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 TrackVia, Inc. is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent organization whose mission is to build user’s trust and confidence in the Internet by promoting the use of fair information practices. This privacy statement covers the Web site www.trackvia.com. Because this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe. If you have questions or concerns regarding this statement, you should first contact Chris Basham at TrackVia. He can be contacted via post at 1732 Wazee Street, Suite 202 | Denver, CO 80202, phone at 303.278.1223, or email at privacy@trackvia.com . If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php TRUSTe will then serve as a liaison with us to resolve your concerns. TrackVia complies with the EU Safe Harbor framework as set forth by the Department of Commerce regarding the collection, use and retention of data from the European Union. TrackVia will comply with your request to change or delete your personal information within 30 days. If you wish to delete your personal information please contact us at privacy@trackvia.com or call 303.278.1223. The following discloses the information gathering and dissemination practices for the services offered by TrackVia, Inc. (the "Services") and for this website. TrackVia reserves the right to amend this Privacy Statement at any time. TrackVia will notify all users of material changes to its privacy practices. TrackVia will contact users via an email notice to the user and/or a prominent notice posted within the message center of the users account 30 days prior to implementing the change. Only the current Privacy Statement is deemed effective, so please review this Privacy Statement periodically. 1. We do not reveal any personal information that we collect about you, nor any information or data that you store in your Account, to anyone else. During the registration process, TrackVia collects personally identifiable information (Required Information: First Name, Last Name, Email Address and Optional Information: Organization Name and Phone Number) from the Subscribing Organizations and their Users. Individuals who sign up are also required to create a user name and password for their account. TrackVia uses this information to communicate with organizations during the trial period via email and phone outreach to help get organizations up and running. In addition, TrackVia sends a monthly newsletter to all users who have not opted out of receiving email correspondence from TrackVia. TrackVia may also collect personally identifiable information at other times, such as when responding to product support inquiries. This information is only used to contact the user to help resolve support inquiries. TrackVia may also contact the user via email to announce improvements to the TrackVia interface. In addition, the TrackVia application allows you to store data and information that is personally identifiable, private, or sensitive. TrackVia may use such information in the aggregate only for its own internal purposes. Account administrators also input their Credit Card information (card type, name on card, billing address, city, state, zip, country, card number and expiration date) when signing up for a paying account. Credit card numbers are stored with payment gateway Authorize.net and no TrackVia employee can see credit card numbers. We will not sell, rent or release a Subscribing Organization's or User's personally identifiable information, application data, or stored information to any other party, except at the request of the Subscribing Organization or under certain rare special circumstances such as court order. 2. TrackVia analyzes information about you only on a basis that does not personally identify you. In order to improve our Service, provide content and develop applications and services that are useful to our Subscribing Organizations and Users, TrackVia may automatically gather information on an aggregate basis about the applications, services and pages of the TrackVia application that Users visit and use. A Subscribing Organization's or its Users' personally identifiable information cannot be linked to or discerned from any of this information. TrackVia may also use demographic information and profile data about Subscribing Organizations and Users for these purposes. 3. Trackvia does not use personally identifiable information to track site visitors. However, once a visitor chooses to create a trial account, then TrackVia is able to link a customer’s personally identifiable information (: First Name, Last Name, Email Address, Organization Name and Phone Number) via a cookie. In order to offer our Services and to enable certain application features and functionality, TrackVia uses cookies. Cookies are used to determine when a users’ account has been inactive for four hours. For security purposes, TrackVia automatically logs users out of an account that has been inactive for over four hours. Cookies are also used to identify IP addresses of site visitors enabling us to determine site pages visited. This information is only used internally to identify opportunities to improve our Web site and application. 4. Internally, we restrict access to all Subscriber information to employees who need access to it to do their jobs. These employees include those engaged in customer support activities or those providing custom services purchased by Subscribing Organizations. These employees are limited in number, and are committed to our privacy and security policies. Any employee who violates our privacy and/or security policies is subject to possible termination and civil and/or criminal prosecution. 5. Newsletters are sent to users on a monthly basis. Newsletters are sent via email to the account administrator’s registered email address. All email correspondence sent from TrackVia includes an opt out link at the bottom of the newsletter. All individuals who opt out are automatically removed from future email distribution lists. Users may also send a letter to TrackVia at 1732 Wazee Street Suite 202 | Denver, CO 80202 requesting removal from our email list or users may call 303.278.1223 to ask for their name to be removed. We will then remove the user’s email address from our mailing list. 6. Legal Disclaimer. We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Web site. 7. Use of Service Providers. TrackVia uses the following services providers to deliver its products: ViaWest for a secure data center. Web analytics through Google Adwords, Visistat, and HubSpot. For billing ,TrackVia uses Authorize.net with Verisign. 8. Updating Your Personal Information. You can email privacy@trackvia.com to request updates, corrections, or deletions to your personal information. Updates, Corrections and Deletions to personal information can also be made via post by sending your request to TrackVia | 1732 Wazee Street Suite 202 | Denver, CO 80202. You may also log into your password protected TrackVia account and update your personal information by clicking on the My Info link in the right hand side of your account. Make the necessary updates, corrections or deletions and click update user information. Your user information will be updated immediately. You may also change your billing information within your account by clicking on the Billing Link in the upper right hand corner of your account. Go to the Credit Card Info tab and click on the Edit Credit Card Link. Update or correct your information and click Update Credit Card Information to save your changes. All change requests submitted via mail or email will be made within 30 days of receiving the request. All changes made within your TrackVia account to the My Info or Billing section will be made immediately when you click the update button. 9. Data Transmission. Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure, and there is a risk that data could be intercepted or interrupted during Internet transmission. TrackVia cannot warrant the security of any information Subscribing Organizations or Users transmit to or from our online services, and Subscribing Organizations and Users do so at their own risk. The Web site uses SSL encryption to transmit sensitive information. All billing information is transmitted over the Internet via SSL Encryption secured by Verisign. In addition, users have the option to have all data encrypted by signing up for a SSL Encryption account. 10. Testimonials. We post customer testimonials on our Web site which may contain personally identifiable information such as the customer’s name. We do obtain the customer’s consent prior to posting the testimonial along with their name. 11. Blogs. If you use a bulletin board, blog or chat room on this Web site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums. 12. Changes in Privacy Statement. If we decide to change our privacy policy, we will post those changes to this privacy statement, send an email message and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what, if any, we disclose it. Notice will be provided 30 calendar days prior to implementing the change. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here and by email and/or by means of a notice in the message center of your account.
TrackVia, Inc. | 1732 Wazee Street Suite 202 | Denver, CO 80202 Effective Date: October 2, 2008 
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