Effective Date – 1/1/2014

Tapstone Holdings, LLC (“Company”) and its wholly owned subsidiaries (collectively the “Company”) respect and value your privacy rights. Accordingly, the following policy (“Privacy Policy”) is specific for Company’s Ad Network wherein we provide technology for an advertising platform in which third party advertisers place ads for delivery by third party publishers. This Policy describes the information collected, stored and used, by Company derived from advertisers and publishers.

Information We Collect.

User Direct Information. Each time you provide or transmit information to our Company, we obtain and collect personal information about you, including, but not limited to, your name, email address, mailing address, social security number, credit card information, bank account information and telephone or mobile phone number(s) (collectively “personally identifiable information” or “PII”).

Survey Information. Company may collect PII when you voluntarily complete a Company survey, order form, or a registration page, either online (by using the Internet) or offline (by providing this information through the mail, in person or using a telephone).

Third Party Information. Company may collect PII from you when you provide information to a third party, and Company subsequently acquires or uses the information provided by that third party. Such information may include, but is not limited to, your name, email address, street address, zip code, telephone number(s) (including mobile phone number(s)), and such other information as you may have provided to the third party. When acquiring this information, Company seeks assurances from the third party that you agreed to provide such information and to such information subsequently being acquired by Company. If you did not give your express permission, or you would like to remove your permission, you may suppress all of your information by sending notification to us at unsubscribe@tapstone.com, or you may change your PII using your log in password.

Cookies, Web Beacons, and Other Information Collected Using Technology. Company currently uses cookie and Web beacon technology to associate certain Internet-related information about you with information held in its database. Additionally, Company may use other new and evolving sources of information in the future.

(a) Cookies. “Cookies” are a feature in your browser software. If enabled, cookies may store small amounts of data on your computer about your visit to any of the pages of websites owned and operated by Company (each a “website”). Cookies assist us in tracking which of our features appeal the most to you, and what content you may have viewed in past visits. When you visit a website again, cookies can enable us to customize our content according to your preferences. We may use cookies to keep track of the number of return visits to our website, accumulate and report aggregate statistical information on website usage, deliver specific content to you based on your interests or past viewing history, and save your password for ease of access to our website. You can disable cookies, although the website may not function properly for you. Your browser preferences can be modified to accept or reject all cookies, or request a notification when a cookie is set. You may read more about cookies at http://cookiecentral.com. In order to use all of the features and functionality of our Company’s websites, you need to accept cookies.

(b) Web Beacons. A Web beacon is a programming code that can be used to display an image on a Web page, but can also be used to transfer your unique user identification to a database and associate you with previously acquired information in that database. They are also known as “clear gifs,” “one-pixel gifs,” “Web bugs,” “Internet tags,” or “pixel tags.” This allows Company to track certain websites that you visit. Web beacons are used to track online behavioral habits for marketing purposes in order to determine which products or services you may be interested in. In addition to using Web beacons on Web pages, Company also uses Web beacons in email messages sent to individuals listed in Company’s database.

(c) IP Addresses. Company automatically tracks certain information based upon your behavior on our websites. We may use this information to do internal research on our users’ demographics, interests, and behavior, to better understand, protect and serve you and our community. This information may include the URL that you just came from (whether this URL is on our website or not), which URL you next go to (whether this URL is on our website or not), your computer browser information, and your IP address. Your Internet Protocol (“IP”) is a unique Internet “address” which is assigned to you by your Internet Service Provider (“ISP”). For Local Area Network (“LAN”), Dedicated Server Line (“DSL”), or cable modem users, an IP address may be permanently assigned to a particular computer. IP addresses are automatically logged by Web servers collecting information about a user’s traffic patterns. While the IP address does not identify an individual by name, it may, with the cooperation of the ISP, be used to locate and identify an individual using the Web. Your IP address can, however, reveal what geographic area you are connecting from, or which ISP you are using. Finally, other websites you visit have IP addresses, and we may collect the IP addresses of those websites and their pages.

(d) Computer Profiles. Company may also collect and accumulate other anonymous data which will help us understand and analyze the Internet experience of our visitors. For instance, Company may accumulate visitor data relating to referring domain names, the type of browsers used, operating system software, screen resolutions, color capabilities, browser plug-ins, language settings, cookie preferences, search engine keywords and JavaScript enablement. When you provide us with PII, we are able to use such visitor data to identify you.

(e) Data Analysis. Data analysis technology may be employed from time to time if used by a Business Client of Company.

No Information Collected from Children. Company will never knowingly collect any PII about children under the age of 13. If Company obtains actual knowledge that it has collected PII about a child under the age of 13, that information will be immediately deleted from its database. Because it does not collect such information, Company has no such information to use or to disclose to third parties.

How Information Is Used and Shared.

Disclosure of Information to Service Providers and Third Party Vendors. Company will disclose your PII to third party service providers and vendors in order to effect or carry out our contractual obligations with you. Company may share anonymous information with both publishers and advertisers to better their target advertising. This includes exchanging information collected from email service providers, providers of direct marketing services and applications, including lookup and reference, and data enhancement, suppression and validation services. We may share your personal information with companies that are directly or indirectly controlled by, or under common control, of Company. Company may also disclose your information to advertisers and publishers on our system.

