Privacy Policy

Effective Date: November 17^th, 2007

Please be advised that BeenVerified™ DOES NOT rent or sell to, or share your personal information with, unaffiliated third parties for marketing purposes.

BeenVerified™ is a licensee of the TRUSTe Web Privacy Seal Program. TRUSTe is an independent, non-profit organization whose mission is to build user’s trust and confidence in the Internet by promoting the use of fair information practices. This privacy statement covers the Web site http://www.BeenVerified.com. Because this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

If you have questions or concerns regarding this statement, you should first contact Ross Cohen at ross@beenverified.com. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with us to resolve your concerns.

Thank you for visiting the website located at www.BeenVerified.com (“Site”). The Site is an Internet property of SnapGenius, LLC (“BeenVerified™,” “we” or “us”). BeenVerified™ has created this privacy policy (“Privacy Policy”) in order to disclose our information gathering and dissemination practices. We understand the importance that Internet users place on privacy and have designed our Site with this in mind. While the Site remains available to end-user visitors without any registration requirements (“Non-Registered Users”), in order to utilize some of the Site’s enhanced features, interested parties must either: (a) register as a browser (“Registered Browser”) by filling out the applicable registration forms (“Browser Registration”) which enables you to browse the Verified Profiles (as defined in BeenVerified™ Website Terms and Conditions (“Terms and Conditions”) made available on the Site and access the various Registered Browser-based services detailed below (“Browser Services”); or (b) register as a BeenVerified™ member (“Verified Member” and together with the Registered Browsers, “Registered Users”) by filling out the applicable registration forms (“Member Registration” and, together with the Browser Registration, the “Registration Forms”), which enables you to utilize a host of services made available to Verified Members by and through the Site (“Member Services”) as described in the BeenVerified™ Verified Member Agreement (“VM Agreement”). In order to complete the Registration Forms, applicants must supply certain personally identifiable information. None of the information that we gather can be used by the public to identify specific individuals. We are an optional service. We collect credit card, address, bank and/or other personal information only from those individuals/entities that choose to participate. Because we offer a variety of services to distinct users, our Privacy Policy contains two (2) separate sets of terms and conditions: one for our Non-Registered Users and one for our Registered Users.

BEENVERIFIED™ IS NOT A CREDIT REPORTING AGENCY FOR PURPOSES OF THE FAIR CREDIT REPORTING ACT (“FCRA”). AS SUCH, THE ADDITIONAL PROTECTIONS AFFORDED TO CONSUMERS, AND OBLIGATIONS PLACED UPON CREDIT REPORTING AGENCIES, ARE NOT CONTEMPLATED BY, NOR CONTAINED WITHIN, THIS PRIVACY POLICY.

I. Non-Registered Users

Information Collected/Tracked by BeenVerified™

As a general rule, BeenVerified™ does not request or collect any personally identifiable information directly from Non-Registered Users.

We gather Non-Registered Users’ server, IP address and browser-type related information as part of the general administration of the Site (“Site Data”). This Site Data is comprised of the demographic, usage and/or other characteristics of Site visitors as a group without any associated personally identifiable information. BeenVerified™ uses third party software for the purpose of tracking, aggregating, storing said non-registered user data.

When a Non-Registered User visits the Site, we send a cookie and/or gif file (“Cookie”) to assign an anonymous, unique identifier to the applicable Non-Registered User’s Internet browser. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. To disable and reject certain Cookies, please reference above website for specific browser disabling information. Even in the case where a user rejects a Cookie, he or she may still use the Site. BeenVerified™ reserves the right to retain Cookie data indefinitely.

Use of Information Obtained by BeenVerified™

As a general rule, BeenVerified™ does not collect any personally identifiable information from Non-Registered Users. BeenVerified™ reserves the right to release current or past Site Data: (a) in the event that we believe that the Site is being or has been used in violation of this Privacy Policy, the Terms and Conditions, the VM Agreement or to commit unlawful acts; (b) if the information is subpoenaed; or (c) if BeenVerified™ is sold or acquired. While BeenVerified™ strongly encourages clients, affiliates and partners to adopt responsible approaches to online marketing, BeenVerified™ is not responsible for the information practices of its clients, affiliates and/or partners. The collection, use and disclosure of information by clients, affiliates and/or partners is subject to their respective privacy policies, which may differ from the Privacy Policy. BeenVerified™ reserves the right to use all Site Data associated with Non-Registered Users to investigate fraudulent or other claims made against BeenVerified™.

If you use a bulletin board, blog,or chat room on this Web site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums.

Changes in our Privacy Policy

If we change our Privacy Policy, we will prominently post a link to those changes on our Site’s homepage so that our Non-Registered Users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page.
The Non-Registered User’s continued use of the Site after posting of the Privacy Policy change on the Site, or receipt of a Privacy Policy change notification e-mail, as applicable, constitutes an affirmative acknowledgement and acceptance by the Non-Registered User of the modified Privacy Policy.

II. Registered Users

Information Collected/Tracked by BeenVerified™

BeenVerified™ gathers two types of information from Registered Users: information that Registered Users submit to us and information that is not directly submitted to us.

