Privacy Policy

Effective Date: June 28, 2011

APP47, INC. PRIVACY STATEMENT

App47, Inc. (“App47,” “we,” “us,” or “our”) has created this privacy statement (“Privacy Statement”) in order to demonstrate our commitment to you, our user (“You” or “Your”), regarding Your privacy with respect to information that App47 collects through the Site or Services (defined below), whether You are a “Visitor” (which means that You simply browse a Site), a “Subscriber” of App47 (which means You have entered into a separate agreement with App47, with respect to the Services), or You are an employee, contractor or agent of a Subscriber that uses the Services for commercial purposes (a “Business Subscriber User”), using the Site or Services in Your capacity as an employee, contractor or agent of that App47 Subscriber. Visitors, Subscribers and Business Subscriber Users are individually referred to as a “User,” and collectively, as “Users”.

A Subscriber that is a business, organization or an individual that is using the Services for commercial purposes (entities referred to as Business Subscribers in our Terms of Service) may control certain or all aspects of its Business Subscriber User’s Accounts. In order to make this Privacy Statement more readable, we refer to a Business Subscriber as an “Employer” with the understanding that the defined term may not be technically accurate in all cases.

Privacy on www.app47.com, cirrus.app47.com and other sites we operate (each, a “Site”) is of great importance to us. Because we gather important information from our Users of the Site and related services provided by App47 (the “Services”), we have established this Privacy Statement as a means to communicate our information collection, use and dissemination practices. In order to access and use the Site and/or Services, You must agree to our Terms of Service and any other applicable agreement. Capitalized terms not defined in this Privacy Statement will have the meaning ascribed to them in the Terms of Service.

SCOPE OF THIS PRIVACY STATEMENT

This Privacy Statement describes App47’s use of Personal Information and Anonymous Information (each as defined below) that we collect from Your use of, or access to, the Site and Services, whether You are an individual or a company, as well as information we may use to update the information You provide us through other means. “Personal Information” means contact information (e.g., Your name, address, email address, and/or telephone number) and any other non-public information that is used or intended to be used to personally identify an individual. “Anonymous Information” means information that is not used or intended to be used to personally identify an individual. “Usage Data” means data relating to Your use of certain third-party applications on Device(s) that You designated for us to monitor, administer and/or control as part of the Services (“Applications”). A “Device” is a wireless phone, personal digital assistant, tablet or other wireless device containing Applications.

BY USING OUR SITE OR SERVICES OR SUBMITTING PERSONAL INFORMATION THROUGH OUR SITE OR SERVICES, YOU AGREE TO THE TERMS OF THIS PRIVACY STATEMENT AND YOU EXPRESSLY CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION ACCORDING TO THIS PRIVACY STATEMENT. YOUR PERSONAL INFORMATION MAY BE PROCESSED BY US IN THE COUNTRY WHERE IT WAS COLLECTED AS WELL AS OTHER COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING OF PERSONAL INFORMATION MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY.

INFORMATION COLLECTED

Personal Information
In general, the Personal Information we gather enables us to provide the Site and Services to You. We collect Personal Information that You submit to us voluntarily. When You register with us, we require You to provide certain Personal Information, such as Your name and email address. We may request additional optional information to support Your access to the Site or Services. When You communicate with us by sending us an email, we may collect and store any information that is contained in Your communications with us. You can choose not to provide us with certain information, but this may limit the features of the

Site or Services You are able to use. Please note that if You are a Business Subscriber User, we may receive Personal Information about You from Your Employer – specifically, your name and device ID. We also collect certain Personal Information from Subscribers in order to process subscriptions, including credit card numbers and associated billing information, to charge and collect the subscription fees. We refer to this information as “Billing information”.

Usage Data
The contents of Usage Data can include both Personal Information and Anonymous Information, but we treat Usage Data differently regardless of its contents. Usage Data includes a unique user ID for your mobile device, your Device’s operating system and platform, your location (if enabled by the applicable Application) and log information about your Device and usage of the Application(s). For example, we may collect information about when an error message is displayed in the Application or an Employer may request that we collect information about the occurrence of certain transaction(s)/action(s) in the Application. We only collect Usage Data that You have requested we collect relating to Your use of Applications. If You are a Business Subscriber User, then Your Employer may have designated the Applications or authorized our services on Your behalf and will select the Usage Data to be collected. If you are Business Subscriber User and want to know specifically what Usage Data is collected, please contact your IT team. We associate Your Usage Data with Your Personal Information.

