SevenPonds, Inc. ("SevenPonds") values your trust and confidence and is committed to protecting your privacy. We want you to know that SevenPonds is not in the business of selling or renting individuals' personal data to other companies for marketing purposes. This SevenPonds Privacy Policy describes the privacy practices of SevenPonds and applies to data collected by SevenPonds through the www.SevenPonds.com domain name (the "Website"), as well as through SevenPonds' proprietary software and information and any other such service provided by SevenPonds (collectively the "Service").

Below you can find detailed information on when and why we collect personal information, how we use it and the limited conditions under which we may disclose it to others. Specifically, the information below how we handle the personal information, information that can be used to contact or identify a natural person ("Personal Information"), gathered by the Service.

Please read all information as provided below. SevenPonds welcomes any questions or comments you may have regarding this Privacy Policy or if you do not understand any information about how we collect, maintain, use or disclose Personal Information. Any such questions or comments, or if more information regarding any item not listed below is needed, should be submitted via email to WeCare@SevenPonds.com. We will make every effort to resolve or answer your concern.

Accessing Your Personal Information.

You may view or edit your Personal Information and preferences by visiting the Website and logging into your SevenPonds account (the "SevenPonds Account") online. From your SevenPonds Account, you can choose to receive or stop the delivery of future newsletters, promotional e-mail, and surveys from SevenPonds.

Please note that this does not apply to the display of online advertising, nor does this apply to the receipt of mandatory service communications that are considered part of the Service, which you may receive periodically unless you cancel your SevenPonds Account.

Collection of Your Personal Information.

When you open a user account with SevenPonds, we ask you to provide certain Personal Information, such as your name, e-mail address, home or work address, and/or telephone number. When you sign up for certain services we provide we may also collect general demographic information, such as your age, gender, zip code, preferences, and interests. We may also collect information about your visit to the Website, such as pages viewed, links clicked and other similar navigation action in connection with the Website.

When you receive promotional e-mails or newsletters from SevenPonds, we may use customized links or similar technologies to determine whether such newsletters or e-mail has been opened and which links you click. This information is used to provide you more focused e-mail communications and/or other information.

Personal Information that is Automatically Collected.

In addition to Personal Information you provide to us, SevenPonds may receive and store certain types of information whenever you interact with the Website or Service. SevenPonds may choose to automatically receive and record information on our server logs from your browser including your IP address, SevenPonds cookie information, and the page you requested.

Generally, our service may automatically collect usage information, such as the numbers and frequency of visitors to the Website and its components. We generally only use this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. SevenPonds may additionally automatically collect information about your visit to the Website, such as pages viewed, links clicked, and other similar navigation action in connection with the Website. Most Web browsers accept cookies, and if your browser accepts cookies, SevenPonds may automatically collect individualized information regarding your visits to the Website ("Individual Usage Information") to provide you with a more personalized user experience. As part of this use of information, we may provide aggregate information to our partners about how our users, collectively, use our websites. If you do not wish to have your Individual Usage Information collected, please see the "Use of Cookies" section below for further information.

Use of Cookies.

Cookies are alphanumeric identifiers that we may transfer to your computer's hard drive through your browser to enable our systems to recognize your browser and tell us how and when pages in our websites are visited and by how many people. SevenPonds use of cookies is only for more accurate traffic analysis. SevenPonds cookies do not collect Personal Information. However, we may combine the general information collected through cookies with other Personal Information in connection with our collection of Individual Usage Information (as described above). If you do not wish to have your Individual Usage Information collected, most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. However, if you choose to decline cookies, you may not be able use the Service.

From time to time, the Website may contain advertisements, references, and links to other websites and organizations, and may also use third parties to display or serve advertising on our site. SevenPonds has no access to or control over cookies of these links to other websites and organizations, nor does SevenPonds have control over or access to cookies by SevenPonds' third-party partners or advertisers. This Privacy Policy does not cover any use of Personal Information that a third-party advertiser or ad server may collect from you.

Use of Your Personal Information.

SevenPonds collects and uses your Personal Information to operate and improve the Website and better deliver the Service. These uses may include performing analysis aimed at improving the Service; making the Website or Service more user friendly by reducing the need for you to repeatedly enter the same information; and displaying advertising and content that are tailored to your preferences and interests.

SevenPonds may support the Website and the Service by advertising, and accordingly, we may use some of the information collected in order to customize the advertisements to your interests and preferences. However, the process of selecting customized ads tailored to you will use data that does not personally identify you, such as using demographic data such as zip code.