Information Submitted to BeenVerified™

To accomplish our goal of bringing Registered Browsers and Verified Members together, we must gather personal information from all Registered Browsers and Verified Members through the applicable Registration Forms. The Browser Registration may or may not require submission of the following information: (a) e-mail address; (b) full name; (c) company name; (d) date of birth; (e) a Verified Member-specified password; (f) mailing address; and (g) telephone number. The Member Registration may or may not require submission of the following information: (i) e-mail address; (ii) full name; (iii) company name; (iv) date of birth; (v) credit card information; (vi) mailing address; (vii) telephone number; (viii) employment history; (ix) employment status; (x) industry of employment; (xi) salary; (xii) credit score; (xiii) education level/degrees; (xiv) schools attended/years; (xv) professional licenses; (xvi) Social Security Number; and (xvii) any additional information required by the applicable Credential Profile or Identity Profile (as those terms are defined in the Terms and Conditions). Further, where the prospective Verified Member resides outside of the United States, the Member Registration may require “International Identity Verification” which requires the submission of a copy of one (1) of the following primary identification documents: (1) passport with photo and signature; (2) driver’s license with photo and signature; (3) state identification issued by a qualifying motor vehicle agency with photo and signature; (4) qualifying national identification card with photo and signature; or (5) qualifying military identification card with photo and signature; and one of the following secondary identification documents: (A) qualifying telephone bill; (B) qualifying utility bill; (C) qualifying cable or television bill; (D) bank statement; or (E) mortgage statement.

Information not Directly Submitted by Registered Users to BeenVerified™

We gather Registered Users’ server, IP address, browser-type, clicks, impressions and other traffic and/or consumer action related information in connection with the general administration of the Site (“Site Data”). BeenVerified™ reserves the right to transfer and/or sell Site Data about Registered Users for lawful purposes. The Site Data is comprised of the demographic, usage and/or other characteristics of Registered Users as a group. BeenVerified™ uses third party software for the purpose of tracking, aggregating, storing said registered user data. By using the Site you agree to allow BeenVerified™ to transfer and/or sell such aggregate data to third parties.

When a Registered User visits the Site, we send a cookie and/or gif file (“Cookie”) to assign an anonymous, unique identifier to the applicable Registered User’s Internet browser. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. To disable and reject certain Cookies, please reference above website for specific browser disabling information. Even in the case where a user rejects a Cookie, he or she may still use the Site. BeenVerified™ reserves the right to retain Cookie data indefinitely.

If you use a bulletin board, blog,or chat room on this Web site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums.

Use of Information Obtained by BeenVerified™

Sharing of the Information Gathered/Tracked by the Site

Any personal information that you submit at the Site remains your property. However, by submitting that information to us, you grant to us the right to use your personal information, subject to applicable state and federal law, in the ways set forth herein. Other than as set forth herein to the contrary, all personally identifiable information that BeenVerified™ collects from Registered Users is intended for administrative needs (e.g., billing, communication of account information), for which purpose such data is required.

In connection with providing the Credential Profiles and/or Identity Profiles, BeenVerified™ may share your personal information with certain third party companies for the sole and exclusive purpose of verifying the subject information applicable to the particular Credential Profile and/or Identity Profile. These third party companies shall be under an obligation of confidentiality regarding such information, and shall not themselves store, save or transfer such information other than as necessary to perform the applicable verification services.

BeenVerified™ may use e-mail addresses of Registered Users in its own database (“BeenVerified™ Database”). BeenVerified™ reserves the right to contact individuals in the BeenVerified™ Database via e-mail with information regarding the Site and associated BeenVerified™ Services (as defined in the Terms and Conditions).

Upon request, and in BeenVerified’s™ sole discretion, BeenVerified™ may contact Verified Members in the BeenVerified™ Database via e-mail on behalf of certain Registered Browsers (“Browser E-mail”) for the sole and exclusive purpose of enabling such Registered Browsers to contact the Verified Member in connection with a request to view that Verified Member’s Verified Profile. The target Verified Member receiving the Browser E-mail will have access to the applicable Registered Browser’s e-mail address; provided, however, that BeenVerified™ will not share the Verified Member’s e-mail addresses contained in the BeenVerified™ Database with such Registered Browsers. The Browser E-mail contain(s) comments, opinions, solicitations, information and other content that is provided directly by Registered Browsers. BeenVerified™ shall have no obligations and incur no liabilities to Verified Members in connection with any such comments, opinions, solicitations, information and other content appearing within the Browser E-mails. BeenVerified™ does not represent or warrant that the comments, opinions, solicitations, information and other content and other content posted in the Browser E-mails is accurate, complete or appropriate.

In addition, Verified Members may elect to make all or some of their Verified Profiles available on the Site for viewing by all site visitors and Registered Browsers (“General Display”). Where Verified Member has opted to make its Verified Profiles available via any form of General Display, BeenVerified™ shall make the associated personal information contained in the subject Verified Profiles available as applicable.

