Privacy is the Best Policy

This is How We Roll

Privacy Policy

ONeil Interactive, Inc. (the "Company" or "we"), in the operation of the Homfiniti services, including through its software (the "Website") is committed to protecting the privacy of its customers (collectively, "our users" or, as applicable to yourself and your organization, "you").

We believe that maintaining privacy is very important and hope you will read this Privacy Policy carefully so that you will clearly understand both our commitment to you and your privacy and our method of collecting and using information.

This Privacy Policy only applies to transactions made, and data gathered, on this Website and associated services, and does not apply to any other website or services.

By using this Website, communicating with us by email, or by otherwise submitting personal information to us, you agree to the terms of this Privacy Policy; you give your consent to the collection, storage and use of personal information as explained in this Privacy Policy.

The term "personal information" refers to non-public information that personally relates to or identifies you, such as your name, password, age, gender, email address, postal mailing address, zip code, home/mobile telephone number, Social Security number and/or taxpayer identification number, credit card information, and other similar information). If we combine or associate information from other sources with personal information that you provide directly to us through or in connection with our services, we will treat the combined information as personal information in accordance with this Privacy Policy.

Other information not treated as personal that may be collected on the Website may include, without limitation, website pages viewed, sites visited before visiting this Website, frequency of visits, clickstream data, browser type, operating system, organization name, articles, internet connection speed, presentations viewed, time spent viewing pages of our website or using certain features of our website, demographic data such as server locations, clickstream data, location services, server location, cookies existing on your computer, search criteria used and results, date and time of access or visits to our website, frequency of visits to our website, connection speed, and other information which does not specifically identify you.

OUR PRIVACY POLICY
We use commercially reasonable best efforts to maintain the confidentiality, integrity and security of our users' personal information. Keeping user information secure, and using it only as our users agree, are matters of principle for all us. With this in mind, here is our commitment to each user:
• We will restrict employee access to user information to those who need to know in order to provide services to you;
• We will educate our employees according to our internal policies to reinforce the importance of confidentiality and client and user privacy;
• We will maintain commercial reasonable and customary security standards and procedures to protect information about you; and
• We will respond quickly to your request to correct inaccurate information.

UPDATES AND CHANGES TO PRIVACY POLICY
We may revise our Privacy Policy at any time. In the event of a change in this Privacy Policy, a revised Privacy Policy will promptly be posted to our Website, and the "Updated" date will be changed. Please revisit this page to familiarize yourself with changes to the Privacy Policy. You agree to accept posting of a revised Privacy Policy as described herein as actual notice to you of such revised Privacy Policy. Your continued use of our Website after such posting constitute consent to the collection and use of your information as described in the then-current Privacy Policy.

HOW AND WHY WE GATHER INFORMATION
When you register for an account for use of this Website or at any later time, we collect certain personal information from you to open an account, transact business, communicate with you, verify your identity and fulfill legal and regulatory requirements. We call this your "Profile." From time to time, we may request additional information (e.g., through surveys) to help us further assess your needs and preferences. If you choose to provide such information, during registration or otherwise, you are giving us permission to collect, store and use it consistent with this Privacy Policy.

We may also obtain your personal information from your transactions with us or other users through the services provided through this Website, or from third parties such as credit reporting agencies.

EMAIL COMMUNICATIONS
We regularly send email newsletters to our registered users. Registered users may subscribe or unsubscribe to an email newsletter at any time by changing their email preferences. On occasion, we may send emails to individuals such as registrants and members who have provided us with their email address, informing them of events or promotions we think might be of interest to them. We also send promotional emails to customers and those individuals who have requested a catalogue or email. Email recipients may always opt out of any email category at any time by following the unsubscribe instructions included in the email message.

Emailing Us: We try to respond to email messages requiring a response in accordance with our internal policies. If you email us, your message and email address will be forwarded to the appropriate department within our business. We may choose to save this information. We are pleased to hear from you. However, any message, material, business information, ideas, concepts or other information sent to us by email will be treated as non-confidential and non-proprietary, and we will not be liable for delays or omissions in receiving or responding to email.

COOKIES AND BEACONS
When you visit the Website, whether or not you register for an account, we may send one or more cookies. "Cookies" are small text files containing a string of alphanumeric characters that may be placed on your web browser. Cookies make it easier for you to navigate our Website by, among other things, "remembering" your identity so that you do not have to input your password multiple times as you navigate between webpages on the Website and/or as you access the Services. This use of cookies for authentication (i.e., verifying that you are who you say you are) is an essential component of site security. You can set your web browser to inform you when cookies are set or to prevent cookies from being set.

