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Friend2Friend Privacy Policy

Last Updated: February 8, 2016

Friend2Friend (“Friend2Friend”) provides an advanced social engagement technology platform (the “Platform”) that enables online marketers (“Customer”) to build, maintain, access, and manage customizable social engagement applications and experiences (each an “App”). This Privacy Policy describes the types of information collected by Friend2Friend in connection with a Customer’s use of the Platform.

In addition to this Privacy Policy, access to and use of the Platform is governed by our Terms of Use and any other applicable agreement between a Customer and Friend2Friend, all of which are incorporated herein by reference as applicable (collectively, the “Friend2Friend Agreements”). For example, Friend2Friend may offer sweepstakes, reward points or other contests of skill on the Platform that are subject to “Official Rules.” Official Rules are a type of Friend2Friend Agreements. If there is any conflict between the terms of this Privacy Policy and the Friend2Friend Agreements, the Friend2Friend Agreements take precedent in relation to that activity promoted by Friend2Friend (“Activity”). Before you participate in any Activity or earn any type of rewards, you should always read the Official Rules.

Special Note to Customers

This Privacy Policy describes how Friend2Friend collects, uses and discloses information provided to Friend2Friend by Customers. If you are a third party user of an App , your information is governed by the Privacy Notice published by the applicable Customer. If you have a complaint regarding an App or believe that an App is collecting information about you without obtaining your consent, you should submit a complaint to the address listed below.

Customer Registration

When you sign up for an account with Friend2Friend as a Customer, Friend2Friend collects the following information (“Customer Data”):

  • Business name
  • App URL
  • Business mailing and email addresses
  • Legal name and contact information of Customer
  • Other personally identifiable information that may be required

Usage Information

When Customers use the Platform or when Users use an App, Friend2Friend may collect certain non-personally identifiable information (“Usage Information”) including:

  • IP address
  • The date and time of use

We may also use certain standard web measurement and tracking technologies such as “cookies”, web server logs, or other statistics programs to collect Usage Information and track and record how you use the Platform or how users use specific Apps. Finally, we may monitor aggregate activity through Apps that takes place on the Platform. We do not identify individual users, but rather track activity that takes place through Apps and information about Customers (for example, we may track the popularity of certain Apps, or the activity of a certain type of Customer). We may also compile data about the types, number, amount, or categories of Customers using the Platform. Collectively, the type of data about Customer activity and App performance described in this paragraph is all referred to as “Customer Data”.

Disclosure of information

Friend2Friend may use third party partners to help us manage the Platform, and we may share your information with those third party partners, consultants and other service providers (“Partners”) who work for us and need to access your information to perform that work. Friend2Friend discloses only the Customer Data that is reasonably necessary for our Partners to perform the tasks they have been assigned, and all Partners are required to adhere to this privacy policy. However, Friend2Friend may also disclose Customer Data to unrelated third-parties for any business reason of Friend2Friend, provided that such Customer Data does not identify any individual Customer. By registering for a Customer Account, each Customer that uses the Platform expressly authorizes Friend2Friend to share information with these third parties for any purpose related to Friend2Friend’s business.

Friend2Friend may also disclose the information it collects: (a) when we have reason to believe that such disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, Customers, or other users of any App or the Platform, or anyone else who could be harmed by such activities, or is appropriate or necessary to enforce any Friend2Friend Agreement, take precautions against liability, investigate and defend against any third-party claims or allegations, and/or protect the security or integrity of the Platform or any App; (b) to respond to judicial process and provide information to law enforcement agencies in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law, or in the good-faith belief that such action is necessary to comply with state and federal laws; (c) to our business partners for research, analytical and marketing purposes, and/or to our subsidiaries, affiliated companies, or other businesses or persons for the purpose of processing any request on your behalf; or (d) otherwise with the applicable Customer’s consent.

Friend2Friend may buy or be bought by other businesses or entities. In such event, Friend2Friend may transfer or assign the information we have collected as part of such merger, acquisition, sale, or other change of control. In such transactions, your information, including all account information and any personally identifiable information collected by Friend2Friend, may be included in the transferred business assets. Also, in the unlikely event of Friend2Friend’s bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, Friend2Friend may not be able to control how your information is treated, transferred, or used and your information may be included in the transferred assets.

Friend2Friend may use this information to (i) operate and improve our Platform, products and services; (ii) understand our customers and their preferences to enhance their experience using our Platform, products, and services; (iii) process and deliver contest entries and rewards; (iv) respond to comments and questions and provide customer service; (v) to send our customers related information, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages; and (vi) communicate with our customers about new contests, promotions, rewards, upcoming events, and other news about products and services offered by Friend2Friend and our selected partners.

Under the laws of some jurisdictions, you may be entitled to request disclosure regarding how we share your Usage Information with third parties for direct marketing purposes (“Information-Sharing Disclosure”). To the extent required by applicable law, we shall provide the Information-Sharing Disclosure to you upon rightful request made in writing to Friend2Friend, Inc.

Security Procedures

Friend2Friend takes commercially reasonable precautions to protect against the risks of unauthorized access to, erroneous disclosure of, and unlawful interception of information submitted via the Platform. However, email transmissions and/or other communications may be unlawfully intercepted or accessed by third parties and/or the Platform may be subject to hostile network attacks or administrative errors. Friend2Friend cannot and does not guarantee the security of any information transmitted over the Internet.

Consent to Worldwide Transfer and Processing of Personal Information

By using the Platform, you agree and acknowledge that the Platform and Friend2Friend databases may be hosted in the United States. If you are attempting to access or use the Platform from a physical location within the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that you may be transferring your Customer Data to the United States and you consent to (a) such transfer, (b) the application of the laws of the United States and/or the State of Massachusetts with respect to any dispute, other than such rules, regulations, case law, and/or international treaties that would result in the application of the laws of a jurisdiction other than the United States or the State of Delaware. Any claim or dispute between you and Friend2Friend that arises in whole or in part from your use of the Website, Network, or Platform or in connection with this Privacy Policy shall be decided exclusively by a court of competent jurisdiction located in the State of Delaware, USA. You submit to the jurisdiction and venue of such courts and waive any objection based on inconvenient forum. Notwithstanding the foregoing, you agree that as a cloud based service, Friend2Friend may process your information in any country in which Friend2Friend operates or offers the Platform. You further agree that although each of these countries has a set of privacy laws that may differ from those in the U.S., Friend2Friend shall only be obligated to treat the privacy of your Customer Data in accordance with this Privacy Policy, regardless of the laws in place in these countries. By providing your information to Friend2Friend, you consent to the transmission to, and processing of your information in, any jurisdiction, in accordance with this Privacy Policy.

Changes and updates to the Privacy Policy

From time to time, we may revise the Privacy Policy. To help you stay current of any changes, Friend2Friend notes the date the Privacy Policy was last updated above. Your use of the Platform following the posting of any revised Privacy Policy shall be deemed acceptance of the revised policy.


If any part of the Privacy Policy is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of the Privacy Policy shall continue in force and effect.

Questions or Comments

If you have any questions or comments regarding our privacy practices, you may contact us at: Attention: Privacy Officer, Friend2Friend, Inc., PO Box 352, Mountain View, CA 94042, or e-mail: privacy (@)

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