OnTrade Travel LLC, http://www.ontrade.com, Effective May 17, 2011

OnTrade Travel, LLC, 4944 South Le Jeune, Suite 101, Coral Gables, Florida 33146 USA

Privacy Policy

1. Personal information collected

We collect information:

• When you register an account to become an OnTrade user ("User"), such as your name, e-mail, country, location, occupation and a password.
• When you add to your profile with further information about yourself or your private contacts.
• We use cookies and other technologies to recognize you, customize your experience and serve advertisements.
• We automatically receive from your internet use such information as your IP address, the URLs of sites from which you arrive or leave the OnTrade website, your type of browser and your ISP.

2. Uses of personal information

We use the information you provide to:

• Administer your account with us and customize the service we provide to you.
• To send you service or promotional communications through email and notices on the OnTrade website.
• We do not sell, rent or otherwise provide your personal identifiable information to any third parties for marketing purposes.
• We provide you with the means to control whether or not your contact information is shared with another User.
• In order to deliver our services, we may share information with third parties. For example, to process subscription payments made by you, we share some of your information with the credit card processing company we use.
• Enable you to share your information and communicate with other Users, or provide (usually at your option) your personal details to third parties offering combined services with OnTrade.

3. Your information choices

You can:

• Review, enhance or edit your personal information through your personal profile page.
• Choose what information you make available through your public profile.
• Control the messages you receive from OnTrade and other Users and how these messages are sent.
• Change your settings to control visibility and accessibility through our website.
• Tell us to close your OnTrade account.

4. Important information

• OnTrade is a licensee of TRUSTe (?), an organization established to promote fair information practices. We have agreed to disclose our privacy practices and have them reviewed by TRUSTe. If we cannot resolve your privacy queries you can raise your complaint with TRUSTe (?).
• Notice of all changes that materially affect ways in which your personal information may be used or shared will be posted in updates to our Privacy Policy.

5. Security

Personal information you provide will be secured with industry standards and technology.

6. How to contact us

If you have any questions or comments please email us at privacy@OnTrade.com or contact us at:
OnTrade Travel LLC
Attn: Privacy Policy Issues
4944 South Le Jeune
Suite 101
Coral Gables, Florida 33146

Your privacy is our top concern. We work hard to earn and keep your trust, so we adhere to the following principles to protect your privacy:

• We do not rent or sell your personally identifiable information to third parties for marketing purposes without your explicit consent.
• We do not share your contact information with another User without your consent.
• Any personally identifiable information that you provide will be secured with industry standard protocols and technology.
• We store and process your information on computers located in the United States that are protected by physical as well as technological security devices.

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. By continuing to use the OnTrade service after notice of changes have been sent to you or published on the OnTrade website, you are consenting to the changes.

Please read this privacy policy to learn more about:

1. What personally identifiable information of yours is collected by OnTrade.
2. How the information is used.
3. With whom the information may be shared.
4. How you can access and change your Account settings.
5. What security procedures are in place to protect the loss, misuse or alteration of information collected by OnTrade.
6. How to contact us.

1. Personal Information Collected

The purpose of the OnTrade website is to permit Users to voluntarily provide information about themselves and Companies where they work for the purposes of developing, maintaining and enhancing a network of professional contacts. You willingly provide us certain personal information, which we collect in order to allow you to benefit from the OnTrade website. If you have any hesitation about providing such information to us and/or having such information displayed on the OnTrade website or otherwise used in any manner permitted in this Privacy Policy and the User Agreement, you should not become a member of the OnTrade community.

We collect your personal information in the following ways:

Registration

In order to become a User, you must first create an account on our website. To create an account you are required to provide the following contact information, which you recognize and expressly acknowledge is personal information allowing others, including OnTrade, to identify you: name, email address, country, ZIP/postal code, a brief summary of the organization you work for, and a password chosen by you.

Profile Information

Once you become a User, you may provide additional information in the Profile section describing your company, your professional experience, and networking objectives. Providing additional information beyond what is required at registration to become a User is entirely optional, but enables you to better identify yourself and find new networking and business opportunities in the OnTrade system. Any information you provide at registration or in the Profile section that is not personally identifiable may be used in the same manner and extent to which other information that is not personally identifiable is permitted to be used hereunder, including for the purpose of serving advertisements through the service. If you opt-out you may lose the potential benefit of being a User, including receiving ads that are more targeted to your interests.

