KeepSafe Privacy Policy

Version 2.0

July 30, 2014

KeepSafe Software Inc. ("KeepSafe") is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our site, located at www.getkeepsafe.com ("Site") and mobile application ("App") and our Service (as defined in the Terms of Service). Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Service located at www.getkeepsafe.com/termsofservice

1. User Consent.

By submitting Personal Data through our Site or Service, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.

2. A Note About Children.

We do not intentionally gather Personal Data from visitors who are under the age of 13.

3. A Note to Users Outside of the United States.

Your Personal Data may be transferred to and processed in the United States. With respect to our collection and processing of Personal Data about individuals in the European Union, we comply with the United States/European Union Safe Harbor Framework as set forth by the U.S. Department of Commerce ("Safe Harbor") and have certified our adherence to the U.S./EU Safe Harbor Privacy Principles (the "Safe Harbor Principles"). For more information regarding Safe Harbor, please visit the United States Department of Commerce Safe Harbor website at http://www.export.gov/safeharbor .

4. Types of Data We Collect. "Personal Data"

means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. "Anonymous Data" means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

(a) Information You Provide to Us

• We may collect Personal Data from you, such as your e-mail address, and password when you create an account to log in to our network (" Account").
• When you order the Service on our Site or App, we will collect all information necessary to complete the transaction, including your name, payment information, billing information and shipping information.
• We retain information on your behalf, such as files and messages that you store using your Account.
• If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
• When you participate in one of our surveys, we may collect additional profile information.
• When you post messages on the help forums or message boards of our Site, the information contained in your posting will be stored on our servers and other users will be able to see it.
• We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Service.
• We may also collect Personal Data, such as at other points in our Site or App that state that Personal Data is being collected.

(b) Information Collected via Technology

• To make our Site and App more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your mobile device type, application version, browser type, computer or mobile operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer or mobile device when you use the Internet, which may vary from session to session), domain name, information about the way you use the application and/or a date/time stamp for your visit of the Site or use of the App.
• We also use cookies, URL information and mobile analytics tools to gather information regarding the date and time of your visit of the Site or use of the App and the information for which you searched and which you viewed. "Cookies" are small pieces of information that a website sends to your device's storage while you are viewing a web site or using our App. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience on our Site and App. Persistent Cookies can be removed by following Internet browser help file directions or by clearing application specific information on your mobile device.

(c) Information Collected from You About Others . If you decide to invite a third party to create an Account, we will collect your and the third party's names and e-mail addresses in order to send an e-mail and follow up with the third party. You or the third party may contact us at [email protected] to request the removal of this information from our database.

(d) Information Collected from Social Networking Sites. If you log on to the Service with your login credentials from a social networking site (e.g., facebook or twitter), we may receive Personal and/or Anonymous Data about you from such social networking site, in accordance with the terms of use and privacy policy of the third party provider of such social networking site. For example, facebook may share your friend list with us, in order to help us establish your Account and find other Service users that you know. We may add this information to the information we have already collected from you via the Service.

5. Use of Your Personal Data

(a) General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We will only use Personal Data in ways that are compatible with the purposes for which it was collected or as subsequently authorized by you. We use your Personal Data in the following ways:

• to facilitate the creation of and secure your Account on our network;
• identify you as a user in our system;
• provide improved administration of our Site, App and Service;
• provide the services you request;
• improve the quality of experience when you interact with our Site, App and Service;
• send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
• send you administrative e-mail notifications, such as security or support and maintenance advisories;
• respond to your inquiries related to employment opportunities or other requests;
• to send newsletters, surveys, offers, and other promotional materials related to our Service and for our other marketing purposes.

(b) Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that make the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Service and improve Site navigation.We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

6. Disclosure of Your Personal Data.

We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

(a) Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Service that we offer you through our Site or App; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide us with other services. These third party service providers are required not to use your Personal Data other than to provide the services we request. We require our third party service providers that have access to any Personal Data that you provide from the European Economic Area to provide at least the same level of privacy protection as is required by the applicable Safe Harbor Principles. Where we have knowledge that a service provider is using or disclosing Personal Data in a manner contrary to this Privacy Policy, we will take reasonable steps to prevent or stop the use or disclosure of such Personal Data.

