BillShrink Privacy Policy

Effective January 22, 2008

BillShrink, Inc. (“BillShrink”) offers certain services, tools, links and recommendations to assist you in comparison shopping for products and services related to the purchase of third party products and services. BillShrink bases many of its recommendations on information you provide regarding your product usage habits.

BillShrink recognizes that you trust us to act in a responsible manner with any information, including product usage information, we learn about you when you visit and use the www.billshrink.com website (the “Site”), when you access, download or use any information, software, features or other content appearing on the Site or offered by BillShrink (the “Services”) or when you access and use any information, text, graphics or other materials appearing on the Site (the “Content”). We are committed to respecting your privacy by explaining, in this Privacy Policy, how we collect, use and disclose information we receive when you visit and use the Site and/or when you access, download or use any Content or Services.

This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site or through a message sent to your registered email address. Unless we provide you with separate notice and an opportunity to opt out, information will be treated in accordance with the policy that was in place when the information was collected. You are advised to consult this Privacy Policy regularly for any changes.

As used in this Privacy 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.

Information Collection & Use

Our primary goals in collecting information are to provide and improve our Site, Content and Services, to administer your subscription and to enable users to enjoy and easily navigate and use the Site, Content and Services.

Personally Identifiable Information

• When you use, subscribe to, or open account on the Site, or if you choose to register and create your own profile account on our Site, we will ask you for certain information that can be used to contact or identify you and administer your account (“Personal Information”). Personal Information includes, but is not limited to, your name, any screen or user names, account passwords, phone number, credit card or other billing information, email address, home and business postal addresses and your privacy preferences. If you sign up to receive promotional offers or alerts via text messaging, any mobile number you provide us to receive such offers or alerts will be collected by BillShrink as Personal Information. BillShrink may also request that you provide Personal Information when you order additional services (for example, premium functionality), when you request promotional information, when you complete customer surveys, when you participate in contests, when you call our customer support line and if you contact or interact with us. Finally, when you apply for a job and provide us with Personal Information, we will collect such information.
• BillShrink uses your Personal Information (in some cases, in conjunction with your Product Usage Information and/or in conjunction with your Site Usage Information) mainly to provide the Site, Content and Services, complete your requests, resolve disputes and communicate with you. For example, BillShrink may use your Personal Information in order to enable us to process and validate your account subscription, to bill for any Services, to contact you regarding the Site, Content or Services, to contact you about new or existing products and services or special offers that may be of interest to you, to process and charge any fees due, to verify your identity or customer qualifications as may be required, to detect and protect us against error, fraud or criminal activity, to enforce our terms of use, to respond to any communications you send us or to provide you with any relevant or requested information. If you decide at any time that you no longer wish to receive certain communications from us, please follow the instructions provided in any of the communications or update your “user preferences” information (see “Changing or Deleting Information” below).
  
• When you register through the Site and submit your Personal Information to create a profile account, other BillShrink users may be able to see your “Screen Name”. You can choose what other Personal Information you provide as part of your profile and in some cases you can choose whether to share that information publicly on the Site by making selections via the “user preferences” section of your profile webpage. Providing such information is voluntary and should correlate with the degree of interaction you want to have with other users. We recommend that you guard your anonymity and sensitive information and that you not use your real name as your “Screen Name,” since that would allow others to identify you.

Product Usage Information

• When you access and use the Site, Content and Services, we will request and collect information about your use of the products and/or services about which you are requesting information, recommendations or comparisons (your “Product Usage Information”). Product Usage Information includes such information as your product preferences, usage patterns, anticipated usage, recent purchases, spending patterns, how long you use such products and services, your activities related to such products and the geographic location in which you live and/or use such products. From time to time, you may elect to give us access to personally identifiable information by providing us with your product account information so that we can provide you with a more detailed and personalized product recommendation. By accessing and using the Site, and in accordance with our Terms of Use (which includes acceptance of this Privacy Policy), you have given us your express consent to collect and use your Product Usage Information.
• BillShrink uses Product Usage Information to offer you a personalized recommendation. Product Usage Information permits us to recommend products and services that we believe will be of interest to you, personalize your viewing, Site, Content and Services usage, select targeted advertisements or other promotions for you and offer you local content and advertising information.

