Privacy Policy

1. INTRODUCTION

Last Revised on May 7, 2020


MentorCloud™, an online platform (hereinafter the “Platform”) for mentoring and knowledge sharing, is a proprietary Platform offered by MentorCloud, Inc., (hereinafter “MentorCloud”, “we”, “us”, “our”, the “company”), a Delaware Corporation. The Platform is intended for individual users or members (hereinafter “users”, “you”, “your”, “them”) affiliated with a specific organization. We provide services (hereinafter collectively the “service”) through one or more Websites (hereinafter our “websites”). 


This Privacy Policy describes our privacy practices on the collection, use and sharing (collectively referred to as “processing” of your Personal Information related to your access to and use of our Platform and our Service, including any content, information, products therein.


PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY REGISTERING AS A USER, OR ACCESSING OR USING OUR WEBSITE, YOU AGREE TO ACCEPT ALL THE TERMS CONTAINED IN THIS PRIVACY POLICY AND ACKNOWLEDGE AND AGREE WITH THE PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT REGISTER, ACCESS, OR USE OUR WEBSITE.


WE DO NOT SELL YOUR PERSONAL INFORMATION. WE DO NOT GIVE ACCESS TO YOUR PERSONAL INFORMATION TO THIRD PARTIES EXCEPT TO SUB PROCESSORS TO ASSIST US IN THE PROVISION OF OUR SERVICES TO YOU.

 

IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT PRIVACY@MENTORCLOUD.COM.


2. CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on the Site home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this privacy policy to check for any changes.

As used in this Privacy Policy, “personal data” or “personal information” means information that relates to an identified individual or to an unidentifiable individual. “Personal data'' or “personal information” are referred to as “personal information” throughout this privacy policy except part (XIV) for GDPR compliance. It can include among other things your name, email address, contact details or any such information gathered about you through your interactions with us or our websites. 

3. WEB SITES COVERED

The Service is currently provided through the Websites identified with the following urls (uniform resource locators): http://www.mentorcloud.com and http://X.mentorcloud.com (where “X” is the name of the organization for whom We provide Our platform, pursuant to separately executed forms and agreements).

Our Websites may contain links to other Websites. We are not responsible for the information practices or the content of such other Websites. We encourage You to review the privacy statements of other Websites to understand their information practices.

4.  INFORMATION COLLECTED

We collect information from individuals who visit our Websites (each a “Visitor” and collectively the “Visitors”) and individuals who register to use the Service (each a “Customer” and collectively the “Customers”). The purpose of the Platform is to permit Customers to provide information about themselves for the purposes of sharing knowledge, networking and forming mentoring relationships. You agree to provide us certain personal and professional information (hereinafter the “Required Information”), which we collect in order to allow you to benefit from our Websites. Such required information may include but is not limited to your name, email address, human values, professional area of expertise and office location.


Please note, we do not process sensitive information on our platform. “Sensitive Information” refers to your credit or debit card numbers, personal financial account information, social security number, Social Insurance numbers, passport numbers, driver's license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other financial or health information

5.  USE OF INFORMATION COLLECTED

We use your information to provide and improve the Services.

a. Customer Data:

MentorCloud may access and use Customer Data as reasonably necessary and in accordance with User’s instructions to

(a) provide, maintain and improve the Services and Instance;

(b) to prevent or address service, security, technical issues or at a User’s request in connection with customer support matters;

(c) as required by law; and

(d) as set forth in our agreement with the User or as expressly permitted in writing by the User.


b. Other information
We use other kinds of information in providing the Services.

i. To understand and improve our Services. We carry out research and analyze trends to better understand how users are using the Services and improve them.

ii. To communicate with you by:

(a). Responding to your requests. If you contact us with a problem or question, we will use your information to respond.

(b). Sending emails and MentorCloud messages. We may send you Services and administrative emails and messages. We may also contact you to inform you about changes in our Services, our Service offerings, and important Service-related notices, such as security and fraud notices. These emails and messages are considered part of the Services and you may not opt-out of them. In addition, we sometimes send emails about new product features or other news about MentorCloud. You can opt out of these at any time by sending us an email at privacy@mentorcloud.com or clicking at the unsubscribe button, where applicable. We are offering an opt-out option in our Website itself.

(c). Billing and account management. We use account data to administer accounts and keep track of billing and payments.

(d). Communicating with you and marketing. We often need to contact you for invoicing, account management and similar reasons. We may also use your contact information for our own marketing or advertising purposes. You can opt out of these at any time by sending us an email at privacy@mentorcloud.com or clicking at the unsubscribe button, where applicable.

