DealMaven Privacy Policy DealMaven Privacy Policy PRIVACY DealMaven secures the information that you provide using http://www.dealmaven.com/ on computer servers in a controlled, secure environment, protected from unauthorized access. Credit card information sent to and from http://www.dealmaven.com/ is sent using Secure Socket Layer (SSL) encrypted protection. INTRODUCTION DealMaven, Inc. (DealMaven) is a Delaware corporation with its principal place of business in New York, NY, USA. DealMaven is a financial modeling and investment analysis-focused technology and consulting company. You can find out more about DealMaven on its web site at www.DealMaven.com. DealMaven's software applications provide licensees with the ability to build and modify complex financial models of businesses, and to effectively present financial modeling, investment analysis and other information using well known and accepted software applications, such as Excel and Powerpoint. DealMaven also provides educational assistance, an online community and knowledge base, and other tools for licensees, users and prospective users of its software in connection with financial model building and investment analysis. The DealMaven Financial Analysis Knowledge Base (http://www.dealmaven.com/training) is a browser based software tool and DealMaven's servers are located in the United States. All personal information provided to DealMaven is stored and processed in the United States. DealMaven values the privacy of the personal information of its licensees and other users of its software applications and/or web sites (Users), and DealMaven is committed to protecting the privacy of Users. DealMaven will not collect, use or disclose personal information except in accordance with this Privacy Policy. This Privacy Policy describes DealMaven's commitment to protection of the privacy of the personal information of Users and covers personal information that is collected or received by DealMaven in the course of its commercial activities, including by means of the DealMaven web site as well as other web sites that may be maintained by DealMaven. Such personal information and data is stored by DealMaven on its servers located in New York, NY and Seacaucus, NJ, USA. This Privacy Policy explains DealMaven's practices regarding its collection, use, retention and disclosure of personal information, and it can be found or accessed on the DealMaven web site home page at www.DealMaven.com. If you have any questions regarding DealMaven's Privacy Policy or do not believe that your concerns have been otherwise addressed, please contact DealMaven's Privacy Officer by sending an email to support@dealmaven.com. Please read the complete DealMaven Privacy Policy before sharing any personal information with DealMaven, subscribing to any service offered by DealMaven, or using http://www.dealmaven.com/. SCOPE OF PRIVACY POLICY AND NATURE OF PERSONAL INFORMATION It is the intent of DealMaven to be in compliance with the principles of the Personal Information Protection and Electronic Documents Act of Canada, the Safe Harbor Agreement between the United States and the European Commission (Safe Harbor Principles, published by the U.S. Department of Commerce on July 21, 2000), the Data Protection Act 1998 of the United Kingdom, and selected legislation worldwide regarding privacy of data. This Privacy Policy covers personal information about Users which is in DealMaven's possession or control. Personal information is information which relates to an individual from which the individual can be identified, or from which the individual can be identified when combined with other information that is in DealMaven's possession or is likely to come into DealMaven's possession. This Privacy Policy does not cover non-personally identifiable data, such as aggregate data from which personally identifiable characteristics have been removed. This Privacy Policy covers personal information processed in countries belonging to the European Economic Area ("EEA") and other countries which adopt similar data privacy laws or rules, including the transfer of such data from those countries to DealMaven, its affiliates or others. In addition to enforcing DealMaven's own privacy procedures, DealMaven, as of May 31, 2007, is a participant in the Safe Harbor Agreement between the United States and the European Union. DealMaven meets the Safe Harbor Principles published by the U.S. Department of Commerce (Safe Harbor Principles). By choosing to comply with the Safe Harbor Principles, transfers of data from countries in the EEA to DealMaven in the United States meet the adequacy requirements of the European Union Data Protection Directive. As additional countries adopt the Safe Harbor Principles or similar laws, this Privacy Policy may extend to protect data collected from those countries as well. This Privacy Policy describes how DealMaven collects, stores and uses personal information that is collected by DealMaven or provided to DealMaven by Users, whether through DealMaven's web sites or by other methods such as reporting of usage statistics by DealMaven software applications, or other means. This Privacy Policy covers the www.DealMaven.com web site and all of DealMaven's other web sites; and it also applies to any personal information that is provided to DealMaven by a User, or stored on DealMaven's servers by Users using DealMaven’s web sites or software applications; however, this Privacy Policy does not cover information collected by affiliate web sites, or given by a User or other individual to affiliate web sites, whether or not linked to DealMaven's web sites. ACCOUNTABILITY DealMaven is responsible for any personal