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PRIVACY POLICY

INTRODUCTION

Thank you for using InXero.com. We are committed to honoring the confidentiality, integrity, and security of the personal information of Users shared through the Services (as defined below) provided on the InXero.com website. InXero facilitates the interaction of its business clients (“Clients”) with their customers and potential customers (each, a “User”) who will interact with InXero Clients in one or more online marketing & sales efforts through an array of showcase and promotion products and services, events, webinar applications, enterprise conversation and information management, vendor software and service databases, vendor marketing content through dedicated channels, websites, mobile devices, customer experience management, social networking, activity tracking, status updating, messaging and commenting, and online collaborative workspace services provided by InXero through its website, mobile applications, and other platforms designed to manage and enhance internal and external business relationships (the “Services”). InXero collects information about Users under the direction of its Clients. InXero has no direct relationship with the Users whose personal data it processes. InXero works with its Clients to help them provide notice to Users concerning, the purpose for which personal information is collected.

This InXero Privacy Policy (this “Policy”) describes how we treat Users’ personal information gathered by InXero through its Services. Please take a moment to read the following to learn more about our information practices and how we safeguard personal information. We take Users’ interests seriously. If you have questions or concerns regarding our privacy practices or this Policy, please contact us at customerservice@InXero.com (please put “Privacy” in the subject line of your email).

This Policy is subject to the InXero Terms of Use and, for registered Clients, subject to the Master Subscription Agreement entered into in connection with such registration. By using InXero, including Services available at InXero.com domains, Users agree to be bound by the Terms of Use or Master Subscription Agreement, as applicable, and this Policy. Additional terms may be defined in the Terms of Use or Master Subscription Agreement, as applicable.

As used herein, the term “personal information” means information that specifically identifies an individual (such as a name, telephone number, mobile number, e-mail address, employer, mailing address, or credit card number), or information about that individual that is directly linked to personally identifiable information. Personal information does not include “aggregate” information, which is data we collect about the use of our website or about a group or category of services or Users, from which individual identities or other personal information has been removed. This Policy in no way restricts or limits our collection and use of aggregate information. The terms “you,” “your,” “yours” and “User” refer to you, the User of this website. The terms “InXero,” “InXero.com,” “we,” “us,” and “our” refer to InXero, Inc.


INFORMATION COLLECTION AND USE

General.

We collect information about Users because it helps us deliver the best Services to our Clients, which in turn help our Clients more effectively connect with and market and sell to you, the User. Most importantly, this information allows us to tune the product experience over time so that we may optimize our Services based on Client and User feedback and actual use. You do not have to register with InXero to be considered a User under this Policy. If you interact with one of our Clients that uses the Services, you will be a User and information about you may be gathered by us because you have connected with one of our Clients and that Client uses our Services. In some instances, your interaction with a Client may lead you to content hosted on an InXero website, in which case your personal information will be gathered directly by our web site, but more often your personal information may be gathered by the Service being integrated into some other User-facing technology, such as a Client’s web site, Facebook or LinkedIn page, Twitter feed, or some other form of Internet based or social media platform which the Client utilizes. You should always be aware of the privacy practices of any website or social media or network application you use. Generally, if our Service operates within a web site or social media network or outlet owned or licensed by one of our Clients, your personal information is subject to the privacy practices of those web sites or applications, which then shares that information with us to help make the Services work more effectively for them. We provide this Policy as a courtesy to those Clients and to Users who may happen to reach our web site.

Use of the Service.

When you interact with the Services, we will collect personal information such as your name, email address, mailing address, zip code, mobile number or telephone number. You may interact with the Services in a variety of ways, including when a Client directs you to visit an InXero.com domain, through our Service hosted on a Client web site or on a Client’s presence on one or more social network or media outlets, or thorough the use of the Service in connection with a solution provider (such as Dell or IBM).

Profile Information.

To the extent that we offer an opportunity for you to register with our web site and obtain a registered account, you may submit personal information in connection with that registration. You acknowledge that registration information is personal to you, and by creating an account on InXero, you allow others, including InXero, to identify you. Once you become a User, you may provide additional profile information through InXero Services that describe background and other personal information. Providing additional information about yourself beyond what is minimally required at registration is entirely up to you. Any information you provide at registration or in other sections may be used by InXero as described in this Policy. However, if you decide not to share certain information, InXero may not be able to deliver the full benefits of its services to you.

Customer Service and Support.

InXero may collect information through the InXero Customer Service and Support interfaces in order to, among other things, accurately categorize and respond to User inquiries and investigate breaches of our terms.

Site Usage.

We may collect information about how Users are using certain InXero features and functionality, whether they are participating in research initiatives like polling and surveys, and whether they are interacting with third-party applications or clicking on advertisements. In addition, we may offer certain social networking features within the Services, including from third party social networking sites like Facebook.com, LinkedIn.com, Google+ and Twitter.com. We may gather information about your profiles on such social networking sites and store and republish such information on our website and as part of our Services. For more information on our social networking practices, see “Social Networking Applications” in the Terms of Use.

