Uses of business identifiable and user personal information

We use the information you provide to:

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

Your Information choices

You can:

• Review, enhance or edit your business' information through your business' profile page.
  
• Choose what business and associated product or requirement information you make available to public or registered users through Confluxes.
  
• Change your settings to control information visibility and accessibility through our website.
  
• Tell us to close your Business' Confluxes account.

Your Business and Users' 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 business' or users' identifiable information to third parties for marketing purposes.
  
• We do not share your Business' contact information with another Business without your consent.
  
• Any identifiable information that you provide will be secured with industry best practice protocols and technology.
  
• 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 Confluxes service after notice of changes have been sent to you or published on the Confluxes website, you are consenting to the changes.

Business and User Information Collected

The purpose of the Confluxes website is to enable Users to voluntarily provide information about their Businesses and associated products and requirements for the purposes of functioning within the business value chain network. You willingly provide us certain information, which we collect in order to allow you to benefit from the Confluxes website. If you have any hesitation about providing such information to us and/or having such information displayed on the Confluxes website or otherwise used in any manner permitted in this Privacy Policy and the User Agreement, you should not become a member of the Confluxes community. We collect your personal information in the following ways:

• Registration of a Business
  In order to become a User, you must first create an account for you as a user and your Business (if you are not joining as an additional User of an existing registered Business on Confluxes) on our website. To create an account you are required to provide the following contact information, which you recognize and expressly acknowledge is business and personal information allowing others, including Confluxes, to identify you: Business name, User's Name , email address, country, ZIP/postal code, city and a password chosen by you.
  
  
• Business Profile Information
  Once your Business is registered and you become a User, you may provide additional information on your Business in the Admin section describing your Business or create dedicated profiles for specific products and/or requirements of your Business. Providing additional information beyond what is required at registration to become a Registered Business and User is entirely optional, but enables you to better identify yourself and find new opportunities in the Confluxes system to build and leverage your business value chain network. 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 will lose the potential benefit of being a registered Business and associated User.
  
  
• Commercial Relationships Information
  In order to establish commercial relationships between your Business and other Businesses, you may use the Confluxes services to submit a relationship type and status confirmation them if they are an existing registered Business, or enter the Businesses' names and email addresses if they are not currently registered Business on Confluxes. This information will be used by Confluxes to send your Business' invitation.
  
  
• Customer Service
  Confluxes may collect information through the Confluxes website or through the Customer Service website in order to, among other things, accurately categorise and respond to a customer's inquiry and deliver appropriate service levels.
  
  
• Cookies
  Like most websites, Confluxes uses cookies and web log files to track site usage. A cookie is a tiny data file which resides on your computer which allows Confluxes to recognize your Business and you (and other associated) Users when you return to the Confluxes website using the same computer and web browser. If your browser settings do not allow cookies, you may not be able to use the Confluxes website. Like the information you enter at registration or in your Business and User Profile, cookie and log file data is used to customise your experience on our website. One type of cookie, known as a "persistent" cookie, is set once you've logged in to your (specifically allocated privileges relevant to your Business) Confluxes account. The next time you visit the Confluxes website, the persistent cookie will allow us to recognise 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 Business' information (like a credit card number), 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 Confluxes 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 Confluxes website. Session cookies expire after a short time or when you close your web browser. 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. Confluxes may “target” relevance based ads to Business' Users based on specific search results and activities on the Confluxes network. Confluxes do NOT use personally identifiable information to target ads. To deliver these ads properly, Confluxes may include a file, called a web beacon, from these ad networks within pages served by Confluxes so the networks may provide anonymised, 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. Confluxes do not provide personally identifiable information to any advertiser or any other third party. You may opt-out of use of web beacons in Confluxes 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 Business' interests which, in turn, may limit your ability to fully realize the benefits of the Confluxes services to build and leverage your value chain network.
  
  
• Log files, IP addresses and information about your computer
  Due to the communications standards on the Internet, when you visit the Confluxes 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 Confluxes. 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 Confluxes service. The linkage between your IP address and your Business or personally identifiable information is not shared with third-parties without your permission or except when required by law.
  
  
• Consent to Confluxes Processing Information About You
  Certain information you provide to Confluxes may reveal, or allow others to identify, your Business' and its Users' nationality and more generally about you. Please be aware that in providing information to Confluxes for the purposes of opening your user account, you are expressly and voluntarily accepting the terms and conditions of this Privacy Policy and Confluxes's User Agreement. The supplying of all such information by you to Confluxes, 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.
  
