Vertecto Services, LLC ("Vertecto") is committed to protecting your privacy. Vertecto owns, operates, or provides access to, several websites (collectively "Vertecto Websites"). This Privacy Policy applies only to websites owned and operated by Vertecto.

This Privacy Policy describes, among other things, the types of information collected about you when you visit a Vertecto Website, how your information may be used and when it may be disclosed, how you can control the use and disclosure of your information; and how your information is protected. THIS PRIVACY POLICY RELATES TO THE USE OF THE VERTECTO WEBSITES BY MEMBERS AND NON-MEMBERS. MEMBERS OF VERTECTO MAY HAVE ADDITIONAL RIGHTS WITH RESPECT TO FINANCIAL AND/OR BUSINESS INFORMATION PROVIDED TO VERTECTO IN CONNECTION WITH THE USE OF THE VERTECTO TRANSACTION PROTECTION SYSTEM AND RELATED ACCOUNTS.

1. Scope of Privacy Policy

This Privacy Policy applies to personal information, including contact information, collected about you by a Vertecto Website. This Privacy Policy does not cover any information collected through any other website.  We are not responsible for the privacy practices of sites which we do not own and operate, including websites that you you may link to from any Vertecto Website and we recommend that you visit the privacy policies of every website that you visit.

2. Information Collected

Information you provide directly to Vertecto Websites. You are not required to provide information about yourself when you visit a Vertecto Website. Vertecto Websites may ask you for some or all of the following types of information when you register for certain services, access various content or features, or directly contact the Website:

· Contact information, such as name, email address, postal address, phone number, facsimile number, and mobile number;

· User name, password, and password reminder questions and answers;

· Certain demographic information;

· Information for a public profile, such as the address of your website;

· Communications preferences, such as which newsletters you would like to receive;

· Search queries;

· In limited circumstances, payment and identity verification information, such as credit card number, social security number or comparable national identifiers, and driver's license number where needed for payment or to access a particular service (e.g., contests);

· Contact information about others when you provide information about others or refer a friend to a particular site or service;

· Information posted in community discussions and other interactive online features;

· Correspondence you send to us; and

· Information collected about you offline (including via facsimile, mail, or in person).

Information we may collect automatically on Vertecto Websites. Vertecto Websites may collect certain information automatically, including:

· Your browser type and operating system;

· Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;

· Sites you visited before and after visiting a Vertecto Website;

· Web pages and data you view and links you click on within Vertecto Websites;

· Unique identifiers, including mobile device identification numbers that can identify the physical location of such devices in accordance with applicable law;

· Information about your interactions with email and other messages, such as the links clicked on and whether the messages were opened or forwarded; and

· Standard server log information.

Information we obtain from other sources. We may collect information about you from other sources, including from commercially available sources (such as data aggregators and public or quasi-public publications and databases).

3. Use of Information

We only use payment and identity verification information as necessary for completing a particular transaction or fulfilling a service  or as otherwise required by law.

We generally use other information we collect about you to:

· Fulfill your requests for products, services, and information, including to send you electronic newsletters, updates and notices, authorize a purchase, and complete a transaction that you have requested;

· Enable you to participate in features such as surveys, polls, databases, and message boards;

· Provide you with special offers and promotional materials on behalf of Vertecto Websites, companies within our corporate family, and third parties, in accordance with applicable law;

· Analyze the use of Vertecto Websites and information about visitors to our Websites to understand and improve our service offerings;

· Customize the content you see when you visit a Vertecto Website;

· Develop and provide advertising tailored to your interests;

· Prevent potentially prohibited or illegal activities and otherwise in accordance with Vertecto's Terms of Use; and

· For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

4. Disclosure of Information

Vertecto is committed to maintaining your trust and we want you to understand when and with whom we may share information collected about you.

· With your consent. You may be asked to consent to have your contact information shared with third-party business partners.

· Authorized third-party service providers. We may share your information with third-party vendors who help us with specialized services, including customer support, email and text message deployment, business analytics, marketing, and data processing. These third parties are allowed to use your contact information to help us provide our services and not for any other purpose.

