1. Our Commitment to Privacy (“GROUPGRAMS”) respects the privacy of our users. As an individual who is a user of our website,, ("Site") or otherwise as a user of the Services provided by GROUPGRAMS, you should know what information we collect from you, as well as how that information is used, disclosed and protected. For the purposes of this Agreement, "Services" means the services provided by GROUPGRAMS, or third parties designated by GROUPGRAMS, through use of the Site. The Site may only be used for lawful purposes to create and distribute group newsletters to the members of a particular group. We encourage you to read this Privacy Policy carefully when using the Site and/or our Services. By using the Site, you are accepting the practices described in this Privacy Policy. If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us. 2. The Information We Collect and How We Collect It We collect various types of information from our users and users of the Site. We may collect personal information that can identify you, such as your name, e-mail address, mailing address and phone number. We also collect other personal information that you provide, such as, personal updates and photos. We also may collect other information that may not identify you individually, such as your postal code, age, gender, occupation, and interests. We also collect behavioral information. Behavioral information is non-personally identifiable information regarding how you use the Site, the areas of the Site that you visit, what services you access, and information about your computer hardware and software including your IP address, geolocation, browser and operating system type, domain names, access times and referring Web site addresses. This information may be used to analyze the allocation of resources for troubleshooting problems, for preventing fraud and/or for improving our services. Some of this information is collected when you register for and opt to use our Services, while other information is collected automatically. From time to time we may supplement the Personal Information you provide through the Site with information from other sources. The information we collect from outside sources will be either publicly accessible information or information that you have given permission to disclose. Thus, information we obtain through the Site may be intermingled with and used in conjunction with information obtained through sources other than the Site, including both offline and online sources. A. Information You Provide. We may collect and store any personal information you enter on the Site or provide to us in some other manner. This personal information includes information provided to us when you request to use any of our Services directly via the Site or through e-mail. On the Site, you may use our newsletter creation platform. To do so you will need to enter information that may include such personal information as your name, e-mail address, personal updates and photos. B. Information About Others. An integral part of GROUPGRAMS is allowing users to invite other people to join groups and to use our group newsletter creation platform. If you choose to invite other people to use our Site, we will ask you to provide the name and email address of a friend, family member or colleague whom you would like to invite to use our service, and GROUPGRAMS will send an e-mail inviting him or her to visit GROUPGRAMS to learn more about our services and to join the specified group he or she was invited to. C. Information Collected Automatically. We automatically collect certain types of information from your browser when you visit the Site. For example, when you visit, our systems automatically collect your IP address and the type of browser you use, as well as the page or address that you may have clicked through to the Site. When you visit the Site, we may also assign your computer one or more cookies to facilitate access to the Site, to personalize your online experience, to record and analyze information about your visit to the Site and to otherwise administer and improve the Site for your use. GROUPGRAMS also contracts with third-party service providers who use cookie technology to track and analyze usage and compile statistical information and to monitor responses to e-mail and advertising campaigns on behalf of GROUPGRAMS. A cookie is a small piece of information that is sent to your browser and stored in your computer's hard drive. The purpose of a cookie is to remember certain user inputs on the Site. Through the use of a cookie, we collect information about your online activity on the Site, such as the web pages you visit, the links or advertisements you click, or other actions you take while on the Site. GROUPGRAMS uses both "session" and "persistent" cookies on this Site. Session cookies are temporary bits of information that are erased once you exit your web browser or turn off your computer. Persistent cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. They store information on your computer for a number of reasons, such as retrieving certain information you have previously provided, helping to determine what areas of the Site you find most valuable, and customizing the Site based on your preferences. Persistent cookies placed on your computer by this Site do not store any personal information. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on the Site. D. Information Collected by Third Parties. We may allow third parties to display advertisements on our site. GROUPGRAMS and these companies may use tracking technologies, such as cookies, to collect information about users who view or interact with these advertisements and connect to the Site. We do not provide any personal information to these third-parties unless you have provided consent. This information allows GROUPGRAMS and these companies to deliver targeted advertisements and gauge their effectiveness. Our business partners (e.g., advertisers) may use cookies on our site. We have no access to or control over these cookies. The GROUPGRAMS privacy policy covers the use of cookies by GROUPGRAMS only and does not cover the use of cookies by any business partners. Some of these third party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of advertisements targeting from member companies. 3. The Way We Use Information We use the information you provide about yourself when subscribing to our Services to provide our group newsletter creation services, to carry out any additional transactions you have requested and/or to provide you with our Services and support. We also share personal information with third parties that offer supplemental products and services that you may be interested in, or with third parties that provide information to those offerors of supplemental products and services. We use the information collected to send communications to you. We may also use the information to provide you with information about other services available from GROUPGRAMS, promotional offers that may be of interest to you and/or to request that you respond to a survey. We use e-mail addresses to (a) answer the e-mail we receive from you; (b) provide helpful reminder notices about the deadlines for creation of your group newsletter; and (c) send you additional information about our Services and the products and services of third parties that may be relevant to you and (d) other communications, as described below. We may also use your home or business address or telephone numbers provided by you to make similar notifications. We also use information we collect to customize, analyze, adjust and improve the Site and Services (including any communications with you) to meet our users' needs and expectations. We use the information to enforce our Terms of Use and/or separate contracts (if applicable) with you. We use the information to prevent fraud and other prohibited or illegal activities. We may use the information for other legally permissible purposes. 