VERBALIZEIT PRIVACY POLICY

(Version Date: February 1, 2013)

VerbalizeIt, Inc. (“VerbalizeIt,” “us,” “we,” or “our”) is committed to protecting the privacy of the users of the http://www.verbalizeit.com web site (our “Site”), the VerbalizeIt mobile application (our “Application”), and the language translation and other services we offer through our Site and Application (our “Services”). This privacy policy (the “Policy”) discloses the information privacy practices for the VerbalizeIt Site, Application and Services.

VerbalizeIt encourages you to contact us with any concerns about our collection, use, or sharing of your information through our Site, Application, or Services. If you have questions or concerns regarding this Policy or our Site, Application, or Services, you should contact VerbalizeIt by e-mail at info@verbalizeit.com or by a letter sent to “Privacy” at: VerbalizeIt, Inc., 141 West 28th, 7th Floor, New York, NY 10001.

CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR INFORMATION

This policy is intended to inform individuals accessing our Site, Application, or Services (collectively, “Users”) of the use and sharing practices for the information we receive, collect, and obtain through our Site, Application, and Services. By accessing or using our Site, Application, or Services, you consent to the collection, use, and sharing of information about you as described in this Policy. We will not use or share the information we receive, collect, or obtain regarding you other than as stated in this Policy.

INFORMATION RECEIVED, COLLECTED, AND OBTAINED BY VERBALIZEIT

The information we receive, collect, and obtain includes information that is both “Personal” and “Non-Personal.” “Personal” information refers to information that may be reasonably associated with, linked to, or used to identify an individual, allowing that individual to be personally identified or contacted. “Non-Personal” information refers to information that may not by itself be reasonably associated with, linked to, or used to identify an individual. We receive, collect, and obtain the following general types of Personal and Non-Personal information (collectively, “Information”):

Information Collected from Users

VerbalizeIt collects Information directly from Users of our Services through their use of our Services and the translations they perform using the Services (“Translations”) regarding their use of and interaction with our Site, Application, and Services. We may use Personal and Non-Personal Information collected from Users in accordance with this Policy.

Information Received from Customers

VerbalizeIt receives Information from companies and other organizations that sign-up with us to enable their employees, members, users, or other individuals to become Users of our Services (our “Customers”) regarding those employees, members, users, or other individuals. We will not use or share the Personal Information we receive from Customers regarding Users except to provide our Services to those Users and Customers. We may use any Non-Personal Information generated from that Personal Information in accordance with this Policy.

Information Obtained from Third Parties

VerbalizeIt receives Information about You if you register for the Services through a third party. Any Personal information you provide to that third party in connection with your registration may be imported into your account for the Services and used by VerbalizeIt in accordance with this Policy. VerbalizeIt may also obtain Information from other third parties regarding our Users as well. We may use any Personal and Non-Personal Information obtained from third parties in accordance with this Policy.

COLLECTION OF INFORMATION BY OUR CUSTOMERS AND OTHER THIRD PARTIES

The web sites and services of VerbalizeIt’s Customers, and other third parties such as advertisers or affiliates, may be accessible through our Site, Application, or Services. You may be asked to provide Personal Information through these other sites or services. For example, when you click on a link on the Site or Application. VerbalizeIt’s Customers and these other third parties maintain their own information privacy policies and practices. This Policy covers only Information received, collected, and obtained by VerbalizeIt and does not extend to our Customers or any other third parties. VERBALIZEIT IS NOT RESPONSIBLE FOR THE POLICIES OR PRACTICES OF OUR CUSTOMERS OR ANY OTHER THIRD PARTIES. YOU SHOULD REVIEW THE APPLICABLE PRIVACY POLICIES OF OUR CUSTOMERS AND ANY OTHER THIRD PARTIES BEFORE PROVIDING THEM WITH ANY INFORMATION.

