Exostar Privacy Policy
(Effective November 1, 2011)
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This Privacy Policy sets forth the policy of Exostar, LLC ("EXOSTAR") with respect to the privacy of information EXOSTAR collects from its visitors and registered users (collectively, "users") on the web based trading exchange located on the Internet at http://www.exostar.com (the "EXOSTAR EXCHANGE").
1. COLLECTION AND USE OF INFORMATION
A. Registration Information. In order to become a registered user on the EXOSTAR EXCHANGE, a user must first register and provide certain contact information and information about the user's company (collectively, "Registration Information"). EXOSTAR uses the Registration Information to communicate with users about: (i) new and modified services and features offered by EXOSTAR; (ii) special offers made available by EXOSTAR or its partners; and (iii) specific activities in which the users are participating. EXOSTAR reserves the right to disclose the name of the user’s company (without identifying the user) to other users and to third parties for promotional purposes. EXOSTAR also reserves the right to use Registration Information of a user to communicate EXOSTAR offers, promotions or incentives to the user. Exostar may also include the Registration Information in a User Directory for distribution to other users (please see section 4 below for details on how to opt out of the User Directory). Except as provided in this Privacy Policy, EXOSTAR will not disclose Registration Information to third parties without the consent of the applicable user.
B. User Information. Users communicate and exchange information with EXOSTAR and other users in connection with their business relationship with each other and with EXOSTAR (collectively, "User Information"). User Information includes, without limitation, information submitted to the EXOSTAR EXCHANGE or others via online communications facilitated by the EXOSTAR EXCHANGE. Except as provided in this Privacy Policy, EXOSTAR will not disclose User Information to third parties without the consent of the applicable user.
C. Tracking Information. When a user accesses the EXOSTAR EXCHANGE, the EXOSTAR EXCHANGE captures,records and retains general data about such user's usage of the EXOSTAR EXCHANGE including, without limitation, the user's domain name, the web page(s) from which the user entered the EXOSTAR EXCHANGE, the web page(s) which the user visited on the EXOSTAR EXCHANGE, and the amount of time the user spent on each web page of the EXOSTAR EXCHANGE (collectively, "Tracking Information"). EXOSTAR uses such information to determine the demographics of users and to develop and distribute to third parties statistics and general information about the EXOSTAR EXCHANGE. Except as provided in this Privacy Policy, EXOSTAR will not disclose Tracking Information in a manner that reasonably permits such information to be identified with an individual user or specific user transaction.
D. Cookies. A "Cookie" is a small piece of information sent by a web server to be stored on a web browser so it can later be read back from that web browser. The information collected from Cookies is currently used to improve the functionality of the EXOSTAR EXCHANGE. The information on the EXOSTAR EXCHANGE is organized and presented based on EXOSTAR's analysis of the aggregate usage of the site. Cookies are also useful in allowing more streamlined log-in for users. Cookies may play an integral part in assuring that information provided to users will reflect their preferences and be most relevant to their needs. If a user disables Cookies, he/she may not be able to log into the EXOSTAR EXCHANGE.
E. Other Information. A user may choose to send EXOSTAR a question via e-mail, register for a special service or otherwise communicate with EXOSTAR. EXOSTAR uses such information to communicate withusers and to enhance the EXOSTAR EXCHANGE to better meet the needs of users. Except as provided in this Privacy Policy, EXOSTAR will not disclose such information in a manner that reasonably permits such information to be identified with an individual user or specific user transaction.
F. Sale of Company. In the unlikely event of a sale of EXOSTAR or its assets, EXOSTAR is likely to disclose Registration Information, User Information and Tracking Information to the new owners, subject to a requirement that such information be used only in accordance with this Privacy Policy.
2. DISCLOSURE OF AGGREGATED DATA
EXOSTAR reserves the right to use, develop, analyze and disclose information in aggregated form that does not reasonably identify an individual user or specific user transaction on the EXOSTAR EXCHANGE ("Aggregated Data") using Registration Information, User Information, Tracking Information and other user data collected, retained, stored or accumulated through the EXOSTAR EXCHANGE, for internal and commercial purposes, including without limitation: (i) developing and making available to third parties aggregated information regarding trends, purchasing patterns and retail intelligence and research; (ii) performing its duties and obligations under agreements with third party licensors or other users; (iii) internal record keeping and internal reporting by EXOSTAR; (iv) measuring the performance of third-partylicensors and service providers; and (v) reporting performance and other statistical information concerning the EXOSTAR EXCHANGE. EXOSTAR will not disclose Aggregated Data in a manner that reasonably permits such information to be identified with an individual user or specific user transaction.
3. DISCLOSURE UNDER LAW.
EXOSTAR may disclose Registration Information, User Information or Tracking Information if EXOSTAR is required to make such a disclosure under applicable laws. In addition, EXOSTAR reserves the right to disclose a user's Registration Information, User Information, Tracking Information and other data collected, retained, stored or accumulated through a user's use of the EXOSTAR EXCHANGE to report a violation or suspected violation of applicable laws to governmental authorities to which notification is appropriate or may be required.
4. OPT OUT
Participation in theEXOSTAR EXCHANGE is voluntary. To opt out of processing of personal data pursuant to this Privacy Policy, a user should send an e-mail to EXOSTAR at privacypolicy@exostar.com as follows:
- To opt out of the User Directory, the e-mail subject line should state “Opt Out Directory” and the body of the email shall include the Exostar-issued ID number;
- To opt out of receiving marketing communications from EXOSTAR, the e-mail subject line should state “Opt Out Communications” and the body of the email shall include the Exostar-issued ID number (if applicable); and
- To opt out of both ofthe above, the e-mail subject line should state “Opt Out All” and the body of the email shall include the Exostar-issued ID number (if applicable).
Notwithstanding any such opt-out request, EXOSTAR reserves the right to continue to process user data for purposes related to Aggregated Data as set out in paragraph 2.
5. QUESTIONS, ACCESS AND COMPLAINTS
Users may contact EXOSTAR at privacypolicy@exostar.com with (i) questions about this Privacy Policy, (ii) requests to review, change or update information previously provided and/or (iii) complaints about this Privacy Policy or its implementation.
6. SAFE HARBOR
EXOSTAR complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. EXOSTAR has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. EXOSTAR has committed to cooperate with EU and Swiss data protection authorities in any enforcement action under the respective Safe Harbor Frameworks. To learn more about the Safe Harbor program, and to view EXOSTAR's certification, please visit http://www.export.gov/safeharbor/.
7. UPDATES TO THE PRIVACY POLICY
Updates to the Privacy Policy will be posted on the EXOSTAR EXCHANGE and will be effective upon posting. EXOSTAR will take reasonable steps to inform users of such updates.