Site Usage Information

• Our Site is designed so that visitors may browse it without the collection of any personally identifiable information (except for such visitor’s internet protocol (IP) address). When you visit the Site, we may collect information indirectly and automatically (through the use of cookies, as described below) about your Site activity, including the geographic location of the IP address you are using to access the internet, the type of browser used, platform type, referring/exit pages and date/time information, which specific areas of a website or webpage you use and for how long, websites you bookmark, search terms you use and referring/exit pages (“Site Usage Information”).
• BillShrink uses Site Usage Information for internal purposes such as to administer, improve and customize the Site, to help BillShrink understand and analyze how the Site, Content and Services are being used, to track aggregate Site, Content and Services usage, to provide technical administration, to increase the Site’s functionality and user-friendliness and to better tailor the Site to our visitors’ needs. For example, some information is collected so that when you visit the Site again, it will recognize you and serve advertisements and other information appropriate to your interests.

Aggregate Usage Information

• BillShrink will aggregate Product Usage Information and/or Site Usage Information (“Aggregate Usage Information”). BillShrink uses Aggregate Usage Information to understand what our customers want, for editorial, feedback, marketing and promotion purposes, for statistical analysis, product development and content improvement and to create aggregate reports of how users are using the Site, Content and Services. We may combine your Personal Information, Product Usage Information and/or Site Usage Information and aggregate it with information collected from other users to provide you with a better experience, to improve the quality and value of the Services and to analyze and understand how our Site, Content and Services 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.

Cookies

We use “cookies” on our Site 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 registration ID and login password for future logins to the Site or use of certain Content or Services. Second, we utilize session ID cookies to enable certain features of the Site, Content or Services, to better understand how you interact with the Site, Content and Services and to monitor aggregate usage and web traffic routing on the Site, Content and Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and close your computer browser. Third party advertisers on the Site or linked through the Site, Content or Services may also place or read cookies on your computer’s 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 (or any) functionality of the Content or Services.

Phishing

Identity theft and the practice currently known as “phishing” are of great concern to BillShrink. 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 account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

Information Sharing and Disclosure

We do not share Personal Information, Site Usage Information, Product Usage Information and/or Aggregate Usage Information with third parties except as follows:

• Service Providers. We may employ third party companies and individuals to facilitate our Site, Content and Services, to provide the Site, Content or Services on our behalf, to perform Site-related services (e.g., without limitation, bill or credit card payment processing, transaction fulfillment, maintenance services, database management, web analytics and improvement of the Site’s features) or to assist us in analyzing how our Site, Content and Services are used. These third parties have access to your Personal Information, Site Usage Information, Product Usage Information and/or Aggregate Usage Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
• Aggregate Information and Non-Identifying Information. We may share Aggregate Usage Information that does not include Personal Information and we may otherwise disclose Product Usage Information and/or Site Usage Information with third parties (including suppliers, advertisers, research companies and other organizations) for industry analysis, demographic profiling and other purposes. Any information shared in these contexts will not contain your Personal Information.
• Compliance with Laws and Law Enforcement. BillShrink cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of BillShrink or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
• Business Transfers. BillShrink may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. BillShrink will notify you before transferring your information to a new entity as part of a merger, acquisition, reorganization or sale of some or all of its assets if the new entity's processing of your information will materially differ from that set forth in this Privacy Policy.

Changing or Deleting Your Information

All Site and Services subscribers may review, update, correct or delete the Personal Information in their registration profile by contacting us. If you completely delete all such information, then your account may become deactivated. If you would like us to delete your record in our system, please contact us and we will attempt to accommodate your request if we do not have any legal obligation to retain the record. See below for privacy contact information. From time to time, we may contact you be mail, email, telephone or SMS to tell you about additional products or services that we or third parties may offer. If you do not wish to receive such calls or promotional materials, please contact us and we will attempt to accommodate your request.

Security

BillShrink is very concerned with safeguarding your information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access.

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 this Site 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.

International Transfers

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, BillShrink transfers Personal Information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Links to Other Sites

Our Site contains links to other websites. If you choose to visit an advertiser by “clicking on” a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party’s website. The fact that the Site permits you to link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

Our Policy Towards Children

The Site, Content and Services are not directed to children under 18. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us via the contact details listed below. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at: Privacy Officer, BillShrink, Inc., 535 Middlefield Road, Suite 245, Menlo Park, CA, 94025, or at: