Privacy Policy

PRIVACY POLICY
Your privacy is important to us. This Soft10 Privacy Policy (“Policy”) describes the practices Soft10, Inc. (“Soft10,” “we,” or “us”) observes when collecting, using, and sharing data and other information (“Information”) we collect through our website located at www.soft10ware.com and any other websites operated by Soft10 (each, a “Site”) and through the services we provide through each Site (each Site and those services, our “Platform”). By accessing or using any part of our Platform, you consent to the collection, use and sharing of your Information by Soft10 as described in this Policy.

1. Information We Collect.

(a) Information we gather and collect through the Platform may include both “non-personal” and “personal” Information and may include, for example, names of files and variables you want to use for prediction, information contained in the files you use for prediction. We may also obtain “sensitive” personal Information about you through the Platform. For purposes of this Policy:
“Non-Personal Information” refers to Information that may not by itself be reasonably associated with, linked to, or used to individually identify you or someone else. For example general, non-specific Information regarding your use of the Platform or derived from the Information that you provide to us through the Platform. Information you provide through your use of the Platform for prediction purposes (e.g., for use in connection with certain predictive analysis services offered by Soft10 via the Platform) shall be deemed to be and shall be treated by us as Non-Personal Information for purposes of this Policy.
“Personal Information” refers to Information that may be reasonably associated with, linked to, or used to individually identify you or someone else or allow you or someone else to be personally identified or contacted. For example, Personal Information may include Information such as your name, email address, telephone number, address, or credit card number, either alone or in combination with other Information.
“Sensitive Personal Information” refers to Personal Information regarding more sensitive areas such as financial information, such as bank account or credit card numbers, medical or health conditions, precise geolocation information, or other sensitive topics.
(b) We may collect and gather Information through the Platform from a variety of sources, for example:
• We may collect Information directly from you when you provide Information to us through the Platform, for example, by visiting and using the Site, registering for the Platform, providing Information through the Platform, or otherwise communicating through the Platform.

• We use Google Analytics, which collects and processes data. For information about how Google uses data when you use our Platform, please see: “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time).

• We may also use live chat services or other services similar to Google Analytics or live chat services and we or our service providers, licensors, or contractors may collect or gather Information via such services.
• We may collect Information about you automatically when you interact with the Platform. For example, Soft10 and our third party service providers, licensors, and contractors may use “cookies,” “web beacons,” and other automated tracking technology to monitor and collect Information regarding how you access, use, and interact with the Platform. “Cookies” are commonly used small files that are stored on your computer or mobile device to help identify you as a unique user of the Platform. “Web beacons” (also known as “single–pixel” or “clear” GIFs) include electronic images imbedded in the Platform that allow us to recognize when you visit that area of the Platform.
• The computers we use to provide the Platform may also automatically record Information about you. For example, our web servers may record the Information you enter on the Platform, the areas of the Platform you visit, the services you use through the Platform, your IP address, or cookies that are set on your browser. We may use any Information we collect from you automatically through the Platform in accordance with this Policy.
• Please note that our third party service providers, licensors, and contractors also use cookies, web beacons, or other tracking technologies in promotional information and other messages displayed on or communicated through the Platform. We do not have access to information that would allow us to identify all uses of cookies, web beacons, or other tracking technology by our third party service providers, licensors, and contractors.

2. Use of Information.

(a) We may use and share the Non-Personal Information we collect and obtain to provide services to you through the Platform, including performing predictions based on Information you provide, and for any other lawful business purpose without any duty or obligation of accounting or otherwise to you, provided that the Information remains Non-Personal Information. This will include, by way of example, sharing that Non-Personal Information with third parties or developing products, services, and other offerings based on the Non-Personal Information and providing those offerings to other users and third parties.
(b) We may use the Personal Information we collect about you for a variety of purposes, for example:
• Operating the Platform;
• Providing services to you through the Platform, including performing predictions based on Information you provide;
• Customizing and improving the Platform and services for you;
• Providing maintenance, support, and customer service for the Platform;
• Providing advertising through the Platform;
• Providing notices and announcements to you relating to Soft10, the Platform, or your Information;
• Providing offers for products, services, or other offerings that we feel may be of interest to you;
• Contacting you for direct marketing purposes;
• Processing payments made through the Platform;
• Developing additional products, services and offerings; and
• Research and analysis.
We may combine and enhance the Personal Information we collect and obtain from you with Information we receive from third parties, provided that we use the combined Information in accordance with this Policy.
We may also use the Personal Information we collect and obtain from you to generate Non-Personal Information. 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 or someone else. This will include, by way of example, storing the Non-Personal Information separately from any Personal Information. Once we generate 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 we receive or obtain third parties.
YOU SHOULD NOT PROVIDE ANY PERSONAL INFORMATION TO US, WHETHER THE PLATFORM OR ANY SERVICES, UNLESS YOU AGREE TO THE — — USE OF THAT INFORMATION IN ACCORDANCE WITH THIS POLICY AND, IF THE PERSONAL INFORMATION IS ABOUT SOMEONE OTHER THAN YOU, UNLESS YOU HAVE THE AUTHORITY TO — — USE THAT INFORMATION AND TO PERMIT OUR — — USE OF THAT INFORMATION IN ACCORDANCE WITH THIS POLICY.
(c) The Information we collect and obtain regarding you may include Sensitive Personal Information. For example, when you share Sensitive Personal Information in communications with us through the Platform. Company will use any Sensitive Personal Information about you that we receive solely in accordance with this Policy to enable the operation of the Platform and the services you ask us to provide to you. Note though Soft10 is not responsible for monitoring the Sensitive Personal Information you may exchange with others through the Platform or for the use of that Information by other third party with whom you share that Information.

3. How We Share Information.

(a) We may share Information about you in a variety of ways, for example:
Affiliates. We may share Information with companies that we own or control, that are owned or controlled by us, or that are under common ownership or control with us.
Business Partners. We may share Information with business partners for which we collect Information through the Platform. We will work with our business partners to provide notice to you concerning the purpose for which any Personal Information is being collected on behalf of any business partner. Unless we otherwise notify you, any information we collect on behalf of a business partner will be in accordance with this Policy.
Advertisers. We may share Information with advertisers, for example to target advertising and other content to you and provide pertinent offers that may be of interest to you based on the Information we collect and obtain about you. In addition, third party advertisers may receive Personal Information about you if you click on advertisements displayed through the Platform. Clicking on any advertisement displayed through the Platform will be considered your consent to “opt in” for this transfer.
Service Providers. We may share Information with third parties that help us provide the Platform and our services. For example, we may use third parties to: (a) host, maintain, or manage the Platform or our services; (b) collect or analyze Information; (c) customize or assist us in managing our databases; or (d) provide other services relating to the Platform.
Other Entities. We may share Information with third parties so that they may develop and offer additional products and services to you that we believe will be of interest to you based on the Information we collect and obtain about you.
Law Enforcement. We may share Information with law enforcement agencies if we reasonably believe unlawful activities have occurred or the Information may aid in an investigation into unlawful activity. We may also share Information with law enforcement if we determine, in our sole judgment, that you have violated our agreements or policies or that the release of your Information may protect the rights, property, interests, or safety of Company or any third party.
Legal Processes. We may share Information as required by, or permitted by, law, whether in response to subpoenas, court orders, other legal processes, or as we believe is necessary to exercise our legal rights, including to defend against legal claims that have been or might be brought against us.
Business Transactions. If we transfer ownership or control of any portion of Company or the Platform to a third party, whether or not in the context of an acquisition, merger, or reorganization, we may transfer Information that third party, provided that the use of any of your Personal Information by that third party remains subject to the terms of this Policy.

4. Choice and Opt-out.

(a) We may give you the opportunity to “opt-out” of having your Personal Information used or shared for certain purposes otherwise permitted by this Policy. For example, we may provide you with a choice whether to receive certain messages through from us, whether through the Platform or through other means.
(b) If you no longer wish to receive certain messages from us or to have your Personal Information shared in the manner otherwise permitted by this Policy, you may seek to opt-out of receiving those messages or having your Personal Information shared in that manner. In some cases, opting out of receiving messages or having your Personal Information shared will not affect your ability to use the Platform or the services we provide through the Platform. However, some messages are necessary to the use and operation of the Platform. Likewise, some sharing of Personal Information is necessary to provide you with the services we offer through the Platform. If you wish to opt-out of receiving these messages or of sharing your Personal Information in this manner, we may be required to limit or cancel your access to the Platform or our services.
(c) All opt-out requests can be made as indicated through the Site or contacting Soft10 as described above. Note that it will take some time to remove contact information from our lists, so messages from us may continue for a time after a removal request is made.

5. Security.

Although we will take reasonable and appropriate steps to insure the safety and security of your Personal Information (including using industry standard security measures to protect the loss, misuse, and unintended alteration of the Personal Information under our control), we cannot guarantee that your Personal Information (or any other Information) will be secure in all situations. Furthermore, although Soft10 encourages its business partners to maintain the appropriate privacy standards, Soft10 does not have control over Information accessible through the Platform that is supported by third parties. Therefore, Soft10 security of your Information while being uploaded or downloaded to or from the Platform is your responsibility. Any Information you use in connection with your use of the Sites or Platform is subject to this Policy; if you wish to use any services provided by Soft10, including predictive analysis services, but do not agree to this Policy with respect to any data required for the provision of such services, please contact Soft10 to inquire about obtaining a license to Soft10 predictive analysis software that would allow you to use the predictive analysis software on designated servers you control.

6. Additional Terms.

(a) Children. The Platform and our services are not directed to children under 13 years of age. The Company does not knowingly solicit or collect personal information from children under 13 years of age.
(b) Do Not Track. Certain web browsers and other devices you may use to access the Platform may permit you to indicate your preference that you do not wish to be “tracked” online. At this time we do not modify your experience on the Site or the Platform, or the Information we collect from you through the Site or Platform, based on whether such a preference is indicated.
(c) 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. 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. We have adopted a policy of allowing you to opt-out of the disclosure of your Personal Information to third parties for direct marketing purposes and thus fall within this exception. Instructions for opting out can be found in the section of this Policy entitled “Choice and Opt-Out.”
(d) Notification of Changes. We may notify you of any changes to this Policy by way of an email, by posting on the Site or through the Platform. Changes to this Policy will be effective 14 days following such notice. Your continued use of the Site or other aspects of the Platform after any change has become effective will constitute your acceptance of that change. Unless we seek and receive consent from you, we will use the Personal Information we collect and obtain about you in accordance with the version of this Policy effective when the Personal Information was last collected.

7. Contact.

(a) If you have any questions or concerns regarding this Policy or our Information collection or usage practices, please contact us at http://soft10ware.com/contact/.
(b) If we need, or are required, to contact you concerning any event that involves this Policy or your Information we may do so using the email address, telephone number, or physical mail address we have on file for you.

The Effective Date of this Policy is 12 December, 2014.