information under its control, including personal information that may be transferred to a third party for processing. Accountability for DealMaven's compliance with the privacy principles on which this Privacy Policy is based rests with DealMaven's Privacy Officer, although other individuals within DealMaven's organization may have responsibility for the collection and processing of personal information and may be delegated from time to time to act on behalf of its Privacy Officer with respect to personal information. Information about DealMaven's privacy policies and practices is available from its Privacy Officer (contact information for DealMaven's Privacy Officer is listed under the section of this Privacy Policy titled ENFORCEMENT/COMPLAINTS). DealMaven will train and educate its staff with respect to its privacy policies and procedures. In the course of providing access to Users to www.dealmaven.com, DealMaven receives assistance from non-affiliated third parties, including the company which hosts its web sites and maintains DealMaven's servers in New York, NY and Seacaucus, NJ. These third party service providers must abide by similar privacy protections in order to conduct business with DealMaven. The relevant portions of this Privacy Policy are communicated to such third party service providers who may have access to personal information provided by Users, and DealMaven will use contractual or other means to provide a comparable level of privacy protection as set forth in this Privacy Policy. Except for disclosures authorized by Users or that DealMaven may be required or is permitted to make under applicable law, for instance to law enforcement, disclosures to non-affiliated third parties will only take place with those third parties who subscribe to the Safe Harbor Principles, subject themselves to applicable data protection laws consistent with the European Union Data Protection Directive, or who sign a contract with DealMaven promising to provide the same level of data security and privacy protection as provided in the Safe Harbor Principles and otherwise in accordance with this Privacy Policy. Further, DealMaven will take appropriate action against any DealMaven employees, service partner or others who violate its privacy policies, up to and including termination from employment or cancellation of a service or supplier contract with DealMaven. PURPOSES OF COLLECTION DealMaven will identify the purposes for which it collects, uses and discloses personal information at or before the time of collection. DealMaven will only collect personal information that is reasonably necessary for the purposes that have been identified by it. DealMaven collects, uses and discloses personal information for the following purposes: to administer and operate www.dealmaven.com; to license the use of www.dealmaven.com and provide related services to licensees and other Users; to enter into contracts, agreements and other legally binding commitments with Users; to establish User accounts; to determine or verify credit ratings and/or make credit decisions; for invoicing and collection purposes; to market, advertise and promote its products and services; to maintain and support www.dealmaven.com and respond to service requests, support requests, notices of deficiencies or operational problems with access to or use of www.dealmaven.com and software applications and tools, and to respond to comments or suggestions received; to provide notice of enhancements, upgrades and technical or informational updates with respect to its products and services; to conduct evaluations and surveys regarding the use and operation of its products and/or services and/or to learn about the needs and preferences of Users; to develop, prepare, license or sell enhanced, improved and/or new products and services; to communicate with Users with respect to new products or services or events offered by DealMaven, its affiliates and/or strategic partners; to prepare and provide a directory of Users to groups or committees for networking purposes, if applicable; to provide a directory of certified Users who have completed certain levels of instruction and/or proficiency regarding DealMaven’s educational offerings and products and services; for job postings and recruitment purposes where authorized in advance by the Users whose information may be used in such postings; to publish and send newsletters or similar communications to Users or User Groups; to conduct aggregated statistical analysis regarding use of its products and services; subject to adequate non-disclosure provisions determined by DealMaven, to enter into business relationships, agreements and other commitments with third parties who work with or on behalf of DealMaven or who supply products, services or other resources to DealMaven; to protect the rights or property of DealMaven and/or its affiliates; subject to adequate non-disclosure provisions determined by DealMaven, in connection with the sale, assignment, transfer, reorganization, merger, amalgamation or divesture of all or any portion of the shares, assets, business operations, intellectual property and/or other property of DealMaven, in whole or in part; to communicate with Users by telephone, e-mail, facsimile and other means for the above purposes; and any other purposes which may be stated herein. If DealMaven proposes to use or disclose personal information which it has collected for a purpose not previously identified, DealMaven will make a reasonable effort to identify this purpose to the individual from whom the personal information was collected (either orally, in writing, by e-mail, by posting a notice on DealMaven's web site(s) or by any other