Last Updated on 04/23/2008

We understand that few things are more important to you than your privacy. As a result, we've put a lot of time, effort and expense into upholding the highest possible standards of integrity and member protection.

Because we understand that you value your privacy and because we know how important it is to respect that privacy, we have published this Privacy Policy to explain how SendMe, Inc., which operates SoLow.com,(the "Site") handles the information you submit to us via any of our Services (throughout this Privacy Policy we will use the term "Services" to refer to both the SoLow.com network of websites as well as the mobile services that we offer on those sites).  Please be sure to read this Privacy Policy carefully before accessing, registering for, or using any of our Services. Your use of the Site, whether you are a "Visitor" (which means you simply browse the Site) or you are a "Member" (which means that you have registered with the Site) indicates to us that you have read and accepted our privacy practices, as outlined in this Privacy Policy.  The term "User" refers to a visitor or a member. We refer to SendMe, Inc. as "SendMe", "we" or "us".  SendMe is a licensee of the TRUSTe Web Privacy Seal Program, and has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

This Privacy Policy is incorporated into and is subject to the SoLow.com Terms of Service. Your use of the Site and any personal information you provide on the Site remains subject to the terms of this Privacy Policy and our Terms of Service. In case of a conflict between the Terms of Service, Privacy Policy or any Rules, the Terms of Service shall govern.

What Information Do We Collect?

In order to use some of the features of the Services, you may need to create a user account which requires you to provide us with some personal information. During the account creation process you will be required to provide certain personal information, such as your cell phone number and email address.  We may also periodically request additional optional personal information, such as contact and billing information or other information about you. The personal information that you provide us may be given through the Site or through messages you send to us from your cell phone. In all cases, your personal information will be covered by this Privacy Policy.

Once you sign up on the Site, we keep track of how you use the Services, including your use of various elements of the Services and communications with us. This information is an important tool we use in evaluating and improving our Services to make them more fun and useful for our Users.  We also log non-personally-identifiable information including, without limitation, IP address, profile information, aggregate User data, and browser type, from Users of the Site.  This non-personally-identifiable information may be shared with third-parties to provide more relevant services and advertisements to members. We do not link the information we store in cookies to any personally identifiable information you submit while on our site.

The Site may also provide you with features that require specific information be provided in order to use that specific feature. For example, we may offer you the ability to sign up to receive newsletters or other alerts to be sent to your email address or cell phone and would ask for that contact information to deliver to you the Services you requested.

We may offer our Members the ability to upload their own information or content to create a personalized web page for Users to see via the Site or as part of other features of the Site. By posting any personal information on or through the Services, you understand and agree that the personal information may be publicly viewable by Users and that we may use it in accordance with this Privacy Policy.

How Do We Use Cookies and Log Files?

Cookies: We use cookies to store preferences you select while visiting the Site. These cookies are pieces of information sent by the Site to your browser and are stored on your computer's hard drive. For example, by providing a cookie on your hard drive, it is possible for you to return to the Site with the same settings you had on a previous visit and if you choose, to store your user name (so you don't have to type it in every time you log in). We use cookies to personalize your experience on the Site, to understand how you use our Services and to tailor content and offers to you when you visit the Site. We may also use cookies to determine how you were referred to the Site.  While we do not require cookies in order to use the Services, most Users find it very difficult and inconvenient to use the Services with cookies turned off.  Please note that the Site allows third-party advertisers that are presenting advertisements on some of our pages to set and access their own cookies on your computer.  Advertisers' use of cookies is subject to their own privacy policies, and not the SoLow.com Privacy Policy.

Log Data: When you visit the Site, our web servers automatically collect anonymous information that describes how our Users use and navigate our Site.  This includes internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. We use this information to keep track of overall Site information, analyze trends, administer the Services, track how Users use the Services, and gather broad demographic information, and improve the Site.

Web Beacons: While you are on our Site, or while you are otherwise viewing our content, you may encounter Web beacons, which may come from us or from third parties, such as advertisers or content providers. A Web beacon, which is sometimes also called a Web bug or "clear gif," is a small graphic image in a Web page, a Web-based document or an e-mail message, which generally allows the party that set the Web beacon to monitor certain information about the viewer of the Web page, Web-based document or e-mail message, and may allow access to certain cookies. Web beacons are usually invisible to the user, because they are very small (generally 1-by-1 pixel). However, in general, any electronic image viewed as part of a Web page, including an advertisement, can act as a Web beacon. Web beacons typically collect the URL of the page the Web beacon comes from, the type of browser requesting the Web beacon, the IP address of the computer that the Web beacon is sent to and the time the Web beacon was viewed. We do not have control over Web beacons used by third parties and do not have access to whatever information they may collect. We may use Web beacons to count Users of our Web pages and we may include Web beacons in HTML-formatted e-mail newsletters in order to count how many of our electronic newsletters (or particular articles, links, etc.) were actually opened. We aggregate all information we collect through Web beacons and we do not use Web beacons to track any individuals' use of the Site. Web beacons can also be linked to personally-identifiable information.

