CIPATH

Welcome to cipath.com, (collectively, CIPATH). CIPATH takes your privacy very seriously. We provide 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.cipath.com (the“Site”). Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use.

Scope

This Privacy Policy, as amended from time to time, applies only to information that you provide to us through the Site and Service. Please note that the Site and Service may contain links to other websites. If you click on a link to another website, this Privacy Policy will not apply to any information collected on that website. CIPATH is not responsible for the privacy practices, security, or content of these other websites, and we recommend that you read the privacy policies of each website that you visit.

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.

The Collection of Information

Our principal goals in collecting information are to provide and improve our Site, services, features and content, to administer your use of the Site (collectively, the“Service”) and to enable users to enjoy and easily navigate the Site. The types of information that we collect include:

Information you provide to us

Personal Information: You may browse the Site without providing any personal information that may be used to identify you personally. However, when you register for and use the Service, access certain content or features, or directly contact the Site or Service, we may ask you to provide information, including:

• your name, email address, telephone number, job title, and affliation;
• your username, password, and account setting preferences;
• your credit card number, billing address and other billing related information.

(collectively,“Personal Information”) Information automatically collected When you visit and interact on the Site or Service, certain information is collected automatically, including:

Non-Identifying Information: We collect other non-identifying information you provide as part of the registration, administration and personalization of your CIPATH Account profile (e.g. account preferences) (“Non-Identifying Information”). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other CIPATH Users (defined below) to attempt to provide you with a better experience, to improve the quality and value of the Site and Service and to analyze and understand how our Site and Service 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.

Log Data: When you visit the Site and Service, whether as a Member or a non-registered user (any of these, a“CIPATH User”), our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type or the webpage you were visiting before you came to our Site and Service, pages of our Site and Service that you visit, the time spent on those pages, information you search for on our Site and Service, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and the Service and for the Site and Service’s technical administration, to increase our Site and Service’s functionality and user-friendliness, and to better tailor our Site and Service to our visitors’ needs. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying 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 use cookies for two purposes. First, we utilize persistent cookies to save your login information for future logins to the Site and Service. Second, we utilize session cookies to enable certain features of the Site and Service, to better understand how you interact with the Site and Service and to monitor aggregate usage by CIPATH Users and web traffic routing on the Site and Service. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site or 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.

Web Beacons: Our Site and Service may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Site and Service are used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our Member communications and marketing campaigns.

Use of Your Information

We do not use Personal Information for purposes other than those disclosed to you in this Privacy Policy and/or at the time it was collected, except with your consent or as required by law. We collect information for one or more of the following purposes:

Email Communications: We may use the information that we collect to send you email communications or information about your account or changes to the Site or Service (including changes to the Terms of Service and this Privacy Policy).

Profile Information: We use the information we collect at registration to create your CIPATH Account and CIPATH profile page. Your CIPATH profile page will include, among other things, your first and last name, your profile picture and your location. We will display your Profile Information in your CIPATH Account or CIPATH profile page publicly via the Site and Service, and, with your prior permission, on third party sites. Any information you choose to provide as part of your Profile Information will be publicly visible to all CIPATH Users and consequently should reflect how much you want other CIPATH Users to know about you. We recommend that you guard your anonymity and sensitive information and we encourage Members to exercise caution regarding the information disclosed in their CIPATH Account profile page. You can review and edit your Profile Information at any time.

Submissions: If you send certain specific submissions, we may publish, use, share or otherwise disclose the content of that submission publicly via the Site and Service and may enable third parties to publish the content on their websites.

Marketing: We may also use your Personal Information to contact you with CIPATH newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of these marketing related notifications at any time by accessing the “Unsubscribe” section of any newsletters. Please note that we may also use your Personal Information to contact you with information related to your use of the Service; you may not opt out of these notifications.

Customer Service Fulfillment: We may use the information that we collect to fulfill your requests for products, services and information. For example, we may use your information to respond to your customer service requests.

Data Analysis: In order to learn more about how our Site and Service is used, we aggregate and analyze the data we collect. We may use the information, for example, to monitor and analyze use of the Site and Service, to improve the functionality of same and to better tailor our content and design to suit our visitors’ needs.

Testimonials: CIPATH posts testimonials on the Site and Service. With your consent, we may post your testimonial on the Site and Service along with your name. To have your testimonial removed, please contact us at www.cipath.com/contactus.html.

