Effective as of: September 24, 2008.

Close Ties Principles

We built Close Ties to make it easy to share information with your family and closest friends. We understand you may not want everyone in the world to have the information you share on Close Ties; that is why we give you control of your information. Our privacy system limits the information displayed in your profile to your confirmed family and friends.

Close Ties helps you share information with those people you have confirmed relationships with. You choose what information you put in your profile, including contact and personal information, pictures, recipes and stories. And you control the users with whom you share that information through Circles of Trust that you manage here.

Sharing information should be easy. And we want to provide you with the privacy tools necessary to control how and with whom you share that information. If you have questions or ideas, please send them to .

Close Ties's Privacy Policy

Close Ties's Privacy Policy is designed to help you understand how we collect and use the personal information you decide to share, and help you make informed decisions when using Close Ties, located at www.closeties.com and its directly associated domains (collectively, "Close Ties" or "Website").

By using or accessing Close Ties, you are accepting the practices described in this Privacy Policy.

The Information We Collect

When you visit Close Ties 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 you register with Close Ties, you provide us with certain personal information, such as your name, your email address, your telephone number, your address, your gender, schools attended and any other personal or preference information that you provide to us.

When you enter Close Ties, we collect your browser type and IP address. This information is gathered for all Close Ties 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 Close Ties. You can remove or block this cookie using the settings in your browser if you want to disable this convenience feature.

When you use Close Ties, you may set up your personal profile, form relationships, send messages, perform searches and queries, form groups, set up events, add applications, 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 relations. When you update information, we usually keep a backup copy of the prior version for a reasonable period of time to enable reversion to the prior version of that information.

You post User Content (as defined in the Close Ties Terms of Use) 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 impenetrable. 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 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 cached and archived pages or if other Users have copied or stored your User Content.

Any improper collection or misuse of information provided on Close Ties is a violation of the Close Ties Terms of Service and should be reported to .

Close Ties may also collect information about you from other sources, such as newspapers, blogs, instant messaging services, and other users of the Close Ties service through the operation of the service (e.g., photo ids) in order to provide you with more useful information and a more personalized experience.

By using Close Ties, you are consenting to have your personal data transferred to and processed in the United States.

Children Under Age 13

Close Ties does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register. If you are under 13, please do not attempt to register for Close Ties or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any personal information to or on Close Ties. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at .

Children Between the Ages of 13 and 18

We recommend that minors over the age of 13 ask their parents for permission before sending any information about themselves to anyone over the Internet.

Use of Information Obtained by Close Ties

When you register with Close Ties, you create your own profile and privacy settings. Your profile information, as well as your name, email and photo, are displayed to people in your circles of trust specified in your privacy settings to enable you to connect with people on Close Ties. We may occasionally use your name and email address to send you notifications regarding new services offered by Close Ties that we think you may find valuable.

Profile information is used by Close Ties 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.

Profile information you submit to Close Ties will only be available to users of Close Ties with whom you have confirmed relationships with and that you have shared with through your circles of trust.

Close Ties may send you service-related announcements from time to time through the general operation of the service.

Generally, you may opt out of such emails here, though Close Ties reserves the right to send you notices about your account even if you opt out of all voluntary email notifications.

Close Ties may use information in your profile without identifying you as an individual to third parties. We do this for purposes such as aggregating how many people have a simalar interest and personalizing advertisements and promotions so that we can provide you a tailored experience. We believe this benefits you. You can know more about the world around you and, where there are advertisements, they're more likely to be interesting to you.

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 Close Ties and other users of Close Ties, to supplement your profile. Where such information is used, we generally 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 your profile (e.g., removing photo id links).