(e). Investigating and preventing bad stuff from happening. We work hard to keep the Services secure and to prevent abuse and fraud.


c. Disaggregated Data.  This Privacy Policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so it is no longer associated with an identifiable user or Customer of the Services.

6.  WEB SITE NAVIGATIONAL INFORMATION

We use commonly used information-gathering tools, such as cookies and Web beacons, to collect information as You navigate the Company's Web sites (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information that may be collected on the Company's Web sites and how this information may be used.

7.  COOKIES

a. Cookies (or browser cookies):

A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites.

b. Cookies:

Flash Cookies are local storage objects (or flash cookies) that collect and store information about your preferences and navigation to, from and on our Websites.

c. Web Beacons:

Web beacons and similar technologies are small bits of code, which are embedded in web pages, ads, and e-mail, that communicate with third parties. We may use web beacons, for example, to count the number of users who have visited a specific web page, to deliver or communicate with cookies, and to understand usage patterns. We also may include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.

d. Automatic Data Collection: 

We use automatic data collection to (a) understand and save your preferences for future visits; (b) compile aggregate data about Website traffic and Website interactions in order to offer better Website experiences and tools in the future; and (c) we may also use trusted third-party services that track this information on our behalf.

e. Advertising Networks: 

We may choose to work with Google AdWords, Double-click, AdRoll or other advertising networks. Each of these companies has its own privacy policy, which we encourage you to review. For more information about advertising and tracking online, visit the Network Advertising Initiative. This website allows consumers to “opt out” of the behavioral advertising delivered by member companies.

f. Personal Information:

We do not collect Personal Information automatically, but we may tie this information to Personal Information about you that we collect from other sources or you provide to us.

8. YOUR CHOICES

a. Customer Data: You provide us with instructions on what to do with your Customer Data. You have many choices and control over Customer Data. For example, you may provision or de-provision access to the Services, enable or disable third party integrations, manage permissions, retention and export settings, transfer or assign instances, share channels, or consolidate instances or channels with other instances or channels.


b. Other Information: If you have any questions about your information, our use of this information, or your rights when it comes to any of the foregoing, contact us at privacy@mentorcloud.com

c. Browser: In addition, the browser you use may provide you with the ability to control cookies or other types of local data storage. Your mobile device may provide you with choices around how and whether location or other data is collected and shared. MentorCloud does not control these choices, or default settings, which are offered by makers of your browser or mobile device operating system.

9.  SHARING AND DISCLOSURE

There are times when information described in this Privacy Policy may be shared by MentorCloud. This section discusses only how MentorCloud may share such information. Customers determine their own policies for the sharing and disclosure of Customer Data. MentorCloud does not control how Customers or their third parties choose to share or disclose Customer Data.


a. Customer Data
MentorCloud may share Customer Data in accordance with our agreement with the Customer and the Customer’s instructions, including:

i. With third party service providers and agents. We engage with third party companies or individuals to provide information and learning tools on Instance; therefore we share Customer Data with those third-party companies or individuals.

ii. With affiliates. We may engage affiliates in our corporate group to process Customer Data.

iii. With third party integrations. MentorCloud may, acting on our Customer’s behalf, share Customer Data with the provider of an integration added by Customer. MentorCloud is not responsible for how the provider of an integration may collect, use, and share Customer Data, as this is the responsibility of the Customer.


b. Other information
MentorCloud may share other information as follows:

i. About you with the Customer. There may be times when you contact MentorCloud to help resolve an issue specific to an instance of which you are a member. In order to help resolve the issue and given our relationship with our Customer, we may share your concern with our Customer.

ii. With third party service providers, content partners and agents. We may engage third party companies or individuals, such as third-party payment processors, to process information on our behalf. You may request a list of all of our third-party sub processors by email us at privacy@mentorcloud.com or mail to our Mailing Address set forth below in subsection 4 of the International Users section.

iii. With affiliates. We may engage affiliates in our corporate group to process other information.
 

c. Other types of disclosure
MentorCloud may share or disclose Customer Data and other information as follows:

i. During changes to our business structure. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of MentorCloud 's assets, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence).

ii. To comply with laws. To comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal process.

iii. To enforce our rights, prevent fraud and for safety. To protect and defend the rights, property, or safety of us or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud.

iv. We may disclose or use aggregate or de-identified information for any purpose.  We may share aggregated or de-identified information with our partners or others for business or research purposes like telling a prospective MentorCloud Customer the average number of messages sent within a MentorCloud Instance in a day or partnering with research firm or academics to explore interesting questions about learning science and knowledge management.