means deemed appropriate in the circumstances) and obtain such individual's consent before such new use or disclosure. DealMaven will state such new purpose in such a manner that an individual can reasonably understand how his or her personal information will be used or disclosed. DealMaven will document the purposes for which personal information is collected. CONSENT - USE OF DEALMAVEN WEB SITE AND SOFTWARE APPLICATIONS AND TOOLS By using DealMaven's web sites or the software applications and tools accessible through DealMaven web sites, and/or by acceptance of DealMaven’s terms and conditions pertaining to use of its web sites and software applications and tools, you signify your acceptance of our Privacy Policy and the specific purposes for which DealMaven may collect, use and disclose your personal information as set forth herein. In certain circumstances, DealMaven may seek consent after the personal information has been collected but before it uses or discloses the personal information (for instance, when it wants to use information for a purpose not previously identified). If you are a registered user or subscriber to any DealMaven services or otherwise a User or licensed User, in order to use DealMaven’s web sites you may have provided a Username and Password that allows you to sign in and access www.dealmaven.com. This Username and Password enables you to log in to DealMaven's www.dealmaven.com web site, and it also serves as the only means of authenticating your identity on DealMaven's www.DealMaven.com web site and as an authorized User of www.dealmaven.com. You should not give your Username or Password to a third party - anyone who has your Username and Password can log in to www.dealmaven.com and view all personal information and account information that you have provided as a User of such web site, and which would normally be accessible to or editable by you alone. Whether you choose to search or browse DealMaven's public site at www.DealMaven.com or to login as a User at DealMaven's private www.dealmaven.com site, you are consenting to DealMaven's collection, use and disclosure of your personal information in accordance with this Privacy Policy and the license or any other terms that you have accepted or agreed to as part of registering on, subscribing to or licensing access to www.dealmaven.com. Depending on the circumstances, DealMaven may obtain consent from individuals by other means, including, in writing, orally, by e-mail or other electronic means. The way in which DealMaven will seek consent, including whether express or implied consent is sought, may vary depending on the sensitivity of the personal information and the reasonable expectation of the individual supplying it. DealMaven will not, as a condition of the licensing of a product or supply of a service, require an individual to consent to the collection, use or disclosure of personal information greater in scope than that required by DealMaven to fulfill the specified and legitimate purposes for which it was collected. Subject to legal or contractual restrictions and upon reasonable notice to DealMaven, an individual may withdraw his or her consent at any time by contacting DealMaven's Privacy Officer. DealMaven will inform an individual of the implications of withdrawing consent, including but not limited to the loss or inaccessibility of access to one or more DealMaven web sites, DealMaven services, and/or any personal information or other data that may be stored at www.dealmaven.com . LIMITING COLLECTION, USE AND DISCLOSURE The DealMaven web site may permit Users to store or post information with DealMaven, as part of the use of the tools and information available, and to make such information accessible to third parties. Except for information selected and stored or posted by Users in www.dealmaven.com, DealMaven will limit its collection of personal information to the amount and type of personal information which it needs for its identified purposes, and DealMaven will only collect personal information by fair and lawful means and not indiscriminately. Personal information will only be used or disclosed for the purposes for which it was collected, except with the consent of the applicable individual (which consent is implied by use of www.dealmaven.com for delivery of information to third parties having access to the web site, including any other Users or licensees with such access), or as permitted or required by law. COLLECTION AND USE OF INFORMATION In order to ensure that DealMaven's web sites are useful and effective for its Users, DealMaven uses log files to analyze information. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track visitor's movement in the aggregate, and gather broad demographic information for aggregate use. These types of log files are not linked to personal information. DealMaven uses these statistics to improve site content and usability; this information does not identify visitors personally. Visitors are not required to be DealMaven web site registered or licensed Users, or subscribers to DealMaven services, in order to gain access to DealMaven's public web sites, with the exception of specific secured pages. However, when a User enters a DealMaven registered User Username and Password in order to access www.dealmaven.com or other secured pages, a "cookie" may be deployed. If the User clicks "Save Login Information", the User Username will be saved in a "cookie" - a small text file stored on the visitor's browser - on the User's computer, so that the User will not have to retype the Username and Password the next time the User visits the DealMaven web site. In addition, the DealMaven web site uses the "Secure