent or legal guardian and that parent or guardian receives an e-mail alerting them to their child’s registration. No information collected from users under 13 years of age is used for any marketing or promotional purposes whatsoever, either inside or outside the Company except as explicitly stated during registration for contests or promotions (and in that case, the information collected is used only for the specific contest or promotion). Although users under 13 years of age may be allowed to participate in some contests and promotions, if such a user wins, notification and prizes are sent to the parents or legal guardians identified in the initial registration process. Publication of contest winner’s names, ages, or images for individuals less than 13 years of age requires prior written consent by the winner’s parent or legal guardian. We do not allow users less than 13 years of age to be listed in our member directory, or to receive direct marketing communications from the Company, or to be sent from our third-party offers. 4. How and When Does the Company Use Non-Public Personal Information? The Company will not disclose your personal information to third parties without your prior written consent. Your consent may take the form of an email, or by clicking on an “opt-in” button that we send to you, or in some other fashion that creates a written record of your consent. The Company may disclose information about any or all of its users in special cases, such as when we have a reasonable basis to believe that disclosing such information is necessary to identify, contact or bring legal action against someone who may be causing injury to, or interference with (either intentionally or unintentionally) the Company’s rights or property, other users, or anyone else that could be harmed by such activities. In addition, the Company may disclose user information to law enforcement agencies, judicial or governmental authorities, or to individuals or entities in response to subpoenas, court orders or other, legal processes issued by courts or governmental agencies having competent jurisdiction. If you are a registered user of our service, we may retain your information as long as you maintain your registered status. We occasionally purge our computer system of information relating to users and their past activities and transactions. In addition, we may purge your account information upon our determination that you have willfully violated any provision of our Terms of Service or if you otherwise have had extended periods of inactivity, at our sole discretion. 5. What Is “Aggregate Information” and What Does the Company Do With It? Typically, as a user browses our website, or uses services offered through it, our computers automatically collect information related to how certain features of our services are used, what general region our users are contacting us from and how many people visit our website and/or use our services at any given time. We only use this information in the aggregate, which means that we only derive meaning from the sum of all such information gathered for a specified period of time. Accordingly, we refer to this information as “Aggregate Information”. Aggregate Information includes, but is not limited to, your computer's (i) Internet browser type (ii) IP address, (iii) resolution settings, (iv) platform type, and (v) originating URLs of referring web pages. We use Aggregate Information to (a) help diagnose problems with our computers, (b) administer our website, (c) share certain generalized demographic information with our advertising partners, business partners, sponsors and other third parties, (d) provide our partners with information regarding which visitors saw and clicked on certain advertisements, all with the intent of delivering a better experience for you. Aggregate Information does not contain any personal information of any of our users. 6. Use of IP Addresses. The Company collects IP addresses for the purposes of system administration, to report Aggregate Information to our advertising partners, business partners, sponsors and other third parties and to audit the use of our website. When users request pages from Company sites, our servers log the users' IP addresses. We do not normally link IP addresses to anything personally identifiable, which means that a user's session will be logged, but the user remains anonymous to us. We can and will use IP addresses to identify a user when we feel it is necessary to enforce compliance with our Terms of Service or to protect our service, website, advertising partners, business partners, sponsors and other third parties or other users. Some services provided by or through the Company, such as certain message boards, may display IP addresses along with the message poster's name and message. Please review each service prior to use and only use those that disclose information you are comfortable with sharing. 7. What Are “Cookies” and How Does the Company Use Them? The term “cookie” is a nickname for files that a website's computer system can deposit onto a user’s computer hard drive when the user is logged on to the website. Cookies are used to recognize a user’s repeat visits to the website and what pages are accessed and what functionalities are used while he or she is there. The use of cookies is commonplace on the Internet and they take up minimal room on your computer hard drive. Cookies work by assigning a number to your computer that has a specific meaning to the assigning website. Cookies, by themselves, cannot be used to find out the identity of any user. Unless you choose to provide us with information about you, we will never know who you are, even though our computer has previously deposited a cookie on your computer's hard drive. Other companies that advertise on our website also have the ability to deposit a different cookie on your computer's hard drive in a process that we do not control. Since cookies aren't useable for identifying individuals (i.e., we will not store non-public personal information in a cookie), these advertisers will never know who you are. We use the information from cookies to provide services better tailored to our users needs. The Company has two primary uses for its cookies. First, we use them to specify unique preferences. For example, in the Howsimple News Center™, users can specify keywords across several news categories. This way you don't have to tell us over and over again about the kinds of news stories you want to see. Secondly, we use cookies to track user trends and patterns. This helps us better understand and improve areas of the Howsimple service that our users find valuable. While both of these activities depend on the use of a cookie, users always have the option of disabling cookies via their browser preferences. Almost all browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or indicate when a cookie is being sent. However, note that some parts of the our services will not function properly or may be considerably slower if you refuse cookies. For example, without cookies, you will not be able to set personalized news preferences, or you may have difficulty completing shopping transactions, entering contests, or playing games. You may occasionally get cookies from our advertisers. The Company does not control these cookies. The use of advertising cookies sent by third-party servers is standard in the Internet industry. 8. Links to Other Websites. Users should be aware that when you are on the Howsimple website, you could be directed to other sites that we do not control. There are links to other sites from specific pages of the Howsimple website that will take you outside our service. For example, if you click on a banner advertisement or a Howsimple search result, the click will take you off the Howsimple website. This includes links from advertisers, center sponsors and partners that may use the Company’s logos as part of a co-branding or similar agreement. These other sites may send their own cookies to users, collect data, or solicit personal information. We are not aware of and are not responsible for the privacy policies, practices, or content of any such other website. Users are strongly encouraged to read and become familiar with the privacy policies maintained by such other websites. Please keep in mind that whenever you give out personal information online, for example, via message boards or chat, that information can be collected and used by people you don't know. While the Company strives to protect its user's personal information and privacy, we cannot guarantee the security of any information you disclose online and accordingly, you acknowledge that you are providing all any and all such information at your own risk. The Company’s Privacy Policy does not extend to anything that is inherent in the operation of the Internet, and therefore beyond the Company’s control. Accordingly, it is not to be applied in any manner contrary to applicable law or governmental regulation. 9. Security Control The importance of security for all personally identifiable information associated with our users is of utmost concern to us. We exercise great care in providing secure transmission of your information from your PC to our servers. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, the Company can't ensure or warrant the security of any information you transmit to us, or from our online products or services. Accordingly, you acknowledge that you are transmitting such information at your own risk. Once we receive your transmission, we make our best effort to ensure its security on our systems. Your Howsimple account is password protected, so that only you can access it and view the member information relevant to that account. We recommend that you do not divulge your password to anyone. The Company will never ask you for your password in an unsolicited phone call or email. Ultimately, you are responsible for maintaining the secrecy of your password(s) and any account information. Remember to log off and close your browser window when you have finished your session. This is to ensure that others cannot access your personal information and correspondence if your computer is accessible to others, or if you share a computer with someone else, or if you are using a computer in a public place like a library or Internet café. 10. Your Consent to the Terms of This Privacy Policy. By using this website or any of the services offered through it, you signify your consent to the terms of our Privacy Policy. If you do not agree with any term or provision of this Privacy Policy, please do not use our any site or any service offered by or though them. The Company will post changes to these this Privacy Policy from time to time and make a general announcement to users about a posted change. Your continued use of the Howsimple websites, or any service offered through them, following the posting of changes to this Privacy Policy will be deemed to be your consent to all such changes. © 2011 Howsimple, LLC. All Rights Reserved.