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Effective September 1st, 2011

ATTENTION: This legal notice applies to the entire contents of this website under the domain name http://www.sefaira.com/ or any related sub-domain, including but not limited to apps.sefaira.com (the "Website", Sefaira). The Website is owned and operated by Sefaira Inc., 419 Lafayette Street, 2nd Floor, New York, NY 10003, United States ("Sefaira" also referred to as "we" or "us").

Please read the privacy policy below carefully before using this Website. By using or registering on this Website you accept and agree to the terms of this privacy policy. If you do not accept these terms, do not use this Website.

This policy (together with our terms of use and any other document referred to in this policy or the terms of use) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data.

Sefaira is committed to preserving the privacy of all visitors to its Website (as well as users of the Software). We are committed to ensuring that you can use the Software on the Website in a safe and secure online environment.

Sefaira complies with the U.S. E.U. Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union. Information regarding the E.U. Safe Harbor Framework can be found at: http://export.gov/safeharbor.

Sefaira Inc. has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions.

The TRUSTe program only covers information that is collected through this Web site www.sefaira.com.,If you have questions or concerns regarding this Policy, you should first contact privacy@sefaira.com. If this does not resolve your complaint, you may raise your complaint with TRUSTe by Internet at http://watchdog.truste.com/pvr.php?page=complaint, by mail at WatchDog Complaints, TRUSTe, 55 Second Street, 2nd Floor, San Francisco, CA, USA 94105, by phone at 415-520-3400, or by fax at 415-520-3420. If you are mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, see http://www.truste.com/why_TRUSTe_privacy_services/online-privacy-watchdog.html or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English.

Use of your information

Should you choose to register on this Website, you will be asked to provide contact information and certain personal information, such as name and email address. Your information will enable us to provide you with access to all parts of our site and to supply any services you have requested. It will also enable us to invoice you and to contact you (if necessary) concerning your use of the Website, email mailings, support and notification of new services, to gather your views on our services and to notify you occasionally about important changes or developments to the site or our services. We will also use and analyze the information we collect so that we can administer, support, improve and develop our business.

If you would rather not receive future marketing e-mails from us, please adjust your marketing preferences from the account settings in your user account or use the unsubscribe mechanism in the email you received. You can also request that we remove you from our marketing list by contacting us via e-mail at sales@sefaira.com.

Tell-A-Friend: If you choose to use our referral service to tell a friend or colleague about our site, we will ask you for your friends name and email address. We will automatically send your friend an email inviting him or her to visit the site. If your friend or colleague does not respond to the first invitation, Sefaira may subsequently send them a follow-on email, reminding them of the invitation. Sefaira stores this information for the sole purpose of sending this email and tracking the success of our referral program.

Your friend may contact us at privacy@sefaira.com to request that we remove this information from our database.

Disclosure of your information

The information you provide to us will be held on our computers and may be accessed by or transferred to our staff working in the UK or in the USA.

We may provide your personal information to companies located in the UK, the USA or elsewhere outside the European Economic Area. Such companies provide services to help us with our business activities such as offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.

Countries outside the European Economic Area do not always have strong data protection laws or data protection laws which offer you an equivalent level of protection. However, we will always take steps to ensure that your information is used by third parties in accordance with this policy.

We may also transfer or disclose your personal information to our professional advisers and to such other parties as we consider necessary for the administration of the Website and related business or if required to disclose such information by law.

We will not disclose your information outside Sefaira's corporate group, except in connection with a joint venture or the proposed or actual sale of the whole or part of Sefaira's business. We will not otherwise share, sell or distribute any of the information you provide to us without your consent unless:

required by law, such as to comply with a subpoena, or similar legal process, or

when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Public Forums: Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at privacy@sefaira.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Customer Reviews: We post customer testimonials on our web site which may contain personally identifiable information. We do obtain the customer's consent via email prior to posting the testimonial to post their name along with their testimonial.

Cookies

Cookies are small amounts of information which we store on your computer. Cookies make it easier for you to log on to and use the site during future visits. They also allow us to monitor Website traffic and to personalize the content of the Website for you. You may set up your computer to reject cookies by modifying the settings in your browser although, in that case, you may not be able to use certain features on our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log onto our Website.

Third Party Cookies and other Tracking Technologies

The use of cookies by our service providers is not covered by our privacy statement. We do not have access or control over these cookies. Our service providers use session ID cookies to make it easier for you to navigate our site.

A third party analytics partner may use images and scripts to on our site. We tie the information gathered our customers personally identifiable information only for the purpose of providing you with support and an improved user experience.

Security and data retention

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact privacy@sefaira.com.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies/web site terms of use and we do not accept any responsibility or liability for these policies. Please check such policies before you submit any personal data to them.

Access to information

You are entitled to see the personal data held about you (and, if you have registered with the site, can see certain data in your user account) and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date. We are entitled by law to make a small administrative charge for providing such data.

If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, amend, delete/remove or deactivate it by making the change in your user account or by emailing our Customer Support at support@sefaira.com. We will respond to your request to access within 7 days.

Changes to our privacy policy

We may update this privacy statement 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 account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact

All comments, queries and requests relating to our use of your information are welcomed and should be addressed to privacy@sefaira.com or in writing to Privacy Officer, Sefaira Inc., 419 Lafayette Street, 2nd Floor, New York, NY 10003, United States.