Any subsequent contact with such Registered Browsers shall be in the applicable Verified Members’ sole discretion. The collection, use and disclosure of information by Registered Browsers, clients, affiliates and partners of BeenVerified™ is subject to their respective privacy policies, which may differ from this Privacy Policy. While BeenVerified™ strongly encourages Registered Browsers to adopt responsible approaches to online communication, marketing and other practices, BeenVerified™ is not responsible for the conduct of Registered Browsers or their partners.

Except as may be otherwise agreed between BeenVerified™ and a Registered User, and as otherwise set forth herein to the contrary, all personally identifiable information provided by individual Registered Users will be kept in strict confidence by BeenVerified™ and will be treated with the same level of confidentiality that it treats other proprietary information and trade secrets. BeenVerified™ will never sell, rent, exchange or barter any personally identifiable Registered User information to or with any third party for financial gain or marketing purposes.

Notwithstanding the foregoing, BeenVerified™ may share personally identifiable information in connection with its affiliated entities or in connection with the sale, merger, consolidation, change in control, transfer of substantial assets or reorganization or liquidation of BeenVerified™. BeenVerified™ may release account and any other personally identifiable information when we believe release is appropriate to: (a) respond to a subpoena or otherwise comply with the law; (b) enforce or apply this Privacy Policy, the VM Agreement, the Terms and Conditions and other agreements; and/or (c) protect the rights, property or safety of BeenVerified™ or others. This includes exchanging information with other companies and organizations for fraud protection.

To the extent that BeenVerified™ collects your credit card-specific information, if ever, we will use the information to process and complete any transaction that you request. By submitting your credit card information to us, you authorize BeenVerified™ to periodically verify that your credit card account continues to be a valid and active one by charging, and thereafter immediately crediting, a small sum to the card. Such verification may be conducted through a third-party and, in that case, BeenVerified™ would share your specific credit card information with this third-party for verification purposes. Apart from said uses, we will not share your credit card information with any third parties without your prior informed consent. Notwithstanding the foregoing, BeenVerified™ reserves the right to share with third parties the fact that we have credit card information on file for specific users, but we will not share your specific credit card information with third-parties without your prior informed consent.

Correcting/Updating or Removing Information

BeenVerified™ provides Registered Users with several options for modifying or removing their information from our database. Verified Members may remove any Verified Profiles appearing on the Site at any time, or revoke any Profile Display Privileges (as that term is defined in the Terms and Conditions) upon prior written notice to BeenVerified™. Please visit the link http://www.beenverified.com/user/personal_info or contact us at help@beenverified.com for an explanation.

Changes in Our Privacy Policy

If we change our Privacy Policy, we will prominently post a link to those changes on our Site’s homepage so that our Registered Users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page. The Registered User’s continued use of the applicable BeenVerified™ service, Site and/or continued receipt of BeenVerified™ e-mails after posting of the Privacy Policy change on the Site, or receipt of a Privacy Policy change notification e-mail, as applicable, constitutes an affirmative acknowledgment and acceptance by the Registered User of the modified Privacy Policy.

Security

BeenVerified™ takes every precaution to protect our Registered Users’ and non-Registered Users’ information. BeenVerified™ regularly reviews, at least once per year, its security practices to identify security threats or opportunities for improvement. When Registered Users submit sensitive information via the Site, we endeavor to keep this information protected both online and off-line. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information that you transmit to us, and you do so at your own risk.

When we ask Registered Users to enter sensitive information (such as a credit card number, Social Security Number, credit score, etc.), and when such information is stored and/or transmitted, that information is encrypted and is protected with SSL encryption software. While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect sensitive and non-sensitive information off-line. All of the information that we collect, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example a billing clerk or a customer service representative) are granted access to personally identifiable information. All such employees are contractually bound to adhere to our security protocols, which they must verify that they have read and understand. The practices for handling sensitive information are disseminated to all of our employees. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage and to engage in remedial measures.

If you have any questions about the security related to the Site, please contact us at help@beenverified.com.

E-mail Choice/Opt-out

Registered Users who no longer wish to receive our notification e-mails or newsletters may opt-out of receiving these communications by contacting us at admin@beenverified.com

III. General Provisions

Links

The Site contains links to other websites. Please be aware that BeenVerified™ is not responsible for the privacy practices of other websites. We encourage our Registered and Non-Registered Users to be aware when they leave the Site and to read the privacy policies of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by the Site.

Children’s Privacy

BeenVerified™ is very sensitive to the issue of children’s privacy and, therefore, we endeavor to protect the privacy of children using the Internet. The Site, as well as its products and services, are not developed for or directed at children. Visitors under eighteen (18) years of age are not eligible to do business with us and we do not knowingly solicit or collect personal information from any person that we actually know is under the age of eighteen (18). BeenVerified™ encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children. If you believe that your child has provided BeenVerified™ with any personally identifiable information, please e-mail admin@BeenVerified.com to have this information removed.

Contacting the Site

If you have any questions about this Privacy Policy, the practices of the Site, or your dealings with the Site, please contact us at admin@beenverified.com,

Mailing Address:

BeenVerified.com

236 5th Ave. 9th Floor

New York, NY 10016