Preamble
Our Principles
Personal Information COOLFRED Collects
What COOLFRED does with the Personal Information
Disclosures of Personal Information
Security of Personal Information Collected via the Websites
Data Usage Policy: Non Personal Browsing and Site Usage Information
Reorganization or Spin-Offs
Children
Third-Party Sites
Special Note to International Users
Changes and Updates to this Privacy Policy
Our Principles
This Master Privacy Policy (”Privacy Policy”) explains the collection, use, and disclosure of “personal information” by Coolfred Software Corporation (”COOLFRED” or “Coolfred Software”), a Wyoming Corporation, with its principal place of business at P.O. Box 280, Hope Mills, NC 28348, USA, through the websites that Coolfred Software operates at http://coolfred.com (the “Coolfred Website”), http://coolfred-1.com, and http://coolfredgames.com, (collectively, together with all sub-domains thereof including, without limitation, http://ota.coolfred.com, http://mobile.coolfred.com and http://advisor.coolfred.com, the “Websites”). Any “personal information” that Coolfred Software collects via our Coolfred support site (http://coolfred-1.com/support) is handled in accordance with our Coolfred Privacy Policy. For avoidance of doubt, this Privacy Policy does not apply to any of the websites operated by affiliates or partners of Coolfred Software.
In addition, additional or supplemental Privacy Policy terms (”Supplemental Privacy Policy Terms”) may apply to a particular Website or service provided thereon. All such Supplemental Privacy Policy Terms will be accessible for you to read either within, or through your use of, that Website or service.
This Privacy Policy also explains our commitment to you with respect to our use and disclosure of non personal browsing and site usage data that Coolfred Software collects as the provider of the Websites and. That commitment is contained in a “Data Usage Policy,” below.
As used in this policy, “personal information” means information that would allow a party to identify you such as, for example, your name, address or location, telephone number or email address.
By accessing the Websites or using Coolfred Software applications, you are accepting and agreeing to the practices described in this Privacy Policy.
Our Principles
Coolfred Software is committed to handling responsibly the information and data we collect about you through our Websites, whether personal information or non personal browsing and site usage data. We have designed our Privacy Policy and our Data Usage Policy consistent with the following principles (the “Principles”):
· Privacy policies and data collection and use policies should be human readable, comprehensive, and easy to locate;
· Only the minimum amount of information reasonably necessary to provide you with services should be collected and maintained, and only for so long as reasonably needed or required;
· Information you provide through our Websites, or that we gather as a result of your use of our Websites or services, should not be used for marketing or advertising purposes, nor should it be provided voluntarily (without your permission) to anyone else unless required; and
· Unless restricted or prohibited by law, and provided your email address has been collected and retained, you should be notified when circumstances require Coolfred Software to provide a third party with your personal information.
Personal Information COOLFRED Collects
We may collect personal information at several places on the Websites, including without limitation:
· in connection with your selection of one of our licenses or applications, without limitation, or your request for services or application licensing;
· when you provide us with your personal information such as by sending an email to us or signing up to receive a newsletter or our events listing;
· when you subscribe to one of our email discussion lists or register to establish a user account on any of our Websites (such as the Coolfred Advisor (located at http://advisor.coolfred.com) or the Coolfred Software Support Forum (located at http://forums.coolfred-1.com);
· when you purchase merchandise;
· when you join the Coolfred Software network through our Coolfred Website, and when you thereafter create/edit your profile page, identify your content, share your story, and/or establish a Coolfred Software ID; and
· when you provide personal information in connection with your participation in any of the forums we make available to that community.
What COOLFRED does with Personal Information?
License/Applications Selection. We use the personal information you provide to us as part of your selection of one of our licenses/applications to provide you the License Key, Uniform Resource Locator that correspond to the license/application you selected. Your email address may expunged after this email has been successfully sent or we may use some or all of this information to maintain license usage data.
Emails and Newsletters. We use the personal information you provide to us when you send us emails or sign up to receive our in order to respond to your request — for example, to reply to your email or to send you communications about news related to Coolfred Software.
When you subscribe to our newsletter or one of our email discussion lists, your name and email address is stored by Coolfred Software. Personal information submitted as part of our email discussion lists is used for the purpose of managing the discussion lists. Your name and email address will typically be visible to other list participants when you correspond on the list and to the general public in the discussion archives. All emails sent to the discussions list are publicly archived.
Purchases. When you purchase merchandise via our Application Store (located at http://coolfred.com), your personal information will be handled in one of two ways, depending on which option you choose.
· If you purchase an application license or other merchandise from Coolfred Software, we will use your personal information for the purpose of sending you the items you purchased.
· If you purchase services or ongoing support we will use your personal information for the purpose of maintaining your account and to provide you with accurate accounting and usage statistics
Coolfred Website. When you join our network you provide personal information to create your account and establish a password and profile, and to create an account on our support page or in our fourms. We use that personal information to establish and maintain your accounts, provide you with the features we provide for account holders, and for the purpose of contacting you about upcoming news relevant to Coolfred Software.