Cookies and Advertising.

Like most websites, InXero uses cookies, web log files, or related technologies to track site usage and trends, improve the quality of our Services, customize your experience on InXero’s website and through its Services, and deliver third-party advertising to Users both on and off the InXero website. A cookie is a tiny data file that resides on your computer, mobile phone, or other device, which allows us to recognize you as a User when you return to the InXero website using the same computer and web browser. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or indicate when a cookie is being sent. Please note, however, that if you decline to allow cookies in your browser, some or all of our features or services may not function properly as a result. In the course of serving advertisements or optimizing the Services to our Users, we may allow authorized third parties to place or recognize a unique cookie on your browser. InXero does not store unencrypted personal information in the cookies. Our Clients may create pages on the InXero platform that use technology from tracking utility companies, such as cookies and web beacons The use of these technologies by our Clients is not covered by this Policy. We do not have access or control over these third party tracking technologies.

In addition, the Adobe Flash Player (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies, but these are managed through a different interface than the one provided by your web browser. This technology creates locally stored objects that are often referred to as “Flash cookies.” We or our Clients may employ Adobe Flash cookies as part of the Service. InXero does not have access or control over our Clients’ Flash cookies, but you may access your Flash management tools from Adobe’s web site directly.

Log Files, IP Addresses, Location and Computer or Mobile Information.

When you visit the Service, whether through an InXero.com domain, through our Service hosted on a Client web site, through a Client’s presence on one or more social media ourtlets, or through the use of the Service in connection with a solution provider (such as Dell or IBM), we may log your IP address, location, access URL, time of access, browser type, and referral URL in order to provide us with internal information regarding site traffic statistics. This information may also be used to identify Users who are using the Services for activity that is deemed in conflict with our Terms of Use. This information is used in the aggregate, and is never linked back to any personal information, except as otherwise described herein.

INFORMATION SECURITY.

We store all User information in secure databases protected via a variety of industry-standard access controls. Secure passwords, SSL encryption and disk-based encryption (however, we do not use encryption during your day-to-day use of our website or interaction with our Services as they may appear on a Client’s web site or social media presence), firewalls, and other electronic measures are in place that help us protect your data. We also maintain physical and procedural safeguards, such as secure areas in buildings, authentication procedures, training our employees in the proper handling of personal information, and limiting employee access to this information to those employees with a business need for access. We employ these measures to ensure this data is accessed only for the purposes specified in this privacy statement. When we use third parties to assist us, we require that they comply with all the same confidentiality and security measures. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of any information gathered by the Service. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

USES OF INFORMATION

Consent to Process Information About You.

The personal information gathered by the Services may reveal, or allow others to identify, your geographic location, age, educational background, or other aspects of your personal life. By interacting with Clients who use our Services, you are expressly and voluntarily accepting the terms and conditions of this Policy and InXero’s Terms of Use.

Sharing with Clients.

As described above, we provide Services to our Clients. At their direction, and as part of the Services we deliver to them, we will communicate to our Clients personal information we gather about you. It is important to note that we do not share your personal information among multiple clients; rather, only the personal information gathered by a single Client’s use of the Services will be conveyed to that Client. In addition, we may share anonymous, aggregated data with any Client, so long as it does not reveal any identifying information about a User.

Communications from Clients.

As part of the Services, you may receive various communications from the Client for whom we provide the Services. By interacting with Clients who utilize the Services, you are affirmatively electing to establish a relationship with each such Client and receive communications from such Client in various forms including, without limitation, e-mails, InXero messages, postal mail, telephone, text messages, Facebook messages, Twitter Tweets, and messages within other social media. You are responsible for paying any service fees associated with your receipt of communications from Clients on your mobile device (including applicable data and text messaging charges and tolls). You acknowledge that InXero is not in control of, nor is it responsible for, the content of any communications which you may receive from individual Clients, nor is InXero in control of or responsible for the frequency with which Clients deliver communications to you. If you terminate your account, you will stop receiving communications from InXero, but you will not stop receiving communications from Clients for which your have requested to receive communications by opting in through the Services. To stop receiving communications from a particular Client, you must contact that Client directly.

Social Networking Applications.

Any information gathered by InXero through your use of social networking applications compatible with the Services, such as your profile picture and/or other profile information, may be shared with Client and/or republished on our website. Because social media or networking sites such as LinkedIn, Facebook, Twitter, etc. are outside the control of InXero, any content you post to such sites, even if in connection with your use of the Services, is subject to the privacy practices of such social media or network provider and not InXero and, therefore such content may be visible by any person using such social application.

Sharing Information with Third Parties. InXero takes User privacy very seriously.

