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ICG CONNECT PRIVACY POLICY


Date of Last Revision: March 15, 2010

Thank you for visiting our website (the "Website").  ICG CONNECT, a division of Infinity Coaching Group, LLC. (collectively “ICG CONNECT” or “We”) operates this Website and maintains this Privacy Policy ("Policy") that summarizes when and how your personal information is collected, used, safeguarded and disclosed in connection with your use of the Website.  We reserve the right to change the provisions of this Policy at any time. We will alert you that changes have been made by indicating on the privacy policy the date it was last updated.  We encourage you to review this Policy from time to time to make sure that you understand how any personal information you provide will be used.

Personal Information

As used herein, the term "personal information" means information that specifically identifies an individual or entity (such as a name, address, telephone number, mobile number, e-mail address, or other account number), and information about location or activities, such as information about his or her use of the Website, when directly linked to personally identifiable information. Personal information also includes demographic information such as date of birth, gender, geographic area and preferences when such information is linked to other personal information that identifies you. Personal information does not include "aggregate" information, which is data we collect about the use of the Website or about a group or category of products, services or users, from which individual identities or other personal information has been removed. Aggregate data helps us understand trends and our users' needs so that we can better consider new features or otherwise tailor our Website. This policy in no way restricts or limits our collection and use of aggregate information.

Personal Information Collected

• Active Collection

Personal information may be collected in a number of ways when you visit our Site. For example, we may collect your name, address, email address, user name and other contact and demographic information when you register and set up an account, apply for a job, or contact us by e-mail or other means for any reason. When you make a purchase, we may also collect your credit card or other payment or billing information. Personal and demographic information may also be collected if you provide such information in connection with creating a profile or group, leaving comments, posting content, sending an email or message to another user or participating in any interactive chat rooms, forums or features on the site. In addition, from time to time we may collect demographic, contact or other personal information you provide in connection with your participation in surveys, sweepstakes, contests, games, promotional offers, and other activities on the Site. You can access certain portion of our Website without providing us with any personal information. However, you will not be able to utilize certain features that require registration or receive materials unless certain information is provided. From time to time we may change the information requested upon registration or with respect to certain features or services, so this may not be a complete list.

• Log Files

When you use the Site, some information is also automatically collected, such as your Internet Protocol (IP) address, your operating system, the browser type, the address of a referring web site, and your activity on the Site. We treat this information as personal information if we combine it with or link it to any of the identifying information mentioned above. Otherwise, it is used in the aggregate only.

• Cookies and Web Beacons

We may automatically collect certain information through the use of "cookies" or clear gifs. Cookies are small data files that are stored on a user's hard drive at the request of a Web site to enable the site to recognize users who have previously visited them and retain certain information such as customer preferences and history. If we combine cookies with or link them to any of the personally identifying information, we would treat this information as personal information. Clear gifs (also know as web bugs or web beacons) are small, invisible graphic images that may be used on the Site or in emails relating to the Site to collect certain information and monitor user activity on the Site. If you wish to block, erase, or be warned of cookies, please refer to your browser instructions or help screen to learn about these functions. However, if a browser is set not to accept cookies or if a user rejects a cookie, some portions of the Site and the Service may not function properly. For example, you may not be able to sign in and may not be able to access certain Site features or services.

We may also use third parties to serve ads on our Website. These third parties may place cookies, clear gifs or other devices on your computer to collect information, and information provided by these devices may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Website and the other sites tracked by these third parties. This policy does not apply to, and we are not responsible for, cookies in third party ads or for compliance with such third parties' privacy policies or data collection practices.

Registration

In order to use this web site, an ICG CONNECT Event Host or Organizer may first need to complete the registration form. During such registration an Event Host or Organizer is required to give its contact information (such as email address). Any information provided is to improve the experience of our Customers.