By joining the Coolfred Software forums, you are also given a public profile page where you can voluntarily post personal information for public viewing. The information that you submit on your public profile page is posted by you at your discretion (although subject to Coolfred’s Master Terms of Use). The information you publish on your public profile page, including your personal information, may be used by anyone who views that information for any lawful purpose
Participating in Our Community: Registered Users. When you register to obtain a user account on any of the Websites (any such person, a “Registered User”), you may be asked to provide personal information to create your account and establish a password and profile. Providing your email address and/or real name is optional. If you do provide your email address, it will allow us to send you your password if you should forget it. If you voluntarily provide your real name in connection with any content you submit to any Website, your name may be associated with the content you contributed (such as when you make a forum post). We will also use that personal information to establish and maintain your membership and provide you with the features we provide for Registered Users, and for the purpose of contacting you about upcoming news relevant to Coolfred Software.
Any other personal information that we may collect which is not described specifically in this Privacy Policy will only be collected and used in accordance with the Principles.
Disclosures of Personal Information
In general, it is not Coolfred Software’s practice to disclose personal information to third parties. We may share personal information in two instances:
First, Coolfred Software may share personal information with our contractors and service providers in order to maintain, enhance, or add to the functionality of the Websites or services.
Second, we may disclose your personal information to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our Master Terms of Use and Privacy Policy; (c) comply with legal process, such as a search warrant, subpoena, statute, or court order; or (d) protect our rights, reputation, and property, of that of our users, affiliates, or the public.
If Coolfred Software is required to provide a third party with your personal information (whether by subpoena or otherwise), then provided we have collected and retained an email address for you, Coolfred Software will use reasonable means to notify you promptly of that event, unless prohibited by law or COOLFRED is otherwise advised not to notify you on the advice of legal counsel.
Security of Personal Information Collected via the Websites
Coolfred Software has implemented reasonable measures to protect against unauthorized access to and unlawful interception or processing of personal information that Coolfred Software stores and controls. However, no website can fully eliminate security risks. Third parties may circumvent our security measures to unlawfully intercept or access transmissions or private communications. We will post a reasonably prominent notice to the Websites if any such security breach occurs.
Data Usage Policy: Non Personal Browsing and Site Usage Information
Our Data Usage Policy covers how we maintain and use information about you that is collected by our Websites and server logs, including when you log into a website using your Coolfred Software.
Non Personal Browsing Information We Collect. When you use the Websites, our servers (which may be hosted by a third party service provider) may collect information indirectly and automatically (through, for example, the use of your “IP address”) about your activities while visiting the Websites and information about the browser you are using. In addition, whenever you use your Coolfred Software ID to log into a website, our servers (which, again, may be hosted by a third party service provider) keep a log of the websites you visit and when you visit them.
No Linking. We do not intentionally link browsing information or information from our server logs to the personal information you submit to us. We use this information for internal purposes only, such as to help understand how the Websites are being used, to improve our Websites and the features we provide, and for systems administration purposes. COOLFRED may use a third party analytics provider to help us collect and analyze non personal browsing information through operation of our Websites for those same purposes.
No Selling or Sharing. Except in the unique situations identified in this Privacy Policy, Coolfred Software does not sell or otherwise voluntarily provide the non personal browsing information we collect about you or your website usage to third parties.
No Retention. COOLFRED discards non personal browsing information from our server logs once we have used the information for the limited purposes noted above, under “No Linking.”
Notice. If Coolfred Software is required to provide a third party with your non personal browsing information or to log in on behalf of a user (whether by subpoena or otherwise), then COOLFRED will use reasonable means to notify you promptly of that event, unless COOLFRED is prohibited by law from doing so or is otherwise advised not to notify you on the advice of legal counsel.
Any other non personal information that we collect which is not described specifically in this Privacy Policy will only be collected and used in accordance with the Principles.
Reorganization or Spin-Offs
Coolfred Software may transfer some or all of your personal and/or non personal browsing information to a third party as a result of a reorganization, spin-off, sale or similar transaction. Upon such transfer, the acquirer’s privacy policy will apply. In such event, Coolfred Software will use reasonable efforts to notify you and to ensure that at the time of the transaction the acquirer’s privacy policy complies with the Principles.
Children
The Websites are not directed at children under the age of 13. Consistent with the federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personal information from anyone under the age of 13 without requiring parental consent. Our Master Terms of Use specifically prohibit anyone using our Websites from submitting any personally identifiable information about persons under 13 years of age. Any person who provides their personal information to COOLFRED through the Websites represents that they are 13 years of age or older.
Third-Party Sites
The Websites may include links to other websites. You should consult the respective privacy policies of these third-party sites. This Privacy Policy does not apply to, and we cannot control the activities of, such other websites.
Special Note to International Users
The Websites are hosted in the United States. If you are accessing the Websites from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use and disclosure that differ from United States laws, please note that you are transferring your personal data to the United States which does not have the same data protection laws as the EU and other regions. By providing your personal data you consent to:
· the use of your personal data for the uses identified above in accordance with the Privacy Policy; and
· the transfer of your personal data to the United States as indicated above.
Changes and Updates to this Privacy Policy
We may occasionally update this Privacy Policy. When we do, we will also revise the Effective Date below. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal information we collect. Your continued use of the Websites constitutes your agreement to this Privacy Policy and any updates.
Questions?
If you have questions about this Privacy Policy, please contact us by email at corporate@coolfred.com.
Effective Date: November 19, 2008