Except for the permitted sharing described above, we do not sell, rent, or otherwise provide your personal information to third parties. Further, except as otherwise described herein, we will only share your personal information with third parties to carry out your instructions or to provide Services, or as necessary to enforce the Terms of Use or protect the rights, property, or personal safety of InXero, its Clients, Users, and/or the public. For example, we may transmit personal information to one or more third parties providing external hosting services to us. These third parties do not retain, share, or store any personal information except to provide these Services (including all third party hosting services, which generally will store this information as part of the service they provide to us), and they are bound by confidentiality agreements limiting the use of your information. We may provide aggregated anonymous data about the usage of the Services to third parties for purposes that we deem, in our sole discretion, to be appropriate, including to prospective advertisers on InXero.

Third Party Services.

InXero may from time to time make available to its Clients services provided by one or more third parties that are incorporated with the Services. If you chooses to use services provided by third parties, you may be asked to confirm acceptance of the privacy policy and/or user agreement of the third-party, which have not necessarily been reviewed or approved by Client or InXero. It is your choice whether or not to make use of these third-party services and whether to proceed under any third party terms. We cannot guarantee that any third-party will abide by this Policy or other agreements we may enter into with such third parties, if any. InXero is not responsible for your use of or inability to use any third party services, including the content, accuracy, or reliability of applications and the privacy practices or other policies of these providers.

Polls and Surveys.

InXero, Clients, or third party providers may conduct polls and surveys. As a User, you may be invited to participate in polls and surveys from the InXero website or from content posted on a Client or other domain. Your selection may be random, or it may be based on information other than personal information or other selection criteria. Your participation in any poll is completely your decision. After you complete a poll, you will be given access to the aggregate responses of the poll on a results page. Some third parties may target advertisements to you on the results page based on your answers in the poll. Further, InXero or third parties may follow up with you within the InXero system regarding your participation. We may use third parties to deliver incentives to you to participate in surveys or polls. We will not disclose any personal information to any third parties in connection with the conduct of any polls or surveys. However, if the delivery of incentives requires your contact information, you may be asked to provide personal information to the third party fulfilling the incentive offer, which will only be used for the purpose of delivering incentives and/or verifying your contact information. It is up to you whether you provide this information, or whether you desire to take advantage of an incentive. Your consent to use any personal information for the purposes set forth in the poll or survey will be explicitly requested by the party conducting it.

Forums, Communities, and Other Services.

If you post on any public forums provided by InXero (either on an InXero domain or on a domain operated by a Client or solution provider) or otherwise communicate through any User-facing portion of the Services, you should be aware that any personal information you choose to provide can be read, collected, or used by other Users of these forums, as well as other third parties, and could be used to send you unsolicited messages. InXero is not responsible for the information you choose to submit in these services.

Compliance with Legal Process.

It is possible that we may need to disclose personal information, profile information and/or information about your activities as a InXero User when required by subpoena or other legal process, or if InXero has a good faith belief that disclosure is necessary to (a) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (b) to enforce the Terms of Use, to investigate and defend ourselves against any third party claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property or personal safety of InXero, Users, employees, or others. All such disclosures shall be made at InXero’s sole discretion without notice to or consent from the User(s).

Disclosures Related to Business Transactions.

In the event InXero, Inc. or a division goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal information will be among the assets transferred. You will be notified of any such change in ownership or control of your personal information. Any third party to which InXero transfers or sells InXero’s assets will have the right to continue to use any personal and other information that you provide to InXero.



OTHER IMPORTANT INFORMATION

Privacy of Minors.

This website is not directed or otherwise promoted for use by children under the age of eighteen (18). We ask that any User under the age of eighteen (18) not submit any personal information to us or use the Services. Users who are under the age of 18 must obtain the consent of a parent or legal guardian before using the Services.

California Privacy Rights.

California Civil Code Section 1798.83 permits Users that are California residents to request that we not share their personally identifiable information with third parties if we know or have reason to know that the third parties use the personally identifiable information for the third parties’ direct marketing purposes. For their protection, we exercise this right on behalf of our California Users and require third parties hired by InXero to keep all personally identifiable information related to California Users secure and to not permit any use of personally identifiable information for direct marketing or any other purposes not authorized by InXero. Although we do not share such information for third party marketing purposes, Users should note that we operate in the capacity of a service provider to the Clients with whom you interact and, as such, we may share such information back with the Client who hired us. Therefore, your privacy relationship is with such Clients and you should confirm their privacy practices directly with such Client.

Changes to this Privacy Policy.

InXero may update this Policy from time to time. When we change this Policy in a material way, such as if there are significant changes in the way we treat your personal information, a prominent notice will be posted on our website along with the updated Privacy Policy. Please check this URL frequently to see the latest version of this policy. Using the InXero Services after a notice of changes is published on our site shall constitute consent to the changed terms or practices.


Should you have any questions or concerns regarding this Policy, please email us at customerservice@InXero.com (please put “Privacy” in the subject line of your email) or contact us at the following address:

InXero, Inc.
Attn: Privacy Policy Issues
c/o Austin Technology Incubator
3925 West Braker Lane
Austin, Texas 78759

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