CONFIDANT SOLUTIONS, INC. PRIVACY POLICY
EFFECTIVE DATE: November 1, 2009


Your privacy is extremely important to us. This privacy policy (“Privacy Policy”) sets forth what information about you (“You”) Confidant Solutions, Inc. (“Confidant”) collects, as well as how that information is used, maintained, and, in some cases, shared. It is designed to help you make informed decisions when using the Confidant Services (as defined in the Terms of Service, available here: Terms of Service). By using or accessing the Confidant Services, you accept the practices described in this Privacy Policy.

The Information We Collect
When you access the Confidant Services you provide us with two types of information: (1) personal information that you knowingly choose to disclose to Confidant, and (2) website use information collected by Confidant as you interact with the Confidant Services.

When you register for and make use of an Account (as defined in the Terms of Service), you provide us with certain personal information, such as your name, company, phone number, email address and credit card type, number, and expiration date, and other information that you may provide depending upon how you sign up for the Confidant Services.

The Confidant Services also employ browser cookies and other technologies to collect information about users, such as their IP address, the type of browsers used, web pages viewed, and other information. We take measures to ensure that our cookies do not collect personally identifiable or sensitive information. The aggregate information we collect is analyzed and may be combined with similar aggregate information of other visitors to our website. You may set your browser to reject cookies; however, this may affect some functions of the Confidant Services.

Use of Information Obtained by Confidant Solutions
We use your name, company, phone number, and email address for the purpose of communication with you regarding the Confidant Services. We use your name, company, phone number, email address and credit card type, number, and expiration date for the purpose of billing you for your use of the Confidant Services. We may use your name, company, phone number, email address and information regarding your use of the service for the purpose of identifying and offering to You relevant products and services but in no case do we rent, sell or share this information with third parties. If you create a profile on the Confidant Services, a user name of your choice will be viewable to other users with whom you establish contact in using Confidant. Confidant can also identify your IP address, but your IP address will not be visible to other users of the Confidant Services.

Cancelling your Account and deleting your data
When you request us to cancel your Account and delete your data for the Confidant Services, your data will be permanently expunged from our primary production servers and further access to your Account will not be possible.

We will also delete all account credentials. However, portions of your data, consisting of data entered by you or others in connection with your use of the Confidant Services, as well as aggregate data derived from your Account Information, may remain on our production servers indefinitely. Your data may also remain on a backup server or media due to the inherent difficulty in deleting data across multiple backup files in different locations. We also reserve the right to use any aggregated or anonymous data derived from or incorporating your personal information.

Sharing Your Information with Third Parties
We do not share, rent, or sell your personal information with third parties for the purposes of marketing third-party products and services to you.

However, in limited circumstances we may share personal information for the purposes of providing the Confidant service to You. For instance, when You conduct payment transactions through our Website, a third-party service provider will process such transactions. The third-party service provider may retain your credit card information indefinitely in its database for future transactions, but will process such transactions consistent with applicable laws and regulations. The third party service provider’s privacy policy will apply to data communicated during these transactions. Our third-party service provider will provide your name, billing address, and credit card information, along with the amount to be charged, to the bank that processes your credit card for billing purposes.

We share your information with third parties only in limited circumstances where we believe such sharing is (1) legally required, (2) done to comply with a request from a government agency, (3) done in conjunction with a corporate restructuring, (4) done to protect against fraud or other damage users of Confidant Services, or (5) otherwise permitted by you. For example:
We may provide information to service providers to help us provide services through the Confidant Services. In connection with this, our service providers may have access to your personal information for a limited time. Where we utilize third parties for the processing of any personal information, such as in conjunction with processing a payment from your credit card, we implement reasonable contractual and technical protections limiting the use of thatinformation to the Confidant-specified purposes.
We may be required to disclose user information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We do not reveal information until we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. Additionally, we may share account or other information when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Confidant Services or using the Confidant name, or to prevent imminent bodily harm. This may include sharing information with other companies, lawyers, agents or government agencies.
Like many other websites that interact with third-party sites, we may receive some information even if you are logged out from our Website from those sites in conjunction with the technical operation of the system. In cases where Confidant receives information on users that are not logged in we do not attempt to associate it with individual Confidant users or Accounts and will discard it.
If the corporate structure of Confidant were to change, your user information may be transferred to the new entity. Confidant does not guarantee that such entity receiving such information in connection with such a transaction will maintain all terms of this policy though Confidant will require such entity to give You advance notice of any changes to this Privacy Policy due to such transfer.


Communications Services
You may also choose to use Communications Services (as defined in the Terms of Service and similar areas of our website [currently labeled the “Learning Center” and viewable at the bottom of the Confidant application] that allow you to post information to our website yourself. Any information that you post on our website is posted at your own risk. We cannot control the actions of other website users who will have access to this information. Therefore, we cannot and do not guarantee that any information you post on the website will not be viewed by unauthorized persons. We are not responsible for circumvention of any security measures contained on the website. You understand and acknowledge that, even after removal, copies of any information you post may remain viewable in cached, archived, and saved pages.

Transfer of Information Out Of European Economic Area
If you use our website outside of the United States, information that we collect about you will be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area. By allowing Confidant to collect information about you, you consent to such transfer and processing of your data.

Children Under Age 13
Confidant does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have information from a child under 13, please contact us at: info@confidantsolutions.com.

Links
Our Website may contain links to other websites. Confidant is not responsible for the privacy practices of other websites. We encourage our users to be aware when they leave our website to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by Confidant.

Changing or Removing Information
You may modify or delete any personal information that you have provided to Confidant through our Website.

Security
Your personal information is located on secured servers behind a firewall. Because email is not recognized as a secure communication method, we request that you not send private information to us by email. If you have any questions about the security of the Confidant Services, please contact us at info@confidantsolutions.com.

Terms of Service, Notices and Revisions
Your use of the Confidant Services, and any disputes arising from it, is subject to this Privacy Policy as well as our Terms of Service. We reserve the right to change this Privacy Policy at any time. If we make changes, we will post them and will indicate at the top of this page the policy’s new effective date. We encourage you to refer to this policy on an ongoing basis so that you understand our current privacy policy.

Contacting Us
If you have any questions about this Privacy Policy, please contact us at info@confidantsolutions.com.
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