  
• We automatically receive from your internet use such information as your IP address, the URLs of sites from which you arrive or leave the Confluxes website, your type of browser and your ISP.• Web Beacons
  
  
• 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@Confluxes.com or by contacting us at:
  Confluxes Ltd
  Attn: Privacy Policy Issues, 2nd Floor, 85 Frampton Street, London, UK, NW8 8NQ
  
  
• Uses of personal information
  Confluxes is an online service dedicated to helping all types of business discover solutions and opportunities, manage commercial relationships and interactions, and function more effectively within the value chain network context. The Business identifiable information you choose to provide on our website is used to help you describe your Business and its associated products and requirements to other Business' Users and the Confluxes value chain network's intelligent matching algorithms. No personally identifiable of you as an individual is collected or ever made public (or within the secure commercial network), but basic User information such as e-mail address is collected by Confluxes from Users (such as, for example, patterns of utilization) and is exclusively owned by Confluxes. This information can be utilized by Confluxes in such manner as Confluxes, in its sole discretion, deems appropriate.
  
  
• Confluxes Communications
  Confluxes will communicate with you through email and communication in your Confluxes Inbox on the Confluxes 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 include a series of up to five welcome emails which help inform new Businesses and their Users about various features of the service. Please be aware that you will always receive certain emails from Confluxes related to the proper functioning of your Business' account, such as email notices when another Business contacts your Business regarding an opportunity or for subscribing Business when an active match is made between one of your Business' products or requirements and a solution or opportunity in the value chain network. Confluxes 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 Business' ‘Admin' and amending your Business and/or associated Users' email notification choices. If you wish, you can also opt-out of receiving promotional emails, by sending a request to customer_service@confluxes.com.
  
  
• Customised Content
  Information provided to Confluxes (or to third parties with whom it offers combined services) is also used to customise your experience on our website. For example, when you login to your Business' account we will display information of new product and/or requirement matches and value chain network information.
  
  
• Sharing Information with Third Parties
  Confluxes take the privacy of Business and their Users very seriously. We do not sell, rent, or otherwise provide your Business or Users' identifiable information to third parties for marketing purposes. We will only share your Business' 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 Businesses for subscription fees. These third parties do not retain, share, or store any Business or User identifiable information except to provide these services and they are bound by confidentiality agreements which limit their use of such information.
  
  
• Confluxes offer a "public profile" feature
  This allows Businesses to publish portions of their Confluxes profile and associated products, including their “name”, but not their “email address” to the public Internet. Users may opt-out of this feature by editing their Business and product and/or requirements administration settings; however Confluxes 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 Confluxes. We may segment our Businesses by industry or geographic location. If you would like to be excluded from the aggregated research or products based upon aggregated data about our Businesses' activities on the site, please email customer_service@confluxes.com.
  
  
• 3rd Party Services
  Confluxes may offer our services in connection with other websites (including updates about the Confluxes service) or may provide other 3rd party online services to give your Business 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 Confluxes has more closely aligned (“Partners”). In the case of Partners, we do some vetting and we only work with trusted Partners. Because of Confluxes' 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 Confluxes. 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 Business' 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 may be displayed publically if you select so. 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 your Business and its Users, your Business' commercial Business relationships connections or other Businesses and their Users of Confluxes 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 your Business 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 Business' data to that User on Confluxes. For example, assuming you have not already given a Platform Application permission to access your Business' information, your non-public Business (and/or product and/or requirement) information should not be visible to someone using a Platform Application if it is not otherwise accessible to that person on Confluxes. To uninstall a Platform Application at any time, 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 Business and other Businesses or Groups within your Business' value chain network or other Users of Confluxes may still be using the Platform Application, and so it may still have access to certain information about your Business, just as those Users do. To report any suspected misuse of information contact: abuse@confluxes.com. Confluxes are not responsible for your Business' 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.
  
  
• Testimonials and Advertisement Placed through Confluxes DirectAds Service
  If your Business provide any testimonials about the Confluxes service or place advertisements through the Confluxes DirectAds services, we may post those testimonials and examples of advertisements your Business place in connection with Confluxes' promotion of its service to third parties, which testimonials and advertisements may include your Business' name and other commercial information that you have provided.
  
