Linqto, Inc. ("Linqto") takes safeguarding online privacy seriously. Please read the following to understand Linqto’s privacy practices regarding information we collect from users of our Site and Application (as defined in the Terms of Use). From time to time, Linqto may change this privacy policy as described in Section 13 (below).

1. CONSENT.

By submitting Personal Data through our Application, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.

2. A NOTE ABOUT CHILDREN.

We do not intentionally gather Personal Data about visitors who are under the age of 13.

3. A NOTE TO USERS OUTSIDE THE UNITED STATES.

Your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country.

4. WHAT DATA DO WE COLLECT FROM YOU?

(a) Data You Provide. "Personal Data" means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. We collect Personal Data from you when you create an account as described in Section 5 below (“Account”). We collect information from you when you use our virtual rooms as described in Section 5 below. When you order services, we (or our service provider) will collect all information necessary to complete the transaction, including your name, credit card information, billing information and shipping information. We retain information on your behalf, such as files and messages that you store using your Account. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply. We may also collect Personal Data, such as at other points in our Site that state that Personal Data is being collected.

(b) Data Collected via Technology. To make our Application more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. Linqto may use cookies on its home page to save users time so they do not have to enter their password each time they visit the Site or enter a virtual room. Linqto may also use cookies on its download page to speed up users’ activities in not having to register more than once. Linqto may also use cookies in other areas on its Site now and in the future. Linqto’s cookies do not contain Personal Data. “Cookies” give users a unique, random ID by storing small text files onto a user’s computer hard drive with the user’s browser. Cookies enable a web site to track a user’s activities on a web site. Users are free to change their web browsers to prevent the acceptance of cookies. Please note that if you disable Cookies, parts of our Site may not function as intended.

(c) Google Analytics. We currently use Google Analytics. Google Analytics collects information anonymously and reports website trends without identifying individual visitors. Google Analytics uses its own cookie to track visitor interactions. Website owners can view a variety of reports about how visitors interact with their website so they can improve their website and how people find it. Please see the following links for more information about Google Analytics: www.google.com/intl/en/analytics/privacyoverview.html.

5. Specific Information About Virtual Rooms

(a) Who may be present in the virtual room and observe what I say or do? There are up to three types of participants in or users of the virtual rooms provided by Linqto: Administrators, observers and invited guests. An Administrator is the individual setting up the virtual room meeting. Administrators must register for an Account with Linqto and have available to them such features as the ability to allow invited guests to ask questions, limit time for questions or comments for invited guests, and other features. Administrators typically manage the technical issues related to the conduct of the virtual meeting and functionality of the virtual room. The presence of an Administrator may or may not be visible or disclosed to invited guests. Observers may be present with the permission of the Administrator to observe the virtual meeting but not participate. The presence of an observer will not be visible to the invited guests. Invited guests are the meeting attendees, similar to attendees at a conference, or members of the crowd at a concert (with added features to participate or interact). Administrators, observers and invited guests may view participant comments through the messaging feature, hear verbal comments and other audible content through the audio feature and view images through the video features. Linqto does not have the responsibility to require that other participants in your room refrain from using, or maintain confidential, items you discuss, disclose or provide. Therefore, any information you submit or disclose in a virtual room should not be considered confidential.

(b) Does Linqto monitor and/or record activity and discussions within the virtual rooms?

(i) Linqto may monitor activity and discussions within the virtual rooms for purposes of ensuring the operation of the Site, monitoring compliance with its Terms of Use, and conducting market research for its own use in developing and improving the use and functionality of the Site and virtual rooms. An Administrator may record the activity and discussions within the virtual rooms, which recording is automatically publicly posted on the Administrator’s Facebook page. These recordings are an accommodation and may be deleted periodically (and Linqto does not warrant or make any representation whatsoever regarding the quality or success of such recording). If you have need for a permanent recording, you must use another screen capture type of recording tool. If Linqto is not the Administrator of a virtual room, Linqto will not separately publish, disclose, record, or retransmit video, audio, text or other items discussed or disclosed within such virtual room without the room Administrator’s consent, except for the Enforcement Exceptions listed below. Please note, that in some instances, Linqto or its representatives may organize topics, presentations and discussions within virtual rooms and act as an Administrator, in which case, Linqto (as an Administrator) may publish disclose, record, or retransmit video, audio, text or other items discussed or disclosed. As set forth above, Linqto is not responsible for preventing other participants from publishing, disclosing, recording, or retransmitting such content.

(c) Do I need to provide Personal Data to Linqto to use the Virtual Room?

(i) You may enter a virtual room within the Site as an invited guest of the Administrator for that room without registering with Linqto. If entering from Facebook, the room will use your Facebook identity. If entering from Linqto, you will be required to enter a screen name. When entering a room, you may disclose your name and other Personal Data which will be visible to other participants in the virtual room.

(ii) You must register an Account with Linqto to be eligible to act as an Administrator. Setting up an Account as an Administrator provides you with the ability set up, organize and conduct meetings, conferences and social gatherings in a virtual room for your invited guests as described on the Site and in accordance with the Terms of Use and pricing and payment requirements, if any. When registering as an Administrator, Linqto may request specific Personal Data from you, such as your name, physical address, e-mail address, and telephone number, and in some cases password information to protect your Account (or virtual room) from unauthorized access.