Sharing Your Information with Third Parties

Close Ties is about sharing information with with your family and closest friends. We allow you to choose the information you provide to confirmed relations through Close Ties. Our network architecture 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 party marketers without your permission. We share your information with third parties only in limited circumstances where we believe such sharing is 1) reasonably necessary to offer the service, 2) legally required or, 3) permitted by you. For example:

• Your news feed may aggregate the information you provide and make it available to your friends and family members according to your privacy settings.
• Unlike most sites on the Web, Close Ties limits access to site information by third party search engine "crawlers" (e.g. Google, Yahoo, MSN, Ask). Close Ties takes action to block access by these engines to your personal information.
• We may provide information to service providers to help us bring you the services we offer. 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 Close Ties, to remove repetitive information from our user lists, to process payments for products or services, to offer an online job application process, or to provide search results or links (including sponsored links). In connection with these offerings and business 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 implement reasonable contractual and technical protections limiting the use of that information to the Close Ties-specified purposes.
• We occasionally provide demonstration accounts that allow non-users a glimpse into the Close Ties world. Such accounts have only limited capabilities (e.g., messaging is disabled) and passwords are changed regularly to limit possible misuse.
• 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 until 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 Close Ties service or using the Close Ties name, or to prevent imminent bodily harm. This may include sharing information with other companies, lawyers, agents or government agencies.
• We let you choose to share information with marketers or electronic commerce providers through sponsored groups or other on-site offers.
• We may offer stores or provide services jointly with other companies on Close Ties. You can tell when another company is involved in any store or service provided on Close Ties, and we may share customer information with that company in connection with your use of that store or service.
• If the ownership of all or substantially all of the Close Ties business, or individual business units owned by Close Ties, 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 Close Ties, certain information you post or share with third parties (e.g., a friend or someone in your family), such as personal information, comments, messages, photos, videos, Marketplace listings or other information, 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, photos, videos, Marketplace listings or other items , this information may become publicly available.

Links

Close Ties may contain links to other websites. We are of course not responsible for the privacy practices of other web sites. We encourage our users to be aware when they leave our site to read the privacy statements of each and every web site that collects personally identifiable information. This Privacy Policy applies solely to information collected by Close Ties.

Third Party Advertising

Advertisements that appear on Close Ties are sometimes delivered (or "served") directly to users by third party advertisers. They automatically receive your IP address when this happens. 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 advertising content. In this way, they may compile information about where individuals using your computer or browser saw their advertisements and determine which advertisements are clicked. Close Ties 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 Close Ties unless you choose to share it with them.

This privacy policy covers the use of cookies by Close Ties 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 most personal information on Close Ties is readily available through the profile editing tools. Close Ties 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 Close Ties account may do so on the My Account page. Removed information may persist in backup copies for a reasonable period of time but will not be generally available to members of Close Ties.

Where you make use of the communication features of the service to share information with other individuals on Close Ties, however, (e.g., sending a personal message to another Close Ties user) you generally cannot remove such communications.

Security

Close Ties takes appropriate precautions to protect our users' information. Your account information is located on a secured server behind a firewall. When you enter sensitive information (such as credit card number or your password), we encrypt that information using secure socket layer technology (SSL). (To learn more about SSL, go to http://en.wikipedia.org/wiki/Secure_Sockets_Layer). Because email and instant messaging are not recognized as secure communications, we request that you not send private information to us by email or instant messaging services. If you have any questions about the security of Close Ties Web Site, please contact us at .

Terms of Use, Notices and Revisions

Your use of Close Ties, and any disputes arising from it, is subject to this Privacy Policy as well as our Terms of Use and all of its dispute resolution provisions including arbitration, limitation on damages and choice of law. We reserve the right to change our Privacy Policy and our Terms of Use at any time. Non-material changes and clarifications will take effect immediately, and material changes will take effect within 30 days of their posting on this site. If we make changes, we will post them and will indicate at the top of this page the policy's new effective date. If we make material changes to this policy, we will notify you here, by email, or through notice on our home page. We encourage you to refer to this policy on an ongoing basis so that you understand our current privacy policy. Unless stated otherwise, our current privacy policy applies to all information that we have about you and your account.

Contacting the Web Site

If you have any questions about this privacy policy, please contact us at . You may also contact us by mail at: