WINKAGE PRIVACY POLICY

Winkage, Inc. ("Winkage" or "we") operates Winkage.com. This Privacy Policy describes Winkage's use and sharing of personally identifiable information ("PII"-- your full name, email address, mailing address, telephone number, or credit card number) that Members voluntarily provide to Winkage when they register (also known as "Registration PII"). The Term "User" refers to a Visitor or a Member. This Privacy Policy applies to the services offered by Winkage, including any Winkage-branded URL (the "Winkage Website"), the Winkage instant messaging service, the Winkage iPhone and Android applications and other features, Winkage mobile services, and any other features, content, or applications offered from time to time by Winkage in connection with the Winkage Website (collectively, the "Winkage Services").  Capitalized terms not otherwise defined herein shall have the respective meanings assigned thereto under the Winkage Terms of Use Agreement (the “Agreement”).  In the event of a conflict between the terms of the Agreement and this Privacy Policy, the terms of the Agreement shall control.

The Winkage Website is a general audience site and does not knowingly collect PII from children under 14 years of age.

From time to time Winkage may modify this Privacy Policy to reflect industry initiatives or changes in the law, our PII collection and use practices, the features of the Winkage Services, or technology, and such modifications shall be effective upon posting by Winkage on the Winkage Website. Your continued use of the Winkage Services after Winkage posts a revised Privacy Policy signifies your acceptance of the revised Privacy Policy. It is therefore important that you review this Privacy Policy regularly to ensure you are updated as to any changes. If Winkage materially changes its practices regarding collection or use of your PII, your PII will continue to be governed by the Privacy Policy under which it was collected unless you have been provided notice of, and have not objected to, the change.

COLLECTION AND SUBMISSION OF PII AND NON-PII ON WINKAGE

General. When Winkage collects PII from you it is because you are voluntarily submitting Registration PII to us in order to register as a Member of Winkage. Winkage may also collect PII from you from other parties or websites if you choose to participate in Winkage Services activities like sweepstakes, contests, and surveys, because you want us to furnish you with products, services, newsletters, or information, or in connection with content or suggestions you submit to Winkage for review and profile creation or registration.

In addition, Winkage collects other non-PII including IP address, aggregate user data, and browser type. This data is used to manage and improve the Winkage Services, track usage, and for security purposes.

Winkage Members may also choose to provide or store non-PII information in their profiles, including but not limited to date of birth, interests, hobbies, lifestyle choices, groups with whom they are affiliated (schools, companies), videos and/or pictures, private messages, bulletins or personal statements (collectively "Profile Information"). The Profile Information in a Member's profile is provided at his or her sole discretion.

Winkage Members can change their Registration PII and Profile Information at any time and can control how Visitors, other Members and Winkage communicate with them by controlling their account settings, available within "All-U" (the personal profile and settings portion of Winkage.

Cookies. Cookies are small bits of information that Winkage places on your computer. Winkage uses cookies to identify your Internet browser, store Users' preferences, and determine whether you have installed the enabling software needed to access certain material on the Winkage Services. Data in cookies may be read to authenticate user sessions or provide services.

Third party advertisements displayed on Winkage Services may also contain cookies set by Internet advertising companies or advertisers (known as "third party cookies"). Winkage does not control these third party cookies and Users of the Winkage Services should check the privacy policy of the Internet advertising company or advertiser to see whether and how it uses cookies. See the "Notice" section below for more information on customized advertising on Winkage. A pixel tag is a tiny image inserted in a webpage and used to record the number and types of views for that page. Winkage may allow third party pixel tags to be present on Winkage Services for purposes of advertising, providing services or data and statistics collection.

You can program your computer to warn you each time a cookie is being sent block third party cookies or block all cookies. However, by blocking all cookies you may not have access to certain features on the Winkage Services.

NOTICE:  WINKAGE WILL PROVIDE YOU WITH NOTICE ABOUT ITS PII COLLECTION PRACTICES

When you voluntarily provide PII to Winkage, we will make sure you are informed about who is collecting the information, how and why the information is being collected and the types of uses Winkage will make of the information to the extent it is being used in a manner that differs from what is allowed pursuant to this Privacy Policy.

Winkage Services may be linked to Internet sites operated by other companies. Winkage Services may also carry advertisements from other companies. Winkage is not responsible for the privacy practices of websites or other services operated by third parties that are linked to or integrated with the Winkage Services or for the privacy practices of third party Internet advertising companies. Once you leave Winkage Services via such a link, access a third party application (such as widgets) or click on an advertisement, you should check the applicable privacy policy of the third party or advertiser site to determine, among other things, how they will handle any PII they collect from you.

Winkage Services may also be linked to sites operated by companies affiliated with Winkage ("Affiliated Companies"). Although all Affiliated Companies will be provided a copy of this Privacy Policy, Users who visit those Affiliated Company sites should still refer to their separate privacy policies and practices, which may differ in some respects from this Privacy Policy.