Anonymous Information
As You use the Site or Services, certain Anonymous Information may be collected and stored on our or our service providers’ server logs, such as Your Internet protocol address, browser type, and access times. We may use Cookies (defined below) or web bugs and navigational data like Uniform Resource Locators (URLs) to gather information regarding the date and time of Your visit. “Cookies” are small pieces of information that a website sends to Your browser while You are viewing a website. Standing alone, Cookies do not personally identify You but merely recognize Your web browser. We may use both session Cookies (which expire once You close Your web browser) and persistent Cookies (which stay on Your browser until You delete them) to improve Your experience on the Site (e.g., by keeping You logged in). If You choose to disable Cookies, You may experience session errors and may not be able to use the Site.

USE OF INFORMATION

Personal Information
We will use Your Personal Information to:

  • Administer Your Account;
  • Provide You with Services and customer support;
  • Tailor the features of the Site or Services to You;
  • Respond to Your requests, resolve disputes and/or troubleshoot problems;
  • Improve our products and services
  • Verify Your compliance with Your obligations in our Terms of Use; and
  • Communicate with You about the Site and the Services.

We may also use Your Personal Information to create Anonymous Information records by excluding information that makes the information personally identifiable to You (and, if You are an Employer, your company). Notwithstanding the foregoing, we will only use Your Billing Information to process and collect fees. We send administrative emails which pertain to the Site and Services on a regular basis, and You may not opt-out of these emails. If You wish to not receive these emails, You must terminate Your Subscription and cease use of the Services.

Usage Data
We will access and use Your Usage Data to provide You with Services designed to enable You to analyze Your usage of Applications, manage Your performance of Applications and control Your deployment of Applications. If You are a Business Subscriber User, we will not provide You with these Services, but we will provide them to Your Employer with the understanding that your Employer will have access to information about Your usage and Your Device. Your Employer is required to ensure that it accesses and uses information about Your usage and Your Device in accordance with its own policies and procedures.

Anonymous Information
We may, through our use of Cookies, keep You logged into the Site during each session. We may also use Your Anonymous Information to improve our internal operations and software.

DISCLOSURE OF INFORMATION

Personal Information
It is our general policy to restrict who can access Personal Information. Except as otherwise stated in this Privacy Statement, we do not trade, rent, or share the Personal Information that we collect with third-parties, unless You ask or authorize us to do so. We may provide Your Personal Information to third-party service providers who work on behalf of or with us to provide some of the Services and features of the Site or Services and to help us communicate with You.

Although we do not currently have a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “affiliates”), we may in the future. We may share some of all of Your Personal Information with these affiliates, in which case we will require our affiliates to honor this Privacy Statement.

In the event of a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we reserve the right to transfer all of Your Personal Information to that entity. We will notify You (via a posting on a Site or email (in our discretion) of such a transfer, and You may choose to modify Your registration information at that time. This means if You are concerned about Your Personal Information being transferred to a new owner, You can deactivate Your account. We will require the acquiring entity to comply with this Privacy Statement.

We may share some or all of Your Personal Information with other third-parties to whom You ask or authorize us to send Your information. This Privacy Statement does not cover the use of Your Personal Information by such third parties. We do not maintain responsibility for the manner in which third-parties use or further disclose Your Personal Information after we have disclosed such information to those third-parties. If You do not want us to use or disclose Personal Information collected about You in the manners identified in this Privacy Statement, You should not use the Site or Services.

We reserve the right to disclose Your Personal Information if we have a good faith belief that disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process or enforceable governmental request; (b) enforce our Terms of Service, including investigation of potential violations thereof; (c) detect, prevent, or otherwise address fraud, security or technical issues; or (d) protect against harm to the rights, property or safety of App47, its users or the public as required or permitted by law You hereby consent to App47 sharing Your Personal Information under the circumstances described herein.

Usage Data
We share Usage Data in the same ways we disclose Personal Information, except that we may also share Your Usage Data to Your Employer if You are a Business Subscriber User;

Anonymous Information
We reserve the right to disclose Anonymous Information to third-parties in our discretion. We will not, however, do so in a way that permits You and/or Your company or Your employees, as applicable, to be individually identified.

FEEDBACK
If You provide feedback to us, we may use and disclose such feedback in accordance with the terms in our Terms of Service, provided we do not associate such feedback with Your Personal Information. We will collect any information contained in such feedback and will treat the Personal Information in it in accordance with this Privacy Statement.

THIRD PARTY SITE
The Site may contain links to other websites. App47 is not responsible for the privacy practices or the content of these other websites. This Privacy Statement applies solely to information collected by us through the Site or Services and does not apply to these third party websites. We encourage our Users to read the privacy statements of each and every website they visit. Users should always use caution and common sense when choosing to provide Personal Information on the Internet, particularly when it comes to information such as credit cards and other payment information. The ability to access information of third parties from the Site or Services is for Your convenience and does not signify our endorsement of such third parties, their services, other websites, locations or their contents.

