SPIRAL16 PRIVACY POLICY

Spiral16, LLC (“Spiral16″) is committed to safeguarding your privacy on its Web site located at http://www.spiral16.com. This Spiral16 Privacy Policy does not apply to services provided, or information obtained, other than through the Web site. Please read the following policy to understand how your information will be treated. This policy may change from time to time so please check back periodically. If there is a material change in the collection, use, or disclosure practices to which you have previously agreed, we will attempt to send you a notice via e-mail if you have provided us with an e-mail address. Please keep in mind that some of the services mentioned specifically in this policy may not be available on the site at this time. If you have questions concerning this policy, please contact support@spiral16.com. This Privacy Policy is effective as of 09/30/2011.

What information does Spiral16 collect from me?

Spiral16 collects information in several ways. For example, if you are an authorized user of an organization with an Access Agreement with Spiral16, certain of your information is provided by that organization, such as name and email address. When you accept your role as an authorized user of that organization, you may verify and update your information. We may also ask for addition information. In addition, some personal information is gathered when you register as a user using our user registration area. During registration, we may ask for your name, city and state, e mail address, and other such information. In addition to registration, we may ask you for information at other times, such as when you report a problem with our site, or contact the company via the corporate e-mail address. If you contact Spiral16, we may keep a record of that correspondence.

If you believe that any inaccurate or inappropriate information has been obtained or disseminated through your use of this Web site, you should contact a representative of Spiral16 at support@spiral16.com.

What are cookies and how does Spiral16 use them?

As part of offering and providing customizable and personalized services, many Web sites use cookies to store and sometimes track information about you. A cookie is a small amount of data that is sent to your browser from a Web server and stored on your computer’s hard drive. We use cookies to allow faster and easier access to your registered account, your organization’s account, monitor traffic on the site and measure traffic patterns to improve functionality. Spiral16 Web pages may in the future contain electronic images known as Web beacons (sometimes called clear giffs or Web bugs) or other advanced technologies that are useful in the provision of services to you. We may use such devices to verify compliance with our terms and conditions of use or with any promotions on the site. You may be required to enable cookies in order to use some functions of our site.

How does Spiral16 use the information?

Spiral16′s primary goal in collecting information is to improve the site and provide the user with the best possible experience on the site. We will also use your personal information to notify you of other products or services available from Spiral16 and its affiliates.

Except as provided in this Privacy Policy, only Spiral16, the organization for which you are an authorized user and their affiliates and service providers, will have access to individuals’ account information. We also may do research on our users’ demographics and behavior based on the information provided to us upon registration, gathered from transaction activity, from our server log files or from surveys. This research may be compiled, analyzed or sold on an aggregated basis, which does not include information identifying individual users. Spiral16 also may share this data with business partners or other third parties.

Who is collecting information?

When you are on a Spiral16 site and are asked for personal information, you are sharing that information with Spiral16 and its affiliates and service providers as well as the organization affiliated with your authorized user account. If personal data is to be collected and/or maintained by any company other than Spiral16 or its affiliates or your organization, we will attempt to notify you on the Web site or in an updated version of this Privacy Policy. If you do not want your data to be shared, you can choose not to allow the transfer by not using that particular service.
Please be aware that other Web sites to which we link may collect personally identifiable information about you when you visit those sites. The information practices of other Web sites linked to our Web sites are not covered by this Privacy Policy.

With whom does Spiral16 share my information?

We will not disclose any of your personally identifiable information except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under the circumstances described below. The following describes some of the ways that your information may be disclosed.
Data in the Aggregate: We may disclose “blinded” aggregated data and user statistics to prospective partners and other third parties, and for other lawful purposes. Blinded data is data which does not identify an individual person.
Other: We also may disclose your information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Use, or may otherwise be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other website users or customers, or anyone else that may be harmed by such activities. We may disclose or access account information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service and improve our products and services.

We occasionally hire other companies to provide limited services on our behalf, including packaging, delivering or mailing, answering customer questions about products or services, sending postal mail, providing investor information and processing data. We will only provide those companies the information they need to deliver the service, and they are contractually prohibited from using that information for any other purpose.

As we continue to develop our business, we may buy or sell businesses or assets. In such transactions, confidential customer information generally is one of the transferred business assets. In the event of a transaction involving the sale of some or all of Spiral16′s businesses, customer and site visitor information will likely be one of the transferred assets and may be disclosed in connection with negotiations relating to a proposed transaction. In such case, the transferred information may become subject to a different privacy policy.

How can I control my personal information?

Spiral16 offers its customers choices for the collection, use and sharing of personal information. You may contact us at 913-944-4500 if you wish to view, edit or delete your personal information from our database, and we will use commercially reasonable efforts to accommodate your request.

What security precautions are in place to protect against the loss, misuse or alteration of my information?

Your account is password-protected so you have access to this personal information. Remember to sign out of your Spiral16 account and close your browser window when you have finished your work. This is to ensure that others cannot access your account by using your computer when you are away from it. Because information sent through the Internet travels from computer to computer throughout the world, when you give us information. That information may be sent electronically to servers outside of the country where you originally entered the information. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Except as specifically designated, this site does not use security encryption measures. Therefore, information that you disclose by use of this site (as with any site that is non-secure), by posting a message or using e mail, potentially could be collected and used by others. This may result in unsolicited messages from third parties or use of such information by third parties for their own purposes, legal or illegal. As a result, while we strive to protect your personal information, Spiral16 cannot ensure or warrant the security of any information you transmit to us or from our services, and you do so at your own risk. Once we receive your transmission, we use commercially reasonable efforts to ensure its security on our systems.

Choice/Opt-out

To ensure that you will not receive recurring marketing information from us unless you choose to, we will provide you with simple instructions on each marketing email from Spiral16 for you to let us know that you have chosen to stop receiving such emails from us.

What else should I know about my privacy?

Please keep in mind that whenever you voluntarily disclose information online, that information is accessible to other customers and users. Ultimately, you are solely responsible for maintaining the secrecy of your passwords and/or any account information. Please be careful and responsible whenever you are online.
When you or we end your customer relationship with us, we will treat the information we have about you as if you were still our customer.