(b) Affiliates and Acquisitions . We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (" Affiliates"), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company, business, or our assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy. In the event of an insolvency, bankruptcy or receivership, your Personal Data may also be transferred on a standalone basis.

(c) Other Disclosures . Regardless of any choices you make regarding your Personal Data (as described below), we may disclose Personal Data if we believe in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on KeepSafe; (c) to protect or defend the rights or property of KeepSafe or users of the Service; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or Terms of Service.

7. Third Party Data Collection.

(a) Information Disclosed to Analytics Companies and Ad Networks. We may work with analytics companies to help us understand how our Site, our Service and our App are being used, such as the frequency and duration of usage. We may also use third-party advertising companies to serve ads when you visit our Site or App. These companies may use some of the information collected by the Site or the App, including the unique identification ID of your mobile device. To protect the anonymity of this information, we limit data sharing to ensure these companies can't identify you personally based on the information we provide. These companies may also obtain information about other applications you have downloaded to your mobile device, the mobile websites you visit, your non-precise location information (e.g., you zip code) and other non-precise location information in order to help analyze and service anonymous targeted advertising on the Site and App and elsewhere.

(i) Opt-Out Rights. Some of the analytics companies and third party advertising companies used on this Site may place "tracking cookies" on your computer. If you would like more information about this practice or to opt-out of having this information used by third-party ad servers that are part of the Network Advertising Initiative ("NAI") or the Interactive Advertising Bureau ("IAB"), please visit:

NAI: http://www.networkadvertising.org/managing/opt_out.asp

IAB : http://www.youronlinechoices.com/opt-out

(b) Third Party Websites. When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.

8. Your Choices Regarding Your Personal Data

(a) Choices. We offer you choices regarding the collection, use, and sharing of your Personal Data.

(i) We may periodically send you free newsletters and e-mails that directly promote the use of our Site, App or Service. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below).

(ii) Despite your indicated e-mail preferences, we may send you service related communication, including notices of any updates to our Terms of Service or Privacy Policy.

(b) Changes to Personal Data. You may change any of your Personal Data in your Account by editing your profile within your Account. You may request deletion of your Personal Data by us, but please note that we may be required to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may retain your information for fraud or similar purposes.

9. Security of Your Personal Data.

We are committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we use reasonable efforts to protect your Personal Data, we cannot guarantee its absolute security.

10. Enforcement.

We conduct periodic self-assessments to verify that we comply with the Safe Harbor Principles, that the attestations and assertions we make about our privacy practices are true, and that such privacy practices have been implemented as presented in this Privacy Policy. We will take reasonable steps to remedy any non-compliance with the Safe Harbor Principles found as a result of any self-assessment.

11. Dispute Resolution.

If you have any complaints regarding our adherence to this Privacy Policy or our compliance with the Safe Harbor program, please first contact us by e-mail at [email protected]. We will investigate and attempt to resolve any such complaints in accordance with the principles contained in this Privacy Policy . If the complaint cannot be or is not adequately resolved through our internal dispute resolution process, you may submit your complaint to the American Arbitration Association ("AAA"). Unless otherwise agreed upon by the parties in writing, the arbitration will be governed by the AAA's Commercial Arbitration Rules and, if the arbitrator deems them applicable, the Supplementary Procedures for Consumer Related Disputes. For more information on AAA, its Rules and Procedures, and how to file an arbitration claim, you may call AAA at 800-778-7879 or visit the AAA website at http://www.adr.org

12. Contact Information.

We welcome your comments or questions regarding this Privacy Policy. Please e-mail us at [email protected]

13. Changes to This Privacy Policy.

This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Site. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Service. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Privacy Policy may affect our use of Personal Data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Continued use of our Site, App or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.