4. With whom we Share your Information We want you to understand when and with whom we may share personal or other information we have collected about you or your activities on the Site and/or while using our Services. A. Personal Information. We share your information for the purposes of providing Services to you or as indicated below. We may share all information collected as outlined above as necessary: I. in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us. II. when we believe disclosure is appropriate in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees or others; to preserve the security of our systems; to comply with applicable law or cooperate with law enforcement; to enforce the terms and conditions or other agreements or policies for the Site; or to collect payments you owe to us. III. in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the event of bankruptcy. IV. with third parties or corporate affiliates (such as providers of credit card processing, billing, shipping, marketing, web analytics, web hosting and other services), so that such third parties may assist us in (a) providing Services to you; (b) carrying out any transactions that you may request; or (c) making our business more responsive to your needs. V. with other third parties (unless you opt out) that offer related and/or supplemental products and services that you may be interested in. We may supply your contact and other personal information to third parties for the purpose of sending you e-mail or otherwise communicating with you about their goods and services. We use data we have about you to determine whether you might be interested in the opportunities, products or services of a particular third-party. B. Aggregated and Non-Personal Information. We may share aggregated information (i.e., information about you and other users collectively, but not specifically identifiable to you) and other non-personal information we collect under any of the above circumstances. We may also share it with third parties to develop and deliver targeted advertising on the Site and on websites of third parties. We may combine non-personal information we collect with additional non-personal information collected from other sources. We may also share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the Site and the most popular features or Services accessed. This information does not contain any personal information and may be used to target advertising and to develop content for the Site and Services that we hope you and other users will find of interest. Regardless of your decision regarding the sharing of your personal information, we may share broad aggregate demographic data and related usage information with our business partners. 5. Third-Party Websites There may be places on the Site where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement or a search result on the Site, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you review the privacy statements of all third-party websites you visit. 6. Your Rights, Our Obligations respects the privacy of your personal information. We will provide you with Opt-Out Notices as may be required by applicable laws. You may access these Notices at If you tell us that you do not wish to have information used as a basis for further contact with you, we will respect your wishes. You can also choose not to provide us with certain information, but that may result in your being unable to use certain features of the Site, because such information may be required in order for you to obtain Services from GROUPGRAMS. You may instruct GROUPGRAMS to stop sending you certain promotional materials (e.g., e-mail messages, catalogues, postcards and letters) by following the unsubscribe instructions provided in those materials. If you wish to speak to a representative about your privacy choices, please email us at: 7. Data Security We maintain a variety of physical, electronic and procedural safeguards designed to protect your personal information from unauthorized access and disclosure. For example, we use accepted tools and techniques to protect against unauthorized access to our systems. In addition, we work to protect the security of your personal information when utilizing a Service via the Site by using well-known Internet encryption technologies, such as Secure Sockets Layer (SSL). You should be aware that GROUPGRAMS has no control over the security of other sites on the Internet that you might visit or interact with, or from which you may buy Services, even when there is a link to said site from ours. We want you to feel confident using the Site. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, searches or other communications will always remain secure. In the event of a breach of the confidentiality or security of your personal information, we will notify you as necessary so that you can take appropriate protective steps. We may notify you under such circumstances using the e-mail address(es) we have on record for you, or if you did not provide an e-mail address, by regular mail. Users should also take care with how they handle and disclose their personal information. Please refer to the Federal Trade Commission’s website at for information about how to protect yourself against identity theft. 8. Our Services are not for Use by Children The Site is a general audience site, and we do not knowingly market to, solicit information about, or accept service from children under the age of 13. If a child under 13 submits personal information to us through any part of our Site or Services, and we become aware that the person submitting the information is a child, we will attempt to delete this information as soon as possible. We require that only persons 18 years of age and older use our Site or our Services. If you are a person under the age of 18, please have your parent or guardian assist you in accessing our Site or using our Services. 9. Other Information About Our Privacy Practices A. California Residents. If you are a resident of California, in addition to the rights set forth in this Privacy Policy, you have the right to request information from us regarding the manner in which we share certain categories of personal information with third parties for their direct marketing purposes. As stated above, we retain the right to share such information with such parties unless you have opted out. B. Visiting Our Website from Outside the United States. Our Site is hosted in the United States. Our Site and our Services are therefore governed by United States law. If you are visiting the Site from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using our Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it, as described in this Privacy Policy. C. No Rights of Third Parties. This Privacy Policy does not create rights enforceable by third parties. D. Changes to this Privacy Policy. We will occasionally update this Privacy Policy to reflect changes in our practices and Services. When we post changes to this Privacy Policy, we will revise the Effective Date. If we make any material changes to our Privacy Policy, we will notify you by sending an e-mail to the e-mail address(es) provided to us in your account profile or by posting notice of the changes on the Site. We recommend that you check the Site from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.