· Co-Branded Partners. Co-Branded Partners are third parties with whom a Vertecto Website may jointly offer a service or feature. You can tell when you are accessing a service offered by a Co-Branded Partner because the Co-Branded Partner's name will be featured prominently. You may be asked to provide information about yourself to register for a service offered by a Co-Branded Partner. In doing so, you may be providing your information to both us and the Co-Branded Partner, or we may share your information with the Co-Branded Partner. Please note that the Co-Branded Partner's privacy policy may apply to its use of your information.

· Vertecto Websites and other Vertecto businesses. We may share information we collect about you within the family of Vertecto Websites and with other affiliated companies, so we can provide you with information about products and services that might interest you.

· Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a Vertecto Website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

· Legal requirements. We may disclose information about our users, including contact information, to respond to subpoenas, court orders, legal process, and other law enforcement measures, and to comply with other legal obligations.

· Protect our Websites and users. We may disclose information to protect and defend the legal rights, interests, and safety of Vertecto Websites, other Vertecto companies, and their employees, agents, and contractors (including enforcing our agreements); to protect the safety and security of users of the Websites and members of the public; and as otherwise disclosed or described in our Terms of Use.

We also may share aggregated or anonymous information with third parties, including to help us develop content and services we hope you will find of interest. This information cannot be used to individually identify you.

5. Options

You can use the content and features on Vertecto Websites without directly providing us with any information about you; however, as described above, some information may automatically be collected or may be requested so you can take advantage of certain features and services offered on Vertecto Websites.

You can opt out of receiving commercial email or text messages from a particular Vertecto Website or service by following the instructions contained in any such message. However, even if you unsubscribe to commercial messages available to the general public , we still may need to send you communications relating to your use of the Vertecto Websites, such as service announcements, messages and transaction related communications.

6. Access

If you choose to share contact information with us, you may have the opportunity to update that information on a Vertecto Website. You also may update or amend your information by contacting us using the contact information on our websites. If you ask us to shut down your account or delete your information, we will disable your account within a reasonable period of time. Please note that we may need to retain some information about you in order to satisfy our legal and security obligations. For example, some of your information may remain in back-up storage even if you ask us to delete it. In some cases, you may be entitled under local laws to access or object to the processing of information that we hold relating to you.

7. Protection of Information

We are committed to protecting your information. We have adopted commercially reasonable technical, administrative, and physical procedures to help protect your information from loss, misuse, and alteration. Please note that no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using Vertecto Websites but we cannot ensure or warrant the security of any information you transmit to us.

8. Visiting from Outside the United States

Vertecto is headquartered in the United States. Please be aware that information you provide to us or we obtain as a result of your use of the Vertecto Websites may be processed and transferred to the United States and be subject to United States law. The privacy and data protection laws in the United States may not be equivalent to such laws in your country of residence. By using and participating in any Vertecto Website or providing us with your information, you consent to the collection, transfer, storage, and processing of information to and in the United States.

9. California Visitors

Residents of the State of California may request a list of all third parties to which a Vertecto Website has disclosed certain information during the preceding year for the third parties' direct marketing purposes. If you are a California resident and want such a list, please contact us.  For all requests, you must put the statement "Your California Privacy Rights" in the body of your request and include the name of the Vertecto Website with respect to which you are requesting the information, as well as your name, street address, city, state, and zip code..

10. Privacy Protections for Children

Vertecto Websites are intended for business, governmental and NGO entities and do not knowingly collect or store contact information about children under the age of 13. Some Vertecto Websites may ask for a birth date to ensure that they are not collecting information from children under 13 or to identify when additional steps may need to be taken in connection with information collected from children under 18.

 11. User-Generated Content

Some Vertecto Websites enable users to submit their own content for databases, referencing message boards, and other functions. Any information you disclose becomes public information.  Exercise caution when deciding to disclose your contact, financial, pricing and other information in a submission. We cannot prevent such information from being used in a manner that may violate this Privacy Policy, the law, or your personal privacy and safety.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices and service offerings. If we modify our Privacy Policy, such changes will be effective upon posting. Check our policies often..

13. Questions

If you have questions regarding this Privacy Policy, please contact us and we will endeavor to respond to your request within a reasonable period of time. You may also submit questions or comments using the postal address listed below:

Vertecto Services, LLC
Brandywine Plaza West
1521 Concord Pike, Suite 301
Wilmington, DE 19803
Attn: Legal Department