Privacy Policy
 Your privacy is very important to us. When you visit flutterstep.com, you provide us with two types of information: personal information you knowingly choose to disclose that is collected by us and Web Site use information collected by us as you interact with our Web Site. When collecting, creating, maintaining, using and disclosing this personal information, we take reasonable steps to assure the data is accurate, complete and timely for the purposes for which it is to be used.
When you register with flutterstep.com, you provide us with certain personal information, such as your name, your email address, your telephone number, your gender and any other personal or preference information that you provide to us. This “Personal Information” is information that we can use to identify you as an individual. All Personal Information will be treated in accordance with this Privacy Policy.
When you enter flutterstep.com, we collect your browser type and IP address. This information is gathered for all flutterstep.com visitors. In addition, we store certain information from your browser using "cookies." A cookie is a piece of data stored on the user's computer tied to information about the user. We use session ID cookies to confirm that users are logged in. These cookies terminate once the user closes the browser. By default, we use a persistent cookie that stores your login ID (but not your password) to make it easier for you to login when you come back to flutterstep.com. You can remove or block this cookie using the settings in your browser if you want to disable this convenience feature.
When you use flutterstep.com, you can set up your personal profile, make contacts and connect with other users, send messages, perform searches and queries, form groups, and transmit information through various channels. We collect this information so that we can provide you the service and offer personalized features. In most cases, we retain it so that, for instance, you can return to view prior messages you have sent or easily see your contact list. When you update information, we usually keep a backup copy of the prior version for a reasonable period of time to enable us to revert to the prior version of that information.
You post User Content (defined as all text, pictures, information and other data) on the Site at your own risk. Although we allow you to set privacy options that limit access to your pages, please be aware that no security measures are perfect or fool proof. We cannot control the actions of other Users with whom you may choose to share your pages and information. Therefore, we cannot and do not guarantee that User Content you post on the Site will not be viewed, modified or deleted by unauthorized persons. We are not responsible for circumvention of any Privacy Settings or security measures contained on the Site. You understand and acknowledge that, even after removal, copies of User Content may remain viewable in certain cached and archived pages or if other Users have copied, stored or otherwise maintained your User Content.
Any improper collection or misuse of information provided on flutterstep.com is a violation of the flutterstep.com Terms of Use and should be reported through privacy@flutterstep.com. You must be 13 years or older to user flutterstep.com. If you believe that we might have information from someone under 13 years of age, please contact us at privacy@flutterstep.com.
If you choose to use our invitation service to tell a friend about our site, we will ask you for information needed to send the invitation, such as your friend's email address. We will send your friend an email in your name inviting him or her to visit the site. Flutterstep.com stores this information to send invitations and reminders, to register a friend connection if your invitation is accepted, to allow you to see invitations you have sent, and to track the success of our referral program. Your friend may contact us to request that we remove this information from our database by clicking on the “Unsubscribe” link at the bottom of the email.
By using flutterstep.com, you are consenting to have your personal data transferred to, stored and processed in the United States.
Use of Information Obtained by flutterstep.com
When you register with flutterstep.com, you create your own profile and Privacy Settings. Your profile information, as well as your name, email and other information, are displayed to your contacts, as well as to people in the groups and conversations specified in your Privacy Settings, to enable you to connect with people on flutterstep.com. We may occasionally use your name and email address to send you notifications regarding new services offered by flutterstep.com that we think you might find interesting and valuable. If you would prefer not to receive these emails, you can click on the “Unsubscribe” link at the bottom of the email.
Profile information is used by flutterstep.com primarily to be presented back to and edited by you when you access the service and to be presented to others permitted to view that information by your Privacy Settings. If at any time Personal Information is collected for some other purpose or is disclosed to third parties, you will be given the option to not provide this Personal Information.
Profile information you submit to flutterstep.com will be available to users of flutterstep.com consistent with your Privacy Settings. Your name and username will be available in search results across the flutterstep.com website and those limited pieces of information may be made available to third party search engines. This is primarily so your contacts and other users can find you and send a request to be added as a contact. People who see your name in searches, however, will not be able to access your profile information unless your Privacy Settings allow for these people and categories of people to see your profile information.