  
• Communications to other Businesses
  Many emails you initiate through Confluxes, e.g., an invitation sent to a non-registered Business, will list your email address, name and Business' name in the header of the message. Emails you initiate may also provide aggregate information about your network (for instance how many Businesses are in your Business' value chain network and existing opportunities and solutions throughout the entire Confluxes network), but will not list the Businesses with whom your Business has direct commercial relationships. Other communications that you initiate through the Confluxes website, like a request for Solution or direct Proposals, will list your Business' name as the initiator but will not include your personal contact information. Your contact information will only be shared with another Businesses 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 Business or User 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 Confluxes 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 Business' and/or User and other information you provide, to another third party as part of a reorganisation or a sale of the assets of a Confluxes Ltd division or company. Any third party to which we transfer or sell Confluxes' assets will have the right to continue to use the information that you provide to us.
  
  
• Your Information Choices
  Accessing and Changing Your Account Information You can review the Business and User information you provided us and make any desired changes to the information you publish, or to the settings for your Confluxes account including your email, and contact preferences, at any time by logging in to “Admin” on the Confluxes website. Please be aware that even after your request for a change is processed, Confluxes may, for a time, retain residual information about your Business, its Users and products and requirements in its backup and/or archival copies of its database.
  
  
• Closing Your Business' Account and/or Your User Profile
  You can also close your Business' account through the Confluxes website. If you close your Business' Confluxes account, we will remove your Business' name and other identifiable information from our publicly viewable database. 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 Confluxes website, please send your request to customer_service@confluxes.com. Please send your request using an email account that you have registered with Confluxes under your name. You will receive a response to requests sent to customer_service@confluxes.com within five business days of its receipt.
  
  

Your Obligations

As a User, you have certain obligations toward the other Business and their Users with whom your Business 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 Confluxes:

• You must, at all times, respect the terms and conditions of the then-current Privacy Policy and the Terms and Conditions of Use. 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 Confluxes and its network of Businesses and their Users.
  
• You must not provide information to Confluxes and/or other Users which you believe might be injurious or detrimental to your Business.
  
  

Safe Harbour

Confluxes have also self-certified its privacy practices as consistent with U.S.-E.U. Safe Harbour principles: Notice, Choice, Onward Transfer, Access and Accuracy, Security, Data Integrity and Enforcement. More information about the U.S. Department of Commerce Safe Harbour 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 Business and User account by Confluxes, as we take these principles seriously and consider them to be the basis on which our Users adhere to the Confluxes website and the services which it offers.

Important Information

• Children
  Children are not eligible to be Users of our service and we ask that minors (under the age of 18) do not submit any personal information to us or use the service. If Users or Business representatives have questions or concerns regarding this statement, you should first contact Confluxes by email at privacy@confluxes.com.
  
  
• Dispute Resolution Process
  We participate in the EU Safe Harbour Privacy Framework as set forth by the United Kingdom Department of Commerce. As part of our participation in the safe harbour, we have agreed to dispute resolution for disputes relating to our compliance with the Safe Harbour Privacy Framework. If you have any complaints regarding our compliance with the Safe Harbour 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 Kingdom or the United States and to process it in the United Kingdom or United States.
  
  
• Changes to this Privacy Policy
  Confluxes 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 Confluxes 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 Confluxes service after notice of changes have been sent to you or published on our site, you hereby provide your consent to the changed practices.
  
  
• Security
  In order to secure your Business' information, access to your Business' data on Confluxes 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 Confluxes 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 centre. It is your responsibility to protect the security of your Business' and it's associated Users' login information. Please note that emails and instant messaging and similar means of communication with other users of Confluxes are not encrypted and we strongly request you not to communicate any confidential information through these means.
  
  
• How to contact us
  If you have questions or comments about this privacy policy, please email us at privacy@confluxes.com
  or contact us at:
  Confluxes Ltd
  Attn: Privacy Policy Issues
  2nd Floor, 85 Frampton Street, London, UK, NW8 8NQ
  
  

Security

• Business and users' information you provide will be secured according to best practice industry standards and technology.
  
• Business and associated product and requirement information publicly accessible is selected so by your business' representative users.

How to contact us regarding privacy

If you have questions or comments about this privacy policy, please email us at privacy@confluxes.com
or contact us at:
Confluxes Ltd
Attn: Privacy Policy Issues, 2nd floor, 85 Frampton Street, London, UK, NW8 8NQ