COLLECTION OF PERSONAL INFORMATION BY VERBALIZEIT

We may use and share the Personal Information we receive, collect, and obtain regarding Users as described in this Policy. We may automatically collect Personal Information from you when you use or interact with the Site, Application, or Services. We may also collect Personal Information from you voluntarily on the Site or through the Application or Services, including through the Translations you perform using the Services and through the other interactions you have through the Site, Application, and Services. These sources may include, for example, registrations, responses, reviews, comments, confirmations, surveys, messages, phone calls, and other communications sent by you to the Site or through the Application or Services. In addition to your name, the Personal Information we may collect from you will include, by way of example:

  • Domain name and Internet Protocol (IP) address
  • Browser type
  • E-mail address
  • Contact information (including, address, zip code, country, and phone number)
  • Gender
  • Occupation
  • Username and password
  • Language desired for translation
  • Language proficiency
  • Payment information
  • Geographic location (including precise location information)
  • Statistics regarding when and how you access to the Site, Application, and Services
  • Information you may volunteer on the Site, during Translations, or through your other interactions with the Application or Services.

YOU SHOULD NOT PROVIDE ANY PERSONAL INFORMATION TO VERBALIZEIT UNLESS YOU WOULD LIKE THAT INFORMATION TO BE USED IN ACCORDANCE WITH THIS POLICY.

USE AND SHARING OF PERSONAL INFORMATION BY VERBALIZEIT

The Personal Information that VerbalizeIt receives, collects, and obtains may be used for a variety of purposes, including by way of example:

  • Providing Translations and our other Services
  • Customizing and improving the Services and the Site and Application
  • Providing advertising through on the Site and through the Application or Services
  • Providing maintenance, support, and customer service for the Site, Application, and Services
  • Providing notices regarding the Site, Application, and Services
  • Analyzing Translations and other data and patterns regarding interactions with the Site, Application, and Services
  • Developing additional products and services based on Translations and on other data and patterns regarding interactions with the Site, Application, and Services
  • Contacting Users for direct marketing purposes
  • Contacting Users for information verification purposes

In addition to the other uses of Personal Information described in this Policy, we may share the Personal Information we collect and obtain in the following ways:

Customers

We may share Personal Information regarding a User with the Customers on behalf of which we have been asked to register that User for the Services.

Service Providers

We may share Personal Information with third parties that help us provide various services relating to the Site, Application, or Services rather than performing the services ourselves. For example, we may contract with a third party to: (a) facilitate or provide payment processing; (b) maintain and manage our database of Information; (c) to host our Site or Services; (d) assist us with Information collection; (e) provide analysis or testing of our Information or Services; (f) to enhance or overlay our Information with other Information obtained from third parties; or (g) provide other services to assist us in our business. We require that these third parties agree to use the Information we share with them only to perform their obligations to us and to treat all Information they receive from us in compliance with this Policy.

Advertisers

We may share Personal Information with advertisement serving companies to target advertising and other content to you and provide pertinent offers that may be of interest to you based on your use of the Site, Application, and Services. The advertisements and content may be displayed or provided either on the Site or through the Application or Services. In addition, third party advertisers may receive Personal Information about you if you click on advertisements displayed on the Site or through the Application. Clicking on any advertisement will be considered your consent to “opt in” for this transfer.

Other Companies

We may share Personal Information with selected third party companies so that they may develop and offer products and services to you that we believe will be of interest.

For instructions on how to “opt-out” of disclosure of your Personal Information to these third parties, including how to opt-out of the disclosure of your Personal Information for direct marketing purposes, please see the Choice and Opt- out section below.