Flutterstep.com may send you service-related announcements based on your Feed Settings. For instance, if someone sends you a new message or a request to be added as a contact, you may receive an email alerting you to that fact if you have indicated in your Feed Settings that you desire this information in an email.
You may limit and even eliminate these emails completely on the Feed Settings page. Flutterstep.com reserves the right, however, to send you notices about your account that we deem important even if you opt out of all voluntary email notifications.
Flutterstep.com may use information in your profile without identifying you as an individual to third parties. We do this for purposes of personalizing advertisements and promotions so that we can provide you with flutterstep.com. We believe this benefits you and makes available to you goods and services you might be interested in, but we won’t disclose your Personal Information to the third-party.
We may use information about you that we collect from other sources, including but not limited to newspapers and internet sources such as blogs, instant messaging services, flutterstep.com API developers and other users of flutterstep.com, to supplement your profile. Where such information is used, we allow you to specify in your Privacy Settings that you do not want this to be done or to take other actions that limit the connection of this information to you and your profile. You can change your choice and your Privacy Settings at anytime.
We may use third party Personal Information to send a one-time email message to you to solicit your consent to using the Personal Information. If you decline, we will not use this information.
Security
Flutterstep.com takes significant precautions to protect our users' Personal Information, in the collection, maintenance and any disclosure of this information. Your account information is located on a secured server behind a firewall. When you enter Personal Information, we may encrypt that information using secure socket layer technology (SSL). Because email and other forms of messaging are not recognized as secure communications, we request that you not send private information to us by email or messaging services. Your private information and the information you choose not to make public is password protected on flutterstep.com.
Sharing Your Information with Third Parties
Flutterstep.com is about sharing information with others — your friends, families and contacts — while providing you with Privacy Settings that restrict other users from accessing any and all information you want to keep private. We allow you to customize your settings and choose the information you provide to contacts and other groups through flutterstep.com. Our website design and your Privacy Settings allow you to make informed choices about who has access to your information. We do not provide contact information to third parties without your permission. We share your information with third parties only in limited circumstances where we believe such sharing is 1) necessary to offer our services, 2) legally required or, 3) permitted by you. For example:
• Your feed may aggregate the information you provide and make it available to your contacts and group members consistent with your Privacy Settings. You may set your preferences for your feeds on the Privacy Settings page.
• Flutterstep.com may limit access to site information by third party search engine "crawlers" (e.g. Google, Yahoo, MSN, bing, Ask). Flutterstep.com may take action to block access by these engines to personal information beyond your name and limited aggregated data about your profile (e.g. number of contacts, number of conversations).
• If you, your contacts or any members of your groups or conversations use any third-party applications developed using the flutterstep.com application programming interface (“API”), those APIs may access and share certain information about you with others in accordance with your Privacy Settings. You can control what information is shared through the APIs or ensure that no information is shared on the Privacy Settings page. In addition, third party developers who have created and operate APIs ("API Developers"), may also have access to your Personal Information (excluding your contact information) if you permit APIs to access your data. Before allowing any API Developer to make any such application available to you, flutterstep.com requires the API Developer to enter into an agreement which, among other things, requires them to respect your Privacy Settings and strictly limits their collection, use, and storage of your information. However, while we have taken contractual and technical steps to restrict possible misuse of such information by such API Developers, we do not guarantee that all API Developers will abide by such agreements. Please note that flutterstep.com does not have the ability to control how such API Developers use any Personal Information that they may obtain in connection with these applications.
• We may be required to disclose user information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We do not reveal information unless we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. Additionally, we may share account or other information when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the flutterstep.com service, or to prevent imminent bodily harm. This may include sharing information with other companies, lawyers, agents or government agencies, subject to warrants, subpoenas or other governmental orders.
• We may provide information to service providers to help us bring you our services. Specifically, we may use third parties to facilitate our business, such as to host the service at a co-location facility for servers, to send out email updates about flutterstep.com, to remove repetitive information from our user lists, to offer an online job application process, or to provide search results or links. In connection with these operations, our service providers may have access to your Personal Information for use for a limited time in connection with these business activities. Where we utilize third parties for the processing of any Personal Information, we put in place reasonable contractual and technical protections limiting the use of that information to the flutterstep.com-specified purposes.
