Effective May 10, 2016

At Vega Factor, Inc., a Delaware corporation (the “Company”), your privacy is very important to us. The purpose of this privacy policy (this “Policy”) is to provide you with a description of the types of information we collect about you when you visit the Vega Factor web site located at vegafactor.com, and associated sub-domains (the “Site”) and/or download and register our mobile applications (each an “Application” and collectively, the “Applications”), and how we use that information. By visiting or using the Site and/or Application or using the products and services we provide to you, and any entity or organization on whose behalf you are accessing the Site and/or Applications, agree to the provisions of our Terms of Use and this Policy. If you do not agree to the terms of this Policy, please do not use or access the Site or the Applications or use the Products. This Policy only applies to information collected while you are on the Site or when you download and use an Application. For more information on how the Site and/or Applications may redirect you to other web sites, please see the “Links and Redirection to Third Party Sites” section below.


Information We Collect.  We collect and store information that you voluntarily provide to us as well as data related to your Site visit or Application usage. In some areas of the Site or Application, we may request that you provide personally identifiable information, including your email address and other information from which your identity is or may be discernible. We may also solicit your responses to survey questions or other inquiries incorporated into the products and services we provide. The information we collect may be stored on our servers, and on the servers of third party service providers. In addition, during your visit to the Site or Application we automatically collect certain aggregate information and analytical data related to your Site visit and Application usage (see “Use of Cookies” below). Aggregate information is non-personally identifiable or anonymous information about you, and may include the date and time of your visit, the IP address of your computer or mobile device, your computer or mobile device browser information, the Internet address that you visited prior to and after reaching the Site, the name of the domain and host you used to access the Internet, the type of mobile device you use, your mobile device’s unique device ID and the features of our Site and Application which you accessed. This data is not associated with your personally identifiable information.


How We Use Information.  We use collected information to make available and to improve our high standard of reliable service. We use such information to: respond to inquiries or service requests and monitor such responses; provide information about and market our products or services; resolve problems; and manage the Site, the Applications and assess their usage and usage of the products and services.


Personally identifiable information gathered during your interactions with the Application, such how you answer particular questions and other usage data may be aggregated with similar data from other users and may be used to benchmark and analyze user trends and to generate aggregate statistical data concerning motivation, performance, and other similar subjects.


We may use data gathered during your interactions with the products and services to provide the products and services to you and, if applicable, your team or sponsor.  In addition, we may use data gathered during your interactions with us in order to provide our products and service to other customers, for benchmarking purposes, improvements to products and services, and creation of aggregated data so long in the course of such actions we do not disclose your data to third parties or disclose you as the source of the data (it being understood we can use subcontractors for that purpose so long as they are similarly limited).  Further, nothing herein limits our use of aggregated non-personally identifiable information to the full extent permitted by applicable law, including without limitation for benchmarking, improvements to products and services, or marketing.


In addition to the provisions of this Privacy Policy, information we collect is also governed by the terms of the Individual User Agreement (“User Agreement”) to which you agreed regarding your use of the Site, Applications or Products. We may also share that information with team members or , if any, as specified in your User Agreement (“Related Users”).  To the extent any of the information collected from you qualifies as “Personal Data” under E.U. Directive 95/46/EC on the Protection of Individuals with Regard To the Processing of Personal Data and on the Free Movement of Such Data (the E.U. Data Protection Directive) or other laws or directives regarding the treatment of Personal Data, you will be provided with all applicable rights and protections thereunder. If you have any questions regarding the foregoing, or our privacy practices, or the products and services, you may contact: support@vegafactor.com.


Disclosure of Information.  We do not sell or rent personally identifiable information to third parties who are not affiliates of the Company, except as described here. We may disclose personally identifiable information to appropriate affiliates of the Company, including strategic alliance affiliates and third party service providers, to respond to a request for service or to provide information about available products or services. And we may disclose information we collect to Related Users, and to assess trends and knowledge regarding the subject matter of surveys we incorporate into our Site, Applications and products and services. We are not limited in our use of non-personal information that does not permit direct association with any specific individual, or non-identifiable aggregate information about our users (such as the number of users of our products, the geographic distribution of our users, the amount of information located and/or removed, etc.). We disclose information that we, in good faith, believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our User Agreement. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity’s contact information to victims who request it. In addition, we reserve the right to disclose aggregate information and personally identifiable information to third parties as required or permitted by law and when we believe that disclosure is necessary to protect our rights. We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action. If the subpoena seeks information about an identified user or limited group of users, we’ll make reasonable business efforts to contact the user(s) before providing information to the party that requests it. We cannot guarantee that we will be able to contact the user(s) in all cases, whether because of a time limit, court order, inability to effectively contact a user, or for any other reason. We may disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).We share information with companies that provide public relations and marketing services for us. Such information will only be shared by us to customize, measure and improve our products and services and advertising; it will not be shared with third parties for their marketing purposes. These third parties are obligated to protect your information and are prohibited from using your personally identifiable information for any other purpose. As with any other business, it is possible that in the future we could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by us, including customer account information, but would continue to be bound by this Policy unless and until it is amended. We share your information with our parent, subsidiaries and joint ventures to help coordinate the products and services we provide to you, enforce our terms and conditions, and promote trust and safety. We share your information with our parent, subsidiaries and joint ventures to help coordinate the Products we provide to you, enforce our terms and conditions, and promote trust and safety. We may share aggregate (non-personally identifiable) information with certain third parties such as advertisers, national industry organizations, and prospective affiliates.