Use of Personal Information

In general, we use personal information we collect to process your requests or transactions, to provide you with information or services you request, to inform you about other information, events, promotions, products or services we think will be of interest to you, to facilitate your use of, and our administration and operation of, the Site, to better understand the needs of our visitors, and for the purpose for which the information was provided. For example, we may use the information we collect:

           to send you a welcoming email and to contact you about your use of the Website;

           to provide the services, products or information you request and to process any transactions in connection therewith;

           to provide technical support and ensure the continued smooth operation of our service;

           for recruitment purposes, and if you are offered a job or become employed by us, for other employment-related purposes;

           to respond to your emails, submissions, comments, requests or complaints;

           to analyze user characteristics and usage patterns in order to better understand how our products and service are used and market them more effectively;

           to send you newsletters, surveys, contest and sweepstake announcements and to notify contest and sweepstakes winners;

           to request feedback and to enable us to develop, customize and improve the Site and our publications, products and services;

           to contact you about our or a third party's services, products, activities promotions, special events or offers and for other marketing, informational, product development and promotional purposes; and

           to prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct involving our products and services, or this Website.

Sharing of Personal Information

Unless otherwise described elsewhere in this Policy, we generally do not disclose, sell or trade any personal information about our visitors and users to any third parties.

We may share personal information with vendors, consultants and other service providers (“Service Providers”) who are engaged by or working with us in connection with the operation of the Site or the Services and who need access to such information to carry out their work for us. In some cases, the Service Provider may be directly collecting the information from you on our behalf. We inform Service Providers that they are not permitted to use personal information they obtain from us other than to provide the services for us. However, we are not responsible for the actions of Service Providers, nor are we responsible for any additional information you provide directly to these Service Providers and we encourage you to become familiar with their practices before disclosing any personal information directly to such Service Providers.

We may also share personal information with third parties when you give us your consent to do so. For example, we may enter into relationships with other parties to make specific services or offers available directly to our users. If a user opts in to these third party services or marketing offers, we may share the personal information you provide at the time of sign-up or such other personal information, such as your name or other contact information, that we deem reasonably necessary or appropriate for our business partner to provide these services or offers or get in contact with you.

We may disclose personal information in the good faith belief that we are lawfully authorized or required to do so, or that doing so is reasonably necessary or appropriate to comply with the law or with legal process or authorities, respond to any claims, or to protect the rights, property or safety of ICG CONNECT, our users, our employees or the public, including without limitation to protect ICG CONNECT or our users from fraudulent, abusive, inappropriate or unlawful use of our Site. Information we collect, including personal information, may also be disclosed or transferred as part of, or during negotiations of, any merger, sale of company assets, financing or acquisition or in any other situation where personal information may be transferred as one of the business assets of ICG CONNECT.

You understand that when you use the community features of our Website, information you post in public or private groups, forums, and other interactive areas of the Site, as well as any information you share with individuals through the Website, will be available to other users and in some cases (such as when you post to a public area of the Site) may be publicly available. We recommend you be cautious in giving out personal information to others or sharing such information in public or private online forums. We are not responsible for the actions of any third parties with whom you share personal information.

Please note that nothing herein restricts the sharing of aggregate information, which may be shared with third parties without your consent.

Links

This web site contains links to other sites. Please be aware that we, ICG CONNECT, are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by ICG CONNECT at this Web site.

Monitoring

You understand and agree that when you use this Website and/or any of its features that may be available, such as instant messaging, forums or chat rooms, such communications and postings are transmitted through our servers, and we may, but are not obligated to, monitor all such communications and postings, including those that are designated as “private.” You acknowledge that you have no expectation of privacy with respect to any such communications or postings, and you expressly consent to such monitoring.

Newsletter

We may offer a newsletter to our Customers. If a Customer wishes to subscribe to our newsletter, we ask for contact information such as name and email address. You will have the choice to Opt-Out of this newsletter. This information will not be made available to any third party for advertising or direct marketing purposes.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the Customer therefore has a choice whether or not to disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.