Sockets Layer" security protocol ("SSL") - a standard industry security technology that protects web communications. SSL will write a "temporary cookie" to the User's computer. This cookie enables the web site to "remember" this authentication information during movement from one page to another during a session. This makes it unnecessary to log in again on each page. The temporary cookie only saves assigned identification information for the session and contains no personal information. If you have set your Internet web browser to reject cookies, access may be denied to secured areas of DealMaven's web sites. DealMaven also collects limited personal information from Users and prospective Users worldwide in order to provide DealMaven web site services and related services to Users. Examples of this information would be: name, email address, and also other information necessary to process credit card or other payment for the purchase by Users of content access or other services at www.dealmaven.com, or product licenses. In addition, the nature and purpose of certain portions of www.dealmaven.com is to allow Users to interact with other Users, to post and store information and/or files that will be available to other Users, which information may be uploaded, in electronic file format, by Users to www.dealmaven.com. It is the User's choice to include or not include personal information in such information or files. A User's stored or posted information can be viewed by other Users of DealMaven’s web site, and may be copied or forwarded on to other persons who are not registered or authorized Users of DealMaven’s web site. Transfer of this data to DealMaven, (i) for storage and display on DealMaven's servers, and (ii) by a User to other Users, is allowed through the explicit consent of the Users (as subscribers to or registered Users or licensees of www.dealmaven.com ), and through adherence of DealMaven to the Safe Harbor Principles. A User who does not desire the transfer of his or her personal information to third parties can prevent such transfer by not posting such information or files at or in the web site. In addition to providing access to other Users, a User may also grant permission to DealMaven to access and use personal information and other data or files stored or posted by the User at or in DealMaven’s web site. DealMaven also may access such information for the purposes of obtaining aggregated statistical information regarding use and information stored in www.dealmaven.com, maintaining www.dealmaven.com , and responding to service requests, support requests, notices of deficiencies, or operational problems with access to or use of www.dealmaven.com received from Users or others. COMMUNICATIONS FROM DEALMAVEN REGISTERED USER OR SUBSCRIBER SERVICES: DealMaven may use personal information Users have voluntarily provided to DealMaven on its web sites, or by other means, to notify Users via e-mail or printed material of DealMaven events or other relevant products and services offered by DealMaven, or to respond to service or support requests, or to contact Users relating to User accounts or licenses. Also, if you are part of a DealMaven user group or committee, or have been certified by DealMaven in any capacity, DealMaven may include your contact information in its directory of such Users for networking, contact or informational purposes. Typically, DealMaven will communicate with Users via email, but such communication may be by other means, such as telephone or mail. If you wish to unsubscribe from receiving marketing materials please inform DealMaven's Privacy Officer. NEWSLETTER: In the event that DealMaven publishes a newsletter or similar publication for Users or User groups, DealMaven may contact Users and request permission to provide Users with the newsletter. In order to provide any newsletter to Users who grant permission, DealMaven may ask Users for certain contact information such as name, address and email address. Out of respect for our Users' privacy, DealMaven will provide a way to opt-out of these communications. DISCLOSURE OF INFORMATION TO THIRD PARTIES DealMaven does not disclose personal information of its Users to third parties, except as authorized by its Users, as disclosed to third party service providers to DealMaven, or as may be permitted or required by applicable law. As noted above, posted or stored information regarding registered Users or subscribers may be available to other Users generally, and the User base may include individuals and businesses that are licensees of DealMaven products and services. Users may upload, store or post personal information within the DealMaven web site, or permit certain personal information to be contained or listed in databases or directories. Such information will be accessible to other registered Users, subscribers, licensees, and to DealMaven and its staff, and those persons or entities may in turn disclose such information to third parties, whether or not such third parties are part of the DealMaven online community. DealMaven may contact Users from time to time and ask Users if they want to receive information about products or services offered by DealMaven, or companies or organizations that are business affiliates or strategic partners of DealMaven. Personal information or other information regarding Users who respond affirmatively will be given to such third party companies or organizations. Users will be given the ability at the time of registering or subscribing, or at such later time as they may be asked if they want to receive such marketing information, to agree to receiving these requests. RETENTION DealMaven may retain personal information