• If the ownership of all or substantially all of the flutterstep.com business, or individual business units owned by Flutterstep, Inc., were to change, your user information may be transferred to the new owner so the service can continue operations. In any such transfer of information, your user information would remain subject to the promises made in any pre-existing Privacy Policy.
When you use flutterstep.com, certain information and comments you post or share with others, such as contacts and group members, may be shared with other users in accordance with the Privacy Settings you select. All such sharing of information is done at your own risk. Please keep in mind that if you disclose Personal Information in your profile or when posting comments, messages, or other items, this information may become publicly available.
Amendments
We can modify this Privacy Policy at any time so long as we provide you notice through flutterstep.com (unless you opt-out of such notice) and an opportunity to comment. We will give you a minimum of seven days notice of any changes or amendments to this Privacy Policy. You can contact us with comments at privacy@flutterstep.com. We can make changes for legal, security or administrative reasons upon notice without opportunity to comment.
Links
Flutterstep.com may contain links to other websites. We are not responsible for the privacy practices of other web sites. We encourage our users to be aware when they leave our web site of the privacy statements of each and every web site that collects personally identifiable information. This Privacy Policy applies solely to information collected by flutterstep.com.
Third Party Advertising
Advertisements that appear on flutterstep.com are sometimes delivered directly to users by third party advertisers. In some instances, they automatically receive your IP address. These third party advertisers may also download cookies to your computer, or use other technologies such as JavaScript and "web beacons" (also known as "1x1 gifs") to measure the effectiveness of their ads and to personalize advertising content. Doing this allows the advertising network to recognize your computer each time they send you an advertisement in order to measure the effectiveness of their ads and to personalize their advertising content. They may compile information about where individuals using your computer or browser saw their advertisements and determine which advertisements are clicked. Flutterstep.com does not have access to or control of the cookies that may be placed by the third party advertisers. Third party advertisers have no access to your contact information stored on flutterstep.com unless you choose to share it with them. Flutterstep.com will not share your Personal Information with any third parties without your consent. Flutterstep.com may contact you on behalf of or in connection with third-party advertising. You can opt out of these notifications by clicking on the “Unsubscribe” link at the bottom of the email.
This Privacy Policy covers the use of cookies by flutterstep.com and does not cover the use of cookies or other tracking technologies by any of its advertisers.
Changing or Removing Information
Access and control over Personal Information on flutterstep.com is available through the Edit My Profile link. Flutterstep.com users may modify or delete any of their profile information at any time by logging into their account. Information will be updated immediately. Individuals who wish to deactivate their flutterstep.com account may do so at any time by emailing support@flutterstep.com. Removed information may persist in backup copies for a reasonable period of time but will not be generally available to users of flutterstep.com.
Where you share information with other individuals on flutterstep.com, however, (e.g., sending a personal message to another user or posting a comment in a conversation) you generally cannot remove such communications.
US-EU Safe Harbor program
The European Commission's Directive on Data Protection that went into effect in October of 1998 prohibits the transfer of data from a European Union nation to non-European Union nations that do not meet the European “adequacy” standard for privacy protection. The US Department of Commerce in consultation with the European Commission has developed the “Safe Harbor” framework as a means for US organizations to comply with this Directive. Flutterstep.com has not yet obtained US EU Safe Harbor certification and is therefore not currently certified as compliant to the European Commission's Directive. By visiting or using flutterstep.com from a European Union nation you do so at your own risk.
Your Acceptance of These Privacy Practices
By visiting flutterstep.com you agree that any dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages, resolution of disputes, and application of the law of the District of Columbia. In the event you have a concern regarding privacy, please contact flutterstep.com at privacy@flutterstep.com and we will try to resolve them.
Contacting flutterstep.com
If you have any questions or concerns about this Privacy Policy, please contact us at privacy@flutterstep.com or via U.S. mail at 1155 23rd Street, N.W., Suite 4E, Washington, D.C. 20037.
The flutterstep.com Privacy Policy has been modeled after privacy expert eTrust (http://www.etrust.org) guidelines.
This Privacy Policy is effective as of August 14, 2009.
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