OptionsCity Software, Inc. takes your privacy and our business very seriously.  Please note the following, which constitute the Privacy Policy (collectively, the “Policy”) applicable to this website, and which, by your use of this website, you consent to and agree to abide by. This Policy applies, in general, to all Internet sites operated by or on behalf of our company and its business units worldwide (each an “Internet Site”).

I.    GENERAL PROVISIONS

It is our policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on having the trust of our customers, employees, business partners and others who share their personal information with us.

This Privacy Policy describes how we protect your privacy when we collect personal or private financial information on our Internet sites. As used in this Policy, the term “personal information” means information that identifies you personally, alone or in combination with other information available to us, as well as any financial or other proprietary information, including trading information.

If you have executed, or you do execute a separate agreement with us, such as a Developer Agreement, which provides authorization for us to post certain specific information about you for purposes you have agreed to, then the terms of that other agreement will supersede this agreement with respect to that specific information and use.

II.    SPECIFIC PRIVACY TERMS AND CONDITIONS

A.    Your Consent

By using our Internet Site or providing personal information to us, you are consenting to the collection, use and disclosure of your personal information as described in this Policy.

If you do not consent to the collection, use and disclosure of your personal information as described in this Policy, do not use our Internet Sites.

B.    Limitations on the Collection, Use and Disclosure of Personal Information

To the extent required by applicable law, whenever we collect personal information on our Internet Sites, we will:

     • not disclose, transfer, sell or otherwise provide your personal information to any third party unless required by law or as expressly stated herein (see “Sharing Personal Information” below);

     • provide timely and appropriate notice to you about our data practices through this Privacy Policy Statement;

     • collect and use your personal information only with your consent, which may be express or implied, depending on the sensitivity of the personal information, legal requirements, and other factors;

     • collect your personal information only for specific, limited purposes. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected;

     • process your personal information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented; and

     • not use your personal information for direct marketing purposes without giving you an opportunity to “opt-out”.

C.    Methods of Information Collection and How We May Use This Information

When you access and use our Internet Site, there are three ways we may collect information about you:

      1.  Information Sent to Us by Your Web Browser

As do most commercial websites, we collect information that is sent to us automatically by your web browser. This information typically includes the IP address of your Internet service provider, the name of your operating system (such as Macintosh® or Windows®) and the name and version of your browser (such as Internet Explorer® or Firefox®). The information we receive depends on the settings on your web browser. Please check your browser if you want to learn what information your browser sends or how to change your settings.  The information provided by your browser does not identify you personally. We use this information to create statistics that help us improve our sites and make them more compatible with the technology used by our Internet visitors.

      2.  Information Collected By Placing a “Cookie” On Your Computer

Again, similar to many commercial websites, we may obtain information about you by installing a “tag” on your computer’s hard drive. This tag is known as a “cookie.”  Our Internet Sites use “session cookies.” A session cookie is used to tag your computer with a computer-generated, unique identifier when you access our site. A session cookie does not identify you personally and expires after you close your browser. We use session cookies to collect statistical information about the ways visitors use our sites – which pages they visit, which links they use, and how long they stay on each page. We analyze this information (known as “clickstream data”) in statistical form to better understand our visitors’ interests and needs to improve the content and functionality of our sites.  We may also use “persistent cookies.” These cookies do not expire when you close your browser; they stay on your computer until you delete them. By assigning your computer a unique identifier, we are able to create a database of your previous choices and preferences, and in situations where these choices or preferences need to be collected again, they can be provided by us automatically, saving you time and effort. For example, after you make a purchase, if you decide to make another purchase, your billing address may have been retained and only need to be confirmed.

Among other cookies, our Internet Site uses the following cookies:

Google Analytics: this cookie allows us to see information on user website activities including, but not limited to page views, source and time spent on website. The information is depersonalized and is displayed as numbers, meaning it cannot be tracked back to individuals. This will help to protect your privacy. Using Google Analytics we can see what content is popular on our website, and strive to give you more of the things you enjoy reading and watching.

Google AdWords: Using Google AdWords code we are able to see which pages helped lead to contact form submissions. This allows us to make better use of our paid search budget.

DoubleClick: We use remarketing codes to log when users view specific pages, allowing us to provide targeted advertising in the future.

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit our Internet Site, you may be unable to use all of the functionality of the site if your browser rejects our cookies.

      3.  Information You Knowingly and Voluntarily Provide

We collect the information you knowingly and voluntarily provide when you use our Internet Site (for example, the information you provide when you purchase a product or sign up for a username and password).  In many cases this information will be personal information.  We use this information for the purposes for which you provide it. We may also use the information we collect for various business purposes such as customer service, fraud prevention, market research, improving our products and services, and providing you with information and offers we believe may be of interest to you. We may also remove all the personally identifiable information and use the remaining information for historical, statistical or other legitimate business purposes.

D.    Sharing Personal Information

We will not sell personal information collected from our Internet sites to mailing list brokers.  We may, however, share your personal information with third parties we hire to perform support services for us. These third parties are required to use the personal information we share with them only to perform services on our behalf and to treat your personal information as strictly confidential.

In some cases, we may share your personal information with third parties who partner with us to provide products and services to our customers. When we do so, we will require our business partners to use the personal information we share with them in a manner consistent with the purposes for which it was originally collected (or to which you subsequently consented) and only as permitted under this Policy and all applicable privacy and data protection laws.

In certain, limited circumstances we may share or transfer personal information to unrelated third parties. For example, we may provide personal information to a third party: (i) at your request; (ii) to comply with a legal requirement or court order; (iii) to investigate a possible crime, such as identity theft; (iv) in connection with the sale, purchase, investment in, merger, reorganization, liquidation or dissolution of our company or business; or (v) under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.

E.    Security of Personal Information

Your personal information will generally be stored in our or our internet service providers’ databases. Most of these databases are stored on servers located in the United States. To the extent required by law, if your personal information will be transferred outside of this country, an appropriate notice will be provided.

We maintain safeguards to protect the confidentiality, security and integrity of your personal information. However, as is the case with all computer networks linked to the Internet, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security unless we have acted in a grossly negligent manner.

F.    Links to Third Party Internet Sites

Our Internet Sites may contain links to Internet sites that are not operated by us. These links are provided as a service and do not imply any endorsement of the activities or content of these sites, nor any association with their operators. We do not control these Internet sites and we are not and cannot be responsible for their content, security, or privacy practices. We urge you to review the privacy policy posted on those other websites you visit before using the site or providing personal information.

G.    Transfer of Personal Information to Other Countries.

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer of your personal information to various countries around the world. By submitting your personal information via our Internet Site, you consent to such transfers.

H.    Retention of Personal Information

We retain the personal information collected on our Internet Sites as long as necessary to provide the services, products and information you request or as permitted by applicable law.

III.    QUESTIONS ABOUT THIS POLICY

If you have any questions about this Policy, please contact us by email at marketing@optionscity.com.