Choice and Opt-Out.  We provide you the opportunity to “opt-out” of having your personally identifiable information used for certain purposes when we ask for this information. For example, if you do not wish to receive marketing material from us, you can indicate your preference by clicking a link to unsubscribe contained in such communications. You can stop all collection of information by an Application by uninstalling that Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each communication.


Use of Cookies.  “Cookies” are simple text files stored on your computer for use by a browser. Certain Site features may only be available through the placement of a cookie. We may use “cookies” to assist in data collection and to track visitor Site usage and trends to help us better serve you. The use of cookies is a standard practice among Internet web sites; most Internet browsers permit a user to accept, decline or delete cookies. We may use persistent cookies to make it easier for you to navigate the Site. Specifically, we may use persistent cookies to track whether you are logged into the Site. A persistent cookie may remain on your local device for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. We may set a persistent cookie to store how you came to the Site and what items you interact with. Persistent cookies also enable tracking and targeting the interests of our users to enhance their experience on the Site. If you reject cookies, you will still be able to view the Site, but your ability to use some areas of the Site may be limited. You may be unable to log into the Site if you reject cookies.  Some of our business partners (e.g., analytical tracking software providers) use cookies and tracking technologies on the Site. We have no access to or control over these cookies or tracking technologies. This Policy covers the use of cookies on www.vegafactor.com and by us only and does not cover the use of cookies or tracking technologies by any such business partner.

Data Security.  We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee its absolute security. In the event of an inadvertent disclosure of your personal information we will take all commercially reasonable steps to limit and remedy the disclosure as required by the applicable law. If you have any questions about security on our Site and Applications, you can contact us via email or telephone at support@vegafactor.com.


Links and Redirection to Third Party Sites.  The Site and Applications contain links to third party web sites and may redirect you to third party web sites (“Third Party Sites”). These Third Party Sites may include, among others, service providers who have a relationship with the Company. Third Party Sites are not under the control of the Company, and the Company is not responsible for such Third Party Sites, including without limitation the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness thereof, any link contained therein, or any changes or updates thereto. The inclusion or access to Third Party Sites does not imply an endorsement thereof by the Company or of the provider of such content or services, or of any third party web site. The Company reserves the right to terminate any link or linking program at any time. Please be aware that when you enter a Third Party Site, any information you provide, including financial information, is subject to the terms of use and privacy policy of that Third Party Site.


Age Limitation.  This Site and our products and services are not directed to person under the age of 18 and the Applications should not be downloaded by any person under the age of 18. If you become aware that your child has provided us with personal information without your consent, please contact us at support@vegafactor.com. We do not knowingly collect or solicit information from, market to or provide products or services to persons under 18 years old. If we become aware that a person under 18 has provided us with personal information, we take steps to remove such information and terminate the person’s account.
Effective Date; Policy Changes.  Each time you use the Site or an Application, the current version of the Policy will apply. Accordingly, when you use the Site or an Application, you should check the date of this Policy (which appears at the top of the Policy) and review any changes since the last version. Our business changes frequently and this Policy is subject to change from time to time. You are encouraged to check the Site regularly for any changes to this Privacy Policy. Unless stated otherwise, our current Policy applies to all information that we have about you. We will not materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected customers.


Lost or Stolen Information.  You must promptly notify us if you become aware that any information provided by or submitted to the Site or an Application is lost, stolen, or used without permission.


Governing Law.  This Policy is governed by the laws of the State of New York, U.S.A. without giving effect to any principles of conflict of law.


Your California Privacy Rights.  California Civil Code Section 1798.83 permits customers who are California residents and who have provided the Company with “personal information” (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a California resident with questions regarding this, please contact us at support@vegafactor.com.


Contact Us.  To contact us with your questions or comments regarding this Policy or the information collection and dissemination practices of the Site or Applications, please email us at support@vegafactor.com. To see the User Agreement that applies to the Site and Applications, see www.vegafactor.com/terms. All trademarks, service marks, and other proprietary materials herein are the property of Vega Factor, Inc. 2016. All rights reserved.