6. Why does Linqto collect Personal Data, and how is it used?

(a) Linqto uses your Personal Data create your Account and to operate, maintain and provide to you the general and personalized features and functionality of the virtual rooms you use within the Site. We may also use your information to improve our Application, provide you with service you request, to send you administrative emails, to respond to your emails, and to notify you of any other changes within the Application that may affect you. Linqto does not use your email address or other Personal Data to send commercial or marketing messages to you without your consent. If you have consented to receive commercial or marketing messages, Linqto may notify you of product upgrades and updates, new products, special offers, seminars and conventions presented through Linqto within an indicated area of interest.

(b) Linqto may use Anonymous Data you submit or related to your usage of virtual rooms for purposes related to Linqto’s business, including, but not limited to, generating statistical studies, conducting market research, and improving website and virtual room services, features and functionality. "Anonymous Data" means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that make the data personally identifiable to you. We reserve the right to use Anonymous data for any purpose and disclose Anonymous Data to third parties in its sole discretion.

7. How do I have my personal information deactivated, changed or updated?

(a) Linqto respects your privacy and realizes that not everyone likes to receive special offers or information. If you would like your name deactivated from Linqto’s lists, please use the contact information below to request that Linqto deactivate you from its lists. Be sure to include your name, postal address, telephone number, information contained in your Linqto mailer, and/or other necessary information requested for deactivation. Despite your indicated e-mail preferences, we may send you service related communication, including notices of any updates to our Terms of Use or Privacy Policy.

(b) If you believe that Linqto may not have your correct and current personal information, you may update your information any time by using the contact information below to inform Linqto of changes in your personal information. You may request deletion of your Personal Data by us, but please note that we may be required 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 any information, it will be deleted from the active database, but may remain in our archives.

(c) Linqto will use reasonable efforts to honor your requests, but we appreciate your patience in allowing us a reasonable amount of time for processing.

8. Does Linqto share the information that it gathers with third parties?

Linqto does not share Personal Data with third parties without your consent except as described below:

(a) When you use a virtual room, your Personal Data may be visible to others as described in Section 5 (above). For example, but without limitation, a recording of the virtual room may be posted on the Administrators Facebook page as described above.

(b) We may share your Personal Data with third party service providers to: provide you with the Application that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of Accounts; to provide technical support; and/or to provide other services to the Linqto. These third party service providers are required not to use your Personal Data other than to provide the services requested by Linqto.

(c) We may share some or all of your Personal Data with our parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company, business, or our assets, that company will possess the Personal Data collected by it and us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

(d) Regardless of any choices you make regarding your Personal Data, Linqto may disclose Personal Data as may be necessary to respond to violations of the Linqto Terms of Use or Privacy Policy, to report suspected unlawful activity to law enforcement officials, governmental agencies, or other third parties, in connection with any legal investigation, to comply with relevant laws or to respond to subpoenas or warrants served on Linqto, or to protect or defend the rights or property of Linqto or users of the Application (collectively, the "Enforcement Exceptions").

(e) Linqto may share Anonymous Data with third parties as described in Section 6(b) above.

9. Social Networking Sites (SNS).

If you associate your Linqto Account with your login credentials from a social networking site (e.g., Facebook) ("SNS"), we may receive Personal and/or Anonymous Data about you from such SNS, in accordance with the terms and conditions (e.g., terms of use and privacy policy) of the SNS ("SNS Terms"). If you elect to share your information with these SNS, we will share information with them in accordance with your election. The SNS Terms of these SNS will apply to the information we disclose to them. For example, your Linqto Account is associated with your Facebook account. Facebook will provide us your basic information (which may include your name, profile picture, gender, networks, user ID, list of friends, or other information you share publicly on Facebook) as well as your email address, location, birthday and publishing stream, each in accordance with Facebook’s terms and conditions. We may add this information to the information we have already collected from you via the Application. In addition, you may elect to share certain content from our Application with Facebook. Once provided to Facebook, Facebook’s terms and conditions will govern its use of this information.

10. Note About Third Party Websites.

When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.

11. What is Linqto’s commitment to data security?

Linqto recognizes your concern for security, and will use reasonable efforts to establish secure connections with you and to limit access to databases containing Personal Data to authorized personnel only. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Linqto uses reasonable efforts to protect your Personal Data, Linqto cannot guarantee its absolute security.

12. What are Linqto’s contact procedures?

If you believe Linqto has not adhered to its privacy statement, if you would like to be deactivated from Linqto’s lists, or if you would like to update your personal information, you may notify Linqto by e-mail to support@Linqto.com, or postal mail at Linqto, Inc., P.O. 1193, Pebble Beach, CA 93953. Linqto will use reasonable efforts to promptly resolve any issues.

13. How may Linqto Change this Privacy Policy?

This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Site. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Application. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Privacy Policy may affect our use of Personal Data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Continued use of our Site or Application, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.