provided by a User for use with the DealMaven web site indefinitely until the User notifies DealMaven that any authorization has been withdrawn by the User. DealMaven may choose not to retain such information at any time. DealMaven will retain other personal information provided by the User only as long as is reasonably necessary or appropriate for the fulfillment of the purposes identified. Where personal information has been provided to DealMaven for any specific purpose, and is not provided, posted or stored by the User for general access and availability to other Users, DealMaven will use reasonable efforts to have it destroyed, erased or made anonymous after such personal information is no longer required to fulfill those specific purposes. ACCURACY AND RIGHT OF ACCESS A User generally has the right and power to control the selection, correction, storage, access and deletion of any personal information provided by the User for posting or storage in www.dealmaven.com. Registered users and subscribers will have access, by logging in as Users of the DealMaven web site, to all information posted or stored by them, and such information may be corrected or deleted, as the User may choose. Registered Users and subscribers also may view and update their personal account information by accessing their account at www.DealMaven.com, available upon login to the User account, and then clicking on the “My Profile” button in the upper-right corner of the site. The following paragraphs of this Section of DealMaven's Privacy Policy ("Accuracy and Right of Access") only apply to personal information other than that stored or posted by Users in the DealMaven web site. DealMaven will use reasonable efforts to ensure that other personal information under its control is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Upon request, DealMaven will inform an individual as to whether or not DealMaven holds any personal information about such individual and as to its use and disclosure of such information. If it is not possible to provide a list of the specific organizations to whom information has been disclosed, DealMaven will provide a list of organizations to whom information may have been disclosed. DealMaven will provide reasonable access to Users who want to review their personal information maintained by DealMaven, and to correct any inaccuracies or incompleteness in such information. Access to personal information also may be requested by emailing support@dealmaven.com or by mailing a request to DealMaven's Privacy Officer. Individuals requesting access should receive confirmation of a request within 2-3 business days. DealMaven will respond to an individual's request for access within a reasonable time. DealMaven's response will typically be provided at no cost to the individual; however, DealMaven reserves the right, depending on the nature of the request, to charge the individual for its costs to process the request and to receive payment of such costs prior to processing such request. If it is demonstrated that personal information is inaccurate or incomplete, DealMaven will amend the information as required to the extent more accurate information is provided and, if appropriate, will advise third parties having access to the information in question. If a challenge is not resolved to the satisfaction of the individual, DealMaven will record the substance of the unresolved challenge. DealMaven is not responsible for verifying the continued accuracy of Users' personal information. In certain circumstances, DealMaven may be unable to provide access to some or all personal information under its control. Those circumstances will be limited to those permitted or required by applicable law. Where permitted, the reasons for such refusal will be provided to the individual upon request. LINKS DealMaven's web sites contain "links" to other sites, including sites that may be operated by DealMaven affiliates or their agents. In addition, DealMaven has provided certain links in the "ResourcesàLinks" section of the www.DealMaven.com web site which are available to Users. DealMaven does not control, and is not responsible for, the accuracy, timeliness, security, or the continued availability or existence of this outside information. Information or content provided on other sites linked from DealMaven's web sites, the www.dealmaven.com program, or in any User's postings, is not necessarily reviewed or screened by DealMaven, nor does DealMaven endorse, warrant, or guarantee products or services described or offered on those other sites. DealMaven is not responsible for the contents of any web sites that choose to link to DealMaven's web sites with or without DealMaven's consent. Other organizations linked to DealMaven's web sites, or through links posted by Users, may collect information about you when you view or click on these sites. DealMaven cannot control this collection of information. You should contact these organizations directly if you have any questions about their use of the information they collect. INFORMATION PROVIDED TO THIRD PARTIES; RISK OF DISCLOSURE Please keep in mind that whenever you voluntarily disclose personal information to third parties through electronic communication - by providing email messages, or posting or storing any information or material online - that information can be collected and used by others, including making copies or printing of such information and forwarding such information to others. By posting or storing information at the DealMaven.com web site, such information, including any sensitive personal information, may be stored, copied, printed, used, published and/or forwarded to others by the viewer, and