A "web beacon" is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site or in an email which allows the website to record the simple actions of the user opening the page that contains the beacon. "Server logs" can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server.

Please note that if you decline to use cookies, you may experience reduced functionality or slower site response times. Declining to use our authentication-related cookies may prevent you from using the Website altogether. You may also clear cookies from your computer via your web browser settings. You may also wish to use a Google Analytics opt-out web browser add-on. Information on this option is available at: http://support.google.com/analytics/bin/answer.py?hl=en&answer=2700409.

We or our service providers may also collect web surfing data related to your use of our services (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences). This may be accomplished by using cookies, web beacons, page tags or similar tools. Such web surfing data may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system and the dates and times that you visit the Website. Web surfing data and similar information may be used: for administrative purposes; to assess the usage, value and performance of our online products and services; and to improve your experience with our services.

HOW INFORMATION HELPS BOTH YOU AND US
Information about you plays a key role in our ability to succeed in this mission. It also helps us service your accounts and administer our business. For example, we use information about you to:

  • Provide you with the services available through the Website;
  • Establish and set up your account, issue an account number, and maintain your transaction history;
  • Respond more accurately and efficiently to your requests;
  • Identify opportunities to give you more convenience and control by developing new services that may benefit you;
  • Verify your identity and contact information to help protect you and us from fraud;
  • Comply with certain legal and regulatory requirements.

We generally use the information that you provide or that we collect to establish and enhance our relationship with you, and to operate, maintain, enhance, and provide our services and the Website. We may use such information to periodically provide you with information, newsletters or offers about features and services available through our services that may be of interest to you. We may also send information or offers to groups of Users on behalf of other Users or third parties. However, you will have the option to opt out of receiving such information.

We use aggregated information provided by or collected from our users to understand and analyze the usage trends and preferences of our users, to improve the way our services and the Website work and look, and to create new features and functionality. We may use aggregated information about our Users' investments to generate statistics and maps that we deem helpful in the provision of our services or any part thereof. We do not and will not sell analytics that identify personal information of our users without written consent from the user.

HOW AND WHY OUR COMPANY DISCLOSES YOUR INFORMATION TO THIRD PARTIES
We limit the sharing of personal information outside our Company. We do not sell, license, lease, or otherwise disclose your personal information to third parties, except as noted below:

  • We may disclose your personal information when such disclosure is legally required or appropriate pursuant to any court orders, subpoenas or any regulations, including responding to court orders and subpoenas, cooperating with government agencies, other regulatory bodies, and law enforcement officials, performing background checks, resolving disputes or performing risk-management functions.
  • We may share personal information with our affiliates, and other companies and organizations who perform work for us under contract or sell products or services that complement our products and services.
  • To help us improve our services, we may engage third parties to help us to carry out certain internal functions such as information management, account processing, client services, or other data collection relevant to our business. Examples of the types of outside companies with which we may share information include non-financial companies that perform services for us, such as data processing, and companies that perform reporting, tax documentation, custody or escrow services on our behalf. Use of any personal information we share with these third parties is limited to the performance of the task we request. The third parties with which we share personal information are required to protect it in a manner similar to the way we protect your personal information.
  • We may make certain automatically collected information about your interactions and activities on our services, such as the business areas of interest to you, and your past activities, projects or proposals, publicly available on or through the services. Any such publicly available information will be accessible by other users.
  • In the event that our Company is acquired by or merged with a third-party entity, we reserve the right to transfer or assign the information that we have collected from users as part of such merger, acquisition, sale, or other change of control. In such cases, we will provide you notice before your personal information is transferred to and becomes subject to the Privacy Policy of a different entity.
  • We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.

We further reserve the right to disclose any of your personal information as we believe appropriate or necessary to take precautions against liability, to investigate and defend against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the services, or to protect the rights, property or personal safety of our Company, our users, or others.

We may also use and disclose personally identifiable information and non-personally identifiable information: to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of our website or network; to protect and defend our rights or property or the rights or property of others; as required by courts or administrative agencies; and in connection with a financing, sale, merger, or reorganization of our business or assets. Any successor in interest to our business would acquire the information we maintain, including personally identifiable information, and may alter the terms of this Privacy Policy.

We do not and will not sell any of your information, including non-personally identifiable or personally identifiable information, to any third party for purposes of advertising, soliciting, or telemarketing. We may use a third party service to collect anonymous visitor information like IP addresses, browser types (such as Internet Explorer), referring pages, pages visited and time spent on a particular service or feature. We collect this information for statistical analysis of web page traffic patterns; to administer our service and servers; to allow for auditing of our services by some third parties who have that right; and for internal purposes to make marketing decisions.