Contacts Information

In order to invite others to connect with you directly in OnTrade, you may use the OnTrade services to invite them if they are a User, or enter their names and email addresses. This information will be used by OnTrade to send your invitation including a message that you write. The names and email addresses of people that you invite will be used only to send your invitation and reminders.

You may also choose to manually enter or upload data about your contacts into the private "My contacts" section of the OnTrade website. You may not invite anyone to connect with you whom you do not know. All information entered there will only be viewable by you and will not be searchable by others in the OnTrade network without your permission. All information that you enter or upload about your contacts will be covered by the same terms of this privacy policy as cover your own information.

Customer Service

OnTrade may collect information through the OnTrade website or through the Customer Service website in order to, among other things, accurately categorize and respond to a customer's inquiry and deliver appropriate service levels.

Cookies

Like most websites, OnTrade uses cookies and web log files to track site usage. A cookie is a tiny data file which resides on your computer which allows OnTrade to recognize you as a User when you return to the OnTrade website using the same computer and web browser. If your browser settings do not allow cookies, you will not be able to use the OnTrade website. Like the information you enter at registration or in your Profile, cookie and log file data is used to customize your experience on our website.

One type of cookie, known as a "persistent cookie", is set once you've logged in to your OnTrade account. The next time you visit the OnTrade website, the persistent cookie will allow us to recognize you as an existing User so you will not need to log in before using the service. In order to access or change any of your private information (like a credit card number) or to send a message to another User, however, you must log in securely again with your password even if your computer contains your persistent cookie.

Additionally, if you log out of the OnTrade website you will need to re-enter your password the next time you visit in order to log in to your account. Another type of cookie, called a "session" cookie, is used to identify a particular visit to the OnTrade website. Session cookies expire after a short time or when you close your web browser.

We use cookies to improve the quality of our service by storing User preferences and tracking User trends. In the course of serving advertisements or optimizing services to our Users, we may allow authorized third parties to place or recognize a unique cookie on your browser. Any information provided to third parties through such cookies will not be personally identifiable but may provide general segment information, e.g. your industry or geographic location, your occupation, or information about your professional or educational background, for greater customization of your user experience. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Unfortunately, if your browser settings do not allow cookies or you opt to refuse all cookies, you may not be able to use the OnTrade website or services. OnTrade does not store personally identifiable information in the cookies.

Web Beacons

We allow other companies, called ad networks, to serve advertisements to Users. Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms. OnTrade may "target" some ads to Users that fit a certain general profile – for example, "car-rental in Miami." OnTrade does NOT use personally identifiable information to target ads.

To deliver these ads properly, OnTrade may include a file, called a web beacon, from these ad networks within pages served by OnTrade so the networks may provide anonymous aggregated auditing, research and reporting for advertisers as well as to target ads to you while you visit other websites.

Because your web browser must request these advertisements and web beacons from the ad network's servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their site.

These general targets may also be used by ad networks to display targeted ads on other websites as a substitute for random, irrelevant ads. OnTrade does not provide personally identifiable information to any advertiser or any other third party.

You may opt-out of use of web beacons in OnTrade pages that you view and of placement of a cookie by ad networks in your browser. To opt-out click here and go to the "Advertising" section at the bottom and change the setting there to "No." If you opt-out you may lose the potential benefit of receiving ads that are more targeted to your interests which, in turn, may limit your ability to fully realize the benefits of the OnTrade services to generate new business leads and prospects.

Log files, IP addresses and information about your computer

Due to the communications standards on the Internet, when you visit the OnTrade web site we automatically receive the URL of the site from which you came and the site to which you are going when you leave OnTrade. We also receive the Internet protocol (IP) address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, email patterns, as well as the name of your ISP. This information is used to analyze overall trends to help us improve the OnTrade service.

The linkage between your IP address and your personally identifiable information is not shared with third-parties without your permission or except when required by law.

Consent to OnTrade Processing Information About You

Certain information you provide to OnTrade may reveal, or allow others to identify, your nationality, ethnic origin, religion or other aspects of your private life, and more generally about you. Please be aware that in providing information to OnTrade for the purposes of opening your user account, you are expressly and voluntarily accepting the terms and conditions of this Privacy Policy and OnTrade's User Agreement. The supplying of all such information by you to OnTrade, including all information deemed "sensitive" by applicable law, is entirely voluntary on your part. You have the right to withdraw your consent at any time, in accordance with the terms of this Privacy Policy and the User Agreement, but please note that your withdrawal of consent will not be retroactive.

Rights to Access, Correct and Eliminate Information About You

You have a right to access, modify, correct and eliminate the data about you which has been collected pursuant to your decision to become a User. If you update any of your information, we may keep a copy of the information which you originally provided to us in our archives for uses documented herein.

We take your rights seriously and encourage you to use them if you deem this to be appropriate. You may exercise these rights by emailing us at privacy@OnTrade.com or by contacting us at:

OnTrade Travel LLC
Attn: Privacy Policy Issues
4944 South Le Jeune
Suite 101
Coral Gables, Florida 33146

2. Uses of personal information

OnTrade is an online service dedicated to helping companies and professionals to connect more effectively with one another. The personally identifiable information you choose to provide on our website is used to help you describe your organization's profile to other Users. Other information, that does not personally identify you as an individual, is collected by OnTrade from Users (such as, for example, patterns of utilization) and is exclusively owned by OnTrade. This information can be utilized by OnTrade in such manner as OnTrade, in its sole discretion, deems appropriate.

OnTrade Communications

OnTrade will communicate with you through email and notices posted on the OnTrade website or through other means available through the service, including text and other forms of messaging. If we send any communications to you via the carrier service with which you have a mobile communications subscription or otherwise have access, you understand you will pay any service fees associated with any such access (including text messaging charges for messages to your mobile device). These may include welcome and/or informational emails which help inform new Users about various features of the service. Please be aware that you will always receive certain emails from OnTrade related to the proper functioning of your account, such as email notices when another User in your network sends you an opportunity. OnTrade may send you promotional information unless you have opted out of receiving such information. You can change your e-mail and contact preferences at any time by logging into your "Account & Settings' and amending your email notification choices. If you wish, you can also opt-out of receiving promotional emails, by sending a request to customer_service@OnTrade.com.

Customized Content

Information provided to OnTrade (or to third parties with whom it offers combined services) is also used to customize your experience on our website. For example, when you login to your account we will display the screen names of new Users who have recently joined your network.

Sharing Information with Third Parties

OnTrade takes the privacy of Users very seriously. We do not sell, rent, or otherwise provide your personally identifiable information to third parties for marketing purposes without your explicit consent. We will only share your personally identifiable information with third parties to carry out your instructions or to provide specific services or information. For instance, we use a credit card processing company to bill Users for subscription fees. These third parties do not retain, share, or store any personally identifiable information except to provide these services and they are bound by confidentiality agreements which limit their use of such information.

OnTrade offers a "public profile" feature which allows Users to publish portions of their OnTrade profile, including their "name," but not their "email address" to the public Internet. Users may opt-out of this feature by editing their account and settings, however OnTrade does not warrant how often third-party search engines will update their cache.

We may provide aggregated anonymous data about the usage of our services to third parties for such purposes as we deem, in our sole discretion, to be appropriate, including to prospective advertisers on OnTrade. We may segment our Users by role (i.e. product managers, vice presidents), industry, geographic location, or company. If you would like to be excluded from the aggregated research or products based upon aggregated data about our Users' activities on the site, please email customer_service@OnTrade.com.

Teaming with Other Organizations to Offer Combined and Other Services

OnTrade may offer our services in connection with other websites (including updates about the OnTrade service) or may team with other online services to give you the combined results of both services or additional services and benefits. Platform Applications (as defined in the User Agreement) can be designed by Platform Developers (as defined in the User Agreement) or by a subset of Platform Developers with whom OnTrade has more closely aligned ("Partners").

In the case of Partners, we do some vetting and we only work with trusted Partners. For example, SimplyHired.com is a Partner which lets you use its services to find jobs combined with the use of OnTrade to find referrals to those jobs. Because of OnTrade's trust in these Partners, Platform Applications or services designed by a Partner may be automatically granted permission to access account information to provide the combined services.

For Platform Applications designed by most Platform Developers, you will be asked to confirm acceptance of the Platform Developers' respective privacy policies and user agreements, which have not necessarily been reviewed or approved by OnTrade. In these cases, it will be your choice whether or not to make use of the services and whether to proceed under the Platform Developers' terms.

Platform Developers are required to agree to restrictions on access, storage and usage of your information. However, while we typically enter into contractual agreements and take technical steps to restrict possible misuse of such information by such Platform Developers, we may not screen or approve Platform Developers, and we cannot and do not guarantee that all Platform Developers will abide by such restrictions and agreements. Certain actions you take through the Platform Applications will be displayed to your connections. You understand that your use of any Platform Applications is on an "as is" basis without any warranty as to the Platform Developers' actions.

If you, your connections, members of your network, or other Users of OnTrade use any Platform Application, or if you interact with a Platform Application being used by any of them, such Platform Application may access and share certain information about you with others. Because a Platform Application can make calls on behalf of the User interacting with it to access non-public information, the level of detail accessible by the Platform Application is constrained by the same settings that govern visibility of your data to that User on OnTrade.

For example, assuming you have not already given a Platform Application permission to access your information, your nonpublic profile information should not be visible to someone using a Platform Application if it is not otherwise accessible to that person on OnTrade.

To uninstall a Platform Application at any time, please click here or, if the relevant Platform Application is not listed there, go directly to the Application Details page for the Platform Application you wish to uninstall. Note, however, that even if you uninstall a Platform Application, your connections, other members of your network, or other Users of OnTrade may still be using the Platform Application, and so it may still have access to certain information about you, just as those Users do. To report any suspected misuse of information contact: customer_service@OnTrade.com. OnTrade is not responsible for your use of or inability to use any Platform Applications, including the content, accuracy, or reliability of such applications and the privacy practices or other policies of Platform Developers.

Surveys and Polls

As a User, you will receive requests to participate in market research including polls and surveys submitted by other OnTrade members. If you participate in surveys and polls offered through our website, the information you provide may be visible to others using the OnTrade website. You may opt-out of participating by changing your Account & Settings to stop receiving these inquiries and requests.

Forums/Chats/Blogs

If you post on the Answers section of OnTrade, or use a bulletin board, import a blog, or participate in a chat room on OnTrade, you should be aware that any personally identifiable information you choose to provide there can be read, collected, or used by other Users of these forums, as well as Platform Developers and other third parties, and could be used to send you unsolicited messages. OnTrade is not responsible for the personally identifiable information you choose to submit in these forums.

Testimonials and Advertisement Placed through OnTrade DirectAds Service

If you provide any testimonials about the OnTrade service or place advertisements through the OnTrade Matchmaking & Search services, we may post those testimonials and examples of advertisements you place in connection with OnTrade's promotion of its service to third parties, which testimonials and advertisements may include your name and other personal information that you have provided. For more information about DirectAds please see the DirectAds Terms of Use.

Communications to other Users

Many emails you initiate through OnTrade, e.g., an invitation sent to a non-User, will list your email address and name in the header of the message. Emails you initiate may also provide aggregate information about your network (for instance how many people are in your network), but will not list the people to whom you're directly connected. Other communications that you initiate through the OnTrade website, like a request for contact, will list your name as the initiator but will not include your personal contact information. Your contact information will only be shared with another User if both of you have indicated that you would like to establish contact with each other.

Legal Disclaimer

It is possible that we may need to disclose personal information when required by law, such as responses to civil or criminal subpoenas, or other requests by law enforcement personnel. We will disclose such information wherein we have a good-faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, subpoena, or other legal process or request to OnTrade brought in any country throughout the world, or to exercise our legal rights or defend against legal claims.

Disclosures to others

We may also disclose your personal and other information you provide, to another third party as part of a reorganization or a sale of the assets of an OnTrade corporation division or company. Any third party to which we transfer or sell OnTrade's assets will have the right to continue to use the personal and other information that you provide to us.

3. Your Information Choices

Accessing and Changing Your Account Information

You can review the personal information you provided us and make any desired changes to the information you publish, or to the settings for your OnTrade account including your email, and contact preferences, at any time by logging in to your account on the OnTrade website. Please be aware that even after your request for a change is processed, OnTrade may, for a time, retain residual information about you in its backup and/or archival copies of its database.

Closing Your Account

You can also close your account through the OnTrade website. If you close your OnTrade account, we will remove your name and other personally identifiable information from our publicly viewable database, however, we will retain information available on public profile pages in the Internet. We may retain certain data contributed by you if we believe it may be necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law. To request that we close your account and remove your information from the OnTrade website, please send your request to customer_service@OnTrade.com. Please send your request using an email account that you have registered with OnTrade under your name. You will receive a response to requests sent to customer_service@OnTrade.com within five business days of its receipt.

4. Your Obligations

As a User, you have certain obligations toward the other Users with whom you will be communicating. Certain of these obligations are imposed by applicable law and regulations, and others have become commonplace in user-friendly communities of like-minded members, such as OnTrade:

• You must, at all times, respect the terms and conditions of the then-current Privacy Policy and the User Agreement. This includes respecting all intellectual property rights which may belong to third parties (such as photographs).
• You must not download or otherwise disseminate any information which may be deemed to be injurious, violent, offensive, racist or xenophobic or which may otherwise violate the purpose and spirit of OnTrade and its community of Users.
• You must not provide information to OnTrade and /or other Users which you believe might be injurious or detrimental to your person, professional or social status.
• OnTrade has also self-certified its privacy practices as consistent with U.S.-E.U. Safe Harbor principles: Notice, Choice, Onward Transfer, Access and Accuracy, Security, Data Integrity and Enforcement. More information about the U.S. Department of Commerce Safe Harbor Program can be found at http://www.export.gov/safeharbor.