REGARDING CHILDREN
The Sites are not directed to children and children are not eligible to use our Services. Protecting the privacy of children is very important to us. We do not collect or maintain Personal Information from people we actually know are under 18 years old, and no part of the Site or Services is designed to attract people under 18 years old. If we later obtain actual knowledge that a User is under 18 years old, we will take steps to remove that User’s Personal Information from our databases.

SECURITY
We have put in place reasonable security measures to help protect against the loss, misuse, and alteration of Your Personal Information. When our Sites are accessed using Internet Explorer version 6.0 or later, or Firefox version 2.0 or later, Secure Socket Layer (SSL) technology protects information using both server authentication and data encryption. These safeguards help prevent unauthorized access, and help to maintain data accuracy and appropriate use of Personal Information. Despite such efforts, however, please note that no company, including App47, can fully eliminate risks or guarantee the security of Your

Personal Information; unauthorized entry or use, hardware or software failure, and other factors may compromise the security of information about You at any time.

CORRECTING & UPDATING YOUR INFORMATION
Users who would like to update or change certain Personal Information associated with their Account may do so at any time by editing their Account profile online or by sending us an email at support@app47.com. Please be aware that certain Usage Data may not be edited, accessed or changed. Please note, that we do not have the ability to update any information previously disclosed to any third party. Certain information is necessary in order for us to provide the Site or Services; therefore, if You delete such necessary information You may not be able to use the Site or Services.

If You wish to have Your Personal Information and/or Usage Data deleted from our databases or to discontinue the Services, You may contact us at support@app47.com or call 703-251-4557. Within a reasonable time period after we receive Your request, we will remove Your Personal Information and/or Usage Data except as provided in the foregoing sentences. Please note, however, that even though You may request the deletion of Your Personal Information or Usage Data by us, we may be required (by law or otherwise, such as to prevent fraud, resolve disputes, troubleshoot problems, or enforce our Terms of Services) to keep this information and not delete it (or to keep this information for a certain time) in which case we will comply with Your deletion request only after we have fulfilled such requirements). When we delete Personal Information or Usage Data, it will be deleted from the active database, but may remain in our archives.

Distinctions for Business Subscriber Users
For purposes of this section on Creating and Updating Your Information, if applicable User is a Business Subscriber User:

  • The Employer will be the owner of the Business Subscriber Users’ Usage Data and will be the only party with access to and control of such Usage Data; and
  • The Employer may request the deletion of its Business Subscriber Users’ Personal Information without the Business Subscriber User’s consent.

NOTIFICATION OF CHANGES
This Privacy Statement is a living document. We reserve the right to modify this Privacy Statement at any time. If we are going to use Your Personal Information or Usage Data that we have previously collected in a manner different from that stated at the time of collection, and You have provided us with Your current email address, we will notify You at that email address of such change. In the event You have provided us with an invalid or incomplete email address, or we do not have Your email address on file, a notice of any such changes will be posted to the applicable Site. You will have a choice as to whether or not we use

Your Personal Information in this different manner. Any such modifications become effective upon the earlier to occur of (i) Your acknowledgement of such modifications; (ii) Your continued access to and/or use of the Site or Services fifteen (15) days after we first provide You with email notification of such modifications; or (iii) if we have not provided You with an email notification of such modifications, Your continued access to and/or use of the Site or Services thirty (30) days after we have first posted such notice to the applicable Site(s).

In addition, if we make any material changes to our Privacy Statement that do not affect User information already stored in our database, we will post a prominent notice on our Site notifying Users of the change, and, at our discretion, email Users who have opted to receive communications from us, notifying them of the changes in our privacy practices. It is Your sole responsibility to check the Site from time to time to view any such changes to the terms of this Privacy Statement. If You do not agree to any changes, if and when such changes may be made to this Privacy Statement, You must cease access to the Site and use of the Services. You give us permission to email You for the purpose of notification as described in this Section.

ADDITIONAL INFORMATION
Questions regarding this Privacy Statement or the practices of the Site or Services should be directed to App47 by e-mailing such questions to privacy@app47.com.

CONTACT INFORMATION
If Users have any questions or suggestions regarding our Privacy Statement, please contact us:

Contact: App47, Inc.
Email: privacy@app47.com
Address: 11951 Freedom Drive, 13th Floor, Reston, Virginia, 20190

    Contact App47

    11951 Freedom Dr., 13th Floor, Reston, VA 20190
    703.251.4557 | info@app47.com

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