Effective March 2014

WhoKnows, Inc. (“WhoKnows”, “our”, “us” or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users using our WhoKnows platform (the “Service”) or our websites, accessible at www.whoknows.com, www.xperscore.com, and www.akatoo.com (collectively, the “Site”). This Privacy Policy applies only to information that you provide to us through the Site and Service. This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site. You are advised to consult this policy regularly for any changes.

As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

Information Collection and Use

Our primary goals in collecting information are to provide and improve our Site, Service, features and content, to administer your use thereof, and to enable users to enjoy and easily navigate the Site and Service.

Personally Identifiable Information
When you register with us as a WhoKnows subscriber or when you choose to create your own profile webpage, we will ask you for personally identifiable information. This refers to information about you that can be used to contact or identify you (“Personal Information”). Personal Information includes, but is not limited to, your name, phone number, credit card or other billing information, email address and home and business postal addresses. We use your Personal Information mainly to provide the Service and administer your inquiries.

We also collect the other information that you provide as part of registration and the administration and personalization of your profile webpage (e.g., without limitation, zip code and individual preferences) and use of the Service (“Non-Identifying Information”). For example, we will collect information related to your internet search and browsing activity in order to develop a profile of your professional expertise.

We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Service, complete your transactions, and administer your inquiries.

Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other WhoKnows Users (defined below) to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how our Site and Service are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.

We also use your Personal Information to contact you with WhoKnows newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications.

Log Data
When you use the Service, use WhoKnows software, or visit the Site, whether as an WhoKnows subscriber or a non-registered user just browsing (any of these, an “WhoKnows User”), our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type or the webpage you were visiting before you came to our Service, pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and the Service and for the Site’s technical administration, to increase our Service’s functionality and user-friendliness, and to better tailor our Service to our visitors’ needs. For example, some of this information is collected so that when you visit the Site again, it will recognize you and serve advertisements and other information appropriate to your interests. We also use this information to verify that visitors to the Site meet the criteria required to process their requests. We do not treat Log Data as Personal Information, unless we use in association with Personal Information. If a WhoKnows subscriber chooses to install WhoKnows software (for example, the WhoKnows Discovery Engine), we may track Log Data for that subscriber’s general web activity in connection with providing the Services.

Cookies

Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your registration ID and login password for future logins to the Site. Second, we utilize session ID cookies to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage by WhoKnows Users and web traffic routing on the Site. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and Service and then close your browser. Third party advertisers on the Site may also place or read cookies on your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Service.

Emailing Via an WhoKnows Account

As part of the Service, WhoKnows subscribers may communicate with other WhoKnows subscribers and non-registered users through use of their accounts. Where WhoKnows subscribers have selected the option of adding one or more email addresses to an online form, the message they create in the corresponding template will be sent from WhoKnows to those email addresses on their behalf. These email addresses will be stored in the address book the WhoKnows subscriber creates and will be used only for the purpose of sending the email communication to the addressee.

Phishing

Identity theft and the practice currently known as “phishing” are of great concern to WhoKnows. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, social insurance number, social security number or any other national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

Information Sharing and Disclosure

WhoKnows Subscribers
When you register for the Service and submit your Personal Information to create a profile webpage, WhoKnows Users will see your “Screen Name” (“Required Subscriber Identifier”). You can choose what other Personal Information you provide as part of your profile (“Other Subscriber Information”) and in some cases you can choose whether to share that information publicly on the Site by making selections via the “user preferences” section of your profile webpage. Providing Other Subscriber Information is voluntary and should correlate with the degree of interaction you want to have with WhoKnows Users. The WhoKnows Service processes your information along with other data to generate an expertise profile about you that is shared automatically with other WhoKnows Users so they can contact you and collaborate with you more effectively. If you feel that any particular expertise added to your profile by the Service is not applicable, you are encouraged to remove it so you are not erroneously recommended to others. WhoKnows also partners with several communities, institutions and organizations with the intent to surface your expertise to those communities so you can be contacted accordingly.

Aggregate Information and Non-Identifying Information
We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

Service Providers
We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Site’s features) or to assist us in analyzing how our Site and Service are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Compliance with Laws and Law Enforcement
WhoKnows cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of WhoKnows or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

Business Transfers
WhoKnows may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Changing or Deleting Your Information

All subscribers may review, update, correct or delete the Personal Information in their registration profile by contacting us. If you completely delete all such information, then your account may become deactivated. If you would like us to delete your account in our system, please contact us at team@whoknows.com with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Security

WhoKnows is very concerned with safeguarding your information. We employ reasonable physical, technological, and administrative security measures and attempt to ensure they are applicable under the circumstances. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

International Transfer

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, WhoKnows transfers Personal Information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Links to Other Sites

Our Service may contain links to other websites. If you choose to visit an advertiser by “clicking on” a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party’s website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

Our Policy Towards Children

The Site and Service are not directed to persons under 18. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at team@whoknows.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.

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