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Icebreaker US Inc® - Crush or Flush™ privacy policy

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Crush or Flush, operated by IceBreaker US Inc., is a fun and easy way to use your cell phone or your computer to meet other people with mutual interests and to safely chat and flirt with them. Privacy and safety are built into the service.

We at IceBreaker US Inc. understand that your privacy is very important to you. That's why we've developed this policy to ensure that your privacy is protected while using the Crush or Flush site. Given this, we have created this privacy policy to demonstrate our commitment to protect your personal information including your email address and to tell you how we handle your personal information. This privacy policy only applies to data gathered on the Crush or Flush Website including your email address at crushorflush.com or its sub-domains (the "Site"). It does not apply to any other Website, service, or offline point of contact between Crush or Flush, or any other company.

Privacy and safety are built into our products. Unlike traditional online sites, where members can hide behind multiple profiles, on Crush or Flush, you can only have one account.  During the sign-up process, your cell number is used to verify that you are a real person, and there can only be one account per number. If someone harasses someone or causes a problem, we will block their number and that person will disappear from Crush or Flush.

Icebreaker US Inc is a licensee of the TRUSTe® Privacy Program. TRUSTe® is an independent, non-profit organization whose mission is to build users' trust and confidence in the Internet by promoting the use of fair information practices. This privacy statement covers the site www.crushorflush.com.  Because this web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information and email practices and have its privacy practices reviewed for compliance by TRUSTe®.

If you have questions or concerns regarding this statement, you should first contact Becky Wright, Community Manager at becky.wright@icebreaker.mobi, 1-866-268-0022, , or via mail at Icebreaker US Inc., 227 Bellevue Way NE, #168, Bellevue, WA 98004.  If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact TRUSTe® at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe® will then serve as a liaison with the Web site to resolve your concerns.

IceBreaker US Inc. complies with the EU Safe Harbor framework as set forth by the Department of Commerce regarding the collection, use, and retention of data from the European Union.

1. Acceptance of Privacy Policy
By using our Site, you are accepting the practices set out in this Privacy Policy. Please review this policy periodically as we may modify it from time to time. Your continued use of any portion of our Site following posting of the updated Privacy Policy will constitute acceptance of the changes. See below “Changing Our Privacy Policy for Previously Gathered Information” for more information.

2. A Special Note about Children
Children under thirteen years of age are not eligible to sign up or use our services. We ask that children not submit any information to us. We respect the privacy of parents and children and are committed to complying with the Children's Online Privacy Protection Act ("COPPA"). We require that all users represent to us that they are at least 13 years old and nowhere on the Site, do we knowingly collect personal information from children under the age of 13. If a parent believes that his or her child has provided us with personal information, he or she can contact us via e-mail or postal mail as listed below. We will promptly delete the information upon learning that it relates to an individual under the age of 13.

3. About Crush or Flush™ and Information We Collect
Crush or Flush is an online network (both mobile and web based), which provides you useful tools and communities to build relationships online. Crush or Flush basic service is FREE to all qualified members.  Some members may be assessed a fee by their Mobile Service Provider ("MSP").  Crush or Flush and your MSP are separate and distinct entities, thus this Privacy Policy applies to information retained by Crush or Flush only.

Like most mobile/web services, each time you visit the Site, we automatically collect your IP address and the web page from which you came to our Site using log files. In order to administer and optimize the Site for you and to diagnose problems with the Site, we use your IP address to help identify you and to gather broad demographic information about you. It is not shared with any other entity. For this purpose, our log files are tied to your personally identifiable information (IP address) …

A "cookie" is a small data file that can be placed on your hard drive when you visit certain Crush or Flush web pages. Like most Websites, the Site uses cookies to keep track of your activities navigating the Site. This is to enhance your future experience with the Site. We also use cookies to deliver content specific to your interests, to save your password, and if you choose, to save other personal information so you do not have to reenter it each time you visit the Site. For this purpose, cookies are tied to your personally identifiable information. If you wish to disable these cookies, the "help" portion of the toolbar on most browsers will tell you how. However, if you set your browser to disable cookies, you may not be able to access certain areas on the Site.

The use of cookies by our partners is not covered by our privacy policy.  We do not have access or control over these cookies.  Our partners use session ID cookies on our site to make it easier to navigate and to buy coins. 

When you access the site using a mobile phone, data about your identity may be provided to us by your MSP. Whether any data is provided, and the exact data provided, depends on the specifics of your mobile phone, MSP, mobile network type and other factors. Data provided may include your mobile phone number and your mobile subscriber identifier number. When available, we use such data to verify your identity and to provide you and other members with increased security.