OUR PRIVACY POLICY DOES NOT APPLY TO THIRD-PARTY ACTIVITIES OR SITES
The Website may provide links to third-party websites for your convenience and information. If you access those links, you will leave our Website. Any information submitted by you to a third party, will be controlled by that third party's Privacy Policy, which may differ from our own. This Privacy Policy does not cover the collection of information by cookies or other methods by such third party services or other third parties, such as our business partners. We do not control how these third party services or third parties collect information or by what means such third party services or third parties may use their own cookies to collect information about you. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services. We encourage you to review the privacy policy of any company before submitting your personal information.

KEEPING INFORMATION SAFE
We limit access to your personal information to those employees who have a legitimate business need to access such information to provide you with our services. In keeping with industry standards and practices, we maintain commercially reasonable physical, electronic and procedural safeguards and controls to protect your information. The Website is built upon a secure infrastructure with multiple layers of protection and we use industry standard encryption technologies to safeguard your information.

We have security standards and procedures in place designed to prevent unauthorized access to your accounts and personal information. A key part of this process helps ensure that all information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your personal information changes, notify us immediately.

The transmission of information via the Internet is not completely secure, and for this reason we cannot guarantee the security of information sent to us electronically. If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Website and the Services in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

OPT-OUT POLICY
We may at times send you e-mail communications with marketing or promotional materials. If you prefer not to receive such marketing or promotional e-mails from us, you may unsubscribe completely by emailing us at: optout@oneilinteractive.com.

Please note that opt-out requests may take up to twenty-four (24) hours to process. Please also note that at times we may need to send you e-mail communications that are transactional in nature such as service or termination announcements or payment confirmations which are communications you will not be able to opt-out of.

You will be able to modify the information concerning your account by visiting your profile page and editing any information you wish to change. You will be able to change your e-mail address, password, contact information, or other login information by visiting your account's settings page subject to our website policy. If you wish to delete your account or need help modifying account information, please contact us at support@oneilinteractive.com. We will require up to twenty-four (24) hours to process such requests.

If you would like us to remove your Personally Identifiable Information from our database, please send a request to:support@oneilinteractive.com.

We are not responsible for removing your personal information from the lists of any third-party services or other third party who has previously been provided your information in accordance with this notice.

REVIEWING, CHANGING OR CORRECTING INFORMATION
You are solely responsible for helping us to maintain the accuracy and completeness of your personal and other information. We urge you to review your information regularly to ensure that it is correct and complete. If you believe that any of your information is incorrect, or if you have any questions regarding this Privacy Policy, please contact us.

You may, of course, decline to share any or all of your personal information with us or ask us to delete your personal information from our systems at any time, in which case we may not be able to provide to you some of the features and functionality found on or through the Website and the Services.

OUR COMMITMENT TO CHILDREN'S PRIVACY
We do not knowingly collect personal information on or through our services from persons under 13 years-of-age without their legal guardian's consent. If we learn that personal information has been collected from persons under 13 years-of-age through our services without their legal guardian's consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has a registered account with the services or we have received any personally identifiable information of that child without your consent, you may alert us by contacting us.

INTERNATIONAL VISITORS
Our services may be accessed and/or used by users located outside the United States in accordance with our Terms of Use and other policies and procedures posted on the Website. If you choose to use the services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States and by providing your personal information on or through the Services you consent to that transfer.

APPLICABLE LAW AND JURISDICTION
This Privacy Notice shall be governed by, construed and entered in accordance with the laws of the State of Maryland applicable to contracts deemed to be made within such state, without regard to choice of law or conflict of law provisions thereof. All disputes with respect to this Privacy Notice shall be brought and heard either in the Maryland state courts located in Baltimore County, Maryland, or the federal district court for Maryland. You consent to the in personam jurisdiction and venue of such courts. YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.

SECURITY
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to our Company is done at your own risk.

Once we receive your transmission, we make reasonable efforts to ensure security on our systems. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. All credit card numbers submitted to the site are encrypted using "Secure Socket Layer" (SSL) encryption. SSL technology is an industry standard for protecting sensitive information as it is transmitted over the Internet. To prevent unauthorized access, maintain data accuracy and ensure the correct use of information, we have put in place other appropriate physical, electronic and administrative procedures to safeguard and secure the information we collect online. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.

If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the service or providing personally identifiable information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of our services. We may post a notice on our Webpage if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

Contact Information
If you have any questions regarding this Privacy Policy, please contact: support@oneilinteractive.com.