Disclosure of Web Technology Information. Company uses and discloses information collected by cookies and Web technology between the parties for payment tracking purposes, and may also share and use PII, or a combination of PII and Non-PII, with its vendors to enhance your experience on the Network by allowing Company to save your preferences and passwords. Cookies may also measure the general activity on the website, which allows Company to determine which areas and features are most popular in order to make improvements to the website. Web beacons, also known as “clear gifs,” “one-pixel gifs,” “Web bugs,” “Internet tags,” or “pixel tags,” are used by Company and third parties to monitor the activity on our website or to make cookies more effective. We use log files to store the data that is collected through Web beacons.

Complying with Legal Process. Company will use or disclose your PII in response to subpoenas, court orders, warrants, or legal process, or to otherwise establish or exercise Company’s legal rights, or defend against legal claims, or in the event of a breach in an agreement with Company. Company will use and disclose your PII if Company believes that a user of this website, or a Business Client, will harm the property or rights of Company, its owners, or Company’s other customers. Finally, Company will use or disclose PII if it believes that it is necessary to investigate, prevent, or take action, regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of Company’s acceptable use policy.

Merger or Sale of Company. If Company sells, merges or otherwise reorganizes its business, Company reserves the right to transfer and disclose PII to the purchaser or investors, but will require such person or entity to govern the collection, storage and use of PII, by the same Privacy Policy that existed prior to any such business change, unless and until you consent to a new Privacy Policy.

Choices Regarding PII Use and Sharing.

As the only information we collect through our website is information we use to connect with you as a client, we do not provide an opt-out for information collected through our website. If you would like to be removed from our client database, please contact us at unsubscribe@tapstone.com. If you wish to review the PII related to you which has been collected by Company on our Network, please provide the request in writing to unsubscribe@tapstone.com. Company reserves the right to confirm the identity and association of the person requesting such information prior to any disclosure.

Privacy Practices of Third Parties.

Publisher Cookies and Web Beacons. Publishers who place advertisements on the Internet may use their own cookies, Web beacons and other technology to collect information. Company does not control publishers’ use of such technology. The publishers’ websites and email messages transmitted on behalf of publishers may contain hypertext links to the websites of third parties. Company is not responsible for the privacy practices or the content of such other websites.

Advertiser PII Collection, Cookies and Web Beacons. Advertisers using the platform will collect data from consumers responding to their advertisement, as well as use their own cookies, Web beacons and other technology to collect information. Company does not control advertisers’ use of such information or technology. The advertisers’ websites may contain hypertext links to the websites of third parties. Company is not responsible for the privacy practices or the content of such other websites.

Security.

We endeavor to safeguard and protect your information. We use redundant and robust servers to host internal data, which are also protected by high performance firewalls housed in one of the premium collocation services in California. Our Web frontend and application systems are user and password protected to prevent access from unauthorized users. Access restriction rules and policies by IP address and domain are also implemented on our high performance firewalls. Thus, when you submit information via the website, such information is protected both online and offline. The servers in which we store PII are kept in a secure physical environment. Company has security measures in place to protect against the loss, misuse, and alteration of personal information under our control. In addition, Company currently uses Secure Socket Layer software (“SSL”) to protect data and to secure any transactions. SSL encrypts information including credit card number(s), and names and addresses, as they are transmitted over the Internet. Please be advised that, although Company takes reasonable technological precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure; therefore, Company cannot and does not warrant that your information will be absolutely secure. Any transmission of data at or through our website(s) is at your own risk.

Do Not Call Waiver.

By registering via our website(s), or otherwise, for our services, you agree that such act constitutes an inquiry and/or application for the purposes of the Amended Telemarketing Sales Rule (16 CFR 310, et seq.), as amended from time to time, and other telemarketing laws such as the FCC rules. Notwithstanding that your telephone number(s) may be listed on the Federal Trade Commission’s Do-Not-Call List, we reserve the right to contact you via telemarketing in accordance with the Amended Telemarketing Sales Rule.

Changes to Privacy Policy.

We reserve the right to make material changes to the substance of this Privacy Policy. We will post those changes through a prominent notice on the website so that you will always know what information we gather, how we might use that information, and to whom we will disclose it.

California User Consumer Rights.

California Civil Code Section 1798.83 permits Californian residents who have provided PII to Company, or any third parties under an Email List Management Arrangement with Company, to request certain information regarding Company’s disclosure of such information to third parties for their direct marketing purposes. Within thirty (30) days of receiving such a request, we will provide a list of the categories of PII disclosed to third parties for third-party direct marketing purposes, during the immediately preceding calendar year, along with the names and addresses of such third parties. This request may be made no more than once per calendar year. In addition, California Residents have the right to know how we respond to their web browser “do not track” signals or other mechanisms. We do not respond to such signals or other mechanisms. We reserve our right not to respond to requests submitted other than to the address specified in this section. If you have any questions about this Policy, please contact us at privacy@tapstone.com or in writing at:

Tapstone Holdings, LLC
9777 Wilshire Blvd. #1000
Beverly Hills, CA 90212
Email: privacy@tapstone.com
Facsimile: 310.943.3339