In our online registration form, we ask you to provide us with certain information such as your mobile phone number, email address, location (based on postal code), your age and the type of relationship you are looking for as part of setting up your user profile. We do not share this information with others unless required for legal reasons.  In addition, NONE of this personally identifiable information (PII) can be accessed or used by the public to identify a specific individual. An exception, as noted above, is if we are required to produce PII for legal reasons such as in response to a subpoena.  We use state-of-the art security measures to insure that no unauthorized person can access any PII. 

We strongly advise that users do not give out personal information to strangers.  If a user does communicate personal information to others, they are assuming full responsibility for any associated difficulties. In order to operate the Site, we may review the content of communications between you and other members of the Site, subject to the rest of this paragraph. Demographic information is divided into two categories:

1) "non-public information", including one-on-one communications between you and other users of the Site; and
2) "public information", which consists of all other demographic information.

To protect your privacy we insist that you do not enter personal into your profile (for example, don't use your phone number as your username). If you do so it may be accessed by other members of the Site and the information will then be treated as "demographic information" that is "public information."
In Crush or Flush, users can communicate with each other only when both users have mutually "crushed" each other otherwise a users activities are kept hidden from other users. If you choose to communicate with other members via SMS or other message means, we will only display such information about you as your chosen user "nickname", age, and area of the country you have given us in the sign-up process. .

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the site, we may collect such information into a file, which is only accessed by authorized personnel.  We may also collect other users' comments about you in our complaints department. We use a third-party tracking service, Google™ Analytics, which uses cookies to track non-personally identifiable information about visitors to our site in the aggregate to capture usage and volume statistics to improve our Web site. We have no access or control over these third party cookies.

If you choose to use our referral service to tell a friend about our site, we will ask you for your friend’s mobile phone number. We will automatically send your friend a one-time SMS inviting him or her to visit the site. Crush or Flush stores this information for the sole purpose of sending this one-time SMS and tracking the success of our referral program. Your friend may contact us at Customer Service to request that we remove this information from our database.  From time to time, we conduct surveys, contests, or sweepstakes. We collect information such as email address and cell phone number in order to contact winners and track traffic on our Web site.

4. Our Use of Your Information
We internally use PII of our users to improve our marketing efforts, to statistically analyze site usage, to improve our content and product offerings as well as to customize our site's content and layout to better tailor your online experience to meet your needs.  We use your email address and your other personal information to help us efficiently operate the Site, to contact you in connection with your interactions and other activities on the Site (including, but not limited to, confirmation emails, mobile text messages or important news that could affect your relationship with Crush or Flush), and to forward messages to you from other Crush or Flush users. These types of communications are known as "Operational Communications." In some cases, Operational Communications may also contain commercial messages, such as banner ads and special offers. A user can choose to opt-out of Operational Communications in various ways.  Within the users profile there is a setting for "Alerts".  This can be set to "Don't Send".  This setting stops any SMS messages arising from mutual crushes or secret crushes.

We also use personal information to send you newsletters, information, offers and other promotional materials for Crush or Flush™ or third parties' goods or services. We attempt to send you offers that are of value to you, such as discounts, exclusive offers or special event information. The Site provides you with options to decline to receive communications from Crush or Flush (other than those contained in Operational Communications). Some of these options may only be for a certain category of communications; others may be more general. If you prefer to not receive promotional emails from us, please follow the unsubscribe instructions included in each email communications For instance, within the Crush or Flush  Newsletter is a link to "unsubscribe" which will allow the user to opt-out of future newsletters. 

We may also use your PII (including Private Personal Information) to generate Summarized Data for internal use and for sharing with affiliates, subsidiaries and business partners for planning and marketing purposes. "Summarized Data" means records which have been stripped of information potentially identifying individuals, and which have been manipulated or combined to provide generalized, anonymous information. Your identity and Private Personal Information will be kept anonymous in Summarized Data. We may monitor traffic patterns, usage and related information. We use this information in order to optimize and assess usage of the Site. We reserve the right to disclose information about your usage of the Site and demographics in forms that do not reveal your personal identity. We use Google™ Analytics (via a cookie) to help us collect Summarized Data for the above mentioned purposes.  We use PII to resolve disputes, troubleshoot problems and enforce our User Agreement.

5. Our Disclosure of Your Information
We DO NOT share, or rent any user PII including email addresses, about you to any third party without your permission, except as described in this privacy policy.  We do not share PII with third parties for their promotional purposes.  We do disclose information in aggregate to advertisers and for other marketing and promotional purposes. However, in these situations, we DO NOT disclose to these entities any information that could be used to personally identify you. Certain information, such as your password, or user ID, are not disclosed in aggregate at all.