COLLECTION, USE, AND SHARING OF NON-PERSONALLY IDENTIFIABLE INFORMATION BY VERBALIZEIT

Our Site, Application, and Services may also automatically collect certain Non-Personal Information when you use or interact with the Site, Application, or Services. We also receive and obtain Non-Personal Information from our Customers and other third parties. This Non-Personal Information will include, by way of example, performance information and other metrics regarding the use of and access to the Site, Application, and Services. We may also generate Non-Personal Information from the Personal Information we receive, collect, and obtain under this Policy. When we do so, we will take reasonable measures to ensure that the Non-Personal Information is no longer personally identifiable and may not later be reasonably associated with, linked to, or used to identify you. This will include, by way of example, storing the Non-Personal Information separately from any Personal Information. Once we generate any Non-Personal Information from any Personal Information, we will not later attempt to again make that information personally identifiable. However, we may combine and enhance that Non-Personal Information with other Non-Personal Information received or obtained from Customers or other third parties. Provided that this Information remains in non-personally identifiable form and may not be reasonably associated with or linked to you or used to identify you, we may use or share any Non-Personal Information we receive, collect, obtain, or generate for any lawful purpose without a further duty or obligation to you. This will include, by way of example, generating product and service offerings based on the Non-Personal Information and providing those offerings to our Customers or other third parties.

RECORDING AND USE OF INFORMATION FROM TRANSLATIONS

VerbalizeIt may also collect Information (both Personal and Non-Personal) from Users through the Translations they perform using the Services. As part of this Information, VerbalizeIt may tape or otherwise electronically record the Translations performed by Users through the Services to the extent permitted by law. By using the Services, you acknowledge and consent to the recording, retention, monitoring, and use by VerbalizeIt of each Translation you perform through the Services, including your verbal communications with VerbalizeIt (or the employee, contractor, or representative of VerbalizeIt providing the Translation Services to you) and all other Information you provide during the course of each Translation. The recording of any Translation and all other Information (both Personal and Non- Personal) collected from any Translation may be used by VerbalizeIt as stated in this Policy and in the Terms of Use for the Services.

SENSITIVE INFORMATION

You are not required to provide VerbalizeIt with any Information regarding your medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs, or other sensitive Information in order to use our Site, Application, or Service. VerbalizeIt does not knowingly solicit or collect, and you should not provide to VerbalizeIt, any such sensitive Information, whether through the Site, Application or any Translation or other Services.

CHILDREN

Our Site, Application, and Services are intended for a general audience and are not directed to children under 13 years of age. VerbalizeIt does not knowingly receive, collect, or obtain Personal Information from children under 13 years of age.

DISCLOSURE OF INFORMATION AS REQUIRED BY LAW

Though we make reasonable and appropriate efforts to preserve user privacy as stated in this Policy, we may need to disclose Personal Information of certain Users when we have a reasonable and good-faith belief that the disclosure is necessary to enforce the Terms of Use for the Site, Application, or Services, to comply with a judicial proceeding, court order or other legal process, to avoid injury to a third party, or to otherwise enforce or protect VerbalizeIt’s rights under applicable law, including, without limitation, VerbalizeIt’s intellectual property rights. In these situations we will use reasonable efforts to provide notice of our disclosure to all affected Users, to the extent reasonably possible under the circumstances.

YOUR CALIFORNIA PRIVACY RIGHTS

California law provides that California residents have a right to request that businesses tell them how their personal Information has been shared with third parties for use in direct marketing purposes. However, there is an exception to this requirement for businesses that have adopted and disclosed, in their privacy policy, a policy of not disclosing a person’s Personal Information to third parties for use in direct marketing purposes if that person has exercised an option to opt-out of the disclosure of their Personal Information to third parties for such purposes. VerbalizeIt has adopted a policy of allowing you to opt-out of the disclosure of your Personal Information to third parties for their direct marketing purposes and thus falls within this exception. Instructions for opting out can be found in the section below entitled “Choice and Opt-Out.”

CHOICE AND OPT-OUT

We provide you with a choice whether to receive certain emails or other messages through the Site, Application, and Services and the opportunity to ‘opt-out’ of having your Personal Information shared with third parties for certain purposes. If you no longer wish to receive messages from VerbalizeIt through the Site, Application, or Services, or to have your Personal Information shared with third parties as permitted by this Policy, you may opt-out of receiving those messages from us or having your Personal Information shared with third parties. In many cases, opting out of receiving messages or having your Personal Information shared with a third party will not affect your ability to use or access the Site, Application, or Services. However, some messages (e.g. account notifications, service announcements, and billing information) are considered necessary to our operation of the Site, Application, and Services. Likewise, some of the third parties with which we share your Personal Information are used by us to provide necessary functionality for the Site, Application, or Services. If you wish to opt-out of receiving these messages or of sharing your Personal Information with those third parties, we may be required to limit or cancel your access to and use of our Site, Application, or Services. Note also that while you may opt-out of receiving messages from VerbalizeIt, you may be required to contact our Customers or other third parties directly to also opt-out of receiving emails or other messages from those Customers and third parties. All opt-out requests can be made by contacting us as described above. Note that it may take up to 10 days to remove your contact information from our lists, so you may receive messages from us for a time after your request.

AUTOMATED TRACKING (COOKIES AND WEB BEACONS)

We and our third party service providers use “cookies,” “web beacons,” and other automated tracking technology to monitor and collect Information regarding your interaction with the Site, Application, and Services. “Cookies” include commonly used pieces of information in the form of small files that are placed on an individual’s computer or mobile device to allow us to recognize your computer or mobile device. “Web beacons” (also known as “single–pixel” or “clear” GIFs) include electronic images imbedded in the Site or Application used to pass information from your computer to us. We may use Cookies, web beacons, and other tracking technology that expire once you close your web browser or that persist and stay on your computer until you delete them. Most browsers will allow you to erase cookies from your computer or mobile device, block acceptance of cookies, or receive a warning before a cookie is stored. You may also be able to refuse certain web beacons by adjusting the settings on your browser or email software. Please refer to your browser or email software instructions or help screen to learn more about these functions. Customers and advertisers may also use cookies, web beacons, or other tracking technologies in messages and advertisements displayed on the Site and through the Application or Services. We do not have access to information that would confirm the use of cookies, web beacons, or other tracking technology by our Customers and advertisers.

ACCESS, REVIEW, AND UPDATE OF INFORMATION

While VerbalizeIt takes reasonable steps to ensure that the Personal Information we collect is reliable for its intended use, accurate, complete, and current, we rely on you to update and correct your Personal information. You may contact us as described above to review, delete, update, or change any of your Personal information received, collected, or obtained by VerbalizeIt.

NOTIFICATION OF CHANGES

We will notify Users of any changes to this Policy. Notification will be made by way of an email to Users or by posting of the changes on the Site or through the Application. Changes to this Policy will be effective 30 days following notice to any existing Users and immediately for any new Users. Your continued use of the Site, Application, or Services after any change has become effective will constitute your acceptance of that change. Unless we seek and receive consent from a User, we will use the Personal Information we collect from each User in accordance with the version of this Policy effective when the Information was last collected. Users may contact us as described above regarding any change to this Policy, including to prevent their Personal Information from being used pursuant to any change to this Policy.

SECURITY

VerbalizeIt is committed to protect and secure your Personal Information. Despite our commitment, no security system can be 100% effective and we cannot guarantee that your Information will be secure in all situations. We will nonetheless take all reasonable and appropriate steps to insure the safety and security of your Personal Information. This includes using at least industry standard security measures to protect the loss, misuse, and unintended alteration of the Personal Information under our control. For example, our policy is that only those individuals who need your Personal Information to perform a specific job for us are granted access to that Personal Information. Likewise, all employees and contractors are kept up-to-date on our security and privacy practices. Finally, the servers that we store personally identifiable information on are kept in a secure environment.

TRANSFER OF INFORMATION

If VerbalizeIt elects, in its reasonable discretion, to transfer ownership or control of the Site, Application, or Services to a third party, whether or not in the context of an acquisition, merger, or reorganization, you consent to the transfer of your Information (both Personal and Non-Personal) by VerbalizeIt to that third party, provided that all use and sharing of your Information by that third party remains subject to the terms of this Policy and any applicable changes.