Winkage may use cookies and similar tools to customize the content and advertising you receive based on the Profile Information you have provided. Profile Information you provide in structured profile fields or questions (multiple choice questions like "Status," "Education" and "Favorite Teams") ("Structured Profile Information"), information you add to open-ended profile fields and questions (essay questions like "About Me," "Interests" and "Future Plans") ("Non-Structured Profile Information") and other non-PII about you may also be used to customize the online ads you encounter to those we believe are aligned with your interests. For example, based on your interests we might display an advertisement to make sure you are advised when an art exhibit is coming to town.

Some of the advertisements that appear on Winkage Services may also be delivered to you by third party Internet advertising companies. These companies utilize certain technologies to deliver advertisements and marketing messages and to collect non-PII about your visit to or use of Winkage Services, including information about the ads they display, via a cookie placed on your computer that reads your IP address.

Third party applications (such as widgets) created by third party developers may also be available on the Winkage Services. Third party applications are small bits of software, often with interactivity, that can be installed into Members' profiles or shared with other Users. However, Winkage does not control the third party developers, and cannot dictate their actions. When a Member engages with a third party application, that Member is interacting with the third party developer, not with Winkage. Winkage encourages Members not to provide PII to the third party's application unless the Member knows the party with whom it is interacting.

WINKAGE’S USE OF PII

Winkage will only use the PII you provide under this Privacy Policy in a manner that is consistent with this Privacy Policy. If Winkage obtains PII from a third party, such as a business partner, our use of that information is also governed by this Privacy Policy.

In order to locate other Winkage Members that you may already know in the physical world, Winkage allows Users to search for Members using Registration PII (i.e., full name or email address). Winkage also allows Users to browse for certain Profile Information in order to help connect with Members (i.e., schools and/or organizations where Users may have attended or participated in). Winkage may also enable Members to publicly display some Registration PII as an element of their Profile Information if they choose to do so via a profile setting under "Edit Profile." Search engines may index the portion of a Member's profile (including the Profile Information it contains) that is publicly displayed.

If you have consented to receive promotional materials (e.g., newsletters) or notifications from Winkage, Winkage may periodically use your email address to send you such materials related to the Winkage Services, as applicable. If you want to stop receiving such materials from Winkage, you can change your profile settings in "All-U” or follow the unsubscribe instructions at the bottom of each email.

Winkage employees, agents and contractors must have a business reason to obtain access to your PII. Winkage may share your PII with those who help us manage or provide Winkage Services' information activities (for example, message board administration, order fulfillment, statistical analyses, data processing), or with outside contractors, agents or sponsors who help us with the administration, judging and prize fulfillment aspects of contests, promotions and sweepstakes.

These outside contractors, agents or sponsors may temporarily store some information on their servers, but they may only use your PII to provide Winkage with a specific service and not for any other purpose. Winkage may also provide your PII to a third party in those instances where you have chosen to receive certain information and have been notified that the fulfillment of such a request requires the sharing of your PII. Winkage also may share your PII with Affiliated Companies if it has a business reason to do so.

As described in "Notice" above, Winkage may customize the advertising and marketing messages you receive on the Winkage Website, or may work with outside companies to do so. Your non-PII and/or Profile Information may be shared with these companies so this customization can be accomplished. Winkage prohibits these companies from sharing your non-PII and/or Profile Information with any third party or from using it for any other purpose. Anonymous click stream, number of page views calculated by pixel tags, and aggregated demographic information may also be shared with Winkage advertisers and business partners.

There may be instances when Winkage may access or disclose PII, Profile Information or non-PII without providing you a choice in order to: (i) protect or defend the legal rights or property of Winkage, our Affiliated Companies or their employees, agents and contractors (including enforcement of our agreements); (ii) protect the safety and security of Users of the Winkage Services or members of the public including acting in urgent circumstances; (iii) protect against fraud or for risk management purposes; or (iv) comply with the law or legal process. In addition, if Winkage sells all or part of its business or makes a sale or transfer of all or a material part of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, Winkage may transfer your PII to the party or parties involved in the transaction as part of that transaction.

SECURITY:  WINKAGE PROTECTS THE SECURITY OF PII, AND YOUR OBLIGATIONS RELATED TO PRIVACY

Winkage uses commercially reasonable administrative, technical, personnel and physical measures to safeguard PII and credit card information in its possession against loss, theft and unauthorized use, disclosure or modification. In addition, Winkage uses reasonable methods to make sure that PII is accurate, up-to-date and appropriately complete.

Whenever possible, Winkage Members may review the Registration PII we maintain about them in our records. We will take reasonable steps to correct any PII a Member informs us is incorrect. If you are a Member, you can view and change your Registration PII, Member preferences and Profile Information by logging into your account and accessing features such as "Edit Profile" and "Account Settings."

If you ask Winkage to stop using your PII, Winkage will honor that request while retaining any record of your PII that is necessary to comply with applicable federal, state or local law.

If you would like to communicate with us about this Privacy Policy or Winkage collection and use of your PII please contact Winkage at helpme@Winkage.com.