In order to maintain a healthy community, Crush or Flush cooperates with all law enforcement inquiries and with all third parties to enforce their intellectual property or other rights.  We reserve the right to disclose your personally identifiable information as required by state or federal law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Web site. In cases of suspected “Child Pornography”, we will disclose to the proper authorities email addresses and other data to help in the investigation of this issue. 

We may use third-party advertising companies to serve ads on our behalf. These companies may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. We have no access or control of these tracking technologies. Please read the information below under the heading "Special Cases in which we Share Personal Information” to learn more ways in which we may collect personal information.

6. Special Cases of other non-user data supplied by a Crush or Flush™ user
In certain cases, a Crush or Flush™ user may provide information (a first name and mobile number) within certain features of the Crush or Flush application e.g. "Secret Crush".  This information is used by the system to send an invitation (via SMS), to that non-registered user, asking them visit and join Crush or Flush.  This information is never displayed to users of the site.  Other than for this singular purpose, this information is not otherwise used, shared or retained in any other area.    

7. Special Cases in which we Share Personal Information
Your personal information including your email address may be passed on to a third party in the event of a transfer of ownership or assets, or a bankruptcy. We may also disclose personal information when we determine that such disclosure is necessary to comply with applicable law, to cooperate with law enforcement or to protect the interests or safety of Crush or Flush or other visitors to the Site. Whenever personal information is disclosed under this paragraph, we may also disclose your demographic information along with it, on a non-anonymous basis. In the event of a transfer of ownership or assets, or bankruptcy, you will be notified via email, SMS, or prominent notice on our Web site for 30 days of any such change in ownership or control of your personal information.

8. Your use of Other Users' Information
You may not use other user's information for commercial purposes, to spam, to harass, or to make unlawful threats. Crush or Flush reserves the right to terminate those who misuse other user's information or who otherwise violate the Crush or Flush Terms of Use.

9. Security
Crush or Flush has security measures in place to protect against the loss, misuse and alteration of the information including email addresses under our control. Our secure server software (SSL) is the industry standard and among the best software available today for secure commerce transactions. We encrypt all of financial information as it travels over the Internet and we store your financial information on our servers in encrypted form. Due to the nature of wireless technology, we cannot ensure the security or privacy of information you submit through the Service using a mobile phone, including Personal Information. Your information may be transferred to and maintained on computer networks which may be located outside of the state, province, country or other governmental jurisdiction in which you reside, and the country or jurisdiction in which these computer networks are located may not have privacy laws as protective as the laws in your country or jurisdiction.

Crush or Flush member accounts are secured by member-created passwords. We take precautions to insure 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 to those employees who need access to perform their job functions, such as our customer service personnel and technical staff. 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 For any additional information about the security measures we use please contact us at support@icebreakersoftware.com.

You may not disclose your password to any third parties or share it with any third parties. If, despite the foregoing, you lose control of your password, you may lose substantial control over your personally identifiable information including email addresses and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately contact Crush or Flush so that we can reissue a new password for your account.
While "perfect security" does not exist on the Internet, our technical experts work hard to ensure your secure use of our services.

10. Reviewing and Changing Your Personally Identifiable Information
Once you register, you will be able to review and change much of your personally identifiable information including email addresses and mobile numbers at Crush or Flush. You may modify, remove or delete any of your personal information at any time by logging into your account and accessing features such as Edit Profile. You may also contact us at support@crushorflush.com with an access request.  We will respond to all access requests within 30 days of receiving them.

11. Opt-out of Notifications
If you no longer wish to receive updates or notifications you may choose not to do so by logging into your account and accessing features such as Notification Settings within Edit Profile.

12. Changing our Privacy Policy for Previously Gathered Information
If at any point, we may decide to use particular personally identifiable information including your email address in a manner different from that stated at the time it was collected, we will notify users by way of an email or by providing 30 days notice on the Site. Please note that we will continue to have the right to change our privacy policy and practices, and how we use your personally identifiable information, without notice, provided that these changes are not material changes Please review our privacy policy frequently.
 
13. Contacting Crush or Flush
If you have any questions or concerns about this privacy policy, the practices of the Site, or your dealings with the Site, you can contact us at:
support@icebreakersoftware.com.  You can also contact us by mail at:

Crush or Flush Privacy Officer,
227 Bellevue Way NE #168,
Bellevue, WA 98004.


14. Effective Date
This privacy policy was last revised on July 16, 2009.

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