Privacy Policy

– IMPORTANT — PLEASE READ

LAST UPDATED: Mar/2014

This Privacy Policy (“Privacy Policy”) describes the commitment to your privacy on the part of Schogini, Inc. (referred to collectively as “Schogini,” “we” and “us”).

PERSONS OR PARTIES COVERED

This Privacy Policy applies to all visitors to any Schogini owned website (the “Website”), all subscribers to Schogini-sponsored lists and/or newsletters (whether paid or unpaid), all members and/or affiliates of memberships or membership sites sponsored by or owned by Schogini (whether paid or unpaid), all affiliates of any site sponsored or owned by Schogini (whether paid or unpaid), and all customers that purchase products and/or services via the Website or otherwise from Schogini. Persons who visit or view the Website, whether intentionally or unintentionally, whether solicited or unsolicited, are referred to herein as “Visitors” and are subject to this Privacy Policy.

Subscribers to Schogini-sponsored lists and/or newsletters are referred to herein as “Subscribers” and are subject to the Privacy Policy. Persons who join an organization or marketing endeavor (e.g. “affiliates”) promoted by and through the Website, or otherwise by Schogini are referred to herein as “Members” and are subject to this Privacy Policy. Individuals that order, attempt to order or receive products and/or services that are sold, advertised on or delivered from the Website, or otherwise by Schogini, even at no cost, are referred to herein as “Customers” and are subject to this Privacy Policy.

If you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third party for marketing purposes, please e-mail us at: Support@schogini.com. Please be advised that where California residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with the law.

MINORS

We do not knowingly collect information from individuals under eighteen (18) years of age, or persons who are otherwise covered by the provisions of the Children’s Online Privacy Protection Act of 1998, as amended (“COPPA”). No information should be submitted to, or posted at, the Website by individuals under eighteen (18) years of age. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

VIEWING, USE AND/OR COMMUNICATION IS CONSTRUED AS ACCEPTANCE OF THE TERMS OF THIS PRIVACY POLICY

Acceptance of the terms of this Privacy Policy is a portion of the consideration required for your right to visit the Website. If you do not accept the terms of this Privacy Policy in their entirety, you have no right to visit the Website.

ABOUT THE PERSONAL INFORMATION SCHOGINI COLLECTS AND HOW IT IS USED

Schogini routinely collects information about Visitors, Subscribers, Members and Customers. This information is obtained in various ways, such as:

VISITOR, SUBSCRIBER, MEMBER OR CUSTOMER INFORMATION OBTAINED FROM REGISTRATION

For purposes of this Privacy Policy, “Registration” means that the Visitor, Subscriber, Member or Customer, as applicable, takes active, positive steps to communicate information to Schogini. This can include, without limitation, where the individual: (a) registers for a newsletter or subscribe to a mailing list; (b) participates in Visitor surveys; (c) participates in promotions, contests and/or sweepstakes offered by Schogini; (d) requests information from Schogini via an online form, email, mail or courier; (e) joins, or attempts to join, an affiliate program or other membership organization sponsored by Schogini; and/or (f) orders a product through the Website or otherwise from Schogini.

The information that you must supply in connection with Registration (as further described below) may include, without limitation, some or all of the following: (i) your full name; (ii) company name; (iii) e-mail address; (iv) mailing address (and billing address if different); (v) home telephone number; (vi) work telephone number; (vii) telecopier number; (viii) credit card information; and/or (ix) any other information requested on the applicable Registration form.

VISITOR EMAIL INQUIRIES

Website Visitors that wish to communicate with Schogini do so under the following conditions: (a) they give their permission to be contacted by Schogini; and (b) they are subject to any ‘submission’ provisions contained in the Schogini Terms of Use,

Schogini Purchase Agreement and/or this Privacy Policy. The email address that you use in connection with your inquiry shall be added to the Schogini database.

CUSTOMER EMAIL OR TESTIMONIALS

If you are a Customer and you send an email to Schogini, or if you communicate with Schogini by phone or U.S. mail, Schogini shall collect information about your communication and by communicating with Schogini, you give your permission for Schogini to collect, archive, retrieve and otherwise use any information collected as Schogini sees fit.

Any communication which, in its sole discretion, Schogini deems to be a testimonial, may be publicized for commercial purposes.