the privacy of such information cannot be protected. By including sensitive information, such as that pertaining to racial or ethnic origins, political or religious beliefs, financial information, or health or sex life, in any electronic forum, or other Internet accessible location, you are providing explicit consent to the disclosure of that sensitive information to any viewers that have access to that electronically stored or posted information. Also, you may receive unsolicited messages from viewers and other parties who obtain access to the information contained in your postings. SECURITY As described above, viewers will have access to any posted or stored information that is generally available at the DealMaven.com web site. DealMaven may store and process personal information provided by Users, through such Users' registration on, subscription to or use of www.dealmaven.com, in the United States or any other country where DealMaven, its affiliates, agents or transferees are located. DealMaven staff will have access to Users' information for service, support and maintenance purposes. Businesses and other entities that have a license from DealMaven may have the ability to be Users and have access to User posted or stored information. DealMaven strongly urges registering or subscribing Users to not divulge their Username and Password to anyone, and to not enable any login storage feature of any web browser or software program, which would permit anyone with access to the User’ computer to have access to the User’s personal www.dealmaven.com account. DealMaven also urges Users to log out and completely close their web browser window when they have finished visiting the DealMaven web site. This is to ensure that others cannot easily access personal information if the computer is shared or is used at a public place like a library or Internet cafe. User’s credit card and payment information is not stored in an unencrypted format in a database or on any servers connected to the Internet. This is to provide the best protection of User payment information. Credit card data transmission is encrypted using SSL or other encryption techniques. DealMaven has physical, electronic and procedural safeguards in place, including an Information Security Policy, to protect personal information provided to DealMaven or stored in www.dealmaven.com from loss, theft, misuse and unauthorized access, disclosure, copying, use, alteration and destruction. Although there cannot be a guaranty of the security of personal information provided by Users to DealMaven or stored in www.dealmaven.com, DealMaven believes that its security policies and safeguards are reasonable and appropriate to adequately protect such information, regardless of the format in which such information is held. DealMaven intends to review and update its security policies and safeguards on a regular basis. DealMaven requires that its employees keep all personal information confidential and comply with its Information Security Policy and privacy practices. DealMaven uses reasonable efforts to ensure that upon disposal or destruction of personal information, confidentiality of the information is maintained. CHANGES TO PRIVACY POLICY DealMaven reserves the right to modify or amend this Privacy Policy at any time and for any reason. Nothing contained herein is intended to create a contract or agreement between DealMaven and any other party. Users of the www.DealMaven.com web site and DealMaven's other web sites should reference this Policy periodically to ensure that they have knowledge of the current provisions of DealMaven's Privacy Policy. If, however, DealMaven will be using the Users' personal information in a manner or for a purpose different from that stated at the time of collection, we will notify the User via email or by other means identified in this Policy. OPTING OUT OF THE RELEASE OF PERSONAL INFORMATION Users can choose to be excluded from certain mailings or other uses of their personal information by DealMaven. To opt out, please send your request via email to support@dealmaven.com. You should receive confirmation of your request within 2-3 business days. However, if you choose to provide DealMaven with personal information by registering or subscribing to www.dealmaven.com, or purchasing or licensing any other product, registering for an event, or requesting other services or support, DealMaven will use that information to provide you with the purchased products or services, for billing purposes, to send immediately relevant information to you, to respond to you, and/or for other purposes related to the reason for which you provided the information, even if you opt out of the use of your information by the means detailed in this Privacy Policy. ENFORCEMENT/COMPLAINTS; LEGAL DISCLAIMER Although DealMaven makes every effort to preserve the privacy of Users, DealMaven may need to disclose personal information when required or permitted by law, for instance, where it has a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on DealMaven or applicable to DealMaven's web sites or software programs. If you have any questions, concerns or complaints regarding DealMaven's privacy policy, would like to request access to your personal information, or if you believe that DealMaven has not adhered to these policies, your should contact DealMaven's Privacy Officer at: DealMaven, Inc. The Privacy Officer's responsibility is to investigate any of your concerns or complaints, and, in consultation with and in conjunction with DealMaven's legal advisors, to recommend and implement any and all appropriate corrective or remedial action.
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