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Privacy Policy (Last Updated: June 21, 2009)

Launchly, Inc. has created this privacy policy (the "Policy") to explain our privacy practices so you will understand when and how personal information is collected, used, disclosed and protected with respect to our launchly services ("Service") and Web site ("Site") located at http://www.launchly.com/. By using the Service, you consent to the privacy practices described in this Policy.

We reserve the right to change this Policy at any time. If we make any material changes to our Policy, we will post a new policy on our Site and update the "last updated" date set forth above. Therefore, we encourage you to check our Policy whenever you use the Service to see if it has been updated since your last visit.

INFORMATION ABOUT YOU

We collect two basic types of information with our Service, namely personal information and aggregate information. Personal information is information that is directly associated with a specific person or entity such as a user's name, initials or nickname, e-mail address, and user-chosen ID and password.

Our definition of personal information does not include "aggregate" information. Aggregate information is data we collect about a group or category of services or users from which individual user identities have been removed. In other words, information on how you use our Service may be collected and combined with information about how others use the Service, but no personal information will be included in the resulting data. Aggregate data helps us understand trends in our users' needs so that we can better consider new features or otherwise tailor our Service. We may share aggregate information about our users with third parties for various purposes, including to help us better understand and improve our Service, and for advertising and marketing purposes.

Those are the types of personal and other information we collect. You should refer to the rest of this Policy to see how we use, disclose and protect this information:

Information You Give Us.

We collect information you give us at various times such as when you register with us and use our Service. Examples include the following:

  • Registration and Transaction Information. When you register to use the Service, we may collect various kinds of contact information about you including, for example, your name and e-mail address. Any billing information is collected by PayPal and stored solely on their servers and systems. We do not collect or store any billing information.
  • Submissions and Customer Service. From time to time we may post surveys, contests or sweepstakes on our Service, which may request demographic information and customer feedback. Participation in these requests is completely voluntary and with each request you will have the choice of whether or not to participate and disclose information. We may also collect personal information if you provide it via e-mail, message boards, or other interactive services. Please do not post any information that you expect to keep private. In addition, we may collect and retain information that identifies you personally when you send us comments, questions or suggestions, or if you send to us job application, resumes, or other business contacts.
  • Automatically Collected Information. We automatically receive certain types of information whenever you interact with us. For example, when you use the Service, our systems may automatically collect your IP address and the type of operating system or browser you use. We may also collect information pertaining to your account activity, information pertaining to the files accessed or used by you, and standard access information, such as the time and date of accessing the Service, and usage of the Service. We use such information to create metrics that are shared with our customers, such as counting the users who have visited those pages and compiling aggregated statistics about Service usage.

Cookies

A cookie is a small amount of data, often including an anonymous unique identifier, which is sent to your browser from a web site's computers and stored on your computer's hard drive. Most browsers automatically accept cookies as the default setting. You can modify the setting to reject cookies or to prompt you before accepting a cookie from the sites you visit by editing browser options. If you decide not to accept our cookies, however, you will not be able to use the Service. We use cookie technology to collect information so that we can improve our Site by seeing which areas and features are most popular; to personalize the Site and improve the Site experience; and to allow you to visit the Site without re-entering your member ID and/or password. While we use cookies to record current session information, we do not use permanent cookies. You are required to sign in again to the Service after a certain period of time has elapsed (currently 4 hours) to protect you against others accidentally accessing your account contents. We also use cookies as part of the Google Web Analytics service, subject to the Google Privacy Policy (currently located at http://www.google.com/privacy.html).

No Information about Children.

Our Site and Service are intended for the general audience. However, we do not knowingly, directly or passively, collect information from children under the age of 13. If you are under the age of 13, please do not provide personally identifiable information of any kind whatsoever. Should a child whom we know to be under 13 send personal information to us, we will use that information only to respond directly to that child to inform him or her that we must have parental consent before receiving his or her personal information.

USE OF PERSONAL INFORMATION

Internal Use of Personal Information.

All contact information submitted by you is stored in our database and may be archived elsewhere. Our records are stored indefinitely, as are our archival backup copies.

In general, we use personal information internally to serve our users and enable them to take maximum advantage of our Service. For example, personal information may be used to conduct marketing analysis, to provide services or complete transactions you have requested, to anticipate and resolve problems with our Service, to respond to customer support inquiries, and to create and inform you of new products and services from launchly that better meet your needs.

Access to the limited amount of personal information that is collected will be limited to specific Launchly, Inc. employees. Specifically, we authorize a limited set of people to act as "super admins" of the Service. While performing functions of customer support, site maintenance, research, debugging, or testing, these individuals may search and alter any information in the database, including but not limited to user information, project information, story information, and time records. As part of the normal engineering process, release engineers will perform tests such as load and performance testing and database migration testing. These tests occur on a backup copy of the production database, which is transferred using secure encryption to a test system.

You should review the following section to understand when Pivotal discloses personal information to non-affiliated third parties.

Disclosure of Personal Information.