INFORMATION OBTAINED FROM VOLUNTARY VISITOR, SUBSCRIBER, MEMBER OR CUSTOMER SURVEYS

Unless otherwise specified in the survey, you must assume that any information provided to Schogini as part of a survey in which you participate may be used as set forth herein below.

INFORMATION OBTAINED FROM ELECTRONIC MEANS AND COOKIES

We may collect certain non-personally identifiable information about you when you visit many of the sections of the Website. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Netscape, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or Mac OS) and the domain name of your Internet service provider (e.g., America Online, Earthlink). We use the non-personally identifiable information that we collect to improve the design and content of the Website and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze Website usage, as well as to offer you products and services. We also reserve the right to use aggregate or group data about our Visitors for any and all lawful purposes. Aggregate or group data is data that describes the demographics, usage and/or characteristics of our visitors as a group. By visiting and/or supplying your personal information at the Website, you agree to allow us to provide such aggregate data to third parties.

“Cookies” is web jargon for bits of computer code placed on your hard drive. The Website uses cookies to keep you ‘logged in,’ to keep track of search criteria, to monitor use, to password protect use of the Website and/or to track use of products and/or services sold by and through the Website. Even in the case where a Visitor rejects a cookie, they may still use our Website. The only drawback to this is that the Visitor may be limited in what he/she can access in some areas on our Website. Cookies can also be used to obtain information about your computer configuration or your use of your computer. To find out more about cookies, including how to disable and/or remove cookies, please visit www.cookiecentral.com.

Some of our advertising partners may use cookies and web beacons on our site. These third-party ad servers or ad networks use technology to the advertisements and links that appear on this website send directly to your browsers. They automatically receive your IP address when this occurs. Other technologies ( such as cookies, JavaScript, or Web Beacons ) may also be used by the third-party ad networks to measure the effectiveness of their advertisements and / or to personalize the advertising content that you see.

Schogini has no access to or control over these cookies that are used by third-party advertisers.

You should consult the respective privacy policies of these third-party ad servers for more detailed information on their practices as well as for instructions about how to opt-out of certain practices. Schogini’s privacy policy does not apply to, and we cannot control the activities of, such other advertisers or web sites.

If you wish to disable cookies, you may do so through your individual browser options. More detailed information about cookie management with specific web browsers can be found at the browsers’ respective websites.

INFORMATION COLLECTED VIA LOG FILES

We collect information via log files, and the information inside the log files includes internet protocol ( IP ) addresses, type of browser, Internet Service Provider ( ISP ), date/time stamp, referring/exit pages, and number of clicks to analyze trends, administer the site, track user’s movement around the site, and gather demographic information. IP addresses, and other such information are not linked to any information that is personally identifiable.

HOW YOUR INFORMATION MAY BE USED

The personal information that you submit to us remains your property, but by submitting such information to us you grant us the right, subject to applicable state and federal law, to use the personal information (other than credit card information) for marketing purposes. Without limiting the generality of the foregoing, we reserve the right to share, sell, rent, lease and/or otherwise distribute any and all personal information with/to any third-party for any and all uses permitted by this Privacy Policy and applicable law. These third parties may include, but shall not be limited to: (a) providers of direct marketing services and applications, including

lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); (d) SMS text-based marketers (where permitted by applicable law); and (e) direct marketers. We may also use your personal information for any promotion-related purpose, and/or marketing and survey purpose, on our own behalf and on behalf of our affiliates and subsidiaries. We may disclose personal information to third-party agents and independent contractors that help us create and/or operate any promotions, surveys or other offerings. You agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Website and any and all offerings made available therein, or otherwise by Schogini.

We are able to offer our products and services to you, in part, based on your willingness to be reached by our third-party advertisers. Your personal information (other than credit card information) will be shared with advertisers on an aggregate and non-aggregate basis. We also use contact information from your personal information to send you information about us, our products and services and to contact you about your billing account status. Please keep in mind, though, that we do not control, and are not responsible for, the practices of our third-party advertisers. If you wish to stop receiving future communications from us and/or third party advertisers, or if you wish to prevent the transfer and/or sale of your personal information to third parties (subject to restrictions contained in applicable state and federal law), please see the Opt-Out/Unsubscribe section below.

