Updated on March 1st, 2007

OVERVIEW AND DEFINITIONS

“Service Provider” in2apps, a distributed web services solution delivering authentication, e-commerce, search and storage functionality through its proprietary delivery platform and Distributed Rich Internet Application (DRIA) client technology.

"Distributed Rich Internet Application" or "DRIA" shall mean the Applications, services and functionality hosted or delivered by Company and deployed by Subscriber on or through a Subscriber Website for use by Subscriber Users using the Administration Services.

Our Policy

Through the DRIA, we and our Service Provider may provide you with access to varied user-generated and other content and interactive and informational resources (collectively, “Services”). This Privacy Policy sets forth our and our Service Provider’s policies with respect to information including personally identifiable data (“Personal Data”) and other information that is collected from you when using the DRIA. Unless otherwise stated in this Privacy Policy, this policy shall be deemed to apply to us and our Service Provider and all references to “we”, “us” and/or “our” shall include our Service Provider.

Information We Collect

When you interact with us through the DRIA, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the DRIA:
We collect Personal Data from you when you voluntarily choose to provide such information such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services. Wherever we collect Personal Data we make an effort to provide a link to this Privacy Policy. By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to this DRIA, you acknowledge and agree that such Personal Data may be transferred from your current location to offices and servers of Service Provider, its Subscribers and their contractors located in the United States and other countries.

Non-Identifiable Data:
When you utilize the DRIA, we may receive certain personally non-identifiable information about your use of the DRIA. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information ourselves or it may be included in databases owned and maintained by our Subscribers, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to the DRIA, the number of visitors to each page of the DRIA, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.

In operating this DRIA, we may use cookies. A cookie is a piece of information that the computer or computers that host our DRIA give to your browser when you access a the DRIA. Our cookies help provide additional functionality to the DRIA and help us analyze DRIA usage more accurately. For instance, our DRIA may set a cookie on your browser that keeps you from needing to remember and then enter a password more than once during a visit to the DRIA. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the DRIA’s features.

Aggregated Personal Data:
In an ongoing effort to better understand and serve the users of the Services, we may conduct research on our end user’s demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregated data with our Subscribers, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Selling Ads on time basis

All of our products and solutions share one common point : You sell your ads for a fixed period of time. Publishers completely control the ad selling and serving process and get rid of click fraud, undeserving or over serving issues, and pricing. Using our solution, you can better predict your inventory and cash flows.

Our Use of Your Personal Data and Other Information

We will use the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide access to such services and to monitor your use of such services. We may also use your Personal Data and other personally non-identifiable information collected through the DRIA to help us improve the content and functionality of the DRIA, to better understand our users and to improve the Services. We may use this information to contact you in the future to tell you about services we believe will be of interest to you.

Our Disclosure of Your Personal Data and Other Information

There are certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, including as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a sale, merger, reorganization, dissolution or similar event relating to all or a portion of our business, assets or this DRIA, Personal Data may be part of the transferred assets.

Service Providers, Agents and Related Third Parties: We sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we may need to provide them with access to certain Personal Data. However, we only provide them with the information that they need to perform their specific function.

Legal Requirements: We may also disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of users of the DRIA or the public, or (iv) protect against legal liability.

Your Choices

You can use the DRIA without providing any Personal Data, however, you may not be able to use certain Services.

Exclusions

This Privacy Policy shall not apply to any unsolicited information you provide to us through this DRIA or to through any other means. This includes, but is not limited to, information posted to any public areas of the DRIA, such as bulletin boards (collectively, “Public Areas”), any ideas for new products or modifications to existing services, and other unsolicited submissions (collectively, “Unsolicited Information”), including all User Content as that term is defined in our Terms of Use. All such Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution. Please also note that any Personal Data or other information you provide to be displayed in your publicly available online profile will be displayed for others to see and thus will not be subject to the terms of this Privacy Policy. We cannot and will not be responsible for what third parties do with any Personal Data or other information that you choose to make publicly available. As such, we advise that you exercise great care in determining what information you choose to make publicly available through this DRIA.

Children

This children's privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of thirteen, and provides important information on your rights under federal law with respect to such information.

Service Provider does NOT knowingly collect personally identifiable information from children under the age of thirteen. If Service Provider becomes aware that it has inadvertently received personally-identifiable information from a user under the age of thirteen, it will delete such information from its records. If Service Provider changes its practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen.

Because Service Provider does not collect any personally identifiable information from children under the age of thirteen, Service Provider also does NOT knowingly distribute such information to third parties.

Service Provider does NOT knowingly allow children under the age of thirteen to publicly post or otherwise distribute personally identifiable contact information.

Because Service Provider does not collect any personally identifiable information from children under the age of thirteen, it does NOT condition the use of the service by a child under thirteen.

Links to Other Websites

This Privacy Policy applies only to the DRIA. The DRIA may frame or contain references or links to other websites not operated or controlled by Service Provider (the “Third Party sites”). The policies and procedures we described here do not apply to the Third Party sites. The links from the sites do not imply our Service review or endorsement of the Third Party sites. We suggest contacting those sites directly for information on their privacy policies.

Security

We take reasonable steps to protect the Personal Data provided via the DRIA from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the DRIA may not be secure. Therefore, you should therefore take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Data to us Provider via the Internet.

Changes to Our Privacy Policy

The DRIA may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. Accordingly, we reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the DRIA after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information; Contacting Us

Through the DRIA, we provide you with access to update your profile and revise Personal Data previously submitted to the DRIA. You may contact us in the event you have questions about Service this Privacy Policy or our information practices. You may contact our Service Provider at the contact details set forth above in our Terms of Use.