10.  SECURITY
a. Protection of Data:  MentorCloud takes security seriously. We take various steps to protect information you provide to us from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology.

b. Security Measures:  We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on secure servers of our hosting service provider partner.

c. Compliance with our Procedures:  The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

11.  YOUR CALIFORNIA PRIVACY RIGHTS UNDER CCPA

This Section supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others to our website, who reside in the State of California (“consumers” or “you”). We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”), which became effective on January 1, 2020, and any terms defined in the CCPA have the same meaning when used in this Section.

If you are a California resident, you may request that we:

a. Request information

Disclose to you the following information covering the 12 months preceding your request:

i. the categories and specific pieces of personal information we collected about you and the categories of personal information we sold.

ii. the categories of sources from which we collected such personal information.

iii. the business or commercial purpose for collecting or selling personal information about you; and

iv. the categories of third parties to whom we sold or otherwise disclosed personal information.


b. Delete Personal Information.

Delete personal information we collected from you; or


c. Opt-out of any future sale of personal information about you.

To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email to privacy@mentorcloud.com or write to us at MentorCloud, 68 Willow Road, Menlo Park, CA 94025.

Note that

(i) if we delete your Personal Information as requested, we will no longer be able to provide our services to you and

(ii) we may need to keep such Personal Information for a while during the shutting down and billing process. If you would like to discuss our Personal Information storage and processing process with us, please send an email to privacy@mentorcloud.com or write to us at MentorCloud, 68 Willow Road, Menlo Park, CA 94025.


d. Response.

We will acknowledge receipt of your inquiry within ten (10) days of the receipt. We will respond within forty-five (45) days of receiving such request or query. Within this period, we are required to verify your identity before further action. Additionally, in order for us to respond to your request or query, we will need to collect information from the requesting party to verify their identity.

12.  COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY) INFORMATION

The Children’s Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities that collect and store “Personal Information,” as the term is defined under COPPA, from children under the age of 13. We are committed to ensure compliance with COPPA. Our Websites are not meant for use by children under the age of 13. Our Websites do not target children under the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of persons identified as under 13. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at privacy@mentorcloud.com. If you believe that we have mistakenly or unintentionally collected personal information of a minor through our sites without appropriate consent, please notify us so that we may immediately delete the information from our servers and make any other necessary corrections.

IF YOU ARE UNDER 13, PLEASE DO NOT ACCESS OR USE OUR WEBSITES.

13.  INTERNATIONAL USERS

a. Processing Personal Information in the US. We are headquartered in the United States.  Most of our operations are located in the United States and India. Your Personal Information, which you give to us during registration or use of our Platform, may be accessed by or transferred to us in the United States.  If you are visiting our web site or registering for our Services from outside the United States, be aware that your Personal Information may be transferred to, stored, and processed in the United States. Our servers or our third-party hosting services partners are located in the United States.  By using our site, you consent to any transfer of your Personal Information out of Europe for processing in the US or other countries. If you are resident, employee, or visitor in Europe, the processing, storage, transfer, and use of your Personal Information may be subject to the rules and regulations of the GDPR.

b. Sharing Personal Information with Third Parties. We do not (i) share such Personal Information with third parties, other than Processors or Sub-Processor (collectively “Agents”), who comply with GDPR and are required by us to provide our Services under our Terms of Service or an agreement with Customers under which we provide our Services, or (ii) utilize any Personal Information for reasons other than that for which it was originally provided.  If this practice should change in the future, we will update this Privacy Policy to identify any third parties and provide you with opt-out or opt-in choice where applicable. We are committed to resolving complaints about your privacy and our collection, storage, processing or use of your Personal Information transferred to the United States pursuant to Privacy Shield quickly and expeditiously. You should submit inquiries or complaints to us at privacy@mentorcloud.com or at our mailing address:

MentorCloud

68 Willow Road,

Menlo Park, CA 94025

14.  GDPR: FOR OUR EUROPEAN VISITORS, CONSUMERS, AND CUSTOMERS

If you are a resident of or a visitor to Europe, you have certain rights with respect to the processing of your Personal Data, as defined in the GDPR. 

Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Information, for example, if we need to verify your identity or the nature of your request.

In such situations, however, we will still respond to let you know of our decision. As used herein, “Personal Data” means any information that identifies you as an individual, such as name, address, email address, IP address, phone number, business address, business title, business email address, company, etc.

To make any of the following requests, contact us using the contact details referred to in the “Contact Information” section of this Policy.

Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.

Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.

Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.

Erasure: You can request that we erase some or all of your Personal Data from our systems.

Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.

Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, it may limit your ability to use some/ all of our Services or Platform and you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services and Platform.

Response. We will respond to your inquiry within thirty (30) days of the receipt. Please see Section 14 for details regarding “Contacting Us.”

Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. Please go to https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm to locate your Data Protection Authority.

For your information, MentorCloud is not obliged to appoint a representative in the EU per the current scenario. The processing of data for EU data subjects is occasional (not regular) at present. Please note, any update on the appointment of such representative will reflect here, in the Privacy Policy. If you have any queries kindly email us at privacy@mentorcloud.com.

15.  EU-US AND SWISS-US PRIVACY SHIELD CERTIFICATION

MentorCloud, Inc. complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. MentorCloud, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, MentorCloud commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact MentorCloud at privacy@mentorcloud.com or at our mailing address,

Name: Ravishankar Gundlapalli

Address: MentorCloud Inc,

68 Willow Road, Menlo Park, CA 94025

Email Address: ravi@mentorcloud.com

MentorCloud has further committed to refer unresolved Privacy Shield complaints to the Better Business Bureau, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information or to file a complaint.  The services of Better Business Bureau are provided at no cost to you. MentorCloud commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of providing our SERVICES to you.

You have the right to access the personal data that we store on you. We are subject to the investigation and enforcement powers of the Federal Trade Commission (FTC). You may require us to arbitrate your complaints under certain circumstances. We will be liable to you for any unauthorized transfers of your personal data to third parties.

You may also be able to invoke binding arbitration for unresolved complaints but prior to initiating such arbitration, a resident of a European country participating in the Privacy Shield must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from BBB PRIVACY SHIELD; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.

16.  CHANGES TO OUR PRIVACY POLICY
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on the Site home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Privacy Policy to check for any changes.

17.  COPYRIGHT INFRINGEMENT/DMCA NOTICE

If you believe that any content on our Website violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent.

  1. Your physical or electronic signature;
  2. Identification of the copyrighted work(s) that you claim to have been infringed;
  3. Identification of the material on our Website that you claim is infringing and that you request us to remove;
  4. Sufficient information to permit us to locate such material;
  5. Your address, telephone number, and e-mail address;
  6. A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and
  7. A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.

MentorCloud’s Copyright Agent to receive DMCA Takedown Notices is Ravishankar Gundlapalli, at ravi@mentorcloud.com, MentorCloud, Attn: DMCA Notice, 68 Willow Road,  Menlo Park, CA 94025, United States of America. You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorneys’ fees incurred by MentorCloud in connection with the written notification and allegation of copyright infringement.

18.  FOR OUR NEW YORK CUSTOMERS

We will fully comply with the letter and the spirit of the New York Shield Act (the “Act’), which became effective on January 1, 2020, to the fullest extent that it is applicable to us. We have adopted reasonable safeguards to protect the security, confidentiality, and integrity of your private information, as defined in the Act ("Private Information"). We will securely protect any personal information, as defined in the Act ("Personal Information"), and/or Private Information in accordance with the requirements set forth in the Act. We will notify you of any unauthorized access to or disclosure of your Personal Information or your Private Information in accordance with the requirements of the Act.


 We will act as a fiduciary to our consumers and dedicate the highest duty of care, loyalty and confidentiality as is expected out of a 'data fiduciary' defined under Section 1102. The consumer will have the liberty to select a method to opt-in or opt-out from sharing of their personal information to indicate their consent or denial.

19.  CAN-SPAM ACT OF 2003

The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:

  1. not use false or misleading subjects or email addresses;
  2. identify the email message as an advertisement in some reasonable way;
  3. include the physical address of MentorCloud, Inc., which is 68 Willow Road, Menlo Park, CA 94025;
  4. monitor third-party email marketing services for compliance, if one is used;
  5. honor opt-out/unsubscribe requests quickly; and
  6. give an “opt-out” or “unsubscribe” option.

If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at customercare@mentorcloud.com and we will promptly remove you from all future marketing correspondences.

20.  DISPUTE RESOLUTION OR FILING A COMPLAINT

If you have any complaints regarding our compliance with this Privacy Policy, please contact us first. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Privacy Policy and in accordance with applicable law.

21.  CONTACT INFORMATION

If Users, Customers and/or Consumers have any questions, concerns, or complaints about our Privacy Policy, our progress on Privacy Shield Certification, or how we process your Personal Information, please email us at privacy@mentorcloud.com or send a letter to the following person:

Name: Ravishankar Gundlapalli

Address: MentorCloud Inc,

68 Willow Road, Menlo Park, CA 94025

Email Address: ravi@mentorcloud.com



PLEASE NOTE: IF YOU USE OUR WEBSITE OR REGISTER AS A USER, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF SERVICE.  IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, PLEASE DO NOT REGISTER, ACCESS, OR USE OUR WEBSITE.