You agree that by submitting your personal information to Schogini, you agree to receive e-mail marketing from Schogini and our third-party advertisers. In addition, you agree that such act constitutes a purchase, an inquiry and/or an application for purposes of the Amended Telemarketing Sales Rule, 16 CFR §310 et seq. (the “ATSR”). With respect to the ATSR, and notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, we retain the right to contact you via telemarketing in accordance with the terms of the ATSR.

In addition, by submitting your personal information to Schogini, you agree to receive mobile marketing including, but not limited to, text-message based marketing, from us and our third party advertisers and marketers (where, and to the extent that, such marketing is permitted by applicable law). As such, notwithstanding that your mobile telephone number may be listed on state and/or federal Do-Not-Call registries, we retain the right to contact you via text-message based marketing in accordance with applicable state and federal law. Further, you agree that we reserve the right to share, sell, rent, lease and/or otherwise distribute your mobile telephone and other mobile data with/to any third-party for any and all non-marketing uses permitted by this Privacy Policy and applicable law.

We reserve the right to release current or past personal information: (a) in the event that we believe that the Website, and any products, services or other offerings is/are being or has/have been used in violation of this Privacy Policy, the Schogini Terms of Use, Schogini Purchase Agreement, or to commit unlawful acts; (b) if the information is subpoenaed; or (c) if any entity comprising Schogini is sold or acquired. Moreover, you hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with other third-parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time. Visitors should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personally identifiable information to be shared or transferred to third parties without permission.

We may also supplement the information we collect with information from other sources to assist us in evaluating and improving the Website, our products and/or services, and to determine your preferences so that we can tailor the Website and our products and/or services to your needs.

CREDIT CARD INFORMATION

Notwithstanding the foregoing, we will not use your credit card information for any marketing purposes, or transfer same to any third party, other than as set forth in this paragraph. Schogini may: (a) transfer your credit card information to third party sellers where necessary to effectuate the purchase of products and/or services that you requested on the Website or otherwise from Schogini; (b) disclose your credit card information pursuant to a court order, litigation and/or fraud investigation; and (c) share with third parties the fact that we have credit card information on file for specific individuals.

INFORMATION OBTAINED FROM VISITOR INTERACTION WITH BANNERS, POPUPS OR WEBSITE ADVERTISERS

The Website may contain third party provided banners, pop-ups, hyperlinked advertising and links to other third-party owned and/or operated websites. Schogini is not responsible for the privacy practices associated with such third party advertisers and/or websites. In some cases, you may be required to provide certain information to register or complete a transaction via such advertisers and/or at such websites. These third-party websites and advertisers have separate privacy and data collection practices and Schogini has no responsibility or liability relating to them. We do not endorse, nor are we responsible for the accuracy of, the privacy policies and/or terms and conditions of such advertisers and/or websites. These third party entities are independent third parties and are not affiliated with us.

OPT-OUT/UNSUBSCRIBE

When you submit personally identifiable information to us at the Website, you have opted-in to the sharing of your personal information with third parties to receive marketing communications. When contacted by any of these companies or third parties, you should notify them directly of your choices regarding their use and sharing of your information. To opt-out of having your information shared with third parties, please notify us by email at support@schogini.com. To stop receiving future e-mail communications from Schogini, please notify us by email at support@schogini.com. Schogini may maintain separate e-mail lists for different purposes. If e-mail recipients wish to end their e-mail subscription from a particular list, they need to follow the instructions at the end of each e-mail message to unsubscribe from the particular list. To unsubscribe from all Schogini e-mail lists, please notify us by email at support@schogini.com.

DATA SECURITY

All collected information is stored in a technically and physically secure environment. When our registration/application process asks users to enter sensitive information (such as credit card number), and when we store and transmit such sensitive information, it is encrypted and protected with SSL encryption software. While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect sensitive information and other personal information off-line. Unfortunately, no data transmission over the Internet, or otherwise, can be guaranteed to be 100% secure. As a result, while we strive to protect your sensitive information and other personal information, we cannot ensure or warrant the security of any information that you transmit to us, and you do so at your own risk.

