Last Updated: March 15, 2013

ContentGems by Intigi, Inc. (“ContentGems”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of our software applications including, but not limited to, our website located at contentgems.com (“Site”) and any other services offered by ContentGems in connection with the Site (any and all of the foregoing the “Services”). This Privacy Policy applies only to information that you provide to us through the Site and Services.

This Privacy Policy may be updated from time to time. We will notify you of any material changes by making the new Privacy Policy available on the Site or via our Services. You are advised to consult this policy regularly for any changes.

Information Collection: Personally Identifiable Information

In the course of using the Site and Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you and administer your use and enjoyment of the Services (“Personal Information”). Personal Information may include, but is not limited to, your name, phone number, and email address. We use your Personal Information mainly to provide the Services and administer your inquiries.

We also collect the other information that you provide as part of registration and the administration and personalization of your user experience (e.g., without limitation, zip code or location (in either case on their own) and individual preferences and interests) (“Non-Identifying Information”).

We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Services and administer your inquiries.

Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non- identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other ContentGems users to attempt to provide you with a better experience, to improve the Services and to analyze and understand how our Site and Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance, to deliver a product to you according to your preferences or restrictions.

We also use your Personal Information to contact you with ContentGems newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications.

Log Data. When you use our Services (e.g., when you visit our Site), our servers automatically record information that your browser sends whenever you visit a website or service connected to the Internet (“Log Data”). This Log Data may include information such as your computer’s or tablet’s Internet Protocol (“IP”) address, browser type, the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, sections of our applications that you access, information you search for on our Site, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and Services for technical administration and tailoring our Services to our users’ needs.

Our Policy Toward Children

If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at contact@contentgems.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our database.

Cookies & Other Technologies

Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We may use “persistent cookies” to save a username and login password for future logins to the Site. We also may use “session ID cookies” to enable certain features of the Site or Services, to better understand how you interact with the Site and to monitor web traffic routing on the Site and aggregate usage of the Site and Services. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Services.

We may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (individually or collectively “Pixel Tags”) in connection with our Services to collect usage, demographic and geographical location data. A Pixel Tag is an electronic image, often a single pixel, that is ordinarily not visible to users and may be associated with cookies on a user’s hard drive. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services and to help determine the effectiveness of promotional or advertising campaigns.

Information Sharing and Disclosure

Aggregate Information and Non-Identifying Information. We may share aggregated information that includes non-identifying information and Log Data with third parties for industry analysis, demographic profiling, and to deliver targeted advertising about other products and services. Any aggregated information shared in these contexts will not contain your Personal Information.

Services Providers. We employ third party companies and individuals to facilitate our Services (e.g., without limitation, cloud computing services, maintenance services, database management, web analytics and improvement of our Services’ features), to provide the Services on our behalf, or to assist us in analyzing how Services are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Compliance with Laws and Law Enforcement. ContentGems cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of ContentGems or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.

Business Transfers. ContentGems may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Changing or Deleting Your Information

You may email us at contact@contentgems.com with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Security

ContentGems is very concerned with safeguarding your information. We employ reasonable physical, technological, and administrative security measures and attempt to ensure they are applicable under the circumstances. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Phishing

Identity theft and the practice currently known as “phishing” are of great concern to ContentGems. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited Email or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

International Transfer

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, ContentGems transfers Personal Information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Links to Other Sites

Our Services contains links to other websites and online services. If you choose to visit a third party service or an advertiser by “clicking on” a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party’s website or online service. The fact that we link to a website, content or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites or services. These other websites or services may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you use.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at contact@contentgems.com.