Can Children Use the Services?

Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or maintain personally identifiable or non-personally-identifiable information from persons under 13 years of age, and no part of SoLow.com is directed to persons under 13.  You must be at least 13 years of age to sign up for or use the Services and each User who signs up or uses the Services represents to SendMe that they are at least 13 years of age. Any User who is under the legal age of majority in his or her state or residence (a "minor") should get his or her parent or legal guardian's permission to use the Site. If SendMe receives a complaint which states that a User is under 13 years of age, we will prohibit further collection of personal information from such User and block their usage of the Services. Such Users will also be ineligible to win any game or to redeem SoLow Points, and will be disqualified upon age confirmation at time of prize award.

How Will We Use Your Information?

We use the personal and other information we collect (i) to provide you with the products and services you order; (ii) to deliver any prizes you may win in games, contests or sweepstakes you choose to participate in; (iii) to notify you about new features and services on the Site or other products and services that we think you will find interesting; and (iv) for analytical purposes to help us to improve the Services and for our business generally.

Will We Share Your Information With Third Parties?

SendMe does not sell, rent or share your personal information with non-affiliated third parties without your prior consent. We do however, share personal information with third party contractors who assist us in providing the Service to you. For example, we may provide your personal information to cellular carriers in order to ensure that products or services you order are successfully delivered. These third party contractors agree to use the information only to perform the service for us.

In addition, advertisements appearing on SoLow.com may be delivered to Users by SoLow.com or one of our Web advertising partners.  Our Web advertising partners may set cookies.  These cookies allow the ad server to recognize your computer each time they send you an online advertisement.  In this way, adservers may compile information about where you, or others who are using your computer, saw their advertisements and determine which ads are clicked on.  This information allows an ad network to deliver targeted advertisements that they believe will be of most interest to you.  This Privacy Policy covers the use of cookies by SoLow.com and does not cover the use of cookies by any advertisers.

From time to time, we or a partner, may sponsor a promotion, sweepstakes or contest on the Site.  Users may be asked to provide personally-identifiable information including name, email address or home address or to answer questions in order to participate.  We may transfer personal information to certain advertising or promotional partners, which will be explicitly stated in the specific prize Official Rules. 

Finally, we may also disclose personal information if we have a good faith belief that the law requires it (such as in connection with a subpoena, court order etc.), to protect the rights, safety or property of our Users, of SendMe or third parties, or if we believe that you have violated this Privacy Policy or the Terms of Service, or if we believe such disclosure will prevent a crime from occurring.

Links to Third Party Sites

We may provide links from the Site to other websites that are not owned or managed by SendMe. Our Privacy Policy does not apply to any of the linked third party websites. The third party operator of the website (and not us) is responsible for the information collection, use and disclosure practices of those third party websites, and we encourage you to review the privacy policy of any other website you visit.

Security

SoLow.com Member accounts are secured by member-created passwords.  SoLow.com takes precautions to ensure that Member account information is kept private.  We use reasonable measures to protect Member information that is stored within our database, and we restrict access to Member information that is stored within our database. Please note that we cannot guarantee the security of Member Account information.  Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of Member information at any time.

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

If you have any questions about security on our Web site, you can send email us at legal@solow.com.

In the Event of Merger, Sale, or Bankruptcy

In the event that SendMe is acquired or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from our Users as part of such merger, acquisition, sale, or other change of control.  In the unlikely event of bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used.

California Privacy Rights

Users of the Services who are residents of California may request certain information regarding our disclosure, if any, of personal information to third parties for purposes of their direct marketing. If you want to make this request, you may contact us at:

SoLow Privacy
c/o SendMe Inc.
585 Howard St.
3rd Floor
San Francisco, CA 94105
Attn: Privacy Agent
or
legal@solow.com

How Do You Change Your Information?

To update your personal information, change the service features you have elected to receive, or change your privacy preferences, you can do so by signing in to the Site and accessing the page titled “My SoLow”.

What If the Privacy Policy Changes?

By using the Site, you signify your agreement to this Privacy Policy, as it may be amended and/or revised at any time.  If you do not agree to this Privacy Policy, please do not use the Site.  We reserve the right, at our discretion, to change, modify, add or remove portions of the Privacy Policy at any time,  so please review it frequently. If we decide to change our privacy policy, we will post those changes to this privacy statement, the home page, or email so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

Your Acceptance of this Policy

By using the Services, you are agreeing to the terms of this Privacy Policy and the SoLow Terms of Service. Any dispute as to these terms shall be governed by California law and subject to the courts located in California.

TRUSTe

SendMe 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 Policy covers the Web site SoLow.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 email legal@solow.com. If you do not receive acknowledgement 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.

Questions?

If you have any questions about this Privacy Policy, please contact us at legal@solow.com.