We also use your Personal Information to communicate with you, such as providing you with mandatory notices or discretionary notices about the Service. Personal information collected on the Website or through the Service may be stored and processed in the United States or any other country in which SevenPonds or its affiliates, subsidiaries or agents maintain facilities, and by using the Website or Service, you consent to any such transfer of information outside of your country.

Sharing of Your Personal Information.

We neither rent, lease, disclose, nor sell your Personal Information to anyone. Except as described in this Privacy Policy, your Personal Information will be used only by SevenPonds and its controlled subsidiaries and affiliates, and your Personal Information will not be disclosed to any other third party without your consent. By accessing your SevenPonds Account, you may choose to share your Personal Information with select SevenPonds partners so that they can contact you about their respective products, services or offers.

We share your Personal Information only with your consent or as described below:

Agents: We may employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, SevenPonds' agents do not have any right to use Personal Information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information for the above purposes.

Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, your Personal Information as a client of SevenPonds is typically one of the business assets that is transferred. Moreover, if SevenPonds, or substantially all of its assets, were acquired, your Personal Information as a client of SevenPonds would be one of the assets that is transferred or acquired by a third party. By using or accessing the Service, you acknowledge and agree that such transfers may occur, and that any acquirer of SevenPonds may continue to use your Personal Information as set forth in this policy.

Protection of SevenPonds and Others: We may release Personal Information when we believe, in good faith, that such release is reasonably necessary to (i) comply with law, (ii) enforce or apply the terms of any of our user agreements, or (iii) protect the rights, property or safety of SevenPonds, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

SevenPonds' Participation in Data Sharing and Benchmarking.

Data sharing is the ability to share the same data resource with multiple applications or users. Shared data will be used to improve the services SevenPonds provides and can help create more powerful features for you to choose from. By accessing the Website or Service, you choose to participate in anonymous data sharing and, should SevenPonds choose to use your data for data sharing purposes, SevenPonds will remove all identifiable information about you. Once all identifiable information about you is removed, the data collected by SevenPonds from you will be combined with data from other users of the Website and SevenPonds will report them in an aggregate form. SevenPonds can then use this anonymous data to improve products and services we provide you and enable benchmarking in your account. You can, however, choose to opt-out of data sharing. To opt out of data sharing or to learn more about data sharing, please contact us at WeCare@SevenPonds.com.

Security of Your Personal Information.

The personally identifiable information SevenPonds collects is securely stored within our database, and we use standard, industry-wide practices such as firewalls, encryption, and (in certain areas) Secure Socket Layers ("SSL") for protecting your information. However, as effective as encryption technology is, no security system is impenetrable. SevenPonds cannot guarantee the security of our database, nor can we guarantee that information you supply won't be intercepted while being transmitted to SevenPonds over the Internet. We recommend that you not disclose your password to anyone.

Collection and Use of Children's Personal Information.

The Website and Service are intended for general audiences, and SevenPonds does not knowingly collect any personal information from children. During the registration process for a SevenPonds Account, SevenPonds does collect age information, and if users identify themselves as under 18 years of age, SevenPonds will block such users from providing personal information.

Advertisements Displayed by Third Parties.

SevenPonds may allow third-party ad serving companies, including ad networks, to display advertisements on the Website. Ad serving companies may place a persistent cookie on your computer in order to recognize your computer each time they display an online advertisement to you, and as such, they may be able to compile information over time about whether you reviewed or clicked on advertisements they display. These companies may use this information to display targeted advertisements and may associate this information with your subsequent visits, purchases or other activities on participating advertisers' websites.

Comments Regarding this Privacy Policy.

SevenPonds welcomes your comments regarding this Privacy Policy. If you have questions regarding this Privacy Policy, please contact us by e-mail at WeCare@SevenPonds.com.

Sole Statement of Privacy.

This document contains and is the sole statement of SevenPonds Privacy Policy. No summary, restatement or other version thereof, or other privacy policy or statement, in any form, is valid.

Modifications of this Privacy Policy.

SEVENPONDS MAY MODIFY THIS PRIVACY POLICY AT ANY TIME, IN SEVENPONDS' SOLE DISCRETION, AND SUCH MODIFICATION SHALL BE EFFECTIVE IMMEDIATELY UPON EITHER POSTING OF THE MODIFIED PRIVACY POLICY ON THE WEBSITE OR NOTIFYING YOU. YOU AGREE TO REVIEW THIS PRIVACY POLICY PERIODICALLY TO ENSURE THAT YOU ARE AWARE OF ANY MODIFICATIONS. YOUR CONTINUED ACCESS OR USE OF THE WEBSITE AND/OR THE SOFTWARE SHALL BE DEEMED YOUR CONCLUSIVE ACCEPTANCE OF THE MODIFIED PRIVACY POLICY.

Last modified on June 4, 2011.