Privacy Policy

Effective as of July, 15th 2012

Sumpto LLC (“Sumpto,” “we,” “us,” or “our”) has created this privacy policy (this “Privacy Policy”) to describe how Sumpto collects information from you, how that information is used, and how we share that information with third parties.

By visiting our website located at www.sumpto.com (the “Website”), you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Service.

The Information We Collect

We collect information from you when you sign up to use the Sumpto Service through our Website, and when you use the Sumpto Service. This information includes personal information about you, such as your name, age and e-mail address (“Personal Information”). We do not collect any Personal Information from you unless you voluntarily provide the Personal Information to us, such as when you use the Sumpto Service.

In addition to the Personal Information noted above that you voluntarily provide, we may collect additional information (collectively, the “Other Information”). Such Other Information may include:

 a. Activity. If you use the internet, most websites collect certain basic information about you and your surfing habits. We collect this information as well. This information includes information about your operating system, your IP addresses, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a website you visit, and similar information concerning your use of the Sumpto Service (the “Usage Information”). We collect this information by using cookies and pixel tags, web server logs, and by passing data through our API. A cookie is a small file containing a string of characters that is sent to your computer and stored on your hard drive when you visit a website. We also use pixel tags (also called web beacons or clear gifs) that allow us to collect information such as the IP address of the computer that downloaded the page on which the pixel tag appears, the URL of the page on which the pixel tag appears, the time (and length of time) the page containing the tag is viewed, and the identification number of any cookie previously placed by that server on your computer. This enables us to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site.

 b. Information from Social Network Platforms and Third Party Sites. We may collect other information from third-party social network platforms on which you have used the Sumpto Service. We may also collect information from third-party websites that those websites have made publicly available.

Communication Preferences

You can opt-out of receiving e-mails from Sumpto at any time by clicking an opt-out link in any message received from Sumpto or by sending notice to the following email: staff@sumpto.com. If you opt-out of receiving e-mails from Sumpto, we will remove you as quickly as possible from our e-mail systems to stop further communication. You should be aware, however, that it is not always possible to completely remove or modify information in our databases, and that if you sign up to use the Sumpto Service through our Website, we may still need to contact you to provide you with important information or notices.

How We Use and Share the Information

We use your Personal Information (in some cases, in conjunction with your Other Information) mainly to provide the Sumpto Service. We will use the information to (a) communicate with you and respond to your inquiries, (b) enable you to create a Sumpto account, store log-in credentials, and customize your Sumpto Service, (c) contact you about the Sumpto Service, and (d) inform you about our products and services and those of our third-party marketing partners that may be of interest to you.

We reserve the right to use your name and limited information about your activity (such as the number of rewards you have received), in materials to promote the Sumpto Service and/or the Website, and you hereby grant us a license to use your name and other information for this purpose.

In an ongoing effort to better understand our users and the Sumpto Service, we also analyze the Personal Information and the Other Information in aggregate form. We may disclose Other Information and/or aggregate data that does not identify you personally with current and prospective business partners and to other third parties for other lawful purposes.

Sumpto does not sell, trade, or rent your Personal Information to others. Unless expressly permitted by this Privacy Policy, we will not disclose your Personal Information to others without your express permission.

We may employ other companies and individuals to perform functions on our behalf. Examples may include providing marketing assistance, information technology support, and customer service. These other companies will have access to the Personal Information and the Other Information only as necessary to perform their functions and to the extent permitted by law.

If we or all or substantially all of our assets are acquired, we expect that the Personal Information and the Other Information would be transferred along with the other business assets.

To the extent permitted by law, we may also disclose Personal Information and the Other Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing the such Information is necessary or advisable, for example, to protect the rights, property, or safety of Sumpto or others.

Data Collected

We collect the following data from public sources, 3rd parties and directly:

• Personal information provided by you while using Sumpto services which includes include name, email address, photo and postal address
• Publicly accessible information from 3rd parties such as Twitter and Facebook
• Private information from 3rd parties such as Twitter and Facebook with your permission
• Analytic and login cookies as well as server log files
• Data for 3rd party metric services

Usage of Data

We use the information collected to provide and enhance the services offered by Sumpto. We will use this information for the:

1. Calculation of metrics for individual users for example Sumpto Score
2. Production of reports for partners and clients that do not include personally identifiable information
3. Fulfillment of Sumpto services such as Sumpto Rewards
4. Enhancement and improvement of the Sumpto web apps and services in order to provide a better user experience
5. Monitoring and reporting for internal business purposes
6. Let users know about offers, promotions, new products and updates to Sumpto services based on their preferences
7. We will NOT share personally identifiable information with 3rd parties that is not already publicly available except: where you have given us permission to (e.g. by participating in a Sumpto Reward or Engagement Prize), the 3rd party already has that information, or as required by law.

How We Protect Your Information

We take commercially reasonable steps to protect the Personal Information and the Other Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We use physical and procedural safeguards to protect the security of such information. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet.

Important Notice to Non-U.S. Residents

The Website and the Sumpto Service are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Service and/or providing us with any information, you consent to this transfer.

Children

You may only use the Website and the Sumpto Service if you are at least 18 years old. If you are not at least eighteen 18 years old, you are not permitted to use the Website or the Sumpto Service, and must cease all use of the Website and the Sumpto Service immediately.

We do not knowingly collect Personal Information from children under the age of 13 through the Service. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Personal Information through the Service without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases. If you are under the age of 13, you must cease all use of the Website and the Sumpto Service immediately.

California Residents

Under California Civil Code Section 1798.83, California residents who have an established business relationship with Sumpto may choose to opt out of our sharing your Personal Information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your Personal Information to third parties for the direct marketing purposes, please send an e-mail to staff@sumpto.com

External Websites

The Website and the Sumpto Service may contain links to third-party websites. Sumpto has no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on the Website as soon as they go into effect. By accessing the Website or using the Sumpto Service after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at staff@sumpto.com