Information Sharing and Disclosure

We do not share or disclose Personal Information for purposes other than those disclosed to you in this Privacy Policy and/or at the time it was collected, except with your consent or as required by law. We will make information about you available to other companies, applications, or people in the circumstances listed below:

Analysis: We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling, payment processing, customer service and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

Service Delivery: We may employ third party companies and individuals to perform Site-related services, including maintenance services, database management, web analytics, data processing and email and notification distribution. These third parties have access to your information only to perform these tasks on our behalf.

Corporate Transaction: We may share information about you in the event that the Site is acquired by or merged with another company or a similar corporate transaction takes place. However, we will notify you by placing a prominent notice on the Site or sending a notice to the primary email address specified in your account before your information is transferred and becomes subject to a different privacy policy.

Investigations: We may share information about you to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety or other rights and interests of any person, violations of CIPATH Terms of Service, or as otherwise required by law.

Compliance with Laws: We may share information about you to respond to subpoenas, search warrants, judicial proceedings, court orders, legal process, or other law enforcement measures, to establish or exercise our legal rights, or to defend against legal claims.

Updating and Deleting your Personal Information

All Members may review, update, correct or delete the Personal Information in their registration profile by contacting us at www.cipath.com/contactus.html or editing their profile. If you would like us to deactivate your CIPATH Account, please contact us at www.cipath.com/contactus.html with “Cancel Account” as the subject of your message and we will attempt to accommodate your request if we do not have any legal obligation or a legitimate business reason to retain the information contained in your CIPATH Account. Please note that, if you cancel your CIPATH Account, any of your Member Content on the Site will remain publicly viewable via the Site and Service. Please see below for privacy contact information

Security and Data Retention

To protect your privacy and information, CIPATH uses multiple security procedures and practices to protect from unauthorized access, destruction, use, modification and disclosure of Personal Information of users.

When you enter Personal Information on our Site and Service, we encrypt that information using secure socket layer technology (SSL). SSL creates a secured connection between our web servers and your browser, which protects against unauthorized access to transmitted data and supports data being sent only to intended recipients.

Your Personal Information is password protected and our main servers are locked and hosted by a leading provider of Internet access to enterprises with mission-critical Internet application requirements. Access to the host environment is secure.

Identity theft and the practice currently known as “phishing” are of great concern to CIPATH. 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 CIPATH Account ID, login password, or national identification numbers in a non-secure or unsolicited email or telephone communication.

We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site and Service, you can contact us at www.cipth.com/contactus.html.

Note that 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 and Service 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.

Sharing personal email addresses, phone numbers, Skype/IM usernames or any other personal contact details.

All communications, information and files exchanged should be performed exclusively using CIPATH system. The main reason this it is required is to keep communications and transactions on CIPATH is for your safety. The internet industry has traditionally been inundated with risk and uncertainty. CIPATH is a new form of communications. For this community to thrive, security and trust must be maintained for all users. This is only possible through maintaining initial conversations within the CIPATH application. Protecting our users’ privacy is of critical concern for everyone on the CIPATH team. To protect our users’ privacy, personal information should be kept anonymous. Requesting or providing email addresses, skype/IM usernames or other personal contact details (other than your name) are strictly prohibited.

International Transfer

CIPATH and its third party partners to whom we disclose information under this policy may perform activities outside of the United States and potentially collect, transfer, store, and process your personal information in other countries. As a result, your information may be subject to the laws of those countries or other jurisdictions. These laws may not be equivalent to the privacy and data protection laws in your jurisdiction. Information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these countries. By using the Site or providing us with your information, you consent to the potential collection, transfer, storage, and processing of information in other countries.

Access

We will make available to you any of your personal information that we have collected, used or disclosed upon request. Please contact us at www.cipath.com/contactus.html.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.

We do not specifically market to children under the age of 13 years old.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to send information, respond to inquiries, and/or other requests or questions. To be in accordance with CANSPAM, we agree to the following:

If at any time you would like to unsubscribe from receiving future emails, you can contact us at www.cipath.com/contactus.html with "Unsubscribe" as the subject of your message, and we will promptly remove you from ALL correspondence.

Updates to This Policy

By using the Site and Service you are accepting the terms of this Privacy Policy, as it may be amended from time to time. Please check the date of this Policy each time you visit to ensure that you are aware of the most current version. If you do not agree to the terms of this Policy, please do not use this Site and Service.

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your CIPATH Account) or by means of a notice on the Site and Service prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Addressing Your Concerns

We are accountable for our compliance with this Privacy Policy and the Personal Information under our control. We have implemented policies and practices to give effect to this policy, including training and communicating with our employees the importance of privacy. We regularly monitor our procedures and security measures to ensure that they remain effective and that they are being properly administered. If you have questions or suggestions or wish to contact us, please send a message using our contact form at www.cipath.com/contactus.html.