Privacy Policy

This website (the “Web Site”) is operated by Octagon, Inc., and its contents are owned or licensed by Octagon, Inc. (collectively, “us”, “we” or “the Company”). This Web Site privacy policy (“Privacy Policy”) governs the Company’s collection, use, and disclosure of personally identifiable information (“Personal Information”) related to your use of the Web Site. If you reside outside the U.S. your personally identifiable information will be transferred to the U.S., and processed and stored pursuant to U.S. privacy standards. By using the Web Site, you consent to any such transfer to, and processing in, the U.S.

Your privacy on the Internet is of the utmost importance to us. Because we gather certain types of information about the users of the Web Site, we feel you should fully understand the terms and conditions surrounding the capture and use of that information.

YOUR AFFIRMATIVE ACT OF USING THE WEB SITE SIGNIFIES THAT YOU AGREE TO THE FOLLOWING PRIVACY POLICY. YOU MAY NOT USE THE WEB SITE UNLESS YOU AGREE TO THIS PRIVACY POLICY.

1. Modifications to Privacy Policy. The Company is free to modify this Privacy Policy at any time and for any or no reason without providing notice. It is your responsibility to periodically review this Privacy Policy for any modifications.

2. Additional Terms. The Company will post separate privacy notices if different or supplement privacy policy terms apply to certain products or services made available through or by the Web Site. You may not use such products or services without agreeing to such additional privacy policy terms.

3. Personal Information Collection and Use; Use of Cookies.

a. Registration. Certain products or services made available through the Web Site require you to register with the Web Site. Person Information that the Company may collect during registration may include your IP address, user name, password, email address, general location (i.e., closest city), zip code, gender, birth year, wireless telephone number, and other information that you decide to provide us with, or that you decide to include in a public profile. This Personal Information is used by the Company to operate the Web Site (including by providing more targeted advertising) and to communicate with you. In addition, the Company may use contact information to communicate with you regarding additional Web Site products or services available to you. The Company will always provide you the opportunity to opt out of receiving such communications for additional the Web Site products or services. If you feel that you are receiving communications for which you previously opted out, please contact the Company at Octagon, Inc., 1751 Pinnacle Drive, Suite 1500, McLean, VA 22102, Attn: General Counsel. Except where noted otherwise, your user name, birth year, gender, location, and zip code, as well as other information you choose to display publicly (“Public Profile Information”), may be made available to other the Web Site users. The Company will obtain your consent prior to using such Personal Information for any additional purpose not noted herein.

b. Additional Information. Certain products or services made available through the Web Site may enable you to provide additional Personal Information to the Company, such as a picture or a link to a personal website. This Personal Information may be used by the Company to operate the Web Site (including by providing more targeted advertising) or to allow the Web Site users to better identify each other and communicate, and may be provided to other Web Site users. In addition, the Company may keep any email, text messages, or instant messages sent by you to the Web Site or the Company as a means to respond back to you. The Company will obtain your consent prior to using such Personal Information for any additional purpose not noted herein.

c. Log Data. The Company automatically collects certain server data anytime you access or use the Web Site (“Log Data”). Log Data may include, but is not limited to, your IP address, browser type, the domain from which you are visiting, the Web Site pages or services you access or use, the search terms you use, and any advertisements on which you click or otherwise access. The Company uses Log Data to monitor the Web Site and to administer the Web Site’s technical aspects. Log Data is not associated with any personally identifiable data except in the case of a violation of the Web Site Terms of Use or as otherwise required by a valid law enforcement request. The Company will obtain your consent prior to using such Log Data for any additional purpose not noted herein.

d. Cookies. The Company utilizes small data files sent to your computer (“cookies”) to collect site usage data, monitor aggregate usage and web traffic, and to improve the Web Site. Cookies are not used to collect any Personal Information. Your web browser may enable you to disable cookies. You acknowledge that certain Web Site products and services may not operate properly if you disable cookies through your browser.

4. Disclosure of Personal Information. The Company will only disclose your Personal Information to the extent: (i) you provide the Company your express consent to disclose your Personal Information, including by agreeing to this Privacy Policy; (ii) such disclosure is made to a Company business partner or affiliated entity for the purpose of operating the Web Site or providing advertising through the Web Site; provided, however, that such third party agrees to comply with this Privacy Policy and other appropriate security and confidentiality policies; or (iii) the Company has a good faith belief that access, use, preservation or disclosure of such Personal Information is reasonably required to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce the Web Site Terms of Use, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the Company or a third party to the extent permitted or required by law. In addition, the Company may sell, transfer or otherwise share your Personal Information in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. You will have the opportunity to opt out of any such transfer if the new entity’s planned collection or use of your Personal Information differs materially from the policies set forth in this Privacy Policy.

5. Updating Personal Information. You may modify any Personal Information that you provide to the Company during registration by contacting the Company at Octagon, Inc., 1751 Pinnacle Drive, Suite 1500, McLean, VA 22102, Attn: General Counsel.

6. Third Party Websites and Services. You may be able to access third party websites or services through the Web Site. This Privacy Policy does not apply to the data collection and use policies of such third party websites and services. You should review the privacy policies of such third party websites or services. You acknowledge and agree that the Company is not liable for any the data collection and use policies of such third party websites and services.

7. Security. The Company takes seriously its privacy obligations and shall employ reasonable measures to protect the confidentiality of your Personal Information and to prevent unauthorized access. To the extent required by law, the Company shall disclose any breach of the security, confidentiality, or integrity of your Personal Information via a notice mechanism permitted pursuant to the Web Site Terms of Use.

Last Updated: November 1, 2008