We do not rent, sell, or share personal information about you with other people or non-affiliated companies except (i) when we have your permission, (ii) as may be necessary to perform internal analyses and business functions, (iii) as part of a business transfer, or (iv) when required by law or permitted to protect our rights, property, or safety. The following section describes these disclosure circumstances more fully.

  • Consent. Unless you choose to do so, we will not disclose your personal information to third parties for their direct marketing purposes. With your consent, we may disclose your personal information to third parties so that they may provide you with products and services that you have requested.
  • Business Functions. We may share personal information with third party vendors who assist us in performing internal functions necessary to operate our business. In the event that we use third party vendors to assist us in performing these functions, the third parties may not use or disclose your personal information for any other purpose.
  • Internal Analysis. We may use information about you for our own internal purposes, such as to estimate our audience size, measure aggregate traffic patterns as well as to understand demographic, customer interest, and other trends among our users. We may outsource these tasks and disclose personal information about you to third parties in aggregate, provided the use and disclosure of your personal information by these third parties is restricted to performance of such tasks.
  • Business Transfers. Information about our users and the Service is one of our most important business assets. Therefore, information about our users, including personal information, will be disclosed as part of any merger or acquisition, creation of a separate business to provide the Service or fulfill products, sale or pledge of company assets as well as in the event of an insolvency, bankruptcy or receivership in which personal information would be transferred as one of the business assets of the company.
  • Protection of Launchly, Inc. and Others. We may release personal information in the good faith belief that release is appropriate and necessary to comply with legal process or authority (e.g., a lawful subpoena, warrant or court order); to enforce or apply our policies; to initiate, render, bill, and collect for amounts owed to us; to protect our rights, property, or personal safety of Pivotal, our users, our employees, or the public; or if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

THIRD PARTY SITES

Please be aware that we may provide links to third party Web sites as a service to our users and we are not responsible for the content or information collection practices of those sites. Please also note that these Web sites' privacy policies will differ from those of Pivotal. Therefore, we encourage you to review and understand their privacy practices before providing them with information or visiting their sites.

We use third-party advertising companies to serve ads when you visit our website. These companies may use information (not including your name, address, email address, or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here.

NETWORK AND INFORMATION SECURITY; DATA STORAGE

All reasonable effort will be taken to prevent unauthorized release, corruption, or loss of your personal and course data.

Launchly, Inc. generates automatic backups of all system data. These backups are transferred using commercially reasonable efforts such as secure encryption, and are stored on systems that are only accessible by authorized employees of Pivotal Labs and our third-party vendors and partners. While we have taken efforts to guard your personal information, we cannot guarantee that your information will not be disclosed or accessed by accidental circumstances or by the unauthorized acts of others.

Launchly, Inc. uses third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run launchly. Although Launchly, Inc. owns the code, databases, and all rights to the launchly application, you retain all rights to your data.

Your account information and access to our Service is accessible only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of our Site and Service by any person using your account user ID and password. Please advise us immediately if you believe your account user ID and password have been misused.

ACCESS AND CONTROL OF PERSONAL INFORMATION

If you are a registered user of our Service, you may view, correct, and delete your personal information, simply by logging into the Service and editing your profile. Generally, you should be careful when making any personal information available to the public.

Users may "opt in" to be notified via email of certain events on the Site, such as when new courses are offered. Classmate updates and recommendations may also result in emails being sent.

Launchly, Inc. may also occasionally send general announcements about the Service (such as a revision to this Policy). Other than for these purposes, Launchly, Inc. will not send unsolicited email to the email addresses. We reserve the right to send you such communications relating to our Service and Site without offering you the opportunity to opt-out of receiving them.

INTERNATIONAL USERS

By using our Site and providing us with data, you acknowledge and agree that due to the international dimension of the Site, we may use the data collected in the course of our relationship for the purposes identified in this policy or in our other communications with you, including the transmission of information outside your resident jurisdiction. Please note that your personal information will be stored and processed on our computers in the United States. The laws on holding personal data in the United States may be less stringent than the laws of your country. If you object to your personal information being transferred or used as described in this Policy, please do not register for the Service.

UPDATING THIS POLICY

We may revise and update this Policy if our practices change, as technology changes, or as we add new services or change existing ones. Any changes will be posted to this document so that you will always know what information we gather and how we use it. If we make any material changes to our Policy or how we handle your personal information, we will post an updated Policy on our site and change the date of the Policy. If we are going to use any personal information in a manner that is materially different from that stated in our Policy at the time we collected such information, we will give you a reasonable opportunity to consent to the change. We will use information in accordance with the most current privacy policy.

CALIFORNIA PRIVACY RIGHTS

California Civil Code section 1798.83 permits customers who are California residents to request certain information regarding disclosure of personal information to third parties for their direct marketing purposes. We do not provide your personal information to any third party for their direct marketing purposes without your consent. If you would like more information with respect to your privacy rights under California law, you may contact us at the contact point below. Please reference your request as "California Disclosure Information."

CONTACTING US

Any questions about this Policy should be addressed to privacy@launchly.com.