Once we receive your transmission, we make reasonable efforts to ensure its security on our systems. Access to this personal information is strictly limited, and not accessible to the public. All of our users’ personal information, not just sensitive information, is restricted in our offices. Only employees who need the information to perform a specific job are granted access to personal information. Our employees are dedicated to ensuring the security and privacy of all Schogini user personal information. Employees not adhering to our written firm policies are subject to disciplinary action. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

DISCLOSURE TO THIRD PARTIES

We cannot provide all services needed for successful operation of the Applications or the Website by ourselves. Therefore we must share collected information with third parties, including third-party advertising companies that assist us in delivering advertising to you that allows us to continue offering the Applications for free or at a low cost.

We have therefore contracted with certain third-party advertising networks such as Apple (iAds), Google (AdMob), InMobi; statistical services providers such as Apsalar,Flurry and HasOffers (for Applications) and Google analytics (for Websites); and other third-party service providers that support the Applications and the Website (collectively, “Partners”). Our Partners provide services such as advertising marketing, information processing, customer information management and enhancement, statistical analysis, customer research and analysis, satisfaction surveys and customer profiling. We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Applications or the Website. For any additional questions about third party information collection please refer to support@schogini.com

PARTNER’S USE OF INFORMATION

We may share information that we have collected with our Partners for the purposes of delivering our services, displaying advertisements and conducting analysis and research. We may share information that can be used to personally identify your device (e.g., persistent identifiers such as UDID, IP address). Partners are not allowed to use the information for any other purpose (other than the one listed above) or share them with third parties. We strive to commit our Partner’s to use the information solely for the purposes as stated above. If they use information that might be considered as personal information, they should use it solely for the purposes of contextual advertising, while for any other purposes they should use the information solely on anonymized and aggregated basis. Notwithstanding the above, we cannot guarantee that our Partners will adhere to the contractual obligations or acceptable business practices.

In addition, Partners may use their own tracking technologies (including without limitation cookies, Web beacons, HTTP cache, and local shared objects) to compile anonymous information about users of the Applications and visitors to the Website. Partners may share anonymous information that they collect with their clients, including the date and time a banner ad was shown, the specific ad shown. We strive to ensure that this information is only disclosed to Partner’s third parties in an anonymized and aggregated manner.

Unlike the tracking technologies used by us in content we control on the Website and in the Applications, we do not control or have access to the information collected by our Partners using their own tracking technologies. Their information gathering practices, including their policies regarding the use of cookies, Web beacons, and other tracking technologies, are governed by their own privacy policies, not this one. We strive to adhere to the generally accepted industry practices regarding the collection and the usage of information by our Partners and to limit their usage to the services they provide for us.

While we strive to protect the information provided to Partners we have no direct control over their uses of the collected information and therefore you acknowledge that we are not liable for any third party privacy breach and that our liability for Partner’s breaches is limited to the amount we are able to receive as indemnification from our Partner, legal costs exempted.

We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a re organization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.

Some of the Applications allow you to submit content generated in or by the Applications to third-party sites like Facebook and YouTube. These submissions follow the information transfer protocols for such third parties, which are designed to enable content sharing with such third parties and generally prevent any storage of information necessary for access to such third party services by us. In addition, we may receive certain information (which may include your personally identifiable information) from such third parties through the use of Application Programming Interfaces provided by such third parties. These third-party sites are governed by their own privacy policies and end user agreements, and we are not responsible for, and have no control over, the sharing practices or policies of the third parties that operate those sites. For additional questions you can contact as at support@schogini.com.

IN-APP PURCHASES

Although some of our Applications are free, they include in-app purchases. In-app purchases may be made only upon entering the app store password and you are responsible for maintaining the security of such password. You should be aware of the 20 minutes window after the downloading of the Application, during which, in-app purchases may be made without inserting an in-app store password. You should also take into account that OS 2.1 or older versions of Android mobile phones do not require entering of the app store account password to carry out the in-app purchase.

CONTACT US

If you have any questions regarding this Privacy Policy, or would like more information on our privacy practices, please contact us at:

support@schogini.com

Schogini, Inc.

501 Silverside Rd, Suite 105

Wilmington, DE 19809

REVISIONS TO THIS PRIVACY POLICY WITHOUT NOTICE

We reserve the right, in our sole discretion, to change, modify, add and/or remove portions of this Privacy Policy at any time. All Privacy Policy changes will take effect immediately upon their posting on the Website. Please check the Website periodically for any changes. Your continued use of the Website and/or acceptance of our e-mail communications following the posting of changes to this Privacy Policy will constitute your acceptance of any and all changes.