PRIVACY
AND SECURITY POLICY
VERSION
1
EFFECTIVE DATE: August 20,
2007
This Privacy and Security Policy sets forth SPINE,
LLC’s (“SPINE,” “we,” “us,” or “our”) policy with respect to the Personal Data
that is collected from Users and Members of the Site and Services. All capitalized terms not defined herein shall
have the meaning attributed to them in the Terms
of Use.
By voluntarily providing us with your
Personal Data, you are consenting to our use of it in accordance with this
Privacy and Security Policy. If you
provide or authorize the provision of Personal Data to the Site, you
acknowledge and agree that such Personal Data may be transferred from your
current location to the offices and servers of SPINE and the authorized third
parties referred to herein located in the United States and in other countries.
Information That You Give Us. We collect Personal
Data from you when you browse the Site, participate in activities in the public
areas (e.g., bulletin boards), voluntarily choose to become a Member, use
certain Services at the Site, or contact us with comments or inquiries. We also may collect Personal Data about you
from your Authorized Designees and/or permit an Authorized Designee to access,
use, and modify your Personal Data, provided, however, that (i)
each Authorized Designee is a Member in good standing at the time of such
access, use, and/or modification, and (ii) you have previously consented to
access and use of your Personal Data by such Authorized Designee and granted
the Authorized Designee the right to modify your Personal Data.
Other Data.
Passively Collected Information:
When you interact with SPINE
through the Site, we receive and store certain personally non-identifiable
information. Such information, which is collected passively using various
technologies, cannot presently be used to specifically identify you. SPINE may
store such information itself or it may be included in databases owned and
maintained by SPINE’s affiliates, agents, or service providers. We may use such information and pool it with
other information to track, for example, the total number of visitors to the Site,
the number of visitors to each page of the Site, and the domain names of our
visitors’ Internet service providers. It
is important to note that no Personal Data is available or used in this
process.
Aggregated Personal Data: In an ongoing effort to better
understand our users, SPINE may analyze the Personal Data that is provided to
the Site in aggregate form. This
aggregate information does not identify you personally. SPINE may share this aggregate data with its
affiliates, agents, and business partners.
Cookies: In
operating the Site, we may use a technology called “cookies.” A cookie is a piece of information that the
computer that hosts our Site gives to your computer when you access the Site. Our cookies help provide additional
functionality to the Site and help us analyze Site usage more accurately. In all cases in which we use cookies, we will
not collect Personal Data except with your permission. On most web browsers, you will find a “help”
section on the toolbar. Please refer to this section for information on how to
receive notification when you are receiving a new cookie and how to turn
cookies off. We recommend that you leave
cookies turned on because they allow you to take advantage of some of the
Site’s features.
How We Use Personal Data. SPINE uses the Personal
Data you provide in a manner that is consistent with this Privacy and Security
Policy. If you provide Personal Data for
a certain reason, we may use the Personal Data in connection with the reason
for which it was provided. For instance, we will use the Personal Data
you input during the registration process to administer access to the Site, to
provide Services, and to respond to submissions made to the Site. If you have consented, we may disclose your
Personal Data to an Authorized Designee and/or permit such Authorized Designee
to access, use, and/or modify your Personal Data. We may use your Personal Data to send you a
newsletter or e-mail messages with updates and notices concerning new Content
posted to the Site and/or products or services that we think might be of
interest to you. SPINE also uses your
Personal Data and other personally non-identifiable information collected
through the Site to help us improve the Content and functionality of the Site
and to better understand the Members of our Site. SPINE may share aggregate data and aggregated
user statistics with other Members, its affiliates, agents, business partners, market analysts,
advertisers, sponsors, and to any other third parties. If SPINE intends on
using any Personal Data in any manner that is not consistent with this Privacy
and Security Policy, you will be informed of such anticipated use prior to or
at the time at which the Personal Data is collected.
Sharing of the
Information that We Receive. We may share your Personal Data with certain
third parties without additional notice including:
Agents, Consultants and Related Third Parties: SPINE, like many
businesses, sometimes hires other companies to perform certain business-related
functions. Examples include mailing
information, maintaining databases, and processing payments. When we employ another company to perform a
function of this nature, we only provide them with the information that they
need to perform their specific function.
Legal Requirements: SPINE may disclose your Personal Data if required to
do so by law or in the good faith belief that such action is necessary to (a)
comply with a legal obligation, (b) protect and defend the rights or property
of SPINE, (c) act in urgent circumstances to protect the personal safety of
users of the Site or the public, and (d) protect against legal liability.
Business Transfers: As we develop our business, we might sell or buy
businesses or assets. In the event of a
corporate sale, merger, reorganization, dissolution or similar event, Personal
Data may be part of the transferred assets.
Your Choices. As outlined in this
Privacy and Security Policy, you can always choose not to provide your Personal
Data to the Site; however, doing so may prevent you from obtaining certain
information or using other valuable Services.
Children. SPINE does not
knowingly collect personal data from children under the age of 13 through the Site.
If you are under 13, please do not give
us any Personal Data. We encourage
parents and legal guardians to monitor their children’s Internet usage and to
help enforce our Privacy and Security Policy by instructing their children to
never provide Personal Data on the Site without their permission. If you have reason to believe that a child
under the age of 13 has provided Personal Data to SPINE through the Site,
please contact us, and we will endeavor to delete that information from our
databases.
Links to Other Web
Sites.
This Privacy and Security Policy applies only to the Site and not to any
Third Party Sites or any Other SPINE Sites. We suggest contacting those sites directly for
information on their privacy, security, data collection, and distribution
policies.
Unsolicited
Information. This Privacy and
Security Policy shall not apply to any Unsolicited Information you provide to the
Site.
Security. We take commercially reasonable steps to
protect Personal Data provided to the Site and to protect such information from
loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security
system is impenetrable. We cannot
guarantee the security of our databases, nor can we guarantee that the Personal
Data you supply will not be intercepted while being transmitted to and from us
over the Internet. In particular, e-mail sent
to or from the Site may not be secure, and you should therefore take special
care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any
Personal Data to SPINE or to any other party via the Internet.
Other Terms and Conditions. Your access to
and use of the Site is subject to the Terms of Use which are hereby
incorporated by reference.
Changes to the Privacy and Security
Policy. We reserve the right to amend the Privacy and Security Policy at
any time and from time to time. We will
not reduce your rights under this Privacy and Security Policy without your
explicit consent, and we expect most such changes to be minor. Regardless, we will post any such amendments
on this page and, if the changes are significant, will provide a more prominent
notice (including, for certain services, e-mail notification of Privacy and
Security Policy changes). Each version
of this Privacy and Security Policy will be identified at the top of the page
by its effective date, and we will keep prior versions of this Privacy and
Security Policy in an ARCHIVE for your review.
How
to Contact Us. Please feel free to contact us if you have any questions
about this Privacy and Security Policy or the information practices of SPINE
with respect to Personal Data collected from the Site.
You may contact us as follows:
SPINE Office of Privacy and Security
PrivacyandSecurity@spinetpw.com