Effective: January 1, 2008
iForem, Inc. (“iForem”) 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 www.iforem.com (this “Site”).
This Privacy Policy may be updated from time to time. We will notify you of
any material changes by posting the new Privacy Policy on the Site.
You are advised to consult this policy regularly for any changes.
As used in this policy, the terms “using” and “processing” information include using
cookies on a computer, subjecting the information to statistical or other analysis
and using or handling information in any way, including, but not limited to collecting,
storing, evaluating, modifying, deleting, using, combining, disclosing and transferring
information within our organization or among our affiliates within the United States
or internationally.
Information Collection and Use
Our primary goals in collecting information are to provide and improve our Site,
services, features and content, to administer your subscription to the services
(together, the “Service”) and to enable users to enjoy
and easily navigate the Site.
Data Submitted to Perpetual Storage. We will never
intentionally access, use or share the content you place in perpetual storage (your
“Subscriber Content”). Notwithstanding the foregoing,
(i) your Subscriber Content is received and stored by entities that provide us with
data centers and other storage services, who are subject to confidentiality restrictions
and (ii) we may disclose your Subscriber Content 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 iForem 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.
Personally Identifiable Information. When you register with us through
the Site, we will ask you for personally identifiable information, including your
name, phone number(s), email address and home and business postal addresses (“Personal
Information”). We use your Personal Information mainly to provide
the Service, administer your inquiries, combat fraud and to verify the status of
beneficiaries of the Inuity Trust.
Log Data. When you visit the Site our servers automatically records
certain information that your browser sends when you visit a website (“Log
Data”). This Log Data may include information such as pages of
our Site that you visit, the time spent on those pages, information you search for
on our Site, access times and dates and other statistics. We use Google Analytics
to collect, monitor and analyze this information in order to increase our Site’s
functionality and user-friendliness, and to better tailor it to our visitors’ needs.
Accordingly, Log Data is shared with Google, which has its own
privacy policy addressing how it uses such information.
Cookies
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 only use session cookies to confirm your identity during each session in order
to enhance the security at the Site. Unlike persistent cookies, session cookies
are deleted from your computer when you log off from the Site and Service and then
close your browser. 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 Service.
Phishing
Id theft and the practice currently known as “phishing” are of great concern to
iForem. Safeguarding information to help protect you from id 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 e-mail or telephone communication. For more information about phishing,
visit the Federal Trade Commission’s website.
Information Sharing and Disclosure
Personal Information. We may share account holders’ Personal Information
with the iNuity Trust, and the iNuity Trust may use and share your Personal Information
only to administrate and manage your account with iForem.
Service Providers. We may employ third party companies and individuals
to facilitate our Service, to provide the Service on our behalf, to perform Site-related
services (e.g., without limitation, maintenance services, database management,
web analytics and improvement of the Site’s features) or to assist us in analyzing
how our Site and Service 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.
Aggregate Information and Non-Identifying Information. We may share
aggregated information that does not include Personal Information and Log Data with
third parties to assist with analyzing this information in efforts to improve the
Site and services you receive through the Site. Any aggregated information shared
in these contexts will not contain your Personal Information.
Compliance with Laws and Law Enforcement. We cooperate 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 iForem 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. iForem 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.
Under certain circumstances, the iNuity Trust may step-in to fulfill iForem’s obligations
to its account holders, in which case iForem will transfer or otherwise share some
or all of its assets, including your Personal Information, with the iNuity Trust,
which will then process such information. To ensure continued perpetual service
thereafter, the iNuity Trust may then transfer or otherwise share some or all of
its assets, including your Personal Information, with entities performing services
that iForem had provided.
In all of the foregoing cases, you will have the opportunity to opt out of any such
transfer if the new planned processing of your information differs materially
from that set forth in this Privacy Policy.
Changing or Deleting Your Information
All registered users and may review, update or correct the Personal Information
in their registration profile by selecting Preferences and then User Personal Information.
If you completely delete all such information, then your account may become inactive.
If you would like us to delete your record in our system, please contact us and
we will attempt to accommodate your request if we do not have any legal obligation
to retain the record. See below for privacy contact information.
Security
iForem is very concerned with safeguarding your information. We employ administrative,
physical and electronic measures designed to protect your information from unauthorized
access. 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 this 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.
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, iForem 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 Site may contain links to other websites. If you choose to click on another
third party link, you will be directed to that third party’s website. The fact that
we link to a website 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. These other
websites may place their own cookies or other files on your computer, collect data
or solicit personal information from you. Other sites 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 you visit.
Our Policy Toward Children
This Site is not directed to children under 18. We do not knowingly collect personally
identifiable information from children under 13. 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 privacy@iforem.com.
If we become aware that a child under 13 has provided us with Personal Information,
we will delete such information from our files.
Contacting Us
If you have any questions about this Privacy Policy, please contact us at
privacy@iforem.com.