Security

We endeavor to take reasonable precaution to safeguard and secure the personal information we collect through the Website. We have put in place physical, electronic, and managerial procedures that are designed to prevent unauthorized access, loss, or misuse.  For example, ICG CONNECT uses SSL protected Gateway servers.  In addition, we restrict internal access to personal information to employees who need the information to perform their duties. The unauthorized access or use of such information by an employee is prohibited and constitutes grounds for disciplinary action. Additionally, our information management systems are configured in such a way as to block or inhibit employees from accessing information that they have no authority to access.  We encrypt all passwords and other sensitive information in our database. Furthermore, ALL employees are kept up-to-date on our security and privacy practices. If you have any questions about the security at our web site, you can contact us at 888-809-8907

You should note that our Service Providers may be responsible for processing, handling or storing some of the personal information that we receive. These Service Providers are contractually required to safeguard and secure the personal information they received from us. However, we are not responsible or liable in any manner for the actions or inaction of any Service Providers.  Similarly, we are not responsible, in any way or fashion, for information stored by third parties or collected by PayPal or other entities involved in the processing of payments on behalf of our users.

Although we strive to protect your personal information, you should be aware, however, that information sent over the Internet is not necessarily secure and may be intercepted or accessed by third parties. Therefore, we cannot guarantee the security of such information, and we are not responsible or liable for any such interception.


Supplementation of Information

In order for this web site to properly fulfill its obligation to our Customers, it is necessary for us to supplement the information we receive with information from 3rd party sources, primarily Paypal. This information is not shared with any additional outside parties.

Site and Service Updates

We also send the Customer site and service announcement updates. Customers are not able to un-subscribe from service announcements, which contain important information about the service. We communicate with the user to provide requested services and in regards to issues relating to their account via email or phone.

Notification of Changes

If we decide to change our privacy policy, we will post those changes on our web site so our Customers are always aware of what information we collect, how we use it, and under circumstances, if any, we disclose it. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

Review and Correction of Personal and Account Information

You may review, update, correct or delete your personal and account information collected through the Website by accessing your profile information on the Website.

Please note that certain types of personal information that is necessary to check eligibility, such as, for example, birth date or age, cannot be deleted unless you close your Account. However, such information may be modified with sufficient verification of the new information. Note that the deletion of your data may lead to the termination of your account and applicable services.

To have access to your personal information, you may have to provide sufficient proof of identification as we may request, and we reserve the right to deny access to any user if we believe there is a question about your identity. Moreover, we reserve the right to retain your information in our files if we believe it is necessary or advisable to resolve disputes, enforce the Terms of Service, and for technical and legal requirements and constraints related to the Website.

No Guarantees

While this Policy states our intended policies and practices for the collection, use and handling of personal information and we endeavor to follow such policies and practices, we are not in a position to guarantee these standards. There may be factors beyond our control that may result in disclosure of personal information or in the handling of personal information in a manner other than as stated in this Policy. As a consequence, we disclaim any warranties or representations relating to maintenance or nondisclosure of any personal information collected from visitors and users.

Collection of Information from Minors

This Website is not intended for use by individuals under 18 or that have not otherwise achieved majority age. By registering for the Website, users represent to us that they are 18 or otherwise of majority of age, and we do not knowingly collect any information from anyone we actually know is under 18 years of age. If you are under 18 or otherwise not of majority age, do not attempt to create an account and do not provide any personal information on our Website.

International Users

ICG CONNECT is a United States based company and our servers and business operations are located primarily in the United States. By using our Website and providing us with information, you are consenting to the storing and processing of your information on computers located in the United States of America in the manner described in this Policy. You acknowledge and understand that the laws regarding personal information in the United States may be less stringent than the laws of your country and may not offer the same protections or rights as those laws. If you object to your personal information being transferred or used as described in this Policy, please do not use this Website.

Contact Us

If you have any questions, concerns, or comments regarding this Policy, please contact us via e-mail at contactus@ICGConnect.com