Any violation of these guidelines may lead to the restriction, suspension or termination of your account by OnTrade, as we take these principles seriously and consider them to be the basis on which our Users adhere to the OnTrade website and the services which it offers.

5. Important Information

Children

Children are not eligible to use our service and we ask that minors (under the age of 18) do not submit any personal information to us or use the service.

TRUSTe and Safe Harbor Adherence

OnTrade is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent organization whose mission is to enable individuals and organizations to establish trusting relationships based on respect for personal identity and information by promoting the use of fair information practices. This privacy statement covers the site www.OnTrade.com. Because we want to demonstrate our commitment to our Users' privacy, we have agreed to disclose our privacy practices and have them reviewed for compliance by TRUSTe.

If Users have questions or concerns regarding this statement, you should first contact OnTrade by email at privacy@OnTrade.com . If you do not receive acknowledgment of your inquiry or it is not satisfactorily addressed, you should then contact TRUSTe through the TRUSTe Watchdog Dispute Resolution Process (http://www.truste.org/consumers/watchdog_complaint.php).

TRUSTe will serve as a liaison with OnTrade to resolve Users' concerns. However, please understand that the TRUSTe program only covers information collected through the site www.OnTrade.com, and does not cover information that may be collected through software downloaded from the site.

We participate in the EU Safe Harbor Privacy Framework as set forth by the United States Department of Commerce. As part of our participation in the safe harbor, we have agreed to TRUSTe dispute resolution for disputes relating to our compliance with the Safe Harbor Privacy Framework. If you have any complaints regarding our compliance with the Safe Harbor you should first contact us.

By becoming a User, you have given us your express and informed consent to transfer the data which you provide to us to the United States and to process it in the United States.

If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet at http://www.truste.org/consumers/watchdog_complaint.php, fax at 415-520-3420, or mail at WatchDog Complaints, TRUSTe, 685 Market Street, Suite 270 , San Francisco , CA , USA 94105.

If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, see http://www.truste.org/consumers/watchdog_complaint.php or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English.

Changes to this Privacy Policy

OnTrade may update this privacy policy at any time, with or without advance notice. In the event there are significant changes in the way we treat your personally identifiable information, we will display a notice on the OnTrade website or send you an email, as provided for above. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.

If you use the OnTrade service after notice of changes have been sent to you or published on our site, you hereby provide your consent to the changed practices.

6. Security

In order to secure your personal information, access to your data on OnTrade is password-protected, and sensitive data (such as credit card information) is protected by SSL encryption when it is exchanged between your web browser and the OnTrade web site. To protect any data you store on our servers we also regularly audit our system for possible vulnerabilities and attacks and we use a tier-one secured-access data center. It is your responsibility to protect the security of your login information. Please note that emails and instant messaging and similar means of communication with other users of OnTrade are not encrypted and we strongly request you not to communicate any confidential information through these means.

7. How to contact us

If you have questions or comments about this privacy policy, please email us at privacy@OnTrade.com or contact us at:

OnTrade Travel LLC
Attn: Privacy Policy Issues
4944 South Le Jeune
Suite 101
Coral Gables, Florida 33146

Summary of Changes to OnTrade Privacy Policy

OnTrade has revised its Privacy Policy as of April 27, 2011. OnTrade did not materially alter any privacy protections, but revised the privacy policy to provide more detail and clarification on OnTrade's collection and use of personal data. We have provided this summary of changes to facilitate your review and understanding of OnTrade's present privacy policies and practices. However, you should read the full privacy policy as you will be bound by its terms when you view, access or otherwise use OnTrade.

Following are highlights of the revisions to the privacy policy:

In Section 6, we set forth that we do not rent or sell your personally identifiable information to third parties for marketing purposes "without your explicit consent." Moreover, we set forth that we store and process your information on computers located in the United States that are protected by physical as well as technological security devices.

OnTrade has also updated its User Agreement. To review the highlights of the changes to OnTrade's User Agreement, please